Privacy Policy

PRIVACY POLICY
This is the Privacy Policy for Clear Hayes Consulting Pty Ltd ( ABN 47 632 283 115) of 4/235 Pittwater Road, Manly, NSW (Clear Hayes) It sets out our commitment to protect the privacy of personal information we collect about you, including through our website, www.ClearHayes.com, as well as through our other business operations or directly from you.
 
WE RESPECT YOUR PRIVACY
Clear Hayes collects, uses and is responsible for certain personal information about you. When we do so, we are regulated under Australian Privacy Laws, including the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) and associated laws.
You can find information about how we handle and manage your personal information in this Privacy Policy. Our aim is to provide this information to you in an open and transparent manner, so that you can make informed decisions about your dealings with us. However, if you have any questions about this Privacy Policy or how we manage your personal information, please contact our Privacy Officer at [email protected] Privacy Policy also provides information about how you can seek access to and correction of the personal information that we hold about you.
We may update or revise this Privacy Policy from time to time. You can find the most current version on our website https://clearhayes.com/privacy-policy/.
Please note that where we pass your personal information to third parties we deal with when providing services to you such as promoters, venues and event partners (“third parties”) such third parties will themselves be responsible for processing your personal information in accordance with their own privacy policies as data controllers. We are not responsible for how they process your personal information where they are not acting on behalf of Clear Hayes. You will need to contact them directly in order to exercise your rights in relation to your personal information.
 
A. KINDS OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
The kinds of personal information that we collect will vary depending upon our interaction with you but may include  :
  1. your name, address and other contact details (like your telephone number);
  2. your email address;
  3. your age;
  4. your gender;
  5. transaction details relating to any purchase(s) that you have made or that have been made on your behalf;
  6. credit card details, if you make a purchase with us or choose to have these stored in your online accounts with us to make the checkout process faster;
  7. any preferences that you select; and
  8. any other personal information (including but not limited to any image of yourself provided by you to us) which may be required to facilitate your dealings with us.
Our services are neither directed nor intended for use by minors under the age of 16. Clear Hayes does not knowingly collect personal information of minors. If Clear Hayes learns that it has done so, it will delete such information. Do not access or use Clear Hayes services if you are under the age of 16 unless you have the consent of your parent or guardian. We recommend reading the information relevant to the event(s) you are attending, to ensure you meet the minimum age requirements for that event.
 
B: HOW DO WE COLLECT PERSONAL INFORMATION?
Generally, we collect personal information when you:
  1. make a purchase through us, for example, over the phone, or via our website;
  2. register your details on our website, mobile site;
  3. participate in a survey, competition, promotion or other marketing campaign;
  4. indicate that you wish to receive news, offers or other marketing material from us;
  5. register to receive event specific updates from us;
  6. make an inquiry or a complaint;
  7. provide your business card to us at an event;
  8. have other dealings with us, for example, via social media or in person, over the phone or when you write to us.
In certain circumstances, we may also collect personal information about you in the course of combining and analysing different data sets which, in and of themselves, may not contain personal information.
If you register for a Clear Hayes hosted or run event with a request for accessible seating or specific dietary requirements, we may also collect health data from you. We need certain health data from you in order to assess your requests. We will only process this data for these purposes and on the basis of your consent. You have the right to withdraw this consent at any time
Sometimes we collect personal information about you from other sources, for example:
  1. agents who we engage to provide services on our behalf to sell tickets to an event;
  2. people making a purchase on your behalf;
  3. our business clients and partners;
  4. third party suppliers and contractors who assist us to operate our business such as:some text
    • information technology suppliers
    • marketing and digital services suppliers
    • research and development organisations
    • data partners
    • analytics consultants; and
  5. publicly available sources of information.
Also, from time to time we may collect personal information about individuals who do not provide this information directly to us. This is usually where we collect the name and business contact details of a person who is the contact in a government agency or company with whom we deal. Our policy is to only use personal information collected from non-Participants for the main business purpose for which it was collected.
 
C: WHETHER INFORMATION HAS TO BE PROVIDED BY YOU, AND IF SO WHY
The provision of personal data including name, address, email address, phone number etc is required from you to enable us to tailor communications and ensure you are up to date with information regarding any event you register to attend.
Where it is lawful and practicable to do so, we will give you the option at the point of collecting information from you, of not providing personal information, or of using a pseudonym, when you deal with us. If you don’t provide us with the personal information requested or the information provided is incorrect or incomplete, this could impact the level of service we are able to provide to you. For example, we will not be able to contact you in the case of an event cancellation or venue change, or your credentials may not be able to be matched to your name.
 
D: HOW DO WE HOLD PERSONAL INFORMATION?
We may hold your personal information in electronic or hard copy format or a combination of both. This personal information may be combined or linked with other information held about you, or linked with other information held about or which we attribute to, you, including   :
  1. information (personal or otherwise) that we collect from our website and mobile site (as described in our Cookie Consent Tool) or from third parties; and
  2. personal information we receive from our client businesses, who, in common with us, have a relationship with you and where we understand that you have consented to such client businesses sharing your personal information with us.
We have taken a number of physical, electronic and procedural steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
We protect the personal information we collect in a secure database stored by our third-party data storage provider. It is in proprietary data format, which can only be read using proprietary tools.
Our employees are required, as a condition of their employment, to treat personal information held by us as confidential, and to maintain the confidentiality of that personal information. They are also required to use a login and password when accessing our systems and to undertake training about how to manage personal information.
 
E: WHAT ARE THE PURPOSES FOR WHICH WE MAY COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION?
Generally, we only use personal information for the primary purpose for which we have collected it, or for another closely related secondary purpose. Our potential uses of personal information which we collect (and for which you consent to us using your personal information for) may include  :
  1. to process and fulfil your purchase and/or registrations with us;
  2. to contact you if there is an event cancellation or change in event details, or for the replacement of lost tickets;
  3. to get a better understanding of you, your needs, your behaviours and how you interact with us in order to identify ways in which we can provide you with a better service, or enhance your experience of our website and mobile site or other services;
  4. to manage your dealings with us as a Clear Hayes customer ;
  5. so that where you have consented to this, we can (and to allow our related companies to) promote our products and services to you and the products and services of third parties that we deal with;
  6. where you have consented to this, to allow our clients to promote their products and services to you and those of their partners;
  7. for business research and the development of new services;
  8. to facilitate the competitions, special offers and promotions that we or our partners run;
  9. to display content and advertising that are customised to your interests, preferences and experiences, including through online targeted marketing, data and audience matching and market segmentation activities;
  10. to verify your identity;
  11. for the conduct of data analytics and predicting trends;
  12. for marketing services in connection with the products and services we or our partners provide;
  13. so that we can respond to inquiries and complaint handling; and
  14. to comply with our legal and regulatory obligations and enforce our legal rights.
Sometimes we will produce aggregated data. We may also receive aggregated data from third-party suppliers and contractors or business customers. This aggregated data does not identify individuals. We use, and may combine, the aggregated data we produce and receive for research purposes and in connection with products and services we provide to our business clients.
From time to time, there may be other purposes for which we collect, hold, use and disclose your personal information. We will tell you about these at the point of collection.
 
F: MARKETING AND COMMUNICATION PREFERENCES
As set out above, we may use personal information about you for marketing and research purposes. You can manage your communications and marketing preferences at any time if you no longer wish to receive marketing material from us. In addition, the marketing communications that we send to you will contain information on how to unsubscribe from those communications.
 
G: REASONS WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION
We require a lawful basis for processing your personal information in relation to the processing in question.
The primary lawful basis we use is that the processing is for the purposes of legitimate interests of us or a relevant third party (such as the operation of our business and to provide the tailored services you would expect and to prevent and detect fraud). For example, we would rely on this basis in order to provide you with services or other purchase you may have made with us, and to contact you if there is an event cancellation or change in event details. We may also rely on an additional basis that the processing in question is necessary for the performance of a contract for which you are a party or relates to steps taken at your request to enter into such a contract.
We rely on consent as a lawful basis where we require this in order to lawfully market you and to pass your data to third parties (such as venue operators, promoters and event partners) to allow them to do so. Where we are relying on your consent you are entitled to withdraw your consent for the processing in question at any time. Otherwise, we rely on our legitimate interests to process your personal information for marketing and promotional purposes.
We may also process your personal information where needed to comply with our legal and regulatory obligations.
 
H: WHO MIGHT WE DISCLOSE YOUR PERSONAL INFORMATION TO?
We may disclose your personal information:
  1. to venue operators and to event partners of any event for which you purchased or received tickets (issued in varying forms) to. We may disclose your personal information to such organisations for operational purposes. If you consent, these organisations may use this information to provide you with promotional and marketing material about the event via email. You may change your preference to receive email marketing at any time directly with the organisations which have obtained your information.
  2. to third party contractors and service providers who help us operate our business or provide a service to you. We may disclose your personal information to third party contractors and service providers who, for example, help us operate our computer systems, send out our mail/email and clean collected data;
  3. to event partners, venue operators, sponsors and promoters if they require this information to fulfil or administer services to you;
  4. to government bodies, in response to, or in anticipation of, a request for your personal information for the purposes of government regulated contact tracing or responding to public health orders or directions. The contact tracing information which may be disclosed includes your full name, contact email and/or contact phone number.
  5. to third party contractors and service providers who help us operate our business or provide a service to you.
Otherwise, we will only disclose your personal information:
i) where we are required to do so by law;
ii) if the disclosure is permitted under privacy laws, or
iii) if you have consented to the disclosure.
 
I: HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
We will only keep your personal data for (a) as long as this is necessary to provide services to you and to keep you informed in accordance with your communication preferences and (in any event) (b) for as long as we are required to do so for legal, accounting or tax purposes or for as long as we need to keep it to bring or defend legal claims or for other reasonable reasons..
 
J: YOUR RIGHTS
Under Privacy laws, you have a number of important rights free of charge. In summary, those include rights to:
  1. fair processing of information and transparency over how we use your personal information that this Privacy Policy is already designed to address;
  2. access to your personal information and to certain other supplementary information;
  3. require us to correct any mistakes in your information which we hold;
  4. receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations;
You also have the right to withdraw your consent at any time where we are relying on your consent as the legal basis for our processing (e.g. direct marketing).
If you would like to exercise any of those rights, please email, call or write to [email protected].
If you would like to unsubscribe from any marketing emails you can follow the information included in your marketing email as to how to unsubscribe from those communications, or click on the ‘unsubscribe’ button at the bottom of the marketing email. It may take up to 4 working days for this to take place.
 
L: COMPLAINTS AND HOW TO CONTACT OUR PRIVACY OFFICER
Our Privacy Officer can be contacted by:
  1. e-mail at [email protected]
  2. letter to 4/235 Pittwater Road, Manly, NSW, 2095.
If you feel that we are not complying with this Privacy Policy or the APPs, please put your concerns in writing and send them to our Privacy Officer by one of the methods set out above.
We will always endeavour to investigate your complaint and respond to you as soon as practicable after receipt, generally within 30 days. If you are not satisfied with our response, you may refer the matter to the Office of the Australian Information Commissioner or the Information Commissioner’s Office, as applicable.
 
Last updated 04 October 2024