Grace Papers Cares About Your Privacy

Transparency and honesty are a huge part of our mission at Grace Papers Pty Ltd (Grace Papers). We care about your privacy and especially about the psychological safety of the coaching environment. As such, whether you are a coach providing services on our platform, a user of our platform, an entity that contracts on behalf of users of our platform, or a visitor to our website, we want you to know how we collect, use and share your data.

We also want to communicate this Privacy Policy in plain language, as much as possible. You may be working with us in other contexts and this policy is intended to address our privacy practices for all stakeholders and situations.

Introduction and Definitions

1.1. This Privacy Policy describes our privacy practices relevant to the Site, our coaching and consulting services (collectively the “Services”) and the Grace Papers platform (“Platform”) and the impact these practices have on Site Visitors, Coaches, Users, User Organisations and any other person who comes into contact with us. Each term is defined below. Let us start with a brief overview of what we do, how and where we might be collecting data and then define some relevant terms.

1.2. Grace Papers is the first career coaching platform to transform gender equality and development for people, teams, and organisations where it matters most – career and leadership development. At the same time, companies need a systemic, business-led approach to gender equality (social and work systems, intersectional lens) as well as a framework for tracking progress (individual, groups, leaders and governance) – a total solution provided by our Platform.

1.3. Our vision is for a world in which women and men are equally responsible for the most important decisions made; where all people, regardless of gender, can be vulnerable and combine career, care and ambition without stigma; a world where work is compatible with the modern lives of families.

1.4. We will need to distinguish between the people to whom we provide Services directly via the Platform (who we will refer to as “Users”) and the entities who contract with us to provide Services to their employees or others on the Platform (who we will refer to as “User Organisations”). We collect, use and share data differently for Users and User Organisations, although they might sometimes be one and the same. In the event you receive Grace Papers Services as a result of your employer or other sponsoring organisation, please be aware of the data which may be shared back to your User Organisation as a result of using the Grace Papers Platform (refer to section 5).

1.5. We also collect data from business coaches (“Coaches”) who typically contract with us to provide services to Users via the Platform and from visitors (“Visitors”) to our website www.gracepapers.com.au (the “Site”).

1.6. To the extent data is associated with an identified or identifiable natural person and is protected as personal information (or substantially equivalent terms) under applicable data protection laws including the Privacy Act 1988 (Cth) (“Privacy Act”) and Privacy Act 2020 (NZ), we will refer to such data in this Privacy Policy as “Personal Data”.

What types of Personal Data is collected and the purposes for collection

2.1. Data from our Site

2.2. If you are a visitor to our public Site we will collect certain information. We use cookies to collect data from our public Site to recognise you and your device(s) on, off and across different services and devices where you have engaged with our Site. We also allow third parties to use cookies as described in the cookie policy contained in the following paragraphs.

2.3. A “cookie” is a small file stored by the web browser software on a computer when you access a website. (An explanation of cookies can be found on the website of the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.)

2.4. We make use of cookies and other technologies of tracking for authentication purposes and to tailor the site to user preferences. We use a session cookie for maintaining contact with a user throughout a web browsing session. Session cookies expire when the browsing session comes to an end or a user shuts down their device.

2.5. You may refuse the use of cookies by selecting the appropriate settings on the browser, however, please note that this may prevent you from using the full functionality of the website.

2.6. We will deal with any Personal Data collected by cookies in the same way we handle other Personal Data under this Privacy Policy.

2.7. Grace Papers and analytics

2.8. The analytics offered at Grace Papers may use machine learning (ML) to customize and enhance your experience with certain Grace Papers Services, such as our Time-Based Rules Engine (TBRE) algorithm and our Session Insights algorithm. These Services rely on User actions and inputs including your decision to accept or reject the proposed coaches or the analytic insights provided.

2.9. When you visit and browse the Grace Papers Site, our website host and some third party service providers may collect information for statistical, reporting and maintenance purposes.

2.10. Subject to the terms of this Privacy Policy, this information is used to administer and improve the performance of Grace Papers and will not be used by us to identify you. The information may include:

the number of users visiting our website and the number of pages viewed;
the date, time and duration of a visit;
visiting patterns of individuals accessing Grace Papers;
the IP address of your computer; and
the path taken through our Site.

2.11. We use website analytic services to help analyse how you use our Site and to also analyse your responses to certain cards, labs and surveys in the Platform against gender equality indicators.

2.12. Website analytics generate statistical and other information by means including but not limited to cookies which are stored on users’ computers. The information generated is used to create reports about the use of and responses to cards, labs and surveys in Grace Papers.

2.13. Our third party providers of these services may store information generated through the use of website analytics. We will not (and will not allow any third party to) use website analytics to track or to collect any personally identifiable information of Visitors to the Grace Papers Site. We will not associate any data gathered from Grace Papers with any personally identifiable
information from any source as part of our use of website analytics.

2.14. Data from coaches

2.15. If you are a Coach, we collect data when you submit an inquiry to provide coaching services for us, when you use the Platform, when you request technical support, and when you otherwise initiate communication with us. This Personal Data includes your name, mobile phone number, work address and coaching work experience.

2.16. We never require Coaches to provide us any commercially sensitive Personal Data (e.g. financial data), although we may request demographic or other personal data from Coaches when we are testing a new tool or feature, staffing a specific program for customers, or conducting research studies. The type of demographic or Personal Data we may request may include gender, race, ethnicity or specialised skills. When asking for demographic data, Grace Papers does so because we believe it will improve the Services for our Users and Coaches; however, providing such sensitive Personal Data is optional for Coaches.

2.17. We may review coaching sessions with Coaches for training, research, or additional purposes, therefore where possible, Grace Papers will minimize the amount of personal data being accessed in these review sessions.

2.18. As a Coach, we may ask you to provide us data to improve your experience on the Platform. For example, we may ask Coaches to:

review your coaching and Platform experience; and/or
update personal preferences within your Coach profile, such as preferred pronouns and preferred language.

2.19. In all circumstances, your decision to provide Grace Papers with Personal Data has no impact on your role as a Coach, and you may withdraw your consent to Grace Papers collecting your personal information at any time by emailing support@GracePapers.com. However, to continue to work as a Grace Papers Coach, we will need to use and store your name, work email address, mobile number and bank account details.

2.20. Data from Users

2.21. If you are a User, we collect data when you register for the Platform and when you access the Services via the Platform. To register for an account, we will require certain Personal Data from you, such as your:

name
email address
gender
Parental leave start date
Parental leave end date
phone number
role or title.

2.22. We also collect demographic information in order to provide you with a more personalised experience, such as:

your postcode
your commute time to work
your nationality
how many years have you lived in Australia (if you weren’t born in Australia)
your industry.

2.23. We require this data for at least the following reasons: 1) to create your account; 2) to ensure you are set up correctly in the Platform and in the right coaching journey; and 3) to ensure you receive applicable surveys or questionnaires commensurate with your coaching journey.

2.24. We may ask you to provide us data to improve your experience on the Platform. For example, we may ask Users:

to complete short surveys to help us understand your coaching experience;
to complete a survey that will allow you to gain insight into gender equality indicators by asking you a series of questions around knowledge, agency, confidence and career;
to review your coaching and Platform experience; and
to update personal preferences within your User profile, such as preferred pronouns and preferred language.

2.25. To facilitate a robust and meaningful coaching experience, both you and your Coach will have access to your gender equality survey and assessment responses. Your sponsoring User Organisation will never receive access to your individual assessment or personalization responses although they may see aggregate and de-identified reports of all Users connected to your sponsoring User Organisation so long as we can confirm a minimum threshold of Users
from your organisation to maintain anonymity.

2.26. We collect usage data from Users accessing the Platform, such as which programs you respond to and attend, your session ratings, when you attend a coaching session, your employment details and any other usage data you share with us (or your User Organisation shares with us) in connection with the Platform.

2.27. We request Users to provide Personal Data on a voluntary basis. However, if you do not provide us with the Personal Data we request, we may:

not be able to provide, or continue to provide, Services to you;
remove your access to the Platform or any of our resources; and
inform your User Organisation/employer and the relevant Coach(es), that you have opted not to provide certain information and convey the consequential effect such a decision will have.

2.28. Data we collect about Users from others

2.29. If you are a User registering on the Platform through a platinum coaching license purchased by a User Organisation (which may or may not be your employer), the User Organisation may provide us with certain demographic data about you.

2.30. In some cases, a User Organisation may choose to integrate its human resources information system with the Platform. If applicable, the User Organisation may share employment data with Grace Papers, including your name, email address, contact number and manager’s details (name, contact and email address).

2.31. In other cases, the Platform may integrate with third party systems on behalf of a User Organisation to manage data and gain insights about the value of the Platform.

2.32. If you as a User have concerns about this data collected from third parties, please speak with your Grace Papers client success manager or your contact at your User Organisation.

2.33. Aggregated data from Use of platform

2.34. Whether you are a Coach or User, we may collect aggregated and de-identified data related to your use of the Platform apart from what has been detailed above. We may analyse your usage data and content when it is uploaded, sent, received, or stored. We may use your data, activity logs, and direct feedback to improve our Platform and Services.

2.35. In order to provide specific functionality within our Platform, there is limited use of tracking technology within our Platform, as also disclosed within our Cookie Policy. Grace Papers will not request specific geo-location data from our Users. Users may manage their Cookie preferences within their User Profile in the Platform.

2.36. Provide customer support

2.37. You may provide data via the Site or Platform that we use, to enable us to provide a better customer support experience to you. For instance, if you were to email support@gracepapers.com.au our team would request specific information for verification purposes and as necessary to help us understand how we can better support you.

2.38. Data we collect about other parties

2.39. We also collect Personal Data about individuals such as our suppliers, contractors, subcontractors, potential contractors and their representatives in relation to providing goods and services to us. This Personal Data includes contact names and telephone or mobile phone number and work email address. We collect this Personal Data when you provide us, or you offer or apply to supply Grace Papers, with goods or services.

2.40. We also collect Personal Data about our past and present employees, including occupational and employment details such as employment status, previous work experience and other personal information you submit in connection with your resume or job application if you apply for a position with Grace Papers. However, the employee records exemption set out in the Privacy Act applies to our acts and practices in relation to the handling of employee records by us in relation to current and former relationships. This Privacy Policy does not apply to our acts and practices in relation to employee records.

How we use your Personal Data

3.1. Use of Personal Data

3.2. We will not sell or disclose any personally identifiable information to third parties unlawfully.

3.3. Personal Data may be used by us to:

enhance our ability to provide you with a Service;
contact you to respond to your queries;
display, update and maintain our Site content;
tailor your experience of the Site and Platform;
send you information about future events, regular email communications (including program email nudges) or newsletters;
conduct quizzes and surveys, use survey and quiz responses, and compile survey and quiz reports;
compile data for preparation of reports for internal use by us and external presentation to third parties;
to process any application submitted by you;
to respond to any queries or complaints you have made;
to comply with our legal obligations; and
to assist government and law enforcement agencies or regulators.

3.4. Services

3.5. At the core of Grace Papers is our belief that our career coaching platform and empowerment model can create the world’s most effective approach to gender equality and cultural transformation, driving impact for you and delivering real metrics that measure success. To do so, Grace Papers will use your data to drive these insights and analytics to serve you, our Users.

3.6. The primary manner in which we use all data is to provide the Services and help us improve the Site, the Platform, and the quality of our Services, and this extends to Personal Data. As described in section 2, we request sensitive Personal Data from Coaches only under very limited circumstances, providing it is always voluntary, and you may revoke permission at any time.

3.7. Generate insights that do not identify you

3.8. Most data that we use is de-identified and aggregate data, which we use to improve the Platform, the Site and the quality of our Services.

How we share your Personal Data

4.1. Communication between Users and Coaches

4.2. We require certain Personal Data from both a User and Coaches for routine communication with each and to facilitate the relationship between them. This may include providing the Coach access to a User’s Personal Data to communicate with the User, including email address and mobile phone number. This is for the sole purpose of enhancing communication between the
Coach and the User.

4.3. We also share certain Personal Data about Users with Coaches (and vice versa) such as responses to surveys to facilitate the ability for Coaches to provide Services to Users.

4.4. Disclosure of User Personal Data

4.5. If you are a User who is accessing the Platform through a paid subscription through a User Organisation (e.g. your employer), we share certain usage data with your sponsoring User Organisation, such as data about your Platform usage (e.g. the number of sessions you attended, when the session was attended, or date of completion of an assessment).

4.6. Your sponsoring User Organisation will receive information from Grace Papers about your usage on the Platform in the following ways:

individually identifiable data regarding your date of registration, number of coaching sessions completed, and the date you have completed certain assessments. Grace Papers will never provide your sponsoring User Organisation details about your specific coaching session or individual topics you have discussed unless we have received your express permission to do so; and
aggregated and de-identified insights and for topics and themes discussed by all Users associated with your sponsoring User Organisation.

4.7. If you are a User accessing a parental journey in the Platform, we will not share any data with your employer until you are at least 20 weeks pregnant and this disclosure is consistent with the purposes for which we collected your pregnancy related information.

4.8. We share aggregate data on responses to surveys, themes from coaching notes but only where there are sufficient people being coached to ensure themes from notes cannot identify an individual’s information with your sponsoring User Organisation to ensure a User Organisation has the tools necessary to ensure the Services are being utilized and that they are effective. We do NOT share your assessment or survey responses or your individual coaching sessions with your User Organisation.

4.9. Your sponsoring User Organisation may see de-identified and aggregated analysis from all participating Users within your organisation as aggregated from your interactions with resources within the Platform and general themes as identified by your Coach, post-session. As discussed in section 4.6 above, we do share limited individual level data with the sponsoring User Organisation.

4.10. We may also share opinions, feedback or reviews you voluntarily provide to us as a User with your User Organisation and your Coach on a de-identified basis, for quality or educational purposes.

4.11. Disclosure of Personal Data to other third parties

4.12. If you are a Visitor, Coach, User or User Organisation, we may also share data about you in the following ways:

with contract Coaches who need access to such data to carry out work on our behalf, on a need-to-know basis;
in response to a request for data if we believe disclosure is in accordance with any legitimate law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
if we believe your actions are inconsistent with the spirit or language of our user agreements or policies, to protect the rights, property, and safety of others and we are legally permitted to do so; and
with your consent or at your direction, including if we notify you through the Site, Services or Platform that certain data you provide will be shared in a particular manner and you choose to provide this data.

4.13. We may also disclose your Personal Data to external providers so that they may perform services for us or on our behalf or to assist us in providing our Platform and Services or to administer our business.

4.14. We may also disclose your Personal Data to a purchaser or potential purchaser in connection with the sale or potential sale of Grace Papers, our business or any of our assets, including in insolvency, in circumstances which require the purchaser or potential purchaser to use such Personal Data consistently with this Privacy Policy.

4.15. Other permitted disclosures

4.16. We may disclose Personal Data in other circumstances, where the person concerned has consented to the disclosure, or where we are expressly permitted to do so by the Privacy Act or another law. These other disclosures may include where:

you would reasonably expect the disclosure to occur (for example, quality assurance
purposes or training);
we are authorised or compelled by law to disclose;
it will prevent or lessen a serious threat to someone’s life, health or safety or a threat to
public health or safety;
it is necessary as part of the establishment or defence of a legal claim;
it is requested by an enforcement agency such as the police; or
it is a necessary part of an investigation following a complaint or incident.

4.17. Other uses and disclosures

4.18. We may collect, use and disclose your Personal Data for other purposes not listed in this Privacy Policy. If we do so, we will make it know to you at the time we collect or use your Personal Data.

Overseas disclosure of Personal Data

5.1. We may disclose your Personal Data to recipients located outside Australia or New Zealand. The countries in which those third party recipients may be located are: The United States of America (USA) and other countries as required by our suppliers to supply the services to Us.

5.2. Where we disclose Personal Data outside of Australia, we will take reasonable steps to ensure that any such person to whom Personal Data is disclosed will deal with that information in a way that is consistent with the Australian Privacy Principles.

5.3. You consent to the collection, use, storage and disclosure of your personal information in those countries, without us being responsible under the Privacy Act for such collection, use, storage and disclosure (or breach) of your information by the third party recipients.

5.4. Where such recipients are located overseas, you may have rights to enforce such parties’ compliance with applicable data protection laws, but you may not have recourse against those parties, or have the same protection, under the Privacy Act or Privacy Act 2020 (NZ) in relation to how those parties treat your personal information.

Your Choices, Rights and Obligations

6.1. Data retention

6.2. We store Personal Data for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

6.3. At the completion of your Platform licence, which is typically on a twelve-month basis either from the time you register with the on-demand Platform or are offered platinum coaching from your sponsoring User Organisation, we will communicate with you asking if you still want to be registered to the Platform and of course we will provide you with the opportunity to continue. If you do however want to leave, we will delete your Personal Data and only retain the data that we are allowed to by law, such as de-anonymised survey results.

6.4. Contacting us regarding accessing, correcting and privacy complaints

6.5. The privacy laws of some jurisdictions give individuals the right to access, amend or delete their Personal Data or, in some circumstances, to restrict or object to the processing of their Personal Data.

6.6. An individual may:

request access to and seek the correction of their Personal Data held by Grace Papers at any time;
make a complaint in relation to an alleged breach of privacy; or
submit a query or concern about this Privacy Policy or Grace Papers’ information handling processes by contacting support@GracePapers.com.

6.7. Information we hold about you should be up-to-date and accurate. Please advise of any changes to your information or if you require access to your Personal Data using the contact details set out in the following paragraph.

6.8. There is no charge for requesting access to your Personal Data, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).

6.9. We will respond to your requests to access or correct Personal Data in a reasonable time and will take all reasonable steps to ensure that the Personal Data we hold about you remains accurate and up to date.

6.10. If we refuse to provide you with access to your Personal Data or to update your Personal Data in the way you request, we will provide you with written reasons.

6.11. If we refuse to correct or update your Personal Data, you may request that we make a note on your record that you are of the opinion the data is inaccurate, incomplete, out of date, irrelevant or misleading.

6.12. If you have a complaint or concern regarding our handling of your Personal Data or think that your privacy has been affected, you should contact us using our contact details set out above to raise your complaint or concern.

6.13. We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

6.14. If you remain unsatisfied with the way in which we have handled your privacy complaint or concern, you may approach an independent advisor or contact the OAIC, the Office of the Privacy Commissioner (NZ) or the relevant regulator in your jurisdiction. See the OAIC’s or the New Zealand Privacy Commissioner’s website for more information about how to make a complaint, as applicable.

6.15. Your choices about email subscriptions

6.16. We will use your Personal Data to offer you products and services we believe may interest you, but will not do so if you tell us not to.

6.17. You may opt out of receiving email communications from us by following the unsubscribe link within those communications or by emailing us at support@GracePapers.com.

Other important information

7.1. How do we communicate changes to this Privacy Policy?

7.2. If we make changes to this Privacy Policy, we will notify you by revising the date at the top of the policy. In some cases, such as a material change in our practices, we may provide you with additional notice, such as adding a statement to our homepage or sending you an email notification. We encourage you to review the Privacy Policy whenever you access the Site, Platform or Services to stay informed about our data practices and the ways you can help protect your privacy. Any changes to our Privacy Policy will be published on the Site.