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Dated: 10 June 2021
- The Privacy Act 1988
- What is personal information?
- How we collect personal information,
- What personal information do we collect and hold?
- Why we collect, hold, use and disclose personal information
- What happens if we can’t collect personal information,
- Accessing and correcting your personal information,
- How you can complain about a breach of privacy,
- How we share your information
- Direct marketing,
- Cross-border disclosure of personal information,
- Storage and retention of your information,
- Security – how we store and protect your information,
- The sale or transfer of our business or assets.
THE PRIVACY ACT 1988
We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Commonwealth) (the Privacy Act).
WHAT IS PERSONAL INFORMATION?
When used in this policy, the term ‘ personal information’ has the meaning given to it in the Privacy Act. In general terms, it is any information that can be used to personally identify you. This may include, but is not limited to, your name, age, gender, postcode and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card, direct debit or PayPal account information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
HOW WE COLLECT PERSONAL INFORMATION
We collect your personal information directly from you unless it is unreasonable or impractical to do so.
We do this in ways including:
- when you complete create an account either has a registered user or as a member.
- through your access and use of the network, including emails and messages sent by you to us;
- through someone else who has provided us with your information (e.g. a gift subscription);
- during conversations between you and our representatives; and
We may also collect personal information from third-parties including:
- agents, contractors and business partners,
- third-party companies, like Facebook, who share your information with us in order to make your online experience more seamless,
- third-party companies such as credit reporting agencies, law enforcement agencies and other government entities,
- advertisers; and,
- mailing lists.
WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?
Information you give us
We may collect the following types of personal information which you have directly given us:
- mailing or street address,
- email address,
- telephone number,
- age or birth date,
- details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries,
- any additional information relating to you that you provide to us directly or indirectly through our websites or applications or otherwise; and,
- information you provide to us through our service center, customer surveys or discussions with our representatives from time to time.
Information you post
The product is designed to enable you to communicate with others.
Any information or content you post when using the product becomes public information and is subject to redistribution by us and other third-parties. There is no expectation of privacy when posting content or participating in interactive forums.
We have no control over how those users may use the information you make public.
You should exercise caution and discretion when deciding to disclose your personal information in a submission or posting
Information given to us by third-party’s
Additionally, we may collect information about you which we have received from third-parties. For example if you access our websites or applications through a third-party connection or log-in, such as Facebook Connect, that third-party may pass some information about your use of its services to us. This information may include, but is not limited to;
- Your user ID associated with your third-party account (for example, your Facebook user ID).
- Any information you have permitted the third-party to share with us.
- Any information you have made public in connection with the third-party provider.
- If you have allowed us to access your ‘friends list’ held by the third-party provider, we will be given access to that list as well as your friends’ user IDs and your connection to those friends. We may store those details to make your experience more enjoyable and social and to allow you to invite your friends to use or join the product. We will also be able to let you know when one of your friends joins the product.
We may collect additional information from you if you access the product through a mobile device. For example, we may collect your unique device identifier, your device’s operating system, the name of your mobile carrier and network, details of your location, and with your permission your GPS/geo-location and billing information.
The degree to which your location can be identified depends on the device you are using (e.g. smart phone, tablet, laptop or desktop).
We collect this information in order to provide you with the best level of service.
If you are unable location services we may collect location data periodically as you use, or leave open your access to the network. We may also use this data internally or in conjunction with our third-party service providers to customise your experience and provide offers that may be relevant to you. Depending on the platform you use (e.g. Apple OSX iOS, Windows, Android etc), to access the network you may be able to control, from within your devices settings, whether you wish to share your location data with us.
WHY WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
The primary purpose for which we collect information about you is to enable us to perform our business activities and functions and to provide the best possible quality of customer service. We collect, hold, use and disclose your personal information for the following purposes:
- to provide products and services to you;
- to provide you with news, information or advice about our existing and new products and services;
- to communicate with you including by email, mail or telephone;
- to manage and enhance our products and services;
- to personalise and customise your experience;
- to provide you with access to protected areas of our websites;
- to conduct competitions or promotions on our behalf or that of selected third-parties;
- to verify your identity;
- to provide as part of business data to third-parties if you have authorised us to do so;
- to conduct business processing functions for operation of our websites or our business;
- for our administrative, marketing (including direct marketing), promotional, planning, product/service development, quality control and research purposes, or those of our contractors or external service providers;
- to provide your updated personal information to us, our contractors or external service providers;
- to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and/or
- as required or permitted by any law (including the Privacy Act).
WHAT HAPPENS IF WE CAN’T COLLECT YOUR PERSONAL INFORMATION?
If you do not provide us with the personal information described in this policy, some or all of the following may happen:
- we may not be able to provide you with the products or services you requested, either to the same standard, or at all (for example, if you do not register as a member of a website, you will not be able to access features or services that are reserved for registered users or members only);
- we may not be able to provide you with information about products and services that you may want, including information about discounts sales or special promotions; or
- we may be unable to tailor the content of our network your preferences and your experience of our websites may not be as enjoyable or useful.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You may request access to any personal information we hold about you at any time by contacting us (details above). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We will not charge for simply making a request and will not charge for making any corrections to your personal information. If you make an access request, we will ask you to verify your identity. There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may ask us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.
Members of our websites will generally be able to access and update their membership details online. We request that you keep your information as current as possible so that we may continue to improve our service to you.
HOW YOU CAN COMPLAIN ABOUT A BREACH OF PRIVACY
We have a formal procedure for investigating and dealing with privacy breaches. Once the Privacy Officer receives a complaint in writing the Privacy Officer will commence an investigation. The investigator will endeavour to determine whether there has been a breach, the nature of the breach and how it occurred. We may contact you during the process to seek any further clarification if necessary. If a breach is found, the Privacy Officer will escalate the matter to management so that the process can be rectified to prevent any further breaches from taking place. We will also contact you to inform you of the outcome of the investigation. We will endeavour to resolve all investigations within a reasonable time.
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
HOW WE SHARE YOUR INFORMATION
We may disclose your personal information to:
- our employees, related bodies corporate, contractors or external service providers for the operation of our websites or our business, fulfilling requests by you, and otherwise provide products and services to you,
- our existing or potential agents, business partners or joint venture entities or partners,
- our sponsors, or promoters of any competition that we conduct or promote via our services,
- specific third-parties authorised by you to receive information held by us,
- the police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator, for example, if we have reason to suspect that you have committed a breach of any of our Terms and Conditions of Use, or have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary; and,
- as required or permitted by any law (including the Privacy Act).
If you do not wish to receive cookies, you should set your browser so that your computer or device does not accept them.
We may collect information from you in response to a survey.
We generally use this information to get your feedback, report statistics, analyse trends, administer our services, diagnose problems and improve the quality of the network. To the extent this information does not constitute personal information, because it does not identify you or anyone else, the Australian Privacy Principles do not apply and we may use this information for any purpose and by any means whatsoever.
If you do not want us to collect information provided by you during the course of a survey, then refrain from completing the survey.
We may send you direct marketing communications and information about products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS or email, in accordance with applicable marketing laws, such as the Spam Act 2004 (Commonwealth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
Offers and Promotional Messages.
We may also use your email address or mobile phone number to send you updates and communications about our products and Services or other messages, such as newsletters, text messages, information about when users check-in, changes to features of the network, or special offers.
You will be given the opportunity, in any promotional email or text message that we send to you to opt out of receiving such messages in the future.
Our application Services include a function that allows us to use push notifications to send you updates, communications, and other messages about the network.
To opt out of getting these push notifications or other messages you must terminate the applicable Service. We do not send promotional messages about other products or services through these push notifications.
We may use the information you have given us about your interests, and other profile or personal information, to develop and display tailored third-party content and advertising.
In addition, at any time, you may opt-out of receiving marketing communications from us by contacting us (details above) or through the privacy settings on the website or application you are using.
If you receive communications from us that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact us using the details provided above.
CROSS-BORDER DISCLOSURE OF PERSONAL INFORMATION
The product operates in a number of international jurisdictions including Australia, New Zealand, the USA and the UK.
As a result, your personal data may be transferred, stored and processed in another country in which we or our subsidiaries, partners or agents maintain facilities. These data processors, acting under our instructions, may be engaged in, among other things, the fulfilment of your information requests and the provision of support tools and services on the product. They may also help us maintain the integrity and security of the product, including emails and messaging platforms on the product.
STORAGE AND RETENTION OF YOUR INFORMATION
SECURITY – HOW WE STORE AND PROTECT YOUR INFORMATION
We will take all reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorised access, including by means of firewalls, password access, secure servers and encryption of credit card transactions.
If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.
In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
Our website may contain links to other websites operated by third-parties. We make no representations or warranties in relation to the privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third-party website. Third-party websites are responsible for informing you about their own privacy practices.
THE SALE OR TRANSFER OF OUR BUSINESS OR ASSETS
If the product, or any part of it, is sold or disposed of as a going concern, whether by merger, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, our users’ personal information may be one of the assets sold or merged in connection with that transaction.
Information about our users may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, and support or funding.