Privacy Policy

1 Introduction

1.1 Shing Long Pty Ltd is the owner and operator of Kool Space Indoor Playcentre & Café (Kool Space, us, we, our).

1.2 We are committed to managing personal information in an open and transparent way. This policy outlines how Kool Space handles personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth).

1.3 We will update this privacy policy when our information handling practices change and publish updates on our website.

2 Who we are

2.1 Kool Space is a play centre providing facilities for children's recreation, enjoyment and leisure at its Premises.

2.2 Kool Space collects, holds, uses and discloses personal information where it is reasonably necessary to carry out our functions or activities, which include:

• (a) operating and maintaining the Kool Space play areas and facilities;
• (b) administering our relationship with ticket or booking holders;
• (c) providing access to our Premises and facilities to visitors;
• (d) managing our staff;
• (e) administering our contracts with service providers;
• (f) sending communications to our community and subscribers, for example, to send newsletters or to advertise our offerings, organise bookings and events.

3 Information we collect

3.1 We try to only collect the information we need for the particular function or activity we are carrying out. Personal information we typically collect from you may include:

• Name
• Age
• Contact details (address, email, phone number)
• Your position in the relevant organisation that you represent, authorising authority
• Banking details
• Evidence of working with children and police checks
• Photographic images and video recordings of you
• Health information such as medical or dietary needs
• Information we are required to provide to the Australian Tax Office, a Superannuation Fund, or other regulatory authority
• Details regarding qualifications and experience which we deem necessary to enable us to form an opinion as to suitability for a task or tasks required to be performed on our behalf
• Any other information which is required to be collected to meet our regulatory reporting obligations.

4 Sensitive information

4.1 Sometimes we may need to collect sensitive information about you, including information about your health, work history via reference checks, criminal history, racial or ethnic origin, political opinions, association memberships, and sexual orientation. For example:

• we may need to know about any dietary requirements for catered group bookings.
• to conduct worker screening checks for our employees and contractors.

4.2 We will only collect your sensitive information with your consent or where we are required or authorised by law.

5 How we collect information

5.1 Collection directly from you

We mainly collect personal information directly from you, when you give it to us though paper forms, online forms, email, over the phone or in person.

5.2 Indirect collection

On occasion, we collect information indirectly from third parties. For example:

• (a) if you are under 18, we will collect information relating to your attendance, and use of our facilities from your parent or guardian or from the person responsible for a group booking or private hire;
• (b) when you apply for an employment position, we will collect information from your referees, employers or other entities you represent; or
• (c) for recruitment and employment purposes, an external recruitment or background screening services provider.

5.3 Collecting through our website

Kool Space's public website, www.koolspace.com.au is hosted in Australia. We will collect information that you provide to us when signing up to mailing lists and registering for our events, or when submitting a form via our website.

6 Social networking services

6.1 We use social networking services such as Facebook and Instagram to communicate the public.

6.2 When you communicate with us using these services we may collect your personal information, but we only use it to help us to communicate with you. The social networking service will also handle your personal information for its own purposes. These services have their own privacy policies. You can access the privacy policies for [insert] on their websites.

7 Disclosure

7.1 Common situations in which we may disclose information are detailed below.

• (a) to government agencies, regulators and enforcement bodies where we are required to do so by law to meet our legal obligations (such as under child safety laws);
• (b) providing any banking details to financial institutions for payroll purposes;
• (c) when receiving services from professional advisors, agents and contractors;
• (d) to our third party catering provider where private hire bookings have been made;
• (e) to our insurance provider; and
• (f) otherwise, where we have your consent.

7.2 Social media and photos

7.3 We may use photos or videos taken in which you are reasonably recognisable in marketing or promotional material unless you have told us your preference.

7.4 Software providers and data storage

7.5 We disclose information to some software providers and utilise others to collect and store information on our behalf. For example, we use Venue Sumo for our online booking system and Windcave as our payment platform.

7.6 Disclosure of sensitive information

7.7 We only disclose your sensitive information for the purposes for which you gave it to us or for directly related purposes you would reasonably expect, for example, where a permitted health situation exists or where you have given your consent.

7.8 Disclosure of personal information overseas

7.9 We store our information in servers located in Australia. We do not disclose personal information overseas.

7.10 When you communicate with us through a social network service such as Facebook or Instagram, the social network provider and its partners may collect and hold your personal information overseas.

7.11 We have no international dealings and therefore will not disclose personal information to anyone outside of Australia.

8 Direct Marketing

We may use your personal information in order to inform you of services that we offer that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting us via the contact details set out here or through any opt-out mechanism contained in a marketing communication to you.

9 Anonymity

Where possible, we will allow you to interact with us anonymously or using a pseudonym. However, for most of our other functions and activities we usually need to collect your name and contact information.

10 Quality of personal information

To ensure the personal information we collect is accurate, up-to-date and complete, we promptly update personal information when you tell us something may have changed.

11 Storage and security of personal information

11.1 We hold personal information on our cloud storage system, on servers located in Australia, and in physical records stored at Kool Space premises. We retain effective control over any personal information held on our cloud, and the information is handled in accordance with the Australian Privacy Principles.

11.2 We take steps to protect the security of the personal information we hold from both internal and external threats by assessing the risk of misuse, interference, loss, and unauthorised access, modification or disclosure of that information (data breaches), and taking measures to address those risks.

11.3 Examples of how we limit the risk of data breaches include:

• (a) restrictions on who has access to different types of information (access controls);
• (b) providing training to our staff about privacy;
• (c) requiring staff to delete photos from personal devices once uploaded to Kool Space systems;
• (c) only Kool Space devices will be used to take photos and bookings;
• (d) requiring digital information to be stored in our databases or on Kool Space issued devices, and not locally on personal devices;
• (e) strict password requirements; and
• (f) locks on physical storage facilities such as filing cabinets.

11.4 We delete, de-identify or archive personal information in a secure manner when we no longer need it.

12 Accessing and correcting your personal information

12.1 You have the right to ask for access to personal information we hold about you and ask us to correct that personal information. You can ask for access or correction by contacting Kool Space by:

• (a) Telephoning us on (03) 9551 3919; or
• (b) Writing us an email info@koolspace.com.au.

12.2 We will respond to your request within 30 days.

12.3 We may ask you to verify your identity before we give you access to your information or correct it. If we refuse your request, we will tell you the reasons in writing.

12.4 If the purpose of your request is other than to correct what you believe to be an error in the information, we may levy a reasonable administration fee for giving access to the requested personal information.

13 How to make a complaint

13.1 If you wish to complain to us about how we have handled your personal information, you can contact us via the contact details below:

13.2 We recommend you send your letter via email, or by registered post, to provide you with confirmation that your complaint has reached us. Privacy complaints are dealt with care. Once we receive your complaint we will:

• (a) acknowledge receipt of your complaint within 14 days;
• (b) take appropriate action to resolve your complaint, including the commencement of an investigation.

13.3 We will provide you with a formal complaint outcome response within 30 days of receiving your complaint. If we require longer to respond to your complaint, we will notify you.

13.4 In the event you are dissatisfied with the outcome of your complaint, you may make a complaint to the Office of the Australian Information Commissioner.

13.5 A copy of this privacy policy is available on our website www.koolspace.com.au.

14 Definitions

14.1 'Personal information' means information or an opinion about an identified individual, or an individual who is reasonably identifiable:

• (a) whether the information or opinion is true or not; and
• (b) whether the information or opinion is recorded in a material form or not.

14.2 'Premises' means the Kool Space Indoor Playcentre & Cafe located at 300 Boundary Road, Dingley Village, Victoria.

14.3 'Sensitive information' is a subset of personal information and is defined in the Privacy Act 1988 (Cth) as:

• (a) information or an opinion (that is also personal information) about an individual's:
• (b) racial or ethnic origin
• (c) political opinions
• (d) membership of a political association
• (e) religious beliefs or affiliations
• (f) philosophical beliefs
• (g) membership of a professional or trade association
• (h) membership of a trade union
• (i) sexual orientation or practices, or
• (j) criminal record
• (k) health information about an individual
• (l) genetic information (that is not otherwise health information)
• (m) biometric information that is to be used for the purpose of automated biometric verification or biometric identification, or
• (n) biometric templates.