This Privacy Policy explains how we manage the Information, including any Personal Information, Sensitive Information or Confidential Information, that you may share with us, we collect, hold, use and disclose when you use our websites (www.integral.global or www.helloable.com), the Able platform (https://app.helloable.co/) and services (collectively, “Services”).

At Integral Development Associates Pty Ltd (“Integral”, “we”, “us”, or "our") we comply with the Australian Privacy Act 1988 (Cth) (“Privacy Act”). This Privacy Policy applies to you only to the extent that the collection and handling of your Personal Information by us is subject to the Privacy Act.

If you notify us that you are located in the European Union, then we will comply with the GDPR in relation to your personal information In that case, all references in this policy to the “Privacy Act” will be taken to refer to the GDPR instead, and clause 22 below will apply to you and your personal information.

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1. Definitions

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

Two specific definitions most relevant to the Privacy Policy include:

• “Able” or our “Platform” means our software application used by Clients, Partners, Participants and Users to design, manage and deliver programs, coaching, workshops and other learning materials; and found at https://app.helloable.co/, and previously found at https://albert.integralsurveys.com. Through this we provide many services including, but not limited to, AI-generated coaching, AI-generated nudges, coaching, micro-learning, survey & feedback products, email & in-app messages, learning content, notifications and recommendations to individuals and organisations.

• "Platform" means collectively our online Applications; including Able and Jarvis; our Software and our Website; and any Services or Information we make available to you.

2. Related Agreement

1. Note that if you are a Client (including a Subscriber), or a Participant authorised by a Client, then your access to our Services will be governed by our relevant Agreement with the Client. The Agreement incorporates our Privacy Policy (this document), our Terms & Conditions, our Terms of Use, the Definitions & Interpretation and the relevant Quote (collectively the “Agreement”).

2. Note that if you are a Partner, then your access to our Services will be governed by our relevant Agreement with you, incorporating our Privacy Policy (this document), our Partner Terms, and the Definitions & Interpretation.

3. This is our generic Privacy Policy for the collection, storage, use and disclosure of Personal Information, and does not displace the terms of the Agreement that we made with you.

3. What is Personal Information?

1. In this Privacy Policy, “Personal Information” has the meaning given by the Privacy Act 1988 (Cth). The Privacy Act defines “Personal Information” as 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. Personal Information your name, age, gender and contact details, and includes other types information including:

   1. “Sensitive Information” (which includes information or opinion about an individual’s racial or ethnic origin, political opinion, religious beliefs, sexual orientation or criminal record, provided the information or opinion otherwise meets the definition of personal information),[3],

   2. “Health Information” (which is also Sensitive Information), [4],

   3. “Credit Information”[5],

   4. “Employee Record” information (subject to exemptions [6]), and

   5. “Tax File Number Information”.[7]

2. For clarity we consider all Information about an individual collected through our software application (Able), AI-Coach, surveys, feedback profiles, evaluation methods, assessment tools or documented within reports or our Platform as Personal Information.

4. What does Integral do?

Integral provides Services including, but not limited to: AI-generated coaching, AI-generated nudges, coaching, leadership & management development programs, RTO qualifications, consulting, strategic planning, micro-learning, learning materials, survey & feedback products and other professional development programs and products. Our services also include the use of messages, learning content, notifications and recommendations to individuals and organisations.

5. What kind of Personal Information do we collect and hold?

1. Integral will only collect your Personal Information by lawful and fair means and not in an unreasonably intrusive manner.

2. The types of Personal Information we may collect and hold include sensitive information, contact information (such as name, email address and mobile phone number), opinions about you, assessments, peer feedback, and financial information (such as credit card details).

3. 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 survey or portal or by email.

4. Integral may also collect your Personal Information from or using third parties such; as a related body corporate of Integral; our partner service providers; third-party software services; or from software applications that you use and give us consent to collect data from (such as Microsoft, Open-AI, Apple, Zoom or Calendly); sub-contractors engaged by Integral to carry out functions on behalf of us, such as coaches, trainers or researchers.

5. Similar to other commercial websites & software applications, our Platform utilizes a standard technology called cookies. Like many websites & software applications, we use cookies that allow us to obtain information about how our Platform is being used so we can continually improve your experiences with Integral. Cookies themselves do not contain Personal Information. They simply operate as a unique identifier which helps us to know what our clients find interesting and useful on our Platform.

6. For what Purpose do we Collect, Use and Hold Personal Information?

1. We collect, use and hold your Personal Information to provide you with our Services. Our Services generally involve us sending you messages, emails, learning and development material, notifications, reminders, generating reports, displayed within our software applications and recommendations to support your professional development.

2. 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 coach, your facilitator or another member of our team). In this case we always will request your permission to share your Personal Information with the relevant third party.

3. Please note we occasionally use third parties such as consultants, trainers or coaches to deliver the Services you have requested from us. In these cases we only provide them the relevant information required to deliver that Service.

4. 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 data or sending you marketing material.

5. 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.

7. Notification of the Collection of Personal Information

1. 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.

2. 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.

8. Dealing with Unsolicited Personal Information

1. 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.

2. 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.

3. 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.

9. To whom will we disclose your Personal Information?

1. In order to carry out the purposes mentioned above, we may disclose your Personal Information to our employees to provide the products or Services you have requested from us.

2. 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.

3. In order to carry out the purposes mentioned above, we may disclose your Personal Information to third parties such as consultants, trainers or coaches to provide the Services you have requested from us. In these cases we only provide them the relevant information required to deliver that Service.

10. How we Handle Personal Information and Confidential Information Disclosed to Us in Coaching & AI-generated Coaching.

1. Coaching Sessions & Conversations: we and our coaches will treat as confidential all information shared with the coach by the Participant, including their opinions about the Client. This obligation will not apply where the coach believes the Participant may be a danger to themselves or others.

2. Disclosures to the Client or Supervisor: unless otherwise agreed we will only provide generic feedback and updates on the Participant's progress and coaching sessions to the Client organisation. We will encourage Participants to provide an update to their supervisor. Additionally, all notes of sessions or meetings will be treated as confidential information between the Participant and coach.

3. AI-generated Coaching: all messages by a User or Participant to our AI-Coach are confidential & private, including their opinions about the Client, however this obligation will not apply where we believe the Participant may be a danger to themselves or others. Some messages are occasionally reviewed & analysed by our engineering team to improve the quality of our AI-generated coaching service.

11. How we Handle Personal Information and Confidential Information Disclosed in Surveys.

1. We keep all individual survey responses private and confidential unless otherwise agreed in your Agreement with us. ​Our data storage, survey Platform, surveys and reporting are designed to ensure the privacy and confidentiality of survey respondents both when we collect data and use it in analysis and reporting.

2. Our survey Platform and data is stored solely within Australia on Microsoft Azure servers and continuously backed up.

3. We use unique urls for each participant, to assist with automated reminders and allowing respondents to return to their survey response if partially complete.

4. When generating either online or hardcopy reports our Platform has a minimum threshold (generally minimum groups of 6) for reporting so that anonymity is maintained, particularly with sensitive data such as open comments and analysis using demographic features.

5. Unless otherwise agreed with individual respondents prior to sharing reports, we will only provide aggregated and anonymised individual (eg. 180º or 360º feedback) reports to Clients (these are called "Group Reports").

12. Confidential Information.

In the course of providing our Services to you, you may share Confidential Information with us and we with you. The following outlines our agreement with each other:

1. Each party (as "Receiving Party") agrees that all code, inventions, know-how, business, technical and financial information it obtains from the disclosing party ("Disclosing Party") constitute the confidential property of the Disclosing Party ("Confidential Information").

2. Any Integral technology, performance information relating to any of our Services, and the terms and conditions of any Agreements with you are our Confidential Information without any requirement for special marking or further designation.

3. Except as expressly authorised herein, the Receiving Party will (1) hold in confidence and not disclose any Confidential Information to third parties and (2) not use Confidential Information for any purpose other than fulfilling its obligations and exercising its rights under our Agreement with you.

4. The Receiving Party may disclose Confidential Information to it’s employees, agents, contractors and other representatives having a legitimate need to know (including, for Integral, any Partners), provided that such representatives are bound to confidentiality obligations no less protective of the Disclosing Party than this Privacy Policy and that the Receiving Party remains responsible for compliance by any such representative with the terms of this Privacy Policy.

5. The Receiving Party's confidentiality obligations will not apply to information that the Receiving Party can demonstrate: (i) was rightfully in its possession or known to it prior to receipt of the Confidential Information; (ii) is or has become public knowledge through no fault of the Receiving Party; (iii) was rightfully obtained by the Receiving Party from a third party without breach of any confidentiality obligation; or (iv) was independently developed by the Receiving Party without relying on the Confidential Information.

6. The Receiving Party may make disclosures of the Confidential Information to the extent required by law or court order, provided the Receiving Party notifies the Disclosing Party in advance and cooperates in any effort to obtain confidential treatment.

7. The Receiving Party acknowledges that disclosure of Confidential Information would cause substantial harm for which damages alone would not be a sufficient remedy, and therefore that the Disclosing Party will be entitled to seek appropriate equitable relief in addition to whatever other remedies it might have at law.

8. Each Party must immediately report to the other Party any breach of the confidentiality of the other Party’s Confidential Information that comes to the first-mentioned Party’s attention.

13. Anonymity and Pseudonymity

1. You have the option of using our Platform 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.

2. In the case that you do not want to provide your personal information or use a pseudonym, we may not be able to deliver services in the normal manner. For example: We may be unable to provide you a specific service; We may not be able to properly investigate or resolve an individual’s complaint; or a different level of service may be provided to you.

14. Marketing

1. If we hold your Personal Information, 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.

2. 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.

3. You may opt-out of receiving marketing information from us at any time by:

   1. emailing us on admin@integral.global, or

   2. unsubscribing from any emails or messages we may send you, or

   3. changing the notifications settings within our web or mobile applications, or

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

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

15. 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:

1. make sure that the Personal Information that we collect, hold, use and disclose is accurate, complete and up to date;

2. protect the Personal Information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure;

3. uses the best SSL security to encrypt and store personal, financial and sensitive information submitted by you; and

4. 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.

16. Do we transfer Personal Information overseas?

Our Platform and the majority of the data we collect is held within Australia on Microsoft Azure. However, we may transfer your Personal Information overseas in the circumstances outlined below:

1. If we or you use an overseas-based software service to communicate or interact with each other, such as Zoom (video conferencing), or Calendly (calendar management and meeting scheduling), any of your Personal Information included in that use may be routed via servers located outside Australia. By participating in that use, you consent to your Personal Information being transmitted overseas for that purpose.

2. We also sometimes use service providers who either host or store information, including Personal Information, in services located overseas, such as Mailchimp (for transactional emails & marketing emails) and Hotjar (for Platform engagement tracking). This means we may transfer your Personal Information between countries to those service providers. In the event that Integral transfers your Personal Information outside Australia, we will comply with the requirements of the Privacy Act that relate to transborder data flows, and as a general rule we will only transmit the minimum amount of information required to use the relevant service.

3. As part of delivering our products, services or operating our website/s we may provide links to third party websites or services. These linked sites or services are not under the control of Integral, and we are not responsible for the conduct of these companies. Before disclosing your Personal Information on any other website, we advise you to examine the privacy policies for those sites.

17. Aggregated or De-Identified Information.

1. We may aggregate or de-identify Personal Information so that it may no longer be used to identify you and use such information to analyze the effectiveness of our Services, to improve and add features to our Services, to conduct research and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with third parties, publish such aggregated information or make such aggregated information generally available. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy. We will maintain and use de-identified information in anonymous or de-identified form and we will not attempt to reidentify the information, unless required by law.

2. As noted above, we may use Content you provide us to improve our Services, for example to train the models that power our AI-Coach.

18. How can you access or correct your information?

1. 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.

2. 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.

3. 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.

4. 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.

5. 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.

19. 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.

20. The Australian Privacy Act and Privacy Principles

Our Privacy Policy is intended to implement the Australian Policy Principles. 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.

21. Further Information

1. Further information about the application of the Privacy Act can be found at the website of the Office of the Australian Information Commissioner. 

2. If you require a copy of the Integral Privacy Policy in another format please contact us.

3. 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

22. Special provisions for EU persons (GDPR compliance)

As indicated above, if we know you are located in the European Union, we will comply with the GDPR in relation to your personal information, meaning that:

You, as a relevant “data subject”, may have the following rights:

• A right to access, update or delete information in our possession.

• A right to rectification, i.e. to request us to correct any information that is inaccurate or incomplete.

• A right to object, i.e. a right to object to our processing of the information.

• A right of restriction, i.e. a right to request that we restrict the processing of the information in certain ways.

• A right to data portability, i.e. a right to be provided with a copy of the information in a structured, machine-readable and commonly used format.

• A right to withdraw consent, i.e. a right to withdraw consent to us processing the information.

Contacting Us & Our Data Protection Officer:

If you claim that your privacy rights have been affected by us, we may ask you to verify your identity and location before we respond to that claim. We will use our best endeavours to respond to all inquiries about your Personal Information quickly and courteously. You may have the right to complain to your regional Data Protection Authority about our collection and use of your Personal Information, and you are encouraged to check with your local Data Protection Authority to learn what your rights are.

Please direct all inquiries to our Data Protection Officer via this email address: admin@integral.org.au

Our Details:

Should you need to contact us regarding any contractual, legal or privacy issues our business and contact details are:

Trading Name: Integral
Legal Name:     Integral Development Associates Pty Ltd
ABN:                  41 008 738 672
Email:               admin@integral.org.au
Web:                  www.integral.org.au
Telephone:        +61 8 9242 8122
Postal:              PO Box 5766, St Georges Terrace, WA, 6831
Address:           Level 3, 88 William Street, Perth, Western Australia 6153