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Privacy Policy

  1. This Privacy Policy
    1. ACN 636 044 374 Pty Limited ACN 636 044 374 (trading as 100 Percent Partners), (100 Percent, we, us or our) respects the privacy of a person accessing or using our Website (you or your).  This Privacy Policy (this Policy) sets out how we process your personal information when you access the CEO Succession Website or engage with us in respect of the CEO Succession Program.  For definitions applicable to this Policy, see under heading 12 below.
    2. This Policy addresses our obligations in respect of the laws of Australia applicable to New South Wales and does not necessarily address the requirements of or rights conferred by other laws (see under heading 8 below).  If you access or use our Website, then your access or use:
      • must comply with the privacy law of the State, region or country in which you are located; and
      • constitutes your representation and warranty to us that the processing of your personal information complies with such applicable privacy law.
    3. By providing personal information to us, you consent to our processing of your personal information in accordance with this Policy and any other arrangements that apply between us (including our other Terms of Use).  If you do not accept this Policy, do not access or use our Website.
    4. We may change this Policy at any time and for any reason (for example, to align with our business needs or legal requirements) by updating our Website and posting an updated effective date.  We encourage you to check our Website periodically to ensure that you are aware of the current terms of this Policy.  We may also notify you by other means such as sending an email or posting a notice on our Home Page.
  2. Legal bases for processing personal information
    1. The legal bases we rely on for processing your personal information depend on the personal information at issue and the context under which the information is processed, and they include:
      • disclosure in this Policy that we may process your personal information,
      • your consent, express or implied, from the circumstances of the processing of your personal information (such as for recording Participant input in Courses or Events,
      • in the case of sensitive Information, your explicit consent, or where processing is required by applicable law,
      • where it is necessary for the purposes of carrying out your or our obligations and exercising our or your specific rights in the field of employment, and
      • where it is necessary for the establishment, exercise or defense of legal rights or claims.
  3. What information may we process?
    1. The type of personal information we collect depends in part on how you use our Website and our relationship with you.  We collect information from and about Participants and Suppliers, as well as other types of professional associates and personal contacts.  Generally, we collect personal information required for the provision of our Services, and may include the following types of personal information about you discussed below.
    2. All contacts: The categories of personal information we collect may include:
      • your full name,
      • email, street and mailing address, telephone number and other contact details and other forms of personal identification,
      • details of the Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries,
      • additional information relating to you that you provide to us directly through our Website or indirectly through your use of our Website or online presence or through other websites or accounts from which you permit us to collect information, and
      • other personal information that may be required in order to enable or facilitate the provision of the Services or our dealings with each other.
    3. Participant: If you are a Participant, the personal information we collect may include, in addition to that referred to in paragraph 3.4, the following information:
      • your device, computer and connection information,
      • your photographic image,
      • your education history, languages and character traits,
      • your professional experience, responsibilities and competencies,
      • your individual capabilities, qualifications, professional style profile, and employment and development preferences,
      • reviews, surveys and responses to evaluation processes, and
    4. Referee or Source: If you are a Referee or Source, the personal information we collect may include, in addition to that referred to in paragraph 3.4, the following:
      • certain professional and employment details (such as title, occupation, qualifications and employment history),
      • references and feedback, and
      • your connection to the relevant individual.
      • Any reference or feedback you provide about an individual will not be attributed to you if shared with third parties, unless you consent to our doing so.
    5. Client or Supplier: If you are a Client or Supplier, the personal information we collect may include, in addition to that referred to in paragraph 3.4, the following:
      • your job title,
      • business records related to the Services, and
      • information you provide to us through Client surveys.
    6. If you are providing personal information of a third party, you must obtain the consent of such party before providing it to us, and you must ensure that they have read and consent to this Policy.  If you do not wish us to process your personal information or that of a third party referred to above, do not submit it to us.
  4. With whom may we share personal information and why?
    1. We may process your personal information in the context of providing our Services and maintaining our business relationship with you, including:
      • Clients, Program participants, and Speakers,
      • Suppliers and third-party service providers; for example, those engaged to perform online payment processors and software providers,
      • regulatory bodies and law enforcement agencies as required by law, or to exercise, establish, or defend your or our legal rights,
      • our employees, related bodies corporate, business partners, agents, professional advisers and contractors, and
      • third parties authorised by you to receive your personal information held by us.
    2. We may process your personal information for any of the following purposes:
      • to enable you to access, request, book and confirm and use our Services,
      • to provide our insights, analyses or reports to our Clients,
      • to send you marketing and promotional messages and other information,
      • to respond to your inquiries and answer your questions about our Services,
      • to enable you to share our content with others,
      • to provide, develop and improve the Services (including performing analytics, benchmarking, conducting research, and advertising and marketing),
      • to administer Events and Courses sponsored or managed by us or our business partners,
      • to maintain business records, including those related to our Services,
      • to exercise our legal rights and to comply with our legal compliance obligations or those of other parties,
      • to secure, improve, back up and maintain our Website and IT systems,
      • for audit procedures, security processes, document storage, and other business administration purposes, and
      • for any other purpose referred to or indicated in this Policy or the Terms of Use.
    3. By using our Website, you consent to the receipt of direct marketing material.  We will only use your personal information for this purpose if we have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from us.
  5. How do we process your personal information?
    1. We collect personal information about you (and see under heading 7 below):
      • automatically when you visit, use and access our Website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer;
      • when you register on our Website,
      • when you complete registration or enquiry forms, order any Services from us, or send emails to us,
      • when you request, book and confirm Services from us,
      • when you provide us with certain types of personal information, such as a resume and contact details, if you wish to obtain a particular Service from us,
      • from Sources, the media, professional networking sites,
      • when you communicate with us through correspondence, chats, email, or when you share information with such persons from other social applications, services or websites; or
      • when you interact with the sites, services, content and advertising of us or any of our Suppliers, agents, contractors or merchants.
    2. We may collect the personal information referred to above either directly from you, or from third parties (for example, Clients, professional partners, Sources, Referees, or from publicly available sources, such as the Australian Business Register, social media (such as LinkedIn), your professional networking profile and news reports.
    3. We may also initiate our own checks about our Suppliers, and with your consent we may also use a third party service to verify your employment, educational and identity records.
  6. How long do we retain your personal information?
    1. We will retain your personal information for as long as the information is needed in connection with the purposes for which it is being processed, depending on the nature of our relationship with you, or with your consent.
    2. When we no longer require your personal information for the purpose for which we obtained it, we will take reasonable steps to destroy and anonymise or de-identify it.  However, we may store your personal information in backup archives, and  personal information stored in our client files and records will be kept for a minimum of [seven] years to fulfil our record-keeping obligations.
    3. We will cease using your personal information in any of the following circumstances:
      • where you have previously given your consent to the processing of your information for a particular purpose and you withdraw consent for that purpose by “opting out” by using the Unsubscribe link; and
      • where we are informed or we discover that the continued use of your personal information is not permitted by privacy law in any jurisdiction which is applicable to your personal information.
  7. Links to other websites and “cookies”
    1. Our Website may contain links to websites operated by third parties.  Those links are provided for convenience and we are not responsible for, and have no control over or rights in relation to, those linked websites, or the conduct of companies linked to our Website.  In particular, we are not responsible for the privacy practices of, or any content on, those linked websites, which may not remain current or be maintained.  The privacy policies that apply to those other websites may differ substantially from this Policy, so we encourage you to read those policies before using those websites.  Those third parties may (or may not) be responsible for informing you of their own privacy policies and updates.
    2. We use “cookies” or other similar tracking technologies on our Website that help us track your usage of our Website and remember your preferences.  (Cookies are small files that store information on your computer, television, mobile phone or other device, which enable the entity that placed the cookie on your device to recognise you across different websites, services, devices or browsing sessions.)
    3. Our cookies are first-party cookies and are used only as part of the reasonable functioning of our Website and our Services, and do not record any personal information of anyone using our Website.  For example, we use Google Analytics to track website traffic and website usage.  Google Analytics cookies are used to store information, such as what time the current visit occurred, whether the visitor has been to the site before, and what site referred the visitor to the web page. Google Analytics’ Terms of Service prohibits the use of its service for the collection of personally identifiable information, such as your name, address, email address or any other data that can be reasonably linked to such.  You acknowledge and accept that we have no control over Google’s data collection.
    4. If for any reason you do not want to be tracked, you can disable cookies through your internet browser.  For example, Google Analytics provides a browser Opt-Out ad-on, which prevents Google Analytics from tracking you but does not prevent data from being sent to our servers nor any other tracking services or tools we may use.
    5. If you choose not to receive our cookies, our Website may not work for you as intended, or your experience with our Website may not be as quick or responsive.
    6. We may also use cookies to enable us to collect data that may include personal information; for example, where a cookie is linked to your account.  In such a case, we will handle personal information collected by cookies in the same manner as other personal information under this Policy.
  8. Transfer or disclosure overseas
    1. Your personal information may be transferred overseas or stored overseas for a variety of reasons.  It is not possible to identify every country to which your personal information may be sent.
    2. For example, if you are a resident in a European Union country, then such privacy law may include the European Union General Data Protection Regulation (EU) 2016/679 and, if you are a resident of California, then such privacy law may include the California Consumer Privacy Act of 2018.  The same applies in respect of other countries also.
    3. If your personal information is transferred to a jurisdiction which does not have data protection laws as comprehensive or as strong as Australia’s, your consent to our transferring your personal information to that jurisdiction is in the knowledge that you may not have a remedy if your personal information is mishandled in that jurisdiction, and we disclaim responsibility to you, and you will not have a remedy under Australian law.
  9. Security of your personal information 
    1. We will take reasonable security measures to ensure personal information is stored securely to protect personal information from loss, unauthorised access, use, modification or disclosure.
    2. We may hold your personal information in either electronic or hard copy form.  We will take reasonable and appropriate steps to have appropriate physical, technical and administrative procedures in place to help protect your personal information from unauthorised access, use or disclosure as required by applicable privacy law.  However, you acknowledge that:
      • the internet is not a secure environment, and we cannot guarantee the security, integrity and privacy of your personal information;
      • if you use the internet to send us any personal information, including your email address, it is sent at your own risk; and
      • your personal information may be viewed or interfered with in transit by a third-party.
    3. You further acknowledge that, if we become aware that the security of our Website has been compromised or that your personal information has been disclosed to third parties as a result of unauthorised external activity (including security attacks or fraud), we may take reasonably appropriate measures (including investigation and reporting, and notification to and co-operation with law enforcement authorities).  In such an event, and if we believe that there is a reasonable risk of harm to you as a result, or if notice is required by law, we will make reasonable efforts to notify you by email, text message or by posting a notice on our Website.
  10. How can I access or correct my personal information?
    1. You have the right under the APPs to request access to your personal information and to request that personal information about you which is inaccurate be corrected.  However, access is subject to some exceptions, including where your personal information:
      • would have an unreasonable impact on the privacy of another person,
      • would reveal a commercially sensitive decision-making process, or
      • may not by law be disclosed, or where access would prejudice certain procedures.
    2. If you think that any of your personal information is inaccurate or out-of-date, please contact us using the information below.  We may also need to verify your identity when you request your personal information.
    3. We require a reasonable time (usually 30 days) to respond.  You will need to be in a position to verify your identity before any access will be granted.  In some cases, we may impose a moderate charge for providing access to personal or sensitive information.
  11. What if I have a complaint?
    1. If you think we have breached this Policy or any privacy law, or you wish to make a complaint about the way we have handled your personal information, you can contact us.  Please include your name, email address and telephone number and clearly describe your complaint.  We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time.  If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
    2. We strive to resolve complaints quickly and informally. If you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by post or email as referred below.  We will acknowledge your formal complaint within 10 working days.
    3. All complaints will be considered by our Privacy Officer, and we may seek further information from you to clarify your concerns.  If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem.  If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.
  12. Interpretation
    1. In this Policy, except where the context otherwise indicates:
      • APPs means the Australian Privacy Principles under the Privacy Act,
      • General Terms means the General Terms and Conditions of Use of our Website,
      • 100 Percent Partners means ACN 636 044 374 Limited ACN 636 044 374 (trading as 100 Percent Partners), incorporated in the State of New South Wales, Australia, and, where the context admits, its related bodies corporate,
      • our Website means the website ceosuccession.com.au which includes this Privacy Policy,
      • privacy law means the privacy and data protection laws of or applicable to the State of New South Wales, Australia and, where the context admits, equivalent privacy or data protection laws of any other country to which this Policy applies in a particular case,
      • process, in relation to personal information, includes collect, process, store, disclose, share and otherwise use,
      • related body corporate has the same meaning as in the Corporations Act 2001 of the Commonwealth of Australia,
      • sensitive information has the same meaning as in the Privacy Act, and is summarised in paragraph 3.2,
      • Terms of Use means, collectively, this Policy and the General Terms, as in effect from time to time,
      • this Privacy Policy means this Privacy Policy as in effect from time to time,
      • we, us or our means 100 Percent Partners, and
      • you or your means any person who accesses or uses our Website.
    2. In this Policy, except where the context otherwise indicates:
      • the terms Candidate, Client, Course, Enrolment Terms, Event, Participant, Referee, Services, Source and Supplier; and
      • other terms or expressions, and the principles of interpretation,
      • have the same respective meanings as in the General Terms.
    3. Headings in this Policy are to be ignored in the interpretation of this Policy.
  13. Contacting us 
    1. If you:
      • seek access to, or correction of, or deletion of your personal information,
      • have an enquiry or a complaint about the way we handle your personal information,
      • seek to exercise your privacy rights in relation to the personal information we hold about you,
    2. you may contact our Privacy Officer as follows:
      • by email: team@ceosuccession.com.au
      • by phone: +61 2 8076 7498
      • by letter addressed as follows:
      • The Privacy Officer
      • 100 Percent Partners
      • Suite 1103, Level 11,
      • 205 Pacific Highway
      • St Leonards NSW 2065
    3. For any feedback or questions regarding this Policy, please contact us on our online Feedback Form.

[Effective date of this version of this Policy: 14 October 2024.]