Privacy Policy

Thrive Canine Pty Ltd (ABN 92 654 676 221) (Thrive Canine) is not bound by or required to comply with the Privacy Act 1988 (Cth) and related legislation. However, Thrive Canine acknowledges the importance of handling Personal Information with care and maintaining client privacy. This privacy policy (Policy) therefore outlines how Thrive Canine endeavours to collect, use, store and disclose Personal Information during the course of providing its services, consistent with the Privacy Act 1988 (Cth).

1 DEFINITIONS

In this Policy, the following words have the following meanings:

Personal Information has the same meaning given to that term in the Privacy Act 1988 (Cth).

Policy means this privacy policy.

Privacy Act means the Privacy Act 1988 (Cth), as amended from time to time.

Sensitive Information has the same meaning given to that term in the Privacy Act 1988 (Cth).

Thrive Canine means Thrive Canine Pty Ltd (ABN 92 654 676 221).

Website means the website available at www.thrivecanine.com.au.

2 ABOUT THIS POLICY

(a) Thrive Canine is committed to protecting the privacy of individuals with whom it interacts and, although it is not bound by the Privacy Act, endeavours to voluntarily handle Personal Information in accordance with the Privacy Act.

(b) In this Policy, ‘Personal Information’ has the same meaning as set out in the Privacy Act. In essence, Personal Information is information or an opinion about an individual who is identified or reasonably identifiable.

(c) ‘Sensitive Information’ also has the same meaning as set out in the Privacy Act. Sensitive Information is a subcategory of Personal Information which relates to areas where prejudices may prevail, such as health information, criminal records, and sexual preferences. Sensitive Information is subject to stricter handling requirements than Personal Information under the Privacy Act.

(d) This Policy sets out Thrive Canine’s policies and practices regarding its management of Personal Information, including how Thrive Canine collects Personal Information, its purposes for collection, and to whom Personal Information may be disclosed.

(e) Where applicable, Thrive Canine will handle Personal Information in accordance with exemptions under the Privacy Act.

3 KINDS OF PERSONAL INFORMATION COLLECTED

(a) Thrive Canine typically collects the following kinds of Personal Information:

(i) Client and related party contact information

Examples: Client names, email, address, and phone numbers. Primary care vet / veterinary behaviourist name, email and phone number. Previous or concurrent trainer name, email and phone number.

(A) When we onboard you as a client, we collect contact details about you and the professionals with which you work to provide you with our services and liaise with relevant contacts.

(B) This information may be disclosed to your primary care vet, veterinary behaviourist, and concurrent trainers, as well as our service providers such as Google Drive, Square and Acuity.

(ii) Sensitive Information about clients

Examples: Allergies, conditions which may affect an individual’s ability to train, and details of previous injury involving a dog.

(A) We may collect health information about you if that information is relevant to the services which we are providing. For example, if you have a health condition which affects your ability to train your dog and requires adjustments, we may make a note of that condition to tailor our services to you. We may also collect health information about you if you have been injured by your dog or another dog and we need to take this into consideration when assessing your dog’s behaviour.

(B) This information may be disclosed to your primary care vet, veterinary behaviourist, and concurrent trainers, as well as our service providers such as Google Drive, Square and Acuity.

(iii) Your dog's history and behaviours

Examples: Information gathered during consultations regarding dog behaviour, including incidents. Behaviour reports developed by us and provided by concurrent or former trainers, vets, and veterinary behaviourists.

(A) When you have a behaviour consult with us, we collate your dog’s history and behaviour concerns so we can develop a plan to work through those concerns. If you attend group training with us, we will also collate information about any issues on which you wish to work.

(B) This information may be disclosed to your primary care vet, veterinary behaviourist, and concurrent trainers, as well as our service providers such as Google Drive, Square and Acuity.

(iv) Information about actual or potential employees, contractors, and mentorship participants

Examples: Name, email, address, phone number, qualifications, CV, experience, referrals.

(A) If you are an actual or potential employee, contractor, or mentorship participant with Thrive Canine, Thrive Canine may collect your Personal Information to assess your suitability to work with us, and to consider any adjustments which might need to be made to allow your participation and involvement.

(B) This information may be disclosed to the clients with which you work and relevant primary care vets, concurrent trainers, and veterinary behaviourists, as well as our service providers such as Google Drive, Square and Acuity.

(v) Sensitive Information about actual or potential employees, contractors, and mentorship participants

Examples: Allergies, conditions which may affect an individual’s ability to train, and results of police checks.

(A) We may collect the results of police checks from you to consider your suitability as a member of the team. We may also collect health information from you if you have a health condition which affects your ability to work with us and requires us to make adjustments to meet your needs.

(B) This information may be disclosed to our service providers such as Google Drive, Square and Acuity.

(i) Use of the Thrive Canine Website

Examples: Cookies and usage information such as IP address, the name of your internet service provider, your browser version, the website that referred you to us, the next website you go to, the pages you request, the date and times of those requests, and the country in which you are located.

(A) Except where you provide it to us via the Website, Thrive Canine does not collect Personal Information such as your name, address, email address or phone number when you are browsing our Website, unless you make an enquiry or booking.

(B) Thrive Canine may use technology such as ‘cookies’ on its Website and in emails you receive from us. A ‘cookie’ is a small data element stored by your web browser on your computer system. Thrive Canine cookies do not store your Personal Information and are used to generate statistics and measure site activity. When you visit the Website, you may receive certain customised information based on the data stored in your cookie. The use of ‘cookies’ is an industry standard and helps Thrive Canine to monitor the effectiveness of its advertising and how visitors use its Website.

(b) Except as stated above, Thrive Canine generally does not request that you disclose any Sensitive Information (such as details of your religious beliefs, sexual orientation, or health information) to us. If you do provide Sensitive Information to Thrive Canine for any reason, including where the information is requested by us, you consent to us collecting that information and to our use and disclosure of that information for the purpose for which you disclosed it to us, as permitted by the Privacy Act and other relevant laws.

4 HOW PERSONAL INFORMATION IS COLLECTED

Thrive Canine usually collects your Personal Information directly from you, for example when you make an enquiry or booking with us, complete our intake form, or attend a consultation with us. However, we may also collect your Personal Information from other sources such as:

(a) your primary care vet, concurrent or former trainers, or veterinary behaviourist; or

(b) publicly available sources.

5 PURPOSES FOR WHICH PERSONAL INFORMATION IS HELD, USED AND DISCLOSED

(a) The purposes for which Thrive Canine uses and discloses your Personal Information will depend on the circumstances in which we collect it. Wherever practical Thrive Canine will endeavour to inform you why your Personal Information is being collected, how Thrive Canine intends to use that information, and to whom Thrive Canine intends to disclose the information at the time it is being collected.

(b) By law, Thrive Canine may disclose your Personal Information:

(i) for the purposes for which we collected it (and related purposes which would reasonably be expected by you);

(ii) for other purposes to which you have consented; and

(iii) as otherwise permitted or required by law.

(c) In general, Thrive Canine collects, uses and discloses your Personal Information so that we can work with you, operate our programs, and provide you with comprehensive behavioural and training support for your dog/s, as set out in clause 3 above.

(d) Some of the specific purposes for which Thrive Canine uses and discloses Personal Information are:

(i) to process bookings and enquiries;

(ii) to provide services to you;

(iii) to contact other professionals who are part of your dog’s behaviour team in support of your dog’s behaviour modification program;

(iv) to maintain contact with you and check in regarding you and your dog’s wellbeing; and

(v) to monitor, report on and improve our services and programs.

(e) Thrive Canine may also use and disclose your Personal Information for the purpose of direct marketing to you where you have consented to us doing so, or where otherwise permitted by law. You can unsubscribe from our direct marketing, or change your contact preferences, by contacting us using our contact details in section 12 below.

6 THIRD PARTIES TO WHICH PERSONAL INFORMATION MAY BE DISCLOSED

(a) Thrive Canine may disclose your Personal Information to third parties in connection with the purposes described in clauses 3 and 5 above. This may include disclosure to the following types of third parties:

(i) our data management providers, including Google Drive, Square and Acuity;

(ii) other professionals who work with you and your dog, such as your primary care vet, veterinary behaviourist, and concurrent or former trainers;

(iii) our contractors, including our behaviour consultants and group class trainers, debt collectors, website and data hosting providers, cloud storage providers and other IT suppliers;

(iv) in the event of an emergency, ambulance or other emergency services;

(v) the relevant council in which our services are provided to you;

(vi) other persons who perform services for or in connection with us;

(vii) our professional advisors, including but not limited to our accountants, lawyers, insurers and auditors;

(viii) any other third parties to whom you have directed or permitted us to disclose your Personal Information;

(ix) third parties that require the information for law enforcement or to prevent a serious threat to public safety; and

(x) as otherwise permitted or required by law.

(b) Thrive Canine will not sell your Personal Information to another organisation for that organisation’s unrelated, independent use.

(c) Where Thrive Canine discloses your Personal Information to third parties, we will use reasonable commercial efforts to ensure third parties only use your information as reasonably required for the purpose for which it was disclosed to them, and in a manner consistent with the Privacy Act.

(d) If you share Personal Information to public parts of our website or social media pages, you acknowledge that such information may be available to and viewed by the public. Thrive Canine encourages you to use discretion in deciding what information to share on such sites.

7 OVERSEAS DISCLOSURE

(a) Some of the third parties to whom we disclose Personal Information may be located outside Australia. The countries in which these third parties are located will depend on the circumstances, and the server locations which our third party service providers choose to utilise. It is not practicable for us to list all of the overseas countries to which that information may be disclosed.

(b) Except where an exception applies under the Privacy Act, we will take reasonable steps to ensure that such overseas recipients do not breach the Privacy Act in relation to your Personal Information.

8 SECURITY OF PERSONAL INFORMATION

(a) Thrive Canine is a paperless organisation. Thrive Canine protects your Personal Information using secure online storage processes.

(b) Thrive Canine takes reasonable steps to protect your Personal Information from misuse, loss, and interference, and from unauthorised access, modification and disclosure. Some of the ways we protect your information include:

(i) utilising secure servers;

(ii) restricting access to your Personal Information only to authorised Thrive Canine personnel who need your information to perform their functions; and

(iii) adopting security measures such as password protection, multi-factor authentication, and anti-virus software.

9 ACCESSING AND CORRECTING PERSONAL INFORMATION

(a) If Thrive Canine has retained Personal Information it has collected about you, you may access it subject to any exceptions under relevant laws. We ask that you provide us with a written application to request access to your Personal Information, and provide us with suitable identification. Where permitted by law, we may charge an administration fee for granting access to your Personal Information.

(b) If you become aware that Personal Information we hold about you is incorrect and you wish to access and update your information, please contact us using our contact details in section 12 below.

10 COMPLAINTS

(a) If you have any questions or concerns regarding Thrive Canine’s collection, handling, use or disclosure of your Personal Information, or if you believe we have not complied with this Policy, please contact us using our contact details in section 12 below. Thrive Canine will investigate your complaint and determine whether a breach has occurred, as well as what action, if any, we should take.

(b) Thrive Canine will take any privacy complaint seriously and will aim to respond in a timely manner. We ask that you co-operate with us during this process and provide us with any information that we may need.

(c) If you remain dissatisfied following the outcome of a complaint, you can also make a formal complaint to the Officer of the Australian Information Commissioner using the details available on its website.

11 CHANGES TO THIS POLICY

Thrive Canine may update this Policy from time to time at its discretion. The latest version of the Policy will be as available on the Website. We recommend you review this webpage on a regular basis, and we will use reasonable endeavours to notify you of any material changes to this Policy.

12 CONTACT DETAILS

If you wish to make a privacy complaint, comment or query, or if you would like to request access to or correction of your Personal Information, please contact us at hello@thrivecanine.com.au.

Last updated: January 2025