Privacy
Privacy Policy
1. About this policy
Padayon Communications ("Padayon", "we", "us", "our") respects your privacy and is committed to handling your personal information openly and responsibly.
Padayon Communications is the practice of Domingo "Jim" Caro III, a strategic communication consultancy based in Perth, Western Australia, serving clients across the Asia-Pacific.
ABN: 66 369 541 556
Email: info@padayoncommunications.com
Location: Perth, Western Australia (Australian Western Standard Time, GMT+8)
This policy explains what personal information we collect, why we collect it, how we use and protect it, and the choices and rights you have. It applies to information collected through our website (padayoncommunications.com), our newsletter, and our direct dealings with clients, partners and contacts.
2. The laws we follow
We handle personal information in accordance with the Privacy Act 1988 (Cth) and the 13 Australian Privacy Principles (APPs), the Spam Act 2003 (Cth) for electronic marketing, and the Notifiable Data Breaches scheme.
Where we deal with individuals located in the European Union, the European Economic Area or the United Kingdom, we also seek to meet the standards of the EU General Data Protection Regulation (GDPR) and the UK GDPR. Section 13 sets out the additional rights those individuals have.
3. What personal information we collect
We only collect personal information that is reasonably necessary for our work. Depending on how you interact with us, this may include:
- Contact and enquiry details: when you complete an enquiry form or email us, your name, organisation, email address, the service area you are interested in, and the content of your message.
- Newsletter details: when you subscribe to The Field Dispatch, your email address (and your name, if you provide it).
- Correspondence: records of our communications with you, including emails and messages exchanged in the course of an engagement.
- Client engagement information: information necessary to scope, deliver and invoice consulting work, which may include professional contact details and information you share with us as part of a project.
- Website usage information: limited technical information collected automatically when you visit our site, such as your IP address, browser type, pages viewed and referring page. See Section 9 on cookies and analytics.
Sensitive information. We do not seek to collect sensitive information (such as health, racial or ethnic origin, or political opinions) and ask that you do not send it to us through the website. If sensitive information is necessary for a specific engagement, we will collect it only with your consent and handle it with additional care.
4. How we collect personal information
We collect personal information:
- directly from you, when you contact us, complete a form, subscribe to the newsletter, or work with us;
- automatically, through standard website and analytics technologies; and
- occasionally from third parties or public sources (for example, a professional referral, or publicly available professional contact details) where relevant to a potential engagement.
Wherever it is reasonable and practicable, we collect personal information directly from you.
5. Why we collect and use personal information
We use personal information to:
- respond to your enquiries and discuss potential work;
- provide, manage and invoice consulting, advisory, training and speaking services;
- send you our newsletter and related updates, where you have asked to receive them;
- maintain our business records and meet legal, tax and contractual obligations; and
- improve our website and understand how it is used.
We will not use your personal information for an unrelated purpose without your consent, unless permitted or required by law.
6. The newsletter and direct marketing
If you subscribe to The Field Dispatch, we will send you newsletter content and occasional updates about our services and resources. We send marketing emails only to people who have asked to receive them.
Every marketing email includes a simple way to unsubscribe, and we act on unsubscribe requests promptly, consistent with the Spam Act 2003. You can also unsubscribe at any time by emailing info@padayoncommunications.com. Unsubscribing from marketing does not stop essential, non-marketing communications about an active engagement.
7. Who we share personal information with
We do not sell your personal information. We share it only where necessary to run our business, and with providers who are bound to protect it. Our key service providers are:
- Website hosting and delivery: Netlify, which builds and serves our website and processes enquiry form submissions. Netlify is based in the United States.
- Additional hosting and domain services: Bluehost, which provides domain services on Australian (Sydney) servers.
- Content management: GitHub, which we use to publish and manage articles on our website.
- Newsletter platform: Beehiiv, which manages newsletter subscriptions and delivery. Beehiiv is based in the United States.
- Email and productivity: Google Workspace, which provides our email (info@padayoncommunications.com) and document storage.
- Website analytics: Google Analytics, which helps us understand how the site is used. This involves Google as a provider, based in the United States.
We may also disclose personal information to professional advisers (such as our accountant) and to government agencies, regulators or others where required or authorised by law.
8. Sending information overseas
Some of our service providers store or process information outside Australia. Our website hosting and delivery (Netlify), newsletter platform (Beehiiv), email (Google Workspace) and analytics (Google Analytics) are provided by companies based in the United States. By providing your information through these services, for example by subscribing to the newsletter or submitting an enquiry, you consent to it being handled overseas.
Where we disclose personal information overseas, we take reasonable steps to ensure it is handled consistently with the Australian Privacy Principles, and we choose reputable providers with their own privacy and security commitments.
9. Cookies and analytics
Our website uses cookies and similar technologies to help the site function and to understand how visitors use it. Cookies are small files stored on your device. Most browsers let you refuse or delete cookies through their settings, though doing so may affect how some parts of the site work.
Our website uses Google Analytics to collect aggregate, largely non-identifying information about how the site is used, such as pages viewed and general location. Google Analytics uses cookies to do this, and information collected is handled in accordance with Google's privacy practices.
You can opt out of Google Analytics tracking using Google's browser opt-out tools, and you can refuse or delete cookies through your browser settings as described above.
10. How we protect your information
We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. These include secure, reputable hosting and platforms, restricted access, and keeping our systems up to date. No method of transmission or storage is completely secure, but we work to protect your information and to respond quickly if a problem arises.
11. How long we keep your information
We keep personal information only for as long as it is needed for the purposes described in this policy, or as required by law (for example, tax and business record-keeping obligations). When information is no longer needed, we take reasonable steps to delete or de-identify it. You can ask us to remove your information at any time (see Section 12).
12. Accessing and correcting your information
You have the right to ask us:
- what personal information we hold about you;
- to access that information; and
- to correct it if it is inaccurate, out of date or incomplete.
To make a request, email info@padayoncommunications.com. We will respond within a reasonable time. There is normally no charge to access your information, and we will tell you in advance if any cost applies. We may need to verify your identity before acting on a request.
13. If you are in the EU, EEA or United Kingdom
If you are located in the EU, EEA or UK, you may have additional rights under the GDPR or UK GDPR, including the right to access, correct, erase, restrict or object to the processing of your personal data, and the right to data portability.
Where the GDPR applies, we rely on the following lawful bases: your consent (for example, for the newsletter), the performance of a contract (delivering services you have engaged us for), and our legitimate interests in running and promoting our consultancy in a way that does not override your rights. You can withdraw consent at any time. To exercise any of these rights, contact us at info@padayoncommunications.com. You also have the right to complain to your local data protection authority.
14. Data breaches
If a data breach occurs that is likely to result in serious harm to anyone whose personal information we hold, we will respond in line with the Notifiable Data Breaches scheme under the Privacy Act, taking steps to contain the breach and, where required, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).
15. Automated decision-making
We do not use automated decision-making or artificial intelligence to make decisions that produce legal or similarly significant effects about you. If this changes, we will update this policy to explain how it works and what it means for you, consistent with our obligations.
16. Making a complaint
If you have a concern about how we have handled your personal information, please contact us first at info@padayoncommunications.com so we can try to resolve it. We take complaints seriously and will respond within a reasonable time.
If you are not satisfied with our response, you can contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au or 1300 363 992. If you are in the EU, EEA or UK, you may also complain to your local data protection authority.
17. Children's privacy
Our website and services are directed at professionals and organisations, not children. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take steps to delete it.
18. Changes to this policy
We may update this policy from time to time to reflect changes in our practices or the law. The current version will always be available on our website, with the "last updated" date at the top. We encourage you to review it periodically.
19. Contact us
Padayon Communications
Email: info@padayoncommunications.com
ABN: 66 369 541 556
Perth, Western Australia