This Privacy Policy applies to all personal information collected by us, or submitted to us, whether offline or online, including personal information collected or submitted through our websites (our Websites) and any mobile sites, applications, widgets and other mobile interactive features (collectively, our Apps), through our official social media pages that we control (our Social Media Pages) as well as through HTML-formatted email messages that we send to you (collectively, including the Social Media Pages, Apps and Websites, the Sites).

This Privacy Policy describes how we deal with information we collect and demonstrates our commitment to the protection of your privacy. By visiting the Sites and otherwise providing personal information to us, you are accepting and consenting to the practices described in this Privacy Policy. If you do not agree with any of the terms of this Privacy Policy, please do not use the Sites or submit any personal information to us.

This Privacy Policy was last updated on 16 Feburary 2019.

1. Meaning of terms used in this Privacy Policy

In this Privacy Policy:

• personal information means any information or an opinion about you (including information or an opinion forming part of a database), by which you may be identified directly or indirectly, whether on its own or in combination with other information, whether true or not, and which is submitted to and/or collected by us in an accessible form.

2. Privacy guidelines for our members and other individuals

2.1. What kinds of personal information do we collect and hold?

We collect and hold:

(a) your contact details, such as office address, home address, telephone numbers and email address;
(b) your personal details, such as your year of study
(d)your membership information, including your membership history and order history;

2.2. How do we collect your personal information?

We collect personal information about you when it is reasonably necessary for one or more of our activities or functions. This personal information is collected in a number of ways, including:

Through our Site: We may collect personal information from the Sites, such as when you visit, use or register on our Websites, Apps or Social Media Pages, join (or request to join), post in or otherwise contribute to a COMSA Social Media Page, or when you complete a survey;

From you: We may collect personal information from you when you contact, do business or interact with us by phone or email, apply for, enrol in or register for a program or activity, or enter into a competition;

2.3. What would happen if we did not collect your personal information?

The provision of your personal information is voluntary. However, if you cannot, or will not, provide us with the personal information we reasonably require, we may not be able to contact you or otherwise interact with you, process orders for services or goods as requested by you, registration, subscription renewal or request or provide you with some or all of our products and services.

2.4. How we use your personal information

We will not collect or use your personal information unless it is lawful for us to do so. We collect and use personal information for the following purposes:

(a) processing membership subscriptions;
(b) fulfilling orders or requests for information, products or services (with your consent, if required);
(c) sending subscription renewals, voting papers and other information relevant to our day to day operations
(d) for promotional and marketing purposes, including communicating information about our products and services (with your consent, if required);
(e) monitoring, moderating and improving our Sites;
(f) conducting competitions;
(g) organising and hosting training and events (including with third parties); 
(h) providing products and services, or information relating to such products and services (with your consent, if required);
(i) assessing or improving our products and services, as well as for training and quality purposes, including building profiles, monitoring, recording and analysing online interactions and communications between you and us; and
(j) providing information to third parties as authorised or required by law or a court or tribunal.

We have a legitimate interest in using your information in these ways. It is also fundamental to the nature of the service we provide.

In some cases it will be lawful for us to collect and use your personal information, for example where it is necessary as part of our, or a third party’s statutory or public function or because the law permits or requires us to.

In addition to the specific circumstances above, we will only use your personal information with your consent (if required under applicable data protection laws) when we process your personal information in order to send you carefully selected marketing materials about our products and services (or those of our third party partners) by email, text or push notification, depending on your account or operating system settings. You have the right to opt out of receiving such direct marketing at any time.

If at any time you wish to stop receiving direct marketing messages from us, the easiest way to do so (for electronic messages) is to use the unsubscribe feature in the marketing message you have received. You can also let us know by contacting us using the contact details set out in the “How to contact us” section. In your request, please indicate that you wish to stop receiving marketing communications from us. 

We will also rely on your consent where we use cookies other than those cookies that are necessary to provide our service for the purposes set out in our cookie policy below.

Our Sites may contain hyperlinks to websites operated by third parties. We are not responsible for the content of such websites, or the manner in which those websites handle any personal information you provide. In some cases, we may use a third party service provider to process payments made through the Sites. In these cases, your personal information may be collected by this third party and not by us and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s use or disclosure of your personal information.

2.5 Use and disclosure of personal information

We do not use your personal information or disclose it to another organisation unless:

(a) it is reasonably necessary for one of the purposes described above;
(b) having regard to the nature of the information or the circumstances of collection we believe you would expect us to use the information or make the disclosure;
(c) required or authorised by law or court or tribunal;
(d) it is necessary to protect the rights, property, health or personal safety of a member, the public or our interests, and it is unreasonable or impracticable to obtain your consent;
(e) the disclosure is necessary to assist any entity, body or person to locate a person who has been reported missing;
(f) we have reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been, is being or may be engaged in, and we believe that the collection, use or disclosure is necessary in order for us to take appropriate action;
(g) it is necessary to obtain third party services, for example to carry out data analysis or provide information processing services (where use of your information by third parties is strictly controlled);
(h) it is for one of the purposes expressly permitted under applicable data protection and privacy laws; or
(i) you have provided your consent.

For avoidance of doubt, we may disclose your personal information to:

(a) any of our related and associated companies, affiliates and subsidiaries, including those established in the future;
(b) any data processors processing your information on our behalf;
(c) where applicable, third parties who provide related services or products in connection with our business such as our vendors, business partners, and any party assisting us in carrying out the purposes described above;
(d) parties which participate in joint marketing schemes with us;
(e) any agent, contractor or service provider who provides administrative, order processing, payment clearing, credit reference, debt collecting or other services necessary to the operation of our business;
(f) any person to whom we are, in our belief in good faith, under an obligation to make disclosure as required by any applicable law;
(g) government agencies, statutory authorities and industry regulators;
(h) our auditors, consultants, accountants, lawyers or other financial or professional advisers; and / or
(i) our sub-contractors or third party service or product providers as may be determined to be necessary or appropriate.

To suppress or limit our use of your personal information that has been previously provided to us, please email, call or write to us using the contact information listed below in the “Contact Us” section.

We will not sell your personal information to third parties.