Privacy Policy

Introduction

Welcome to the Touching Base Privacy Policy. 

The terms: 

• “we,” “us,” “our,” and “ours” means Touching Base Incorporated (ABN 18 213 997 639) ; and 
• “you,” “your,” and “yours” refer to the user or viewer of the Website or user of our Services. 

In acknowledging that sexual and physical intimacy are core to the human experience, the Touching Base Inc vision is for a societal culture where people with disability can freely choose and easily access sexual supports, including the services of sex industry professionals, to meet their sexual and physical intimacy needs. 

Touching Base Inc is committed to protecting the privacy of personal information which the organisation collects, holds, uses and discloses. 

This Privacy Policy applies to all personal information and data collected by us in the conduct of our business and about all users of https://www.touchingbase.org/(Website) and the services available from Touching Base Inc and on the Website (Services). 

This Privacy Policy explains the categories of personal data we may collect about you, it also explains the purpose of processing your data and how we keep it safe.

If you have any questions or concerns about our use of your personal information or this privacy policy, then please contact us using the details set out in the ‘How to Contact Us’ section. 

This Privacy Policy applies only to our collection of personal information and your use of our Website. Our Website may contain links to other websites. We have no control over how your personal information is collected, stored, or used by other persons or websites and we advise you to check the privacy policies of any third party or their websites before providing any personal information to them.

The types of personal information that we collect about you, or someone providing information on your behalf, will depend on the interaction you have with us. For example, if you: 

• Become a member,we may collect your name, email, phone number, postal address, whether you are a sex worker or operator of commercial sex services premises, the amount and frequency of your membership fee, and payment details. 
• Submit a Referral Request Form, we may collect your name, email address, phone number, general location, and gender. We also gather personal information to assist us to make referrals to the most appropriate sex service providers, depending on the personal preferences of the potential client.
• Register forProfessional Disability Awareness Training (PDAT),including for its waitlist, we may collect your working name, email address, phone number, payment details and details of your work experience. 
• Register forService Provider Awareness Training (SPAT), including for its waitlist, we may collect your name, email address, phone number, details of your role, payment details and current work status. 
• Purchase items from our shop, we may collect your name, email address, phone number, postal address and payment confirmation.
• Visit our website, we use Google Analytics 4 to collect information about how visitors use our website, utilising first-party cookies to distinguish unique users and sessions for the purpose of improving our services.
• Apply for a role at Touching Base, we may collect the information you include in your application, including your cover letter, resume, contact details, and referee reports. 
• Make a donation or become a Touching Base sponsor,we may collect your name, email address, the amount and frequency of your contribution, and payment details. Touching Base does not retain your credit card information or other financial details, but third parties we use (such as Stripe) may.
• Make a complaint, we may collect your name, email address, and the details of your complaint. 
• Make a payment online, we may collect your name, email address, and the details of what you have paid for. Your card numbers are not stored on our servers. They are processed through a third party (Stripe) and we can’t access this information. We do however know when you paid, what you purchased, and at what time. “Payment processing for memberships and donations is handled by Stripe. When you make a payment, Stripe collects your payment method information (such as credit or debit card number) and transaction history.

We may collect information that is sensitive information (a particular type of personal information under the Privacy Act 1988 (Cth) (Act)) if it is relevant to our functions and activities. Sensitive information includes information about a person’s ethnic origin, sexual orientation and practices, political opinions, health, religious or philosophical beliefs and relevant criminal history. If we request sensitive information, we hold ourselves to strict requirements in relation to it including to only collect and use sensitive information with consent and for the purposes for which it was collected. 

Third Party Personal Information 

You might also need to provide us with information about other persons (e.g., a referee). If so, please ensure you: 

• are authorised to do so; and 
• agree to inform that person who we are and that we will use and disclose their personal information as set out in this policy, and that they can gain access to their personal information. 

You further acknowledge and agree we may send that person a notice that we have collected and hold that person’s personal information. 

The main purposes for which we collect, hold, use and disclose personal information are set out below: 

• confirming your identity; 
• providing referral services to clients with disability; 
• delivering training and providing certificates of attendance; 
• maintaining membership records; 
• seeking donations; 
• tracking attendance of fundraising events; 
• communicating with you; 
• complying with legislative and regulatory requirements; and 
• performing administrative functions, including accounting, risk management, record keeping, archiving, analytics and statistics for systems development and staff training. 

If we request personal information and you choose not to or you cannot provide us with that information, we may be unable to provide you with the relevant Services you have requested or need. 

From time to time we will use the personal information we collect from you to inform you of products and services that we consider may be of interest to you. 

If you elect to follow or link-in with us via our web pages or opt to follow us on Twitter, Facebook or other social media or networking platforms, we will infer you are open to receiving direct marketing through these mediums. 

If you do not wish to receive direct marketing information you can tell us at any time by contacting us using the details set out in the ‘How to contact us’ section or using the unsubscribe function in the relevant electronic communication. 

Who we disclose your personal information to 

We can, and usually will, disclose personal information where: 

• you have consented to the disclosure; 
• you would reasonably expect that your information will be disclosed as a part of our providing Services to you; or 
• the disclosure is authorised or required by or under law, including circumstances where we are under a contractual or lawful duty of care to disclose information. 

However, we do not sell or rent your personal information or data to any third parties for any purpose. The only uses of your personal information are those highlighted in this policy. Users are the only owner of their personal information or data and can request modification or deletion at any time. 

Embedded content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, payment systems etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

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.

Third Party	Purpose	Data Category	Policy Link
Stripe	Payment Processing	Financial /Contact	View Policy
Google Analytics 4	Site Analytics	Usage /Device Info	View Policy
Vimeo	Video Hosting	Usage /Technical Info	View Policy

Touching Base does not store your full credit card details. This information is provided directly to Stripe, whose use of your personal information is governed by their Privacy Policy

If we need to disclose your information to recipients or organisations based outside of Australia to provide Services to you, then wherever possible, we deal with such third parties who are bound by the provisions of the Act and Australian Privacy Principles (APPs). 

We need to share your personal information and data with third parties to meet legal and regulatory obligations and provide our Services and fulfil our contractual obligations to you. Whenever personal information or data is provided to these parties it remains our property and is only used for the specific purpose for which it is supplied, or a purpose related to that specific purpose as permitted under the Act or applicable law. 

Examples of third parties to whom we may disclosure personal information you provide include: 

• regulatory bodies, government agencies, law enforcement bodies and courts but only if we are required by law to do so; 
• external payment systems operators; 
• providers and users of our Services to connect individuals wishing to receive or provide external services; 
• your executor, administrator, trustee, guardian or attorney; or 
• your referees.

How we collect personal information 

How is personal information collected? 

We collect personal information via: 

• our website; 
• online and paper forms; 
• electronic and paper correspondence; 
• telephone; and 
• our social media channels and accounts. 

Collection of personal information from you 

Where possible, we will collect your personal information directly from you, your authorised representative or third parties you have authorised us to contact such as a referee or previous employer. 

If we receive your personal information from another party, we will contact you, if we have enough information to do so and it is reasonable in the circumstances. Some exceptions to advising you may arise where: 

• you have provided consent or reasonably expect the collection to occur;
• the collection is required or authorised by or under law; 
• the collection is for purposes of an investigation or providing services to you; or
• the collection is for the purposes of litigation or legal advice. 

How we hold your personal information 

We hold personal information in digital and hardcopy formats. Paper copies are stored in lockable cabinets or archived in boxes and stored in a secure location. The security of your personal information is important to us and we use the recommended industry standards when storing and dealing with your personal information. We use a secure server using encryption technology to process any financial transactions. 

The steps we take to secure the personal information we hold include: 

• website protection measures (such as encryption, firewalls and anti-virus software); 
• access restrictions to our computer systems (such as login and password protection); 
• restricted access to our office premises; and 
• staff/volunteer training and implementation of workplace policies and procedures that cover access, storage and security of information. 

We take reasonable steps to destroy or permanently de-identify personal information when it is no longer required for any purpose for which it may be used or disclosed. However, it is not always practicable to destroy or de-identify electronic data. Where it is not reasonable to destroy or permanently de-identify personal information in electronic form, we will take reasonable steps to prevent inadvertent access to it.

How you can access and correct your personal information 

How you may access and correct personal information we hold about you 

You have a right to request changes to, or deletion of, your personal information that we hold. We will provide you with a copy of the information we hold as requested, if it is reasonable and practicable to do so. There may be a moderate charge for us to provide access and there may be instances where we refuse your request such as: 

• providing access would pose a serious and imminent threat to the life or health of any individual; 
• providing access would have an unreasonable impact on the privacy of other individuals; 
• the request for access is frivolous or vexatious; 
• the information sought relates to existing or anticipated legal proceedings between you and us and that information would not be accessible by the process of discovery in those proceedings; 
• providing access would be unlawful; 
• denying access is required or authorised by or under law; or 
• providing access would be likely to prejudice an investigation of possible unlawful activity. 

If we deny your request for access, we will, where permitted by law, provide you with reasons for that denial. 

You may request corrections to any of your personal information that we hold to ensure the information is accurate, up to date, complete, relevant and not misleading. 

Verifying identity 

We must be satisfied that you are seeking access to or correction of your own personal information. We may ask you to provide verification of your identity. This process is free of charge. 

How to request access or correction 

If you wish to access or correct personal information we hold about you please contact us. Details of how to contact us are in the ‘How to contact us’ section.

Touching Base Inc recognises that individuals have the right to confidentiality and privacy and Touching Base Inc respects that right. You have the right to contact us anonymously or by using a pseudonym unless there is a legal requirement that prevents this. 

You should be aware that there may be instances where we cannot respond to you or properly investigate a complaint if you do not provide contact details or sufficient information. 

Comments

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.

An anonymised 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.

Media

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.

Cookies

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.

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.

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.

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.