Privacy Policy – Toddle

1. Introduction

1.1 Toddle Enterprises Group Pty Ltd T/A Toddle (ABN: 77 618 980 706) and its subsidiaries (Toddle, we or us) are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth).

1.2 Toddle provides services which allows you to research, compare and obtain information on, connect and communicate with, and assist you to enrol your child / children at, child care centres (Centres) (collectively the Services).

1.3 This document sets out our policies for managing your personal information and is referred to as our Privacy Policy and tells you how Toddle generally collects, uses and discloses your personal information.

1.4 In this Privacy Policy, “we”, “us” and “our” refers to Toddle and “you” refers to any individual about whom we collect personal information.

1.5 This Privacy Policy applies to all personal information collected by us, or submitted to us whether offline or online, including personal information collected or submitted through our website (https://toddle.com.au/) or app (collectively, the Website), through email and other messages we have sent to you or receive from you.

1.6 Other terms may also apply to you and the personal information we hold about you (for example where we provide you with a specific privacy collection notice).

1.7 Other terms may also apply to you and the personal information we hold about you (for example where we provide you with a specific privacy collection notice).

2. What is personal information and what personal information does Toddle collect?

2.1 In this Privacy Policy, the term “personal information” means information we collect which personally identifies you or from which you are reasonably identifiable. To provide some of our Services, you may provide us with personal information which relates to another person (for example, your child, partner or other family member). If you provide us with information about your child, partner or any other person, you must obtain that person’s permission to give us the information and inform them of our privacy policy

2.2 The types of personal information collected by Toddle will vary depending on the circumstances of collection and the nature of your dealings with us, but may primarily include:

• your name, address and contact details (for example, email, phone and fax number);
• information about your child (including, name, gender and date of birth);
• your or your child’s government identifiers (for example, Tax File Numbers and Customer Reference Numbers); and
• any additional personal information you provide to use, or authorise to use to collect, as part of your interactions with us such as personal information which is contained on any financial information provided to us via the Services or any other information that you provide via out Website, app or other communication with us.

2.3 In limited circumstances, we may need to collect and hold your sensitive information (such as medical information). This may be necessary, for example, if you need to enquire about the facilities of a Centre. We will only collect sensitive information about you with your consent or where we are otherwise permitted to do so under relevant privacy laws.

3. How and why does Toddle collect and use your personal information?

3.1 We collect only the personal information that is reasonably necessary for us to carry out our business and provide the Services.

3.2 The purposes for which Toddle usually collects and uses personal information depends on the nature of your interaction with us, but may include:

• providing you with our Services;
• responding to requests for information and other general inquiries about our Services;
• generally researching, developing and expanding our Services;
• analysing your interactions and use of our online services to understand the effectiveness of our marketing initiatives;
• maintaining and improving our customer service by monitoring our Services for quality control, quality and training purposes;
• responding to enquires and complaints; and
• meeting our regulatory and legal obligations.

3.3 We generally collect personal information directly from you. We may also collect personal information from other sources, for example:

• when a Centre provides information to Toddle for the purposes of enabling Toddle to provide the Services; and
• when a Centre provides information to Toddle for the purposes of the Centre providing services to you.

3.4 Where personal information is collected from a third party such as a Centre, Toddle will treat your personal information in accordance with the practices described in this Privacy Policy. Toddle cannot guarantee the accuracy of personal information provided by the third party.

4. How does Toddle use and disclose personal information

For customers

4.1 The purposes for which we may use and disclose your personal information will depend on the Services we are providing to you. For example, if you have made an enquiry to a Centre, we may disclose information about you to the Centre.

Disclosure to contractors and other service providers

4.2 Toddle may disclose information to third parties we engage in order to provide our Services, including contractors and service providers used for data processing, data analysis, information technology services and support, website maintenance/development.

4.3 Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.

Use and disclosure for administration and management

4.4 Toddle will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:

• planning, managing, monitoring and evaluating our Services;
• quality improvement activities;
• statistical analysis and reporting;
• training staff, contractors and other workers;
• risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
• responding to enquiries and complaints regarding our Services;
• obtaining advice from consultants and other professional advisers; and
• responding to subpoenas and other legal orders and obligations.

Other uses and disclosures

4.5 We may use and disclose your personal information as explained at section 7, or for other purposes explained at the time of collection (such as in a specific privacy collection statement or notice) or otherwise as set out in this privacy policy.

5. How does Toddle interact with you via the internet?

Website and Cookies

5.1 You may visit our Website without identifying yourself. If you identify yourself (for example, by submitting an inquiry or filling out a form), any personal information you provide to Toddle will be managed in accordance with this Privacy Policy.

5.2 We wish to provide you with a positive user experience on our Website. To do so, our Website uses ‘cookies’ to help us collect information about visitors to our Website. 'Cookies' are small alphanumeric data files that are stored by the web browser on your device’s hard-drive that enable our system to recognise a returning visitor to the Website and remember a visitor’s preferences.

5.3 We use cookies to help track basic visitor information on our Websites for the purposes of optimising the design of our Website and for our marketing activities and to personal your browsing experience (for example, by remembering your preferences and recognising you as a repeat visitor to our Website). We also collect device information (such as IP address, and pages you have accessed on our Website) and advertising identifiers.

5.4 Most web browsers automatically accept cookies and you can control how your browser deals with cookies by changing the browser settings. However, in doing so, you may not be able to utilise certain content on our Website and may not have the same user experience.

5.5 We use Google Analytics, including Google Analytics Advertising and to help analyse use of the Website and this may be used to deliver targeted advertising more relevant to you and your interests based on previous browsing. This analytical tool uses cookies to collect standard internet log information and visitor behaviour information in an anonymous and aggregate form.

To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. Alternatively, you can contact us (see our details below in section 14) or visit youronlinechoices.com.au, which is a website that allows you to opt out of some online behavioural advertising.

Third party Links

5.6 Our Website may contain links to third-party websites. Toddle is not responsible for the content or privacy practices of websites that are linked to our Website.

6. How does Toddle hold information securely?

6.1 Toddle stores information in paper-based files or using electronic record keeping methods in secure databases (including trusted third party storage providers based in Australia). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed).

6.2 We take reasonable steps to protect your personal information from loss, interference, misuse and from unauthorised access, modification or disclosure.

6.3 We take security seriously and take precautions to keep your personal information secure. We have put in place reasonable physical, electronic, and procedural safeguards in order to protect your personal information. We maintain physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security; for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.

6.4 Although we take reasonable steps to protect your personal information, no website, internet connection or transmission, computer system or wireless connection is completely secure and we cannot provide any assurance regarding the security of transmission of information you communicate to us online, so any information which you transmit to us online is at your own risk.

7. Does Toddle use or disclose your personal information for direct marketing?

Toddle may use or disclose your personal information for the purpose of informing you about our Services which we think may be of interest to you or other opportunities that may interest you, or as otherwise permitted under applicable privacy laws. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us (see our details below in section 14) or using the opt-out functionality accompanying our message. If you opt-out of receiving marketing material from us, Toddle may still contact you in relation to its ongoing relationship with you.

8. Does Toddle disclose your personal information outside Australia?

Toddle will not transfer any Personal Information overseas.

9. Retention period and Disposal of Personal Information

9.1 We will retain your personal information for the period necessary to fulfil the purposes outlined in this privacy policy unless a longer retention period is required or permitted by law.

9.2 If we no longer require your personal information for any purpose, including as required by an applicable law, we will take reasonable steps to securely destroy or permanently de-identify the personal information.

10. How can you access your personal information?

10.1 You are entitled to access your personal information held by Toddle on request. You may request access to your personal information by contacting us (see our details below in section 14).

10.2 We will take reasonable steps to meet requests for access. However, if we decline a request for access to the personal information we hold in accordance with the Australian Privacy Principles, we will provide you with reasons for our decision when we respond to the request.

10.3 There is no cost to you for requesting access but we may charge a reasonable fee for the administrative costs of the provision of the requested information (such as document retrieval, photocopying, labour and delivery).

11. How can you seek correction of your personal information?

11.1 We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date, though we will be reliant on you helping us to do these things in some circumstances.

11.2 If you believe that any Personal Information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you may contact us (see our details below in section 13) to request the correction of the personal information. After receiving a request from you, we will take reasonable steps to correct the your personal information.

11.3 If we refuse to correct your personal information in accordance with the Australian Privacy Principles we will provide you with reasons and, if you disagree, you may ask us to add a note of your requested correction to your personal information.

12. What should do you if you have a complaint?

12.1 If you have any complaints or concerns regarding Toddle’s management of your personal information please contact us via our contact details set out below (see section 14) and provide details of the incident so we can investigate it.

12.2 Once we receive a complaint regarding Toddle’s use of your personal information, we will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.

12.3 If your complaint or query requires more detailed consideration or investigation, we will acknowledge receipt of your complaint or query within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint or query and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved.

12.4 In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

12.5 If you are not satisfied with our response to your complaint, or you consider that Toddle may have breached the Australian Privacy Principles or the Privacy Act 1988 (Cth), a complaint may be made to the Office of the Australian Privacy Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

13. Changes to this privacy policy

From time to time, Toddle may amend this Privacy Policy, with our without notice to you. We recommend that you visit our Website regularly to keep up to date with any changes.

14. Contact Us

If you have any further queries or concerns relating to Toddle’s Privacy Policy or wish to make a complaint in relation to the way your personal information has been handled by Toddle, please contact us at hello@toddle.com.au