​

1. Introduction

• Purpose and Commitment
  Ballarat Support Services ("we", "us", "our") is committed to protecting the privacy of individuals ("you", "your") who interact with our website, located at https://www.ballaratsupportservices.com.au/ (the "Website"), and our associated services. We are dedicated to handling your personal information transparently and responsibly, in accordance with applicable privacy laws. This Privacy Policy outlines our practices concerning the collection, use, disclosure, storage, and security of your personal information. Building trust with our users is paramount, and transparent data handling practices are fundamental to this relationship.1

• Governing Law
  Our handling of personal information is governed by the Australian Privacy Act 1988 (Cth) (the "Privacy Act") and the Australian Privacy Principles (APPs) contained within Schedule 1 of that Act.2 The APPs set out standards, rights, and obligations for the handling of personal information.5 The Office of the Australian Information Commissioner (OAIC) is the independent national regulator responsible for privacy and freedom of information, and it enforces compliance with the Privacy Act.2 Non-compliance with the APPs can lead to regulatory action, including investigations and potential civil penalties.2

• Scope
  This Privacy Policy applies to all personal information collected by Ballarat Support Services through the Website, including via contact forms and booking systems, as well as potentially through other interactions related to the services offered or discussed via the Website. It is important to note that this Website is developed, hosted, and operated on the Wix.com platform ("Wix"). As such, Wix acts as a data processor for information collected via the Website, and their data handling practices, as outlined in their own privacy policy, are also relevant.7 However, under privacy law and Wix's terms, Ballarat Support Services, as the website owner, is considered the data controller and remains primarily responsible for ensuring the lawful collection and handling of your personal information, including obtaining necessary consents and providing fair processing notices.8

• Policy Availability
  This Privacy Policy is publicly available on our Website. In line with the principle of open and transparent management of personal information (APP 1), we strive to make this policy easily accessible and understandable.5 Should you require a copy in a different format, please contact us using the details provided in Section 11.12

• Legal Foundation
  The requirement to maintain a clear, up-to-date, and readily available privacy policy stems directly from APP 1.5 This policy serves as a key tool for transparency, informing you about how we manage your personal data. Given our use of the Wix platform, it is essential to clarify that while Wix provides the infrastructure and associated tools 8, the legal responsibility for compliance with the Privacy Act and the APPs rests with Ballarat Support Services as the entity collecting and determining the purposes for processing your information.8

2. What Personal Information We Collect

• General Statement
  Throughout this policy, "personal information" refers to 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 recorded in a material form or not.3 We are committed to collecting only personal information that is reasonably necessary for, or directly related to, our functions and activities as a provider of support services, in accordance with APP 3.11

• Types of Information Collected
  In compliance with APP 1.4, which requires entities to outline the kinds of personal information they collect and hold 13, we collect various types of information through different interactions:

  • Information You Directly Provide:

    • Contact Form Submissions: When you use the contact form on our Website, we collect your First Name, Last Name, Email address, and the content of your message related to our Services/Programs.16

    • Online Bookings: Our Website features a "Book Online" option.16 When you use this service, we likely collect information necessary to schedule and manage your booking, such as your name, email address, phone number, the specific service you require, and your preferred dates and times. If online payments are processed through Wix's integrated tools (e.g., Wix Bookings, Wix Stores), we may collect billing details like your address, while Wix securely handles full payment card information.1

    • Direct Communications: We may collect personal information when you communicate with us through other channels, such as email or telephone, including records of those communications.

  • Information Collected Automatically (Primarily via Wix):

    • Technical Information: When you visit our Website, the Wix platform may automatically collect technical data. This can include the Internet Protocol (IP) address used to connect your computer to the internet (which may be stored in an anonymized format by Wix or associated analytics tools like Google Analytics), login details (if applicable), email address (if logged in), password (hashed), computer and connection information, device type, operating system, and browser type/version.4

    • Usage Information: We, through the Wix platform and potentially integrated analytics tools, may collect information about your interaction with the Website. This includes your browsing and 'click-stream' activity, session heatmaps and scrolls, pages visited, page response times, length of visits to certain pages, page interaction information (like scrolling, clicks, and mouse-overs), methods used to browse away from the page, search terms used on the site, referring domain, and download activity.4 This data is often collected using cookies and similar technologies (detailed further in Section 5).

  • Information from Social Media Platforms:

    • Our Website includes links to our Facebook and Instagram pages.16 If you interact with us through these social media platforms, we may collect personal information that you make publicly available (e.g., your profile name) or information you provide directly through messages or comments. Please note that these social media platforms operate under their own privacy policies, which govern their collection and use of your data.

• Sensitive Information
  The Privacy Act defines "sensitive information" as a specific category of personal information that includes details about an individual's health, racial or ethnic origin, political opinions, religious beliefs, sexual orientation, or criminal record, among other things.3 Given the nature of "Support Services," it is possible that individuals seeking assistance may, voluntarily and unsolicitedly, disclose sensitive information within their messages submitted via the contact form or during interactions related to service provision.
  We generally do not actively solicit sensitive information unless it is reasonably necessary for providing a specific service and we have obtained your explicit consent. APP 3 imposes stricter requirements for the collection of sensitive information, mandating both consent and reasonable necessity.11 If you choose to provide sensitive information to us (for example, health details relevant to the support you are seeking), we will consider that your provision of this information constitutes consent for us to collect it and use it for the primary purpose of assessing your needs and providing the requested support services. We handle all sensitive information with heightened care and confidentiality. If we receive sensitive information that is unsolicited and not reasonably necessary for our functions, we will handle it in accordance with APP 4, which typically involves destroying or de-identifying the information.11

3. How We Collect Your Personal Information

• Methods of Collection
  Consistent with APP 1.4's requirement to describe how personal information is collected 13, we gather information through several methods:

  • Directly from You: The primary method of collection is directly from you when you actively provide information. This occurs when you:

    • Complete and submit the contact form on our Website.16

    • Utilize the online booking system.16

    • Communicate with us directly via email, telephone, or other means.17

    • Engage with our official social media pages linked from the Website.16 APP 3.6 generally requires collection directly from the individual unless it is unreasonable or impracticable to do so, or consent is given for collection from a third party.15

  • Indirectly or Automatically: Certain information is collected automatically as you navigate and interact with our Website. This is primarily facilitated by the Wix platform and potentially integrated third-party services:

    • Wix Platform: As detailed in Section 2, technical and usage data is collected by Wix when you browse the site.1

    • Cookies and Tracking Technologies: Much of the automated data collection relies on cookies and similar technologies deployed by Wix and potentially by third-party applications or services integrated into the site (e.g., Google Analytics). Section 5 provides more detail on cookies.4 The use of the Wix platform for automated data collection means we may not have direct control over every specific data point gathered this way, but we are committed to transparency regarding these processes.

  • Unsolicited Personal Information: Occasionally, we might receive personal information that we did not solicit (e.g., information included in an email signature, or details provided in a message that go beyond what was requested). In accordance with APP 4, if we receive unsolicited personal information, we will determine within a reasonable period whether we could have collected that information under APP 3 (i.e., if it's reasonably necessary for our functions). If we determine we could not have collected it, and it's not contained in a Commonwealth record, we will take reasonable steps to destroy the information or ensure it is de-identified as soon as practicable, provided it is lawful and reasonable to do so.5

• Notification of Collection (APP 5)
  APP 5 requires that at or before the time we collect personal information, or as soon as practicable afterwards, we take reasonable steps to notify you or ensure you are aware of certain matters.3 This Privacy Policy serves as the primary means of providing this notification. It outlines:

  • Our identity and contact details (Section 11).

  • The types of personal information collected (Section 2).

  • The purposes of collection (Section 4).

  • The usual disclosures of personal information, including potential overseas disclosures (Section 4 and Section 7).

  • Information about how you can access and correct your personal information (Section 8).

  • Information about how you can lodge a complaint (Section 8).

  • Whether collection is required or authorized by law (generally not applicable to our standard collection, unless related to specific legal obligations).

  • The main consequences, if any, for you if all or part of the information is not provided (e.g., inability to respond to an inquiry or process a booking).

Where practicable, we may also provide shorter notices at the point of collection (e.g., on our contact form).

4. Why We Collect, Hold, Use, and Disclose Personal Information

• Primary Purposes of Handling Personal Information (APP 6)
  In line with APP 1.4 and APP 6, we collect, hold, use, and disclose personal information primarily for the purposes for which it was collected, which are directly related to our functions and activities as a support services provider.5 These purposes include:

  • Service Provision and Operation: To provide the support services you request, including managing inquiries submitted via the contact form and administering online bookings.17

  • Communication and Support: To communicate with you regarding your inquiries, bookings, or requests for assistance, and to provide ongoing customer support.14

  • Transaction Processing: To process any transactions related to bookings or services, if applicable (e.g., confirming payments made via integrated Wix payment solutions).17

  • Website Improvement and Maintenance: To monitor and analyse website usage (often using aggregated or de-identified data) to understand user behaviour, improve website functionality, enhance user experience, and ensure the effectiveness of our services.4

  • Security and Fraud Prevention: To maintain the security of our Website and services, protect against fraudulent activities, and ensure the safe operation of the Wix platform.7

  • Legal Compliance: To comply with our legal and regulatory obligations under applicable Australian laws and regulations.17

• Secondary Purposes and Purpose Limitation
  APP 6 generally restricts the use or disclosure of personal information for a purpose other than the primary purpose for which it was collected (a 'secondary purpose').5 We will not use or disclose your personal information for a secondary purpose unless:

  • You have consented to the use or disclosure; or

  • The secondary purpose is related to the primary purpose (and if sensitive information, directly related), and you would reasonably expect us to use or disclose the information for that secondary purpose; or

  • The use or disclosure is required or authorized by or under an Australian law or a court/tribunal order; or

  • A permitted general situation or permitted health situation exists (as defined in the Privacy Act); or

  • We reasonably believe the use or disclosure is necessary for enforcement related activities conducted by, or on behalf of, an enforcement body.

A crucial application of this principle relates to direct marketing (see Section 9). Using contact details collected solely for a booking inquiry to send unrelated marketing materials would typically require your explicit consent and must comply with APP 7.5

• Disclosure of Personal Information
  We may disclose your personal information to third parties in certain circumstances, consistent with the purposes outlined above and as required by APP 1.4.13 These parties may include:

  • Wix.com: As our website hosting platform and data processor, Wix necessarily has access to personal information submitted through or stored on the Website.1 Wix processes this data on our behalf according to our instructions (as the data controller).

  • Third-Party Service Providers: We may engage third-party companies or individuals to perform functions on our behalf, such as payment processing (if integrated with Wix Bookings), data analytics (e.g., Google Analytics integrated via Wix), or potentially email marketing services (if used). We only disclose personal information necessary for them to perform their services and take reasonable steps to ensure they handle the information consistently with the APPs. As the site owner, we are responsible for ensuring any third-party apps or services we integrate are compliant, as Wix does not assume responsibility for their data handling.1

  • Social Media Platforms: If you interact with us via our linked social media pages 16, your information may be handled according to those platforms' policies.

  • Legal and Regulatory Authorities: We may disclose personal information if required or authorized by an Australian law, or a court or tribunal order.15

  • Other Disclosures Permitted by Law: Disclosures may occur in specific circumstances allowed under the APPs, such as to lessen or prevent a serious threat to life, health or safety, or in relation to suspected unlawful activity or serious misconduct where disclosure is necessary for appropriate action to be taken.15

5. Cookies, Analytics, and the Wix Platform

• What are Cookies?
  Cookies are small text files containing pieces of data that are stored on a site visitor's browser (computer, tablet, or mobile device) when they visit a website.19 They serve various functions, such as keeping track of user settings and preferences, enabling website functionality, analysing website performance and usage, ensuring security, and facilitating targeted advertising.19

• Cookies Used on this Website
  Our Website is built using the Wix.com platform. Wix utilizes cookies for several important reasons, primarily to ensure the proper functioning, security, and effectiveness of websites built on its platform.19

  • Essential Wix Cookies: Wix places certain cookies that are generally considered essential for the Website's operation. These support functions like security, user session identification, performance monitoring, and platform stability.19 You cannot opt-out of these essential cookies via a consent banner, as the site may not function correctly without them. The table below lists the primary essential cookies Wix may place on visitor browsers by default:
    Table 1: Essential Wix Cookies

Cookie Name

Purpose

Duration

Cookie Type

XSRF-TOKEN

Used for security reasons (cross-site request forgery prevention)

Session

Essential

hs

Used for security reasons

Session

Essential

svSession

Identifies unique visitors and tracks a visitor's sessions

6 months

Essential

SSR-caching

Indicates how a site was rendered (server-side rendering)

24 hours

Essential

TS* (e.g., TS01xxxxxx)

Used for security and anti-fraud purposes

Session

Essential

bSession

Used for system effectiveness measurement

24 hours

Essential

fedops.logger.sessionId

Used for stability/effectiveness measurement

12 months

Essential

`_wixAB3

*`

Used for A/B testing of new features

6 months

server-session-bind

Used for API protection

Session

Essential

client-session-bind

Used for API protection

Session

Essential

 

 

 

    *(Source: Adapted from Wix documentation.[19] Note: Specific cookie names and details may change over time based on Wix platform updates.)*

*   **Third-Party Cookies and Analytics:** Beyond the essential Wix cookies, our Website may utilize additional cookies placed by third-party services or applications that we have integrated. This could include:
   *   *Analytics Tools:* Services like Google Analytics, which help us understand website traffic and user behaviour.[4, 18, 19, 20] These tools typically use cookies to collect data such as pages visited, time spent on site, and referring websites.
   *   *Social Media Buttons/Widgets:* Buttons linking to Facebook or Instagram [16] may place cookies if interacted with.
   *   *Other Wix Business Solutions or Third-Party Apps:* If we use Wix features like Wix Stores, Wix Bookings, or install apps from the Wix App Market, these may place additional cookies related to their specific functions.[19]

   As the website owner, we are responsible for any third-party apps or services implemented on the site and should ensure their use is disclosed and managed appropriately.[8, 18] Wix explicitly states it assumes no responsibility for how these third-party services handle personal information.[1]
 

• Cookie Consent Management
  Data privacy regulations, including the Australian Privacy Act (implicitly through transparency and consent principles) and potentially stricter laws like the GDPR if we have visitors from the European Union, often require user consent before placing non-essential cookies on a device.2 Essential cookies, like those listed in Table 1 required for basic site functionality and security, generally do not require opt-in consent but still require transparency.
  To manage consent for non-essential cookies (such as those used for analytics, marketing, or optional functionality), we may utilize a cookie consent banner. This banner, often implemented using tools provided by Wix 14 or other third-party consent management platforms 20, typically:

  • Informs you about the use of cookies on the site.

  • Distinguishes between essential and non-essential cookies.24

  • Provides options to accept all cookies, reject non-essential cookies, or customize preferences for different categories of non-essential cookies (e.g., analytics, marketing).24

  • Requires your affirmative action (opt-in) before non-essential cookies are placed.8

  • Provides a link to this Privacy Policy for more detailed information.

Displaying a cookie banner helps ensure legal compliance and builds user trust by providing transparency and control.1 However, if users decline non-essential cookies, it may impact the availability of certain site features or limit our ability to gather analytics data.23

• Managing Cookies Through Your Browser
  Independently of any cookie banner, you can typically manage cookie preferences directly through your web browser settings. Most browsers allow you to view existing cookies, delete them, and block cookies from specific sites or altogether. Instructions for managing cookies in common browsers can usually be found via the browser's help menu or support website.19 Resources like www.allaboutcookies.org also provide general information. Please note that blocking all cookies, including essential ones, may affect the functionality of this and other websites.

• Checking Cookies Used
  If you wish to check the specific cookies being used on our site during your visit, you can typically use your browser's built-in developer tools. For example, in Google Chrome, while viewing the site (preferably in incognito mode to avoid detecting irrelevant cookies from other browsing), you can often right-click, select "Inspect" or "Inspect Element," and navigate to the "Application" or "Storage" tab to view cookies associated with the domain.19

6. Data Storage, Security, and Retention

• Data Storage Location and Methods
  As required by APP 1.4 13, this section outlines how we hold personal information. Primarily, personal information collected through the Website (e.g., via contact forms, booking systems) is stored electronically on the Wix.com platform.7 Wix utilizes a global network of data centers to store user and site visitor data. As detailed further in Section 7, these data centers are located in various countries, including the United States, Ireland, South Korea, Taiwan, and Israel.8
  In addition to storage on the Wix platform, we may hold personal information in other ways, such as:

  • In electronic databases or files stored locally on our secure computer systems (e.g., downloaded booking confirmations or inquiry lists).

  • Within our email system archives (e.g., records of communications).

  • Potentially in hard copy files stored securely, although electronic storage is our primary method.

• Data Security (APP 11)
  We are committed to protecting the personal information we hold from misuse, interference, and loss, and from unauthorized access, modification, or disclosure. APP 11 requires us to take such steps as are reasonable in the circumstances to ensure this protection.5
  Our security measures include, but are not limited to:

  • Platform Security: Relying on the security infrastructure, measures, and certifications maintained by Wix.com for data stored on their platform.8 Wix commits significant resources to data protection and security.

  • Access Controls: Implementing password protection and access restrictions for our Wix account backend and any local systems where personal information is stored.

  • Secure Data Handling: Employing secure practices when handling any downloaded personal information or hard copy records.

  • Technical Measures: Utilizing security software and keeping systems updated.

  • Staff Practices: Ensuring any staff or volunteers who may handle personal information are aware of privacy obligations (if applicable).

While we take reasonable steps to secure your personal information, it's important to acknowledge that no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. However, we strive to maintain robust security practices appropriate to the sensitivity of the information held.13 This involves balancing reliance on the security provided by our platform provider (Wix) with our own responsibilities for securing access to our account and managing any data handled outside the platform, thereby fulfilling our obligations under APP 11.

• Data Retention and Destruction/De-identification (APP 11)
  We retain personal information only for as long as it is reasonably necessary for the purposes for which it was collected, or for related purposes that you would reasonably expect, unless a longer retention period is required or permitted by law (e.g., for record-keeping, legal, or regulatory compliance).5
  In accordance with APP 11.2, when personal information is no longer needed for any purpose for which it may be used or disclosed under the APPs, and we are not legally required to retain it, we will take such steps as are reasonable in the circumstances to destroy the information or ensure that it is de-identified.5 De-identification involves removing or altering information so that the individual is no longer identifiable. Wix provides tools that allow us, as the site owner, to delete customer data from the Wix database upon request or when no longer needed.18

• Notifiable Data Breaches (NDB) Scheme
  We comply with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act. In the event of an "eligible data breach" (unauthorized access to, disclosure of, or loss of personal information likely to result in serious harm to affected individuals), we will conduct a prompt assessment. If required, we will notify the Office of the Australian Information Commissioner (OAIC) and affected individuals as soon as practicable, providing relevant information about the breach and steps individuals can take to mitigate potential harm.2

7. Cross-Border Disclosure of Personal Information

• Likelihood of Overseas Disclosure
  APP 1.4(f) requires us to state in our privacy policy whether we are likely to disclose personal information to overseas recipients.13 Due to our use of the Wix.com platform for website hosting and data storage, it is likely that personal information collected via the Website will be transferred to, and stored in, locations outside of Australia.

• Locations of Overseas Recipients
  Where it is practicable to specify the countries in which overseas recipients are likely to be located, APP 1.4(g) requires us to do so.13 Based on information provided by Wix, the data centers they use to store website data (which includes personal information collected through our Website) may be located in the following countries 8:

  • United States of America

  • Ireland

  • South Korea

  • Taiwan

  • Israel

It is possible that Wix may use other locations or change these locations over time. By using our Website and services, you acknowledge that your personal information may be processed in these countries.

• Compliance with APP 8
  APP 8 sets out requirements for the cross-border disclosure of personal information. Before disclosing personal information to an overseas recipient (such as Wix for storage in their international data centers), APP 8.1 requires us to take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to the information.11
  In the context of using a global platform provider like Wix, the "reasonable steps" typically involve:

  • Reviewing and relying on Wix's terms of service and privacy policy, which outline their data handling practices and security commitments.

  • Relying on Wix's established infrastructure and data processing agreements designed to comply with international data transfer requirements.

By using Wix, we rely on their systems and contractual commitments as the primary mechanism for ensuring that data transferred overseas via their platform is handled in a manner consistent with the principles of the APPs. The use of such global platforms inherently involves cross-border data flows, making compliance with APP 8, through reliance on the platform's safeguards, a necessary aspect of our data management.8

8. Your Privacy Rights

We respect your rights regarding the personal information we hold about you. The Privacy Act grants individuals several rights concerning their data.

• Right to Access Your Personal Information (APP 12)
  You have the right to request access to the personal information that Ballarat Support Services holds about you.5 To request access, please contact us using the details provided in Section 11. We will need to verify your identity before providing access.
  We will respond to your request within a reasonable period after the request is made.15 We will provide access to the information in the manner you request, if it is reasonable and practicable to do so.15 Access will generally be granted, unless one of the exceptions outlined in APP 12.3 applies (e.g., providing access would pose a serious threat to life or health, unreasonably impact the privacy of others, prejudice negotiations or legal proceedings, or reveal commercially sensitive information).15 If we refuse access based on an exception, we will provide you with a written notice explaining the reasons for the refusal (unless unreasonable to do so) and the mechanisms available to complain about the refusal. Wix provides tools enabling us, as site owners, to retrieve a copy of customer data stored within their systems upon receiving a verified request.18

• Right to Correct Your Personal Information (APP 13)
  You have the right to request the correction of personal information we hold about you if you believe it is inaccurate, out-of-date, incomplete, irrelevant, or misleading.5 To request a correction, please contact us using the details in Section 11. We will need to verify your identity.
  We will respond to your request within a reasonable period.15 If we are satisfied that the information needs correction, we will take reasonable steps to correct it.11 If we correct information that we have previously disclosed to another APP entity, we will take reasonable steps to notify that other entity of the correction, if requested by you, unless it is impracticable or unlawful to do so. If we refuse to correct the information, we will provide you with a written notice explaining the reasons (unless unreasonable) and the mechanisms available to complain. You also have the right to request that we associate a statement with the information indicating that you believe it is inaccurate, out-of-date, incomplete, irrelevant, or misleading. Wix provides tools that may allow us to amend or delete customer data stored within their systems to facilitate corrections.18 Fulfilling access and correction requests comprehensively remains our responsibility, which may involve utilizing Wix tools and potentially interacting with any relevant third-party services where data might also reside.18

• Right to Make a Complaint
  If you believe that Ballarat Support Services has breached the Australian Privacy Principles or mishandled your personal information, you have the right to lodge a complaint.5 We encourage you to contact us first using the details in Section 11, outlining the nature of your complaint.13
  We will acknowledge receipt of your complaint promptly and investigate the matter. We aim to resolve complaints efficiently and will respond to you with our findings and any proposed actions within a reasonable timeframe (typically within 30 days).
  If you are not satisfied with our response to your complaint, you have the right to escalate the matter to the Office of the Australian Information Commissioner (OAIC).2 The OAIC can investigate complaints about the handling of personal information under the Privacy Act. You can find their contact details and complaint forms on their website: www.oaic.gov.au.

• Right to Anonymity and Pseudonymity (APP 2)
  Wherever it is lawful and practicable, you have the option of not identifying yourself, or of using a pseudonym, when dealing with us.4 For example, you can browse our Website without providing personal information. However, for certain interactions, such as making a booking, submitting a specific inquiry requiring a response, or receiving personalized services, we will require you to provide identifying information as it will be impracticable to deal with you anonymously or pseudonymously.5

• No Fees for Requests
  We will not charge you a fee for making a request to access or correct your personal information, nor for lodging a privacy complaint.15 (Note: While the request itself is free, the Privacy Act allows organisations to potentially charge a reasonable fee for the cost of providing access to information, such as photocopying or staff time involved in retrieval, but we would inform you of any potential charges beforehand).

9. Direct Marketing

• Our Policy (APP 7)
  Ballarat Support Services respects your preferences regarding direct marketing communications. APP 7 regulates how organisations may use or disclose personal information for the purpose of direct marketing.5

• Use of Information for Direct Marketing
  We will only use or disclose your personal information for direct marketing purposes if:

  • We collected the information directly from you; and

  • You have consented to the use or disclosure for that purpose; or

  • You would reasonably expect us to use or disclose the information for that purpose (e.g., if you are an existing client receiving information about similar services); and

  • We provide a simple means by which you can easily request not to receive direct marketing communications from us (an 'opt-out' mechanism); and

  • You have not made such an opt-out request.

If we collect your personal information from a third party, or if you would not reasonably expect us to use your information for direct marketing, we will only use it for that purpose if you have consented (or it is impracticable to obtain consent) and we provide the required opt-out mechanism.

• Opt-Out Mechanism
  All our direct marketing communications (such as email newsletters, if implemented) will contain a prominent, simple, and clear way for you to opt-out of receiving further communications.5 This may be an 'unsubscribe' link in emails or instructions to reply with a specific word. You can also request to opt-out at any time by contacting us using the details in Section 11. We will process your opt-out request promptly and at no cost to you. Including this section ensures clarity and compliance with APP 7, even if direct marketing is not a current primary activity, setting expectations for any future use of contact details.16

10. Updates to this Privacy Policy

• Review and Changes
  This Privacy Policy will be reviewed periodically to ensure it remains accurate, up-to-date, and compliant with applicable laws and best practices.12 We may need to update this policy to reflect changes in our information handling practices, business operations, new technologies, or amendments to the Privacy Act (such as those proposed in recent reviews 3) or changes in the Wix platform's features or policies.7 Maintaining an up-to-date policy is a requirement under APP 1.5

• Notification of Changes
  Any updates to this Privacy Policy will be posted on our Website, and the revised version will be indicated by an updated "Effective Date" at the beginning of the policy.12 We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the Website or our services after any changes constitutes your acceptance of the revised policy.

11. Contact Us

If you have any questions or concerns about this Privacy Policy, our handling of your personal information, or if you wish to exercise your privacy rights (including requesting access or correction, or making a complaint), please contact us using the following details 5:

• Position Title: The Privacy Officer / Manager

• Email: [Insert relevant email address e.g., privacy@ballaratsupportservices.com.au]

• Postal Address:

• Phone: [Insert relevant phone number - Optional but recommended]

Providing a dedicated point of contact facilitates communication and demonstrates our commitment to accountability under APP 1.13 We will endeavour to respond to your inquiries promptly and address your concerns effectively.

Works cited

1. Privacy Policy for Wix: A Complete Guide [With Examples] - CookieYes, accessed on April 25, 2025, https://www.cookieyes.com/blog/privacy-policy-for-wix/

2. How to Make Website Australian Privacy Principles Compliant - Feroot Security, accessed on April 25, 2025, https://www.feroot.com/blog/australian-privacy-principles-compliance/

3. Data protection laws in Australia, accessed on April 25, 2025, https://www.dlapiperdataprotection.com/index.html?t=law&c=AU

4. Privacy policy - OAIC, accessed on April 25, 2025, https://www.oaic.gov.au/about-the-OAIC/our-corporate-information/plans-policies-and-procedures/privacy-policy

5. What are Australian Privacy Principles | Privacy Act Guidelines - Imperva, accessed on April 25, 2025, https://www.imperva.com/learn/data-security/australian-privacy-principles/

6. Australian Privacy Principles - OAIC, accessed on April 25, 2025, https://www.oaic.gov.au/privacy/australian-privacy-principles

7. About Privacy | WIX - Wix.com, accessed on April 25, 2025, https://www.wix.com/about/privacy

8. Preparing Your Wix Site for GDPR | Help Center, accessed on April 25, 2025, https://support.wix.com/en/article/preparing-your-wix-site-for-the-gdpr

9. Privacy Policy for Wix Websites - PrivacyPolicies.com, accessed on April 25, 2025, https://www.privacypolicies.com/blog/privacy-policy-wix-websites/

10. Privacy Policy for Wix Website [Create it in Minutes] - WebsitePolicies, accessed on April 25, 2025, https://www.websitepolicies.com/blog/privacy-policy-for-wix

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