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Privacy Policy Statement

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1. Purpose of this Policy

The Council of Small Business Organisations Australia (COSBOA) and 89 Degrees East (“we”) deliver the Cyber Wardens initiative.

We are committed to protecting your privacy when you interact with us, our content, products, or services. This policy explains how we collect, use, and disclose information about you or your use of our content, products, or services.

This policy complies with the Privacy Act 1988 (Cth).

Update Notice: This  Cyber Wardens Privacy Policy Statement is posted on 8th April 2024 and is effective 8th April 2024 . Your continued participation in the  Cyber Wardens program automatically constitutes your acceptance of this updated Statement. This updated Cyber Wardens Privacy Policy Statement completely replaces all previous versions.

2. What is personal and sensitive information?

‘Personal Information’ and ‘Sensitive Information’ are defined under the Privacy Act. 

Personal information is information or an opinion that identifies an individual. 

Examples of personal information we collect include names, addresses, email addresses, and phone numbers.

‘Sensitive information includes information about an individual’s racial or ethnic origin, political opinions, professional or political or religious affiliations or memberships, sexual orientation or practices, criminal record, health, genetics and/or biometrics.

Examples of sensitive information we collect include gender and whether you identify as First Nations.

3. How we collect personal information

The  three main circumstances in which we collect personal and sensitive information about you are:

(a) when you provide it to us:

We may collect personal information you choose to give us or which may be required to access a particular service. For example, information is collected via online forms when you enrol to be part of Cyber Wardens, subscribe to our newsletters, enter competitions or participate in one of our events.

(b) automatic collection in relation to your use of our digital services:

Some personal information is automatically collected due to your visit to our Cyber Wardens websites. We collect information about your use of our websites and training portal to improve your experience and our content. Our websites use technologies such as cookies and analytics, which track where a user goes on the site and which content they access. We may track your IP address to see where our site users are located, but we will not seek to identify you.

(c) when a third party provides it to us on your behalf:

We use third-party software to collect information about your interaction with our website. When you visit our Cyber Wardens websites, your web browser automatically sends certain information to these software providers. This policy covers each of these instances of personal information collection in more detail. 

(d) when using social media sites to access or share Cyber Wardens content:

When using social media sites to access or share Cyber Wardens content, you are exposed to the various tracking and analytic technologies applied by third parties. These third parties may collect personal and sensitive information.

4. Purposes for which we collect, use and disclose personal and sensitive information

The purposes for which we collect, use and disclose personal and sensitive information include:

  • to provide our products and services;
  • to improve our products and services,
  • to tailor and enhance user experience;
  • to manage our relationship with users and
  • to meet Commonwealth of Australia grant reporting requirements.


Unless we are permitted to do so by law, we will not send you unsolicited direct marketing emails without your prior consent. We will always give you the ability to opt out of further communications.

We may occasionally send you an email on behalf of our partners with a direct offer or information about an appropriate service or product.

We may send you electronic communications for account administration purposes when you register with the Cyber Wardens e-learning program.

We may use personal information collected from you to provide you with direct marketing material, updates regarding our website and information in the form of a newsletter. This will only apply if you have registered to enrol or subscribed to such publications by registering your details with us. If you wish to stop receiving any such publications, let us know either by email or unsubscribe at any time. We will action your request as soon as possible.

Individual profiles and company details are not used for any other purpose. Details are only supplied to third parties when it is required by law, for the supply of goods or services that you have purchased, or to help protect our copyright, trademarks and other legal rights.

5. Storage and security of your information

Your personal information is stored in a manner that reasonably protects it from misuse and loss and unauthorised access, modification or disclosure.

When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information.

6. Third parties

We may disclose personal information that we collect to our technology service providers, including internet service providers, cloud hosting service providers, software suppliers, maintenance and support service providers and security services on a confidential basis so that they can provide services to us.

We may include links to third-party content on our website and in other electronic communications. We do not have any control over the privacy practices of those third parties. Please check the website of each relevant third party for details of their privacy policies. 

We sometimes give you the option to use products or services provided by other entities, such as social media. You should read each service’s privacy policy and terms and conditions carefully before deciding whether to accept them. You should also be careful to ensure that you only post information online if you are happy for it to be, and to remain, publicly available.

7. Automatic collection by third-party software vendors

We use several online tools to deliver the Cyber Wardens program, which includes the websites and, newsletters and social media pages. 

We also use third-party tools that measure your use of services to help us improve your experience, maintain the services, and formally report on this program.

Third-party software that we (or our Suppliers)  use includes: 


Please review their privacy policies to learn how these third-party software vendors handle your personal information. Information that Cyber Wardens may share with third parties includes:

  • personal and sensitive information provided to us via forms to  enrol to Cyber Wardens training or subscribe to other services
  • network location and IP address
  • the date and time of your visit to our website/s
  • the types of web browser (e.g. Internet Explorer, Google Chrome, Safari) and operating system (e.g. Windows 10, Mac OS X, etc.) you are using
  • Flash version, JavaScript support, screen resolution and screen colour processing ability
  • referring site details (such as the URL that you came through to arrive at our website)
  • page visited and the time spent on each page
  • documents downloaded and search terms used
  • which forms accessed on our website
  • unique device identifier
  • cookies and data about which page you visited
  • device information, hardware model, operating system information, app version, app usage, debugging information, browser information
  • geo-location information (if enabled by the user)
  • may assign a unique user identifier.


The information we disclose to some of our third-party vendors may travel outside Victoria and Australia.

Third-party software vendors may alter how they collect and handle personal information at any time.

8. Use of Cookies, Web Beacon, Local Storage, and Other Technologies Across our digital services

What are these technologies?

A “cookie” is a small data file downloaded to your computer or device that lets our digital service gather and store information. Your web browser then sends these cookies back to the website or application on each subsequent visit so they can recognise your IP address. 

A “web beacon” is a small amount of code on a web page, application or email notification that allows the site to record simple actions of the user. For example, whether they have viewed a piece of content. These requests can gather information from a website, such as your computer’s  IP address, the time the material was viewed, the type of browser used, and the existence of cookies previously set by that server. This information is available to any web server you visit; these beacons represent a convenient method of gathering simple statistics and managing cookies.

“Local storage” is a technology that allows a website or application to store information locally on your computer or device.

Why do we use these technologies?

We use these technologies to deliver, measure and improve our website and content. We typically use these technologies to target our promotional activities and access audience analytics, which helps us improve our content and accessibility.

9. Can I opt out of the collection of web analytics data?

You cannot opt out of the automatic collection of information used for analytical purposes. However, you may turn off cookies or delete any individual cookie. If you choose to turn off cookies, our websites may not function fully; your ability to browse, read, and download information contained on our websites may be impaired. However, you may still access our services by contacting our office via other methods such as telephone, email, or mail.

You can enable a “Do Not Track” setting on your browser to help protect your privacy. When Do Not Track is turned on, your browser will send a Do Not Track request to the sites you visit and the third parties whose content is hosted on those sites. However, sending a Do Not Track request does not guarantee privacy protection. Many websites will still collect and use your browsing data following their privacy practices. 

Instructions on how-to enable the Do Not Track setting are provided by browser:

You can also opt out of tracking and website analytics using a Google browser plug in.

10. Access to your Personal Information

You have the right to request access to personal information that we hold about you. Cyber Wardens will handle access requests in accordance with the Freedom of Information Act 1982 (Cth) or Privacy Act 1988 (Cth).

You also have the right to request the correction of your personal information. We will take reasonable steps to make appropriate corrections to personal information so that it is accurate, complete and up-to-date.

 To seek access to or correct your personal information, please write to us via email:

11. Making a complaint

We welcome feedback about privacy issues and promptly attend to all questions and complaints. Please  get in touch with us using the following  details: 

By email:

By mail: Cyber Wardens Privacy Officer

5/30 Collins Street

Melbourne, VIC, 3000

March 2024

If Cyber Wardens takes more than 30 days to respond to your privacy complaint, or if you are dissatisfied with the outcome, you can lodge a privacy complaint with the  Office of the Australian Information Commissioner (OAIC) using the following details: 

By phone: 1300 363 992 

Via their website:

12. Updates to this policy

This privacy policy was last updated on 8 July 2024. Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.