Privacy Policy

1. RAW Marvels commitment to privacy

1. RAW Marvels (ABN: 61579502368), its subsidiaries and affiliates in Australia (collectively referred to as “we” and “us”) are committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws.
2. RAW Marvels respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. This policy sets out how we collect and treat your personal information.
3. This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.
4. In this Privacy Policy, “we” and “us” refers to RAW Marvels and “you” refers to any individual about whom we collect personal information.
5. ”Personal information” is information we hold which is identifiable as being about you. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly.

2. About RAW Marvels

1. RAW Marvels is a provider of photography education, photography tours and general discussion on photography.
2. RAW Marvels offers a complete range of services, including photography workshops, photography tours, online education.
3. Please contact us for a full list of the companies which comprise RAW Marvels and which are subject to this Privacy Policy.

3. What information does RAW Marvels collect about you?

1. Clients and prospective clients

   1. When you enquire about our services or when you become a client of RAW Marvels, a record is made which includes your personal information.
   2. The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:
      1. your name, e-mail, postal address and other contact details;
      2. information about your employer or an organisation who you represent;
      3. your professional details; and
      4. any additional personal information you provide to us, or authorise us to collect, as part of your interaction with RAW Marvels.

2. Prospective employees or applicants

   1. We collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.
   2. We may also collect personal information from third parties in ways which you would expect (for example, from recruitment agencies or referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (for example, positions which involve working with children).

3. Other individuals

   1. RAW Marvels may collect personal information about other individuals who are not clients of RAW Marvels. This includes customers and members of the public who participate in events we are involved with, individual service providers and contractors to RAW Marvels, and other individuals who interact with RAW Marvels on a commercial basis. The kinds of personal information we collect will depend on the capacity in which you are dealing with RAW Marvels.
   2. If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings which identify you.
   3. In limited circumstances, RAW Marvels may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by RAW Marvels we may collect health information about you in an emergency or otherwise with your consent.
   4. You can always decline to give RAW Marvels any personal information we request, but that may mean we cannot provide you with some or all of the services you have requested. If you have any concerns about personal information we have requested, please let us know.

4. Visitors to our websites

The way in which we handle the personal information of visitors to our websites is discussed below.

4. How and why does RAW Marvels collect and use your personal information?

1. RAW Marvels collects personal information reasonably necessary to carry out our business, to assess and manage our clients’ needs, and provide services including photography workshops, photography tours, online education.. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you or third parties and managing client relationships.
   1. By providing us with personal information, you consent to the supply of that information subject to the terms of this Privacy Policy.
2. The purposes for which RAW Marvels usually collects and uses personal information depends on the nature of your interaction with us, but may include:
   1. responding to requests for information and other general inquiries;
   2. managing, planning, advertising and administering programs, events, competitions and performances;
   3. researching, developing and expanding our facilities and services;
   4. informing you of our activities, events, facilities and services;
   5. recruitment processes (including for volunteers, internships and work experience);
   6. investigating and responding to enquires and complaints;
   7. when visitors leave comments or reviews on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
   8. an anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
   9. If you request a password reset, your IP address will be included in the reset email.
3. RAW Marvels generally collects personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet or social media, or in person. We may also collect personal information about you from other sources, for example:
   1. our affiliated and related companies;
   2. third party suppliers and contractors who assist us to operate our business; and
   3. advertising agencies and social media platforms such as LinkedIn, Facebook and Instagram.
4. RAW Marvels also collects and uses personal information for market research purposes and to innovate our delivery of products and services.
5. We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request.
6. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.

5. How does RAW Marvels interact with you via the internet?

1. You may visit our website (rawmarvels.com) without identifying yourself. If you identify yourself (for example, by providing your contact details in an enquiry), any personal information you provide to RAW Marvels will be managed in accordance with this Privacy Policy.
2. You may provide basic information such as your name, phone number, address and email address to enable us to send you information, provide updates and process your product or service order.
3. RAW Marvels’s website uses cookies. A “cookie” is a small file stored on your computer’s browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, IP address, pages you have accessed on our websites and on third-party websites. You are not identifiable from such information.
4. You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.
5. RAW Marvels’s website may contain links to third-party websites. RAW Marvels is not responsible for the content or privacy practices of websites that are linked to our website.
6. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer service team.

6. Can you deal with RAW Marvels anonymously?

1. RAW Marvels will provide individuals with the opportunity to remain anonymous or use a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for RAW Marvels to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

7. How does RAW Marvels hold information?

1. RAW Marvels stores information in paper-based files or other electronic record keeping methods in secure databases (including trusted third party storage providers based in Australia or overseas). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
2. RAW Marvels maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
3. Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.
4. We take steps to destroy or de-identify information that we no longer require.

8. Does RAW Marvels use or disclose your personal information for direct marketing?

1. RAW Marvels may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us using the contact details below.
2. If you opt-out of receiving marketing material from us, RAW Marvels may still contact you in relation to its ongoing relationship with you.

9. How does RAW Marvels use and disclose personal information?

1. For clients

   The purposes for which we may use and disclose your personal information will depend on the services we are providing you. For example, if you have engaged us to deliver a service, we may disclose information about you to service providers where this is relevant to our services.

2. For customers and participants

   If you are a customer or participant in an event, we may disclose your personal information to our clients and venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings which identify you for promotional purposes where you would reasonably expect this to occur.

3. Disclosure to contractors and other service providers

   1. RAW Marvels may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance/development, printing, archiving, mail-outs, and market research.
   2. Personal information may also be shared between related and affiliated companies of RAW Marvels, located in Australia or overseas.
   3. Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
   4. Articles on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
      1. These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

4. Cookies

   1. If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
   2. If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.
   3. When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.
   4. If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

5. Media

   1. If you upload images to the website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.

6. Comments

   1. When visitors leave comments on the site we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
   2. An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.

7. Use and disclosure for administration and management

   RAW Marvels will also use and disclose personal information for a range of administrative, management and operational purposes. This includes:

   1. administering billing and payments and debt recovery;
   2. planning, managing, monitoring and evaluating our services;
   3. quality improvement activities;
   4. statistical analysis and reporting;
   5. training staff, contractors and other workers;
   6. risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
   7. responding to enquiries and complaints regarding our services;
   8. obtaining advice from consultants and other professional advisers; and
   9. responding to subpoenas and other legal orders and obligations.

8. Other uses and disclosures

   We may use and disclose your personal information for other purposes explained at the time of collection or otherwise as set out in this Privacy Policy.

10. General Data Protection Regulation (GDPR) for the European Union (EU)

1. RAW Marvels will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.
2. We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.
3. We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.
4. We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure.
5. We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.
6. We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.
7. We do not collect or process any personal information from you that is considered “Sensitive Personal Information” under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.
8. You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.

11. Your rights under the GDPR

1. If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used. RAW Marvels complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU.
2. Except as otherwise provided in the GDPR, you have the following rights:
   1. to be informed how your personal information is being used;
   2. access your personal information (we will provide you with a free copy of it);
   3. to correct your personal information if it is inaccurate or incomplete;
   4. to delete your personal information (also known as “the right to be forgotten”);
   5. to restrict processing of your personal information;
   6. to retain and reuse your personal information for your own purposes;
   7. to object to your personal information being used; and
   8. to object against automated decision making and profiling.
3. Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy.
4. We may ask you to verify your identity before acting on any of your requests.

12. Does RAW Marvels disclose your personal information overseas?

1. RAW Marvels is a global organisation and works with clients, service providers, sponsors and commercial interests across the globe. It is likely that your personal information will be disclosed to overseas recipients predominantly in order to deliver our services, for example booking accommodation or sub-contracted tour activities.
2. Unless we have your consent, or an exception under the Australian Privacy Principles applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.
3. Entities which are related entities of RAW Marvels or are otherwise affiliated with RAW Marvels in Australia, USA and New Zealand. In circumstances where your information is disclosed to overseas recipients, those recipients are likely to be located in countries in the regions in which RAW Marvels and its related entities and affiliates operate.
4. Visitor comments may be checked through an automated spam detection service, the servers of which may be based overseas.

13. Security of your personal information

1. RAW Marvels is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
2. Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
3. The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

14. How can you access or seek correction of your personal information?

1. You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth), and to the extent applicable the EU GDPR. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at [email protected].
2. You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
3. We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your personal details change.
4. However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
5. We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

15. What should you do if you have a complaint about the handling of your personal information?

1. You may contact RAW Marvels at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.
2. You may make a complaint about privacy to the privacy officer at the contact details set out below.
3. The privacy officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.
4. If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
5. In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
6. If you are not satisfied with our response to your complaint, or you consider that RAW Marvels may have breached the Australian Privacy Principles or the Privacy Act, a complaint may be made to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or by using the contact details on the website (www.oaic.gov.au).

16. Website

1. When you visit our website
   1. When you come to our website (rawmarvels.com), we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
2. Cookies
   1. We may from time to time use cookies on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Cookies are not malicious programs that access or damage your computer. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords. These ads may appear on this website or other websites you visit.
3. Third party sites
   1. Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that RAW Marvels is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

17. How changes are made to this Privacy Policy?

RAW Marvels may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website (rawmarvels.com) regularly to keep up to date with any changes.

18. How can you contact RAW Marvels?

The contact details for RAW Marvels are:

1. RAW Marvels privacy officer: Ty Stedman
2. PO Box 1941, Busselton, Western Australia, 6280
3. [email protected]

This Privacy Policy was last updated on 9th March 2023