Our Privacy Policy


Our Privacy Policy for our coaching, survey and feedback services (“Able”).

At Integral Development Associates Pty Ltd (Integral) we comply with the Australian Privacy Act 1988 (Cth) (Privacy Act). We are committed to ensuring that the privacy and security of personal information and sensitive information remains protected. This Privacy Policy explains how we manage the personal information that we collect, hold, use and disclose and how to contact us if you have any further queries about our management of your personal information. This Privacy Policy applies to you only to the extent that the collection and handling of your personal information by Integral is subject to the Privacy Act.

1. Definitions
For purposes of this Privacy Policy the Definitions as outlined on the Definitions page apply.

2. What is Personal Information? 
Personal information is information or an opinion about an individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, or is recorded in a material form or not. It includes your name, age, gender and contact details. In this Privacy Policy, a reference to personal information includes sensitive information.

3. What does Integral do? 
Integral provides products and services related to leadership coaching, leadership & management development programs, surveys and feedback. Our service also provides messages, notifications, reminders and behaviour change recommendations to individuals and organisations regarding these behaviours.   

4. What kind of Personal Information do we collect and hold? 
Integral will only collect personal information about you by lawful and fair means and not in an unreasonably intrusive manner. The types of personal information we may collect and hold include contact information (such as name, email address and mobile phone number) and financial information (such as credit card details).

Integral may collect your personal information from you in a number of ways including face-to-face, over the telephone, through an online form or portal or by email. Integral may also collect your personal information from third parties such as a related body corporate of Integral, our partner service providers, partner software services or from software applications that you use and give us consent to collect data from (such as Gmail, Microsoft Exchange, Apple, Confrere, Calendly).

Integral may also collect your personal information from organisations engaged by Integral to carry out functions on behalf of us, such as coaches and leadership development programs. Where Integral collects your personal information from third parties, it may use that information for a number of reasons including to display your information within our software applications.

5. For what Purpose do we Collect, Use and Hold your Personal Information? 
We collect, use and hold your personal information to provide you with products and services, including professional development related programs, surveys and other products and services offered by us or a third party. Our products and services generally involve us sending you messages, emails, notifications, reminders and recommendations to support your professional development.

With your consent we also provide you with the ability to share and distribute your personal information to other individuals and organisations (such as your employer, your colleagues, your personal trainer or your health insurer). In this case we always will request your permission to share your personal information with the relevant third party. 

We also collect, use and hold your personal information to manage our ongoing relationship with you and perform functions and activities relating to our businesses (such as undertaking marketing campaigns, processing and analysing your organisational data).

Our range of products and services and our functions and activities, as well as those of our contracted service providers, may change from time to time.

6. Notification of the Collection of Personal Information
When we collect Personal Information from you or on your behalf from a third party, we will notify you beforehand, at the time, or, if that is not practical, as soon as possible afterwards. When we notify you we will inform you of our identity, contact details, the circumstances of that collection, if the collection is required or authorised by or under law or a court/tribunal order (including the name of the law or details of the court/tribunal order), the purposes for the collection, any other entities we usually discloses personal information to, how you may access or correct the personal information, how you may complain about a breach of the Australian Privacy Principles,  how we will deal with such a complaint, whether we are likely to disclose the personal information to overseas recipients, and the countries in which such recipients are likely to be located.

7. Dealing with Unsolicited Personal Information
If we receive personal information and we did not solicit the information we will, within a reasonable period after receiving the information, determine whether or not we could have collected the information ourselves.

  1. If we determine that we could not have collected the personal information; and the information is not contained in a Commonwealth record; we will, as soon as practicable but only if it is lawful and reasonable to do so, destroy the information or ensure that the information is de-identified.

  2. If we determine that could have collected the personal information; or that the information is contained in a Commonwealth record, our Privacy Policy will apply in relation to the information as if we had collected the information ourselves.

8. To whom will we disclose your personal information? 
In order to carry out the purposes mentioned above, we may disclose your personal information to persons or organisations such as our software service providers,  professional advisors and regulatory bodies. Integral may also disclose your personal information to the organisations described under the heading “What kind of personal information do we collect and hold?” from which Integral may collect your personal information.

9. Anonymity and Pseudonymity
You have the option of using our service or dealing with us in relation to a particular matter without identifying yourself, or of using a pseudonym, except where we are required or authorised by or under an Australian law, or a court/ tribunal order, to deal only with individuals who have identified themselves; or it is impracticable for us to deal with individuals who have not identified themselves or who have used a pseudonym, in relation to the relevant matter.

10. Marketing
If we hold personal information about you, we will not use or disclose your personal information for the purpose of direct marketing without your consent. However, if you have given us your consent we may use your personal information to contact you (including by telephone call, text message, in app notifications, mail or email) in relation to other products or services we think may be of interest to you. This may include our own products and services, the products or services of a related body corporate of Integral, or the products or services of third parties. We may contact you about products and services we think may be of interest to you during the period you have a relationship with Integral and after you cease using any products or services from or through Integral.

In each direct marketing communication with you we will provide a simple means by which you may easily request not to receive direct marketing communications from us. You may opt-out of receiving marketing information from us at any time by:

  • emailing us on admin@integral.org.au, or

  • unsubscribing from any emails or messages we may send you, or

  • changing the notifications settings within our web or mobile applications, or

  • ‘ticking the box’ on the relevant form when you apply for a product or service.

Please allow five working days for your request to be actioned.

11. How do we hold and manage the data quality and security of your personal information?
To the extent required by the Privacy Act, we will take reasonable steps to:

  • make sure that the personal information that we collect, hold, use and disclose is accurate, complete and up to date;

  • protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and

  • where permitted by law, destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the Privacy Act.

12. Do we transfer personal information overseas? 
We may transfer your personal information overseas in the circumstances outlined below. If you consent to Integral transferring your personal information to an overseas third party service provider, including to an overseas software service. If you request an overseas software service to collect your personal information from Integral, we may provide access to your personal information. By making such a request, you give consent for your personal information to be transmitted overseas in these circumstances. We sometimes use service providers who either host or store personal information overseas. This means we may transfer personal information about you between countries to those service providers for the purposes outlined in this policy. In the event Integral transfers your personal information outside Australia, we will comply with the requirements of the Privacy Act that relate to transborder data flows.

13. How can you access or correct your information? 
Please contact us if you would like to seek access to or correct the personal information we hold about you by emailing us at: admin@integral.org.au. We will generally provide you with access to your personal information if practical, and will take reasonable steps to amend any personal information about you which is inaccurate or out of date. If we have disclosed your personal information to another entity, and you requests us to notify the other entity of the correction, we will take such steps (if any) as are reasonable in the circumstances to give that notification unless it is impracticable or unlawful to do so.

In some circumstances and in accordance with the Privacy Act, Integral may not permit you access to your personal information, or may refuse to correct your personal information, in which case we will provide you reasons for this decision.

In some circumstances we may need to charge you for access to your personal information; the charge will not be excessive and will not apply to the making of the request.

14. How we handle Complaints 
If you have any concerns or complaints about the manner in which your personal information has been collected or handled by Integral, please contact by email: admin@integral.org.au. Your concern or complaint will be directed to the appropriate complaint person who will consider and respond to your complaint within 7 days. It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you may contact the Office of the Australian Information Commissioner who may investigate your complaint further.

15. The Australian Privacy Act and Privacy Principles
Our Privacy Policy is intended to mirror the Principles and sub-clauses of the Australian Policy Principles, with their language modified as necessary to be implementable, practical, relevant consistent and readable.  Any inconsistency between this Privacy Policy and the Australian Policy Principles is unintentional, and in such a case the wording of the relevant part of the Australian Policy Principles will apply and the inconsistent language of this Policy must be ignored. References to “the Act” or to the “Privacy Act” are to the Privacy Act 1988 (Cth) as amended, and its regulations. References to “APP” are to the Australian Privacy Principles contained in the Privacy Act, as amended. 

16. Further Information 
Further information about the application of the Privacy Act can be found at the website of the Office of the Australian Information Commissioner.  If you require a copy of the Integral Privacy Policy in another format please contact us. If you would like to contact us regarding any other matters related to your privacy and personal information please email us at: admin@integral.org.au