Privacy policy
KOOEE Privacy Policy
This is the Privacy Policy of KOOEE Pty Ltd (ACN 697 697 822) (KOOEE).
Protecting your privacy is important to KOOEE. We are committed to maintaining the security of all Personal Information provided to KOOEE, whether by individuals with whom we do business, visitors to and users of our websites or otherwise. This Privacy Policy details how we collect, use, and manage this Personal Information.
KOOEE has appointed a Privacy Officer who will ensure that our activities are carried out in compliance with applicable laws. For questions regarding this Policy, to exercise your rights or to lodge a complaint with us, please contact our Privacy Officer at privacyofficer@kooeeconnect.com.au
For the purposes of this Privacy Policy and applicable data protection and privacy laws:
- Personal Information is defined as information and data, whether recorded in a material form or not, relating to an identified or identifiable natural person that is processed by or on behalf of KOOEE, whether by automated means; and
- KOOEE is considered the "data controller" in respect of the Personal Information that it collects, uses, and manages in connection with this Privacy Policy.
Whose information do we collect?
KOOEE is a platform which is primarily designed for the purposes of connecting Providers with Instructors. It follows that in most cases, the information and data we collect will be that of either Providers or Instructors in the outdoor education, school camp, or adventure tourism businesses.
KOOEE collects Personal Information from a range of individuals in the context of its business activities, including (but not limited to):
- Instructors;
- Providers;
- Representatives of our customers, and business partners;
- Contractors;
- Landowners;
- Industry association representatives;
- Users of KOOEE websites; and
- Job applicants.
What information we collect and why we collect it
We collect Personal Information from you where it is relevant for our purposes as further detailed below.
Business use
KOOEE may collect a range of information in a business context, such as your name, or company or business particulars, gender, job title, photographic identification, email address, home address and other contact details, details of your business and other interests, experience and/or academic and professional qualifications, third party references, communications with you (including notes from meetings and telephone call recordings), feedback or survey responses that you provide to us, financial and payment information, and information collected from questionnaires and/or interviews.
KOOEE uses information collected from you for business-related purposes, including negotiating, concluding and performing contracts, managing business relationships, administering real estate leases and licences, recruitment, managing accounts and records, communicating with you and third-party contacts, supporting corporate social responsibility activities, security, legal, regulatory and internal investigations and debt administration.
Our websites
When you use our websites, KOOEE collects certain standard information that is sent by your browser to our website. This includes technical information, such as your IP address, browser type, operating system, language, time zone setting, access times, and any referring website addresses.
KOOEE uses this information to administer our websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes. KOOEE also collects certain information to provide users with a personalised experience when visiting our websites. Through the use of a 'cookie', KOOEE can record information about your visit to our website including the clickstream to, through and from our site (including date and time), the pages visited, page interaction information and methods used to browse away from the page. This information is used anonymously and in aggregate and is collected and logged for statistical purposes. Through analysis of these records, KOOEE can provide an improved service when users revisit our websites. See below for further information on our use of cookies and related technologies.
Other than as stated in this Privacy Policy, no attempt is made to identify our users of our websites or their browsing activities except:
- where a law enforcement agency exercises a warrant to inspect logs or any such information is otherwise required to be produced by KOOEE to authorities or regulators; or
- where KOOEE believes it is required to collect and produce relevant electronic documentation to fulfil its obligations to third parties, including statutory organisations under local law.
Access to other websites via hyperlink
Other websites that may be accessible via hyperlinks from KOOEE websites are owned and operated by third parties and are not subject to KOOEE's Privacy Policy. KOOEE has no control over the content of those websites. Please review the privacy policy of each individual website you access and assess whether the policy is satisfactory to you before you use the other websites.
Cookies & Related Technologies
Our websites and mobile applications (apps) use cookies. A cookie is a small text file that is placed on your computer or mobile device when you visit a website or use an app. Cookies collect information about users and their visit to the website or use of the app, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or app. A cookie cannot read data from your hard disk or read cookie files created by other websites.
KOOEE uses cookies and other technologies to facilitate your internet sessions and use of our apps, offer you services according to your preferred settings, track use of our websites and apps and to compile statistics about activities carried out on our web sites and/or through our apps.
You may set up your web browser to block cookies or remove cookies stored from your computer or mobile device. However, if you do so, you may not be able to use certain features and functions of our websites and apps.
Providing Personal Information
At times, KOOEE may ask you to voluntarily supply Personal Information, such as your name, email address, location, telephone number, and preferred means of communication, for purposes such as subscribing to KOOEE news alerts, direct marketing or requesting further information from KOOEE.
Where we ask you to voluntarily supply Personal Information, we will use it to provide you with the information or services that you have requested from us.
The types of information KOOEE collects and utilises includes (but is not limited to) the following:
- Full legal names;
- Dates of birth;
- Mobile phone numbers;
- Email address;
- Residential addresses;
- Criminal history;
- Medical records;
- Qualifications and certifications (including but not limited to first aid, working with children checks, activity specific qualifications, driver's license particulars);
- Emergency contact information;
- Bank account details; tax file numbers; and superannuation fund details;
- Professional references;
- Program and engagement history;
- Company names and particulars, including business addresses, billing details, ABN and ACN; and
- Names and contact details of authorised administrative users. Generally, the financial and taxation information we collect and retain are obtained in connection with Instructor payment, payroll, and financial transactions we undertake more generally. The financial and taxation-based data that we store and collect are stored in a secure manner, on a platform visible only to the Provider once the Instructor has approved that specific access. KOOEE collects sensitive information. Information collected such as criminal history, working with children checks, and other general background checks, to ensure it connects the right Instructor with the right Provider. Safety is a paramount concern for KOOEE. Providers need KOOEE to collect sensitive information to ensure that they meet their respective legal obligations insofar as they relate to duty of care and professional requirements. Similarly, the storage of health information is only held for safety and emergency response purposes, this data is stored separately to an Instructor's public profile.
Job Applicants' Personal Information
When you submit a job application to KOOEE, or to a recruitment agent or advisor engaged to administer our employment marketing initiatives and/or the recruitment/engagement process, we will collect more specific Personal Information about you, such as your name, email address and telephone number, qualifications and career history. We may also ask you for other information, such as information on your interests and the types of jobs in which you are interested. We may also collect your Personal Information from publicly available sources (such as Facebook and LinkedIn); and from third parties (such as references, psychometric test results, and police checks). The Personal Information you provide to KOOEE in, and in connection with, your job application, and the further information which we collect will only be processed for the purpose of considering employment or internship positions at KOOEE.
If any job application you make is unsuccessful, KOOEE may choose to retain your Personal Information for a period of up to 12 months for the purposes of considering you for other roles within KOOEE. KOOEE is under no obligation to retain your Personal Information for this purpose and may elect to delete your Personal Information at any time following an unsuccessful application. You may also request that KOOEE deletes your Personal Information if you do not wish to be considered for further roles. You can do this by informing KOOEE when you submit your job application, or at any time after applying, by emailing us at privacyofficer@kooeeconnect.com.au
Sensitive Personal Information
Sensitive Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or medical conditions, genetic or biometric information, sexual orientation, or criminal convictions and offences may be processed by KOOEE if such processing is necessary to comply with laws and regulations or where you provide this information voluntarily or otherwise consent for us to do so.
Email monitoring
KOOEE may monitor emails sent to and from its workforce, which may contain Personal Information relating to third parties. The information contained in such emails may be used for business-related purposes, for example when investigating incidents within KOOEE. Although KOOEE endeavours not to review the contents of personal emails, there may be occasions when this is necessary, for example, to investigate a breach of security within KOOEE, or in the context of legal proceedings.
The legal basis for KOOEE processing your Personal Information
To comply with applicable data protection and privacy laws, KOOEE is required to set out the legal basis for the processing of your Personal Information. In accordance with the purposes for which we collect and use your Personal Information, as set out above, the legal basis for KOOEE processing your Personal Information will typically be one of the following:
- your consent;
- the performance of a contract that we have in place with you or other individuals;
- KOOEE's or our business partners' legitimate business interests; or
- compliance with our legal obligations.
Disclosure of the information we collect
KOOEE may share your Personal Information with people within KOOEE who need to know that information for business or legal reasons, for example, in order to carry out an administrative function such as processing an invoice, or to direct a query that you have submitted to the relevant department within KOOEE.
Primarily, Instructor information is shared with Providers searching the marketplace. KOOEE allows for an Instructor to create a profile with select personal details on it. Once engagement of an Instructor is confirmed by the Provider, further personal information of that Instructor becomes available for review by the selecting Provider. Those further personal details include financial and taxation information shared for the purposes of payroll, and health and emergency information shared for compliance and safety.
We may disclose your Personal Information to third parties including the authorities, KOOEE's advisors, suppliers of financial or IT services and third parties engaged by KOOEE for the purpose of providing services requested by you; to protect any intellectual property rights in any materials displayed on or otherwise available from KOOEE's websites; for the purposes of seeking legal or other professional advice; to respond to a legal request or comply with a legal obligation; and to enforce KOOEE's trading terms.
We may disclose your Personal Information to third parties if we sell, buy, or merge any business or assets, including to the prospective seller or buyer of such business or assets. KOOEE may also disclose the Personal Information you provide to us in connection with the job recruitment process to KOOEE HR practitioners and to KOOEE's recruitment advisors for the purpose of considering you for career opportunities with KOOEE.
Transfer of your Personal Information to other countries
Please note that any person to whom KOOEE may disclose your Personal Information under this Privacy Policy may be situated in a country other than your own and that such country may provide a lower level of data protection requirements than your own country. By agreeing to this Privacy Policy, you consent to the transfer of your Personal Information to a country other than your own.
Whenever we transfer Personal Information across borders, we take steps to put in place adequate safeguards to protect your Personal Information and to make sure it is treated in accordance with this Privacy Policy.
Access to KOOEE’s eBusiness websites
Access to KOOEE's eBusiness websites or portals may be provided to KOOEE's customers to conduct ecommerce transactions or for management purposes. Users of KOOEE's eBusiness websites or portals may be required to register with the customer database by providing their email address; their name, company name, office name; their business address, business phone; and a valid KOOEE internal contact name.
KOOEE will collect details in the customer database that are relevant to the use of the eBusiness websites. While KOOEE will use the registration details for demographic analysis and to personalise your web experience, KOOEE will not make customer details available to external parties.
Retention of Personal Information
KOOEE's aim is to keep your Personal Information for no longer than is necessary for regulatory or KOOEE's business reasons. The amount of time for which records are kept varies depending upon the type of Personal Information they contain. KOOEE retains and stores its data in Australia.
Your rights in relation to your Personal Information
If you would like to access or obtain a copy (which may be in machine-readable form) of the Personal Information KOOEE holds about you, please email your request to privacyofficer@kooeeconnect.com.au
KOOEE endeavours to ensure that the Personal Information it holds about you is complete, accurate, and up to date. If you consider that your Personal Information is incomplete, inaccurate, or out of date, you have the right to require us to correct it. To correct, erase or limit the processing of any of the Personal Information we hold about you, please email your request to privacyofficer@kooeeconnect.com.au
If you do not provide us with the information sought in the required fields, we may be limited in our ability to provide you with services.
Complaints and Concerns
If you have a concern or complaint about how KOOEE has used your Personal Information, as a first step, you should raise this in writing with KOOEE, via email to privacyofficer@kooeeconnect.com.au
If you are not satisfied with the handling of your concern or complaint by KOOEE, you can escalate this to the Australian Information Commissioner (www.oaic.gov.au) if you are in Australia.
Changes to this Privacy Policy
This Privacy Policy is effective from 10 August 2026. Any changes KOOEE may make to this Privacy Policy in the future will be posted on this web page and will apply to all your Personal Information held by us at that time.
Contact
Questions, comments, and requests regarding this Privacy Policy are welcomed and should be submitted via email to privacyofficer@kooeeconnect.com.au