1. About this Privacy Policy

Caring Arms Australia Pty Ltd, referred to in this policy as “Caring Arms”,
“we”, “us” or “our”, respects your privacy and is committed to protecting
the personal information collected through our online channels.

This Privacy Policy explains how we collect, use, store and disclose
personal information obtained through:

• our website at
  www.caringarms.com.au;
• Caring Arms landing pages and campaign pages;
• online contact, enquiry and referral forms;
• our Facebook, Instagram, LinkedIn and other social media pages;
• social media messages and lead-generation forms;
• Google, Meta and other online advertising campaigns;
• email, SMS and telephone follow-up arising from an online enquiry; and
• other digital marketing channels operated on behalf of Caring Arms.

This policy applies primarily to website visitors, prospective
participants, family members, representatives, healthcare professionals,
professional referrers, job applicants and other people who contact us
through our online channels.

We manage personal information in accordance with the
Privacy Act 1988 (Cth), the Australian Privacy Principles, the
Spam Act 2003 (Cth) and other applicable Australian laws.

2. Scope of this policy

Our websites, landing pages, social media accounts and online advertising
forms are primarily used for:

• providing information about Caring Arms and our services;
• receiving general enquiries;
• receiving initial expressions of interest and referrals;
• responding to prospective participants, families and representatives;
• communicating with healthcare professionals and professional referrers;
• promoting service availability, vacancies, events and community
  information;
• recruitment; and
• measuring and improving our marketing activities.

These online channels are not intended to collect or store detailed
participant, medical, clinical or service-delivery records.

When a person proceeds beyond an initial enquiry or referral, relevant
information may be transferred to Caring Arms’ secure client management
system or another appropriate operational system. Participant and
service-delivery records held in those systems are managed under Caring
Arms’ separate privacy, consent, information-security and recordkeeping
policies and procedures.

3. Personal information we may collect

The information we collect depends on how you interact with us.

General contact information

We may collect:

• your name;
• telephone number;
• email address;
• suburb, postcode or general service location;
• your preferred contact method;
• your preferred contact time; and
• the contents of your enquiry or message.

Enquiry and referral information

We may collect information such as:

• the type of NDIS or disability support service being sought;
• whether you are making an enquiry for yourself or another person;
• whether you are a participant, family member, representative, Support
  Coordinator, healthcare professional or other referrer;
• your relationship to the person being referred;
• the general reason for the enquiry or referral;
• preferred service location;
• broad accessibility or support requirements;
• information about service availability or accommodation needs; and
• other information voluntarily provided in an online form or message.

Where you provide information about another person, you should have their
consent or appropriate authority to provide that information.

Limited disability or support-related information

We do not intentionally request detailed medical records, clinical
documents, NDIS plans or highly sensitive information through our general
online channels.

However, a person may voluntarily provide limited disability or
support-related information when explaining the reason for an enquiry.

We will use that information only where reasonably necessary to:

• respond to the enquiry;
• identify the appropriate Caring Arms service or staff member;
• assess whether the enquiry is within our service scope;
• arrange further contact; or
• transfer the enquiry to an appropriate secure system where the person
  wishes to proceed.

Please do not upload or send detailed medical reports, clinical records,
medication information, NDIS plans or other highly sensitive documents
through a general website form, public social media comment or social media
message unless specifically requested and an appropriate secure method has
been provided.

Social media information

When you interact with our social media pages, we may receive or collect:

• your social media name or username;
• publicly available profile information;
• comments, reactions and other interactions;
• direct messages;
• responses to advertisements;
• information submitted through social media lead forms; and
• information voluntarily provided as part of an enquiry.

Comments posted publicly may be visible to other social media users.

We recommend that you do not post personal, confidential,
disability-related or sensitive information in public comments. Where
appropriate, we may ask you to continue the conversation by telephone,
email or through another more secure communication channel.

Recruitment information

Where you apply for employment through our website, social media pages or
an online advertisement, we may collect:

• your name and contact details;
• résumé or curriculum vitae;
• employment history;
• qualifications and experience;
• professional registrations;
• work rights or visa status;
• referee details; and
• other information relevant to your application.

Technical and website usage information

When you visit or interact with our websites or landing pages, we may
automatically collect information including:

• your IP address;
• browser type;
• device type;
• operating system;
• approximate geographic area;
• referring website or advertisement;
• pages viewed;
• links or buttons selected;
• the date and time of your visit;
• time spent on a page;
• form or advertising interactions; and
• cookie, pixel and similar technology identifiers.

This information may not identify you directly, but it may be combined with
other information in a way that makes you reasonably identifiable.

4. How we collect personal information

We may collect personal information:

• directly from you;
• when you complete an online form;
• when you call or email us following a website or advertising enquiry;
• when you send us a social media message;
• when you comment on or interact with our social media content;
• through Google, Meta or other online advertising lead forms;
• from a family member, representative or professional referrer;
• from a recruitment platform or job advertisement;
• through cookies, analytics tools, advertising pixels and similar
  technologies; and
• from publicly available sources where reasonably necessary.

Where practical, we will collect personal information directly from the
person concerned.

5. Why we collect and use personal information

We may collect and use personal information to:

• respond to enquiries;
• contact you about the service you asked about;
• assess whether Caring Arms may be able to assist;
• direct your enquiry to the appropriate staff member;
• arrange a call, meeting, property viewing or initial consultation;
• process an initial referral or expression of interest;
• communicate with your authorised representative or referrer;
• provide information about Caring Arms services;
• manage job applications and recruitment enquiries;
• maintain records of enquiries and communications;
• improve our websites, landing pages, forms and online content;
• understand how people find and use our websites;
• measure the performance of our advertising campaigns;
• prevent spam, misuse, fraud or security threats;
• comply with legal and regulatory obligations; and
• send marketing communications where we have your consent or are otherwise
  permitted by law.

We will not use information voluntarily provided about a disability or
support requirement for unrelated advertising purposes.

6. Responding to your enquiry

When you submit an enquiry, you authorise Caring Arms to contact you using
the details you provide for the purpose of responding to that enquiry.

We may contact you by:

• telephone;
• email;
• SMS;
• social media message; or
• another method you requested or reasonably expect.

Responding to an enquiry about a particular service is not the same as
subscribing you to ongoing marketing communications.

Submitting an enquiry, referral or expression of interest does not create a
service agreement and does not guarantee that Caring Arms can provide or
accept the requested service.

7. Direct marketing

Where you have consented, or where otherwise permitted by law, we may send
you information about:

• Caring Arms services;
• service availability and vacancies;
• community events;
• educational information;
• business updates; and
• other relevant Caring Arms news.

Marketing communications may be sent by email, SMS, telephone, social media
or online advertising.

Where required, we will provide a clear and separate opportunity to consent
to receiving marketing communications.

We will not automatically treat a general service enquiry as consent to
receive unrelated or ongoing promotional communications.

You may unsubscribe or withdraw your marketing consent at any time by:

• using the unsubscribe link in an email;
• replying “STOP” to an SMS where that option is provided;
• contacting us using the details in this policy;
• asking our staff to remove you from the relevant marketing list; or
• changing your advertising or social media preferences through the
  relevant platform.

We will action unsubscribe requests within the period required by law.

We may continue to send communications that are necessary to respond to an
active enquiry or administer an existing relationship, even where you have
unsubscribed from general marketing.

8. Cookies, analytics and advertising technologies

Our websites and landing pages may use cookies, pixels, tags and similar
technologies.

These technologies may be used to:

• operate and secure our websites;
• remember preferences;
• understand how visitors use our websites;
• identify which advertisements or search results lead to an enquiry;
• measure website traffic and advertising conversions;
• improve the design and performance of our online content;
• prevent fraudulent or automated activity; and
• display advertising that may be more relevant to website visitors.

We may use services provided by organisations such as:

• Google, including Google Analytics and Google Ads;
• Meta, including Facebook and Instagram advertising tools;
• website hosting and content-management providers;
• online form providers;
• customer relationship management providers;
• email and SMS communication providers; and
• other analytics or digital advertising providers.

These providers may collect technical information about your device,
browser and interaction with our websites or advertisements.

You can control or disable cookies through your browser settings. Disabling
some cookies may affect the functionality or performance of our websites.

You may also be able to manage advertising preferences through your Google,
Facebook, Instagram or other platform settings.

9. When we may disclose personal information

We may disclose personal information to:

• Caring Arms directors and authorised employees;
• contractors and consultants assisting with an enquiry;
• service providers who operate our website, forms, email, telephone or
  information technology systems;
• advertising, analytics and digital marketing providers;
• social media platforms;
• recruitment and employment service providers;
• professional advisers, including lawyers, accountants, auditors and
  insurers;
• government, regulatory or law-enforcement authorities where required or
  authorised by law;
• emergency services where reasonably necessary to address a serious threat
  to health or safety; and
• another person or organisation where you have authorised the disclosure.

We only disclose information where reasonably necessary for the purpose for
which it was collected, where you would reasonably expect the disclosure,
where you have consented, or where the disclosure is required or permitted
by law.

Caring Arms does not sell personal information.

10. Overseas processing and storage

Caring Arms operates and provides its services in Australia.

However, some third-party technology, website, social media, analytics,
advertising, cloud-storage, email or software providers may store or process
information using systems located outside Australia.

The locations used by these providers may vary and may include countries in
which their systems, related companies or service providers operate.

Where required, we take reasonable steps to select reputable providers and
protect personal information disclosed or processed through those services.

Your use of third-party platforms, including Facebook, Instagram, LinkedIn
and Google, is also subject to the privacy policies and terms of those
organisations.

11. Storage and security

We may hold website and marketing information in:

• website administration systems;
• email accounts;
• online form platforms;
• advertising platforms;
• social media inboxes;
• lead-management systems;
• recruitment systems;
• secure business files; and
• other approved information technology systems.

We take reasonable steps to protect personal information from:

• misuse;
• interference;
• loss;
• unauthorised access;
• unauthorised modification; and
• unauthorised disclosure.

These safeguards may include:

• password protection;
• multi-factor authentication where available;
• restricted staff access;
• user permissions;
• secure hosting and software systems;
• staff confidentiality obligations;
• security updates;
• data backups; and
• procedures for managing privacy and security incidents.

No internet transmission, social media platform or electronic storage
system is completely secure. You should avoid submitting unnecessary
sensitive information through general online channels.

12. Retention and deletion

We retain website, enquiry, marketing and recruitment information only for
as long as reasonably necessary for:

• responding to an enquiry;
• following up an active lead;
• maintaining appropriate business records;
• managing marketing consent and unsubscribe requests;
• evaluating advertising and website performance;
• managing recruitment;
• resolving disputes or complaints; and
• complying with legal, taxation, insurance or regulatory requirements.

When information is no longer reasonably required, we will take reasonable
steps to delete, destroy or de-identify it, unless we are required or
permitted by law to retain it.

Where an enquiry progresses to participant intake or service delivery,
relevant information may be transferred to our secure client management
system and retained in accordance with Caring Arms’ separate participant
recordkeeping requirements.

13. Accessing or correcting your information

You may ask us to provide access to personal information we hold about you.

You may also ask us to correct information that is:

• inaccurate;
• out of date;
• incomplete;
• irrelevant; or
• misleading.

We may need to verify your identity before processing an access or
correction request.

In limited circumstances, we may refuse access where permitted by law. If
we refuse a request, we will generally explain the reason and the available
complaint options.

14. Anonymous enquiries

Where practical, you may browse our website or make a general enquiry
without identifying yourself or by using a pseudonym.

However, we may need your correct name and contact information to:

• respond to your enquiry;
• arrange a meeting or service discussion;
• assess a referral;
• process a job application; or
• proceed with participant intake.

If you do not provide the information reasonably required, we may be unable
to respond fully or provide the requested assistance.

15. Third-party websites and social media platforms

Our websites, landing pages and social media accounts may contain links to
third-party websites, applications or services.

Caring Arms is not responsible for the privacy, security or content
practices of third-party websites or platforms.

You should review the privacy policy and terms of the relevant third party
before providing personal information.

Information posted publicly on social media may be visible to others and
may be copied, shared or stored by other users.

16. Data breaches

If we become aware of a suspected privacy or information-security incident,
we will assess and respond to it in accordance with our legal obligations.

Where a breach is likely to result in serious harm and meets the
requirements of the Notifiable Data Breaches scheme, we will notify
affected individuals and the Office of the Australian Information
Commissioner as required.

17. Privacy complaints

You may contact us if you:

• have a question about this Privacy Policy;
• believe we have mishandled your personal information;
• wish to make a privacy complaint; or
• wish to request access to or correction of your information.

Please provide enough information for us to understand and investigate your
concern.

We will review your complaint and respond within a reasonable period.

If you are not satisfied with our response, you may contact:

18. Contact details

Privacy enquiries, access requests, correction requests and complaints may
be directed to:

19. Changes to this Privacy Policy

We may update this Privacy Policy when our websites, landing pages, social
media activities, technology providers, marketing practices or legal
obligations change.

The latest version will be published on our website and will display its
effective date.