Privacy Policy

No Problems Publishing Incorporated and

Australian Institute of Tibetan Healing Practices – Privacy Policy

Last updated: October 2020

About this Privacy Policy

No Problems Publishing Incorporated (ABN 74 439 575 326) (hereafter referred to as “NPP”) is the owner and operator of Overcoming Problems, Tibetan Healing and Yoga services (“NPP Services”), which is provided to both the Australian Institute of Tibetan Healing Practices Incorporated (ABN 84 512 506 043) (hereafter referred to as “AITHP”) and Tibetan Buddhist Healing Practices Incorporated (ABN 45 712 569 215) (hereafter referred to as “TBHP”).

AITHP provides services both directly to individuals at AITHP and TBHP centres but also via NPP Services (“AITHP Services”). Your rights to use the NPP Services and AITHP Services (the “Service”) are set out in this Privacy Policy (“Privacy Policy”) and in our Terms of Service (“Terms of Service”).

“Website” means the whole or any part of the web pages located at https://www.noproblems.org.au/ and includes the layout, individual design elements, underlying code elements and any text, sounds, videos, graphics, animated elements or other content contained on our Website.

In this Privacy Policy, the terms “we”, “us”, and “our” refers to NPP and AITHP.

Our Terms of Service, Release Waiver and our Privacy Policy are collectively referred to as the Agreement (“Agreement”).

NPP and AITHP provides this Privacy Policy to help you make an informed decision about whether to use or continue using the NPP and AITHP Service. If you do not agree to our practices, please do not use the Service.

This Privacy Policy is subject to the Terms of Service. Your use of the Service and any Personal Data you provide through the Service remains subject to the terms of this Agreement.

Capitalised terms defined in NPP and AITHP’s Terms of Service have the same meaning in this Privacy Policy.

We know how important security and privacy is to you. They are at the heart of NPP and AITHP and as such, we strive to make things as safe and clear as possible for everyone involved.

This Privacy Policy sets out how NPP and AITHP (“we”) treat the privacy of those who use our Service and others with whom we interact.

This Privacy Policy outlines the specific legal obligations we have when collecting and handling your personal information in accordance with the Privacy Act 1988 (Cth), and in particular the Australian Privacy Principles found in that Act.

We will update this Privacy Policy when our information handling practices change. Updates will be published on our website.

A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au .

1. What is Personal Information?

This Privacy Policy refers to all “Personal Information” as information or an opinion about an identified individual, or an individual who is reasonably identifiable:

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

2. Changes

From time to time we will review our Privacy Policy to keep pace with changes in our Service and any data protection and privacy laws applicable to the processing of Personal Data that we are committed to comply with, including:

a) the privacy Act 1988 (Cth, Australia);

b) the Privacy Act 1993 (New Zealand);

c) the Personal Data Protection and Electronic Documents Act, SC 2000, c5 (federal, Canada);

d) the Personal Data Protection Act (Alberta, Canada);

e) the Personal Data Protection Act (British Columbia, Canada);

f) all applicable United States federal and state privacy laws, including, but not limited to, the California Online Privacy Protection Act (CalOPPA), Early Learning Personal Data Protection Act (ELPIPA);

g) the General Data Protection Regulation (EU);

h) the Data Protection Act 2018 (UK);

i) any other applicable privacy legislation.

(the above collectively referred to as “Data Protection Laws”)

This Privacy Policy is our most recently updated Privacy Policy. Your continued use of the Service constitutes your agreement to this Privacy Policy and any amendments. We encourage you to read our Privacy Policy carefully.

3. Collection of Personal Data

(a) We may collect your Personal Information if you:

speak with a volunteer who is in an authorised position to receive personal information directly over the phone;
have contact with a volunteer who is in an authorised position to receive personal information in person;
participate in public or closed surveys, questionnaires, or events;
register for and/or participate in face-to-face or online events (such as classes);
interact with us online, via our website, email, mobile applications and/or social media pages (such as Facebook, Twitter, YouTube, Instagram or LinkedIn – these social media platforms will also manage your personal information in accordance with their own privacy policies);
apply for a position with us (either as an employee, or as a volunteer or as a contractor).

(b)The collection of your Personal Information may be required in order for you to:

join our website as a registered user;
participate in face-to-face or online events (such as classes);
receive information from us including alerts via email or SMS communications;
register to use forum or digital application;
download our online resources
register as a volunteer
access services or resources for your educational institution or organisation;
receive information about or become involved in our programs, campaigns or other initiatives and/or
work with us

4. Collecting personal information through our website

In some instances, we may also collect your personal information through the use of “cookies”. When you access one of our websites, we may send a “cookie” (a small summary file containing a unique ID number) to your computer or internet enabled device.

Cookies are used to:

Recognise your computer or internet enabled device
Greet you each time you visit our website
Keep track of services you view
With your consent, send you news about viewed services
Measure traffic and engagement patterns, to evaluate our website visitor’s habits
Identify and continually improve our services, programs, content and resources
If you do not wish to receive cookies, you can set your browser so that your computer does not accept them

By using our Website and mobile applications, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

What personal information do we collect?

We collect the personal information which you provide to us. This may include your name, address, age or date of birth, telephone number, organisation, service or institution details, email address, communication preferences. In some instances, with your consent, we may also collect health information about you.

If you make a purchase or donation via our Website, you may also provide credit card details and other information which will allow us to process your request and make the transaction.

We may also request:

your preferences for receiving further information about our programs, campaigns or activities;
additional types of personal information such as title, department name, company information, or demographic information

The choice of how much information you provide to us is yours, but we require certain information from you in order to provide particular services. Where possible, you have the option of interacting with us anonymously (for example, as a visitor of the website).

5. Use of Personal Data

We collect your Personal Information for the primary purpose of providing our services to you. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing via our website.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.

6. Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, qualifications/study, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

For the primary purpose for which it was obtained
With your consent; or where required or authorised by law

Information may also be stored on a service called Mailchimp which sends electronic messages and newsletters to you via email. By supplying your contact details, you agree to subscribe to this list, your name and email address are stored on Mailchimp servers to enable us to communicate with you in this way. You can opt out at any time by clicking the ‘unsubscribe’ button at the bottom of emails. Please refer to Mailchimp’s Privacy Policy for further information.

Information may also be stored on a service called Adobe Sign which is an electronic signature service which facilitates the signing, tracking and managing of electronically signed documents. A tamper-evident seal is applied to the final document. By using Adobe Sign you agree to store the completed form on Adobe Sign servers to enable us to receive signed documents from you in this way. You can opt out of this service by downloading and printing the document and returning the signed document by email to enrol@noproblems.org.au. Adobe Sign’s Privacy Policy can be found here.

7. Privacy and Confidentiality

People attend classes at NPP, AITHP and TBHP to solve everyday personal problems through the wisdom of Tibetan Healing Principles. Due to the nature of the classes, people may supply private and sensitive information that should not be discussed outside of the class environment. A safe environment is essential for supporting students in facing and addressing their problems, and the assurance that personal information that they choose to disclose is treated to maintain privacy and sensitivity. Note: NPP, AITHP or TBHP are not a mental health service. If there is a mental health issue the student themselves must seek medical advice.

The purpose of this Privacy Policy is to tell you what kind of information may be gathered or shared, how we may use that information, whether we disclose it to anyone, and the choices you have regarding our use of, and your ability to correct this information.

The Privacy Policy also details the obligations of each student to respect the privacy and confidentiality of fellow students.

Objectives of this clause

To create a safe environment for all students to learn about themselves, social contact between students outside the centre is not permitted.
Communicate appropriate guidelines of personal conduct for all students, which include that issues relating to privacy and confidentiality will be referred to the Centre’s Committee.
Encourage the reporting of behaviour which may breach this policy.
Treat all complaints in a sensitive, fair, timely and confidential manner.

Sensitive Information and Confidentiality

During the course of classes, students may share information that is personally sensitive. Any personal information about other students and their families must be kept strictly confidential and not discussed outside the class setting. Within the class setting, students who have directly witnessed personally sensitive information are asked not address that topic with the student unless that student invites the conversation.
The disclosure of personal and sensitive information about themselves or their families can be an important part of learning about themselves, so it is important to be mindful about what is said when students meet each other or their families. Due to the risk of breaching this confidentiality, social interaction between students outside the centre is not permitted, unless a prior relationship existed.
Because personal information frequently concerns family members, students who have pre-existing friendships, family or relationships with other centre students or ex-students are asked to disclose the existence of that relationship with the Committee.
Please respect your own and centre students’ (both past and present) privacy outside the centre and do not share contact details such as phone numbers and email addresses or access centre students’ online social networking tools including blogs, twitter and other online sharing mechanisms.
AITHP maintains strict confidentiality with personal contact details and students may not have access to another student’s contact details.

Students are encouraged to disclose any concerns about privacy or confidentiality with a committee member.

If this policy is breached

During class attendance, any incidents or issues (such as students socialising outside the centre) that place the safety of other students or visitors at personal risk will be investigated by the Committee. Students who breach this policy may be given a warning, or may be asked to discontinue their contact with the centre, depending on the severity of the situation.

8. Third Parties

Where reasonable and practicable to do so, we will collect your Personal Information only from you.

9. Disclosure of Personal Data

Personal information will only be disclosed to third parties in accordance with this Privacy Policy. NPP and AITHP may at its discretion use other third parties to provide essential services. We may share your details as necessary for the third party to provide that service.

We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services and associated purposes. We deal with third parties that are required to meet the privacy standards required by law in handling your Personal Data and use your Personal Data only for the purposes that we give it to them.

We may disclose your personal information to:

service providers that host our website servers;
marketing service providers;
professional advisors

We may also disclose your personal information if:

you have consented to the disclosure;
the disclosure is necessary to prevent injury to life or health; or
it is required or authorised by or under an Australian law or a court/tribunal order

If you engage in donating or payment for our Services, Personal information may be used through our payment service Paypal. We do not store or collect any financial information. All financial information is collected and stored by Paypal’s Privacy Policy can be found here.

In our office, Personal information is stored on our personal and NPP and AITHP computers and hard copies of enrolment are kept in a locked, private location. Access is only available to administrators, accountant and teachers of NPP and AITHP.

We only disclose your information for the purposes for which you gave it to us, for a directly related purpose which you would reasonably expect, or with your consent.

10. Security of Personal Data

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorized access, modification or disclosure.

Given internet transmissions cannot be guaranteed to be entirely secure, you acknowledge and agree that you use the Service at your own risk.

11. Retention and deletion of Personal Data

We will retain your Personal Data for as long as NPP and AITHP needs to provide you with our Service.

We take steps to regularly destroy Personal Data, however we may:

(a) in some cases, retain a copy of your Personal Data to comply with our legal obligations, resolve disputes, enforce our agreements and to comply with our trust and safety obligations. Personal Data retained for this purpose will be archived and stored in a secure manner and will not be accessed unless required for any of these reasons;

(b) retain Personal Data in an aggregated, de-identified or otherwise anonymous form, such that there is no reliable way of identifying you from the information.

(c) retain Personal Data in order to create statistical information, including reports, about health trends pursuant to the sensitive medical information you have provided.

12. Your Rights

You may decline to submit Personal Data through the Service, in which case NPP and AITHP may not be able to provide certain services to you. If you do not agree with our Privacy Policy or Terms of Service, please discontinue use of the Service. Your continued usage of the Service will signify your assent to and acceptance of our Privacy Policy and Terms of Service.

You have the right to:

(a) access and correct your Personal Data that is held by us;

(b) request the erasure of any or all of your Personal Data;

(d) withdraw any consent to processing that you have previously given in respect of any or all of your Personal Data.

You may access the Personal Information we hold about you and request to correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing at the email address below.

In order to protect your Personal Information, we may require identification from you before releasing the requested information.

13. Maintaining the Quality of your Personal Information

It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.

14. Notifiable Data Breaches Scheme

In the event of any unauthorised access or unauthorised disclosure or loss of your personal information that is likely to result in serious harm to you, we will investigate and notify you and the Office of the Australian Information Commissioner in accordance with the Privacy Act.

15. Policy Updates, Complaints, and Enquiries

This Policy may change from time to time and is available on our website.

If you have any queries or complaints about our Privacy Policy, please contact us.

16. Questions and comments

If you have any questions or comments, or want to access, update, or delete the Personal Data we hold about you, or have a privacy concern please contact us at:

No Problems Publishing Inc.

Email: enquiries@noproblems.org.au

Phone: 0451 658 572

Please provide sufficient detail about the information in question to help us locate it. We will respond to any privacy request in compliance with the applicable Data Protection Law.