- how and when the Company collects personal information;
- how the Company uses and discloses personal information;
- how the Company keeps personal information secure, accurate and up-to-date;
- how an individual can access and correct their personal information; and
- how the Company will facilitate or resolve a privacy complaint.
The Company recognises the importance of protecting the privacy of personally identifiable information collected about our customers.
1. Personal information
- The Act defines ‘personal information’ to mean information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is reasonably identifiable, from the information or opinion.We collect personal information when we provide our services to you. Generally we will tell you why we are collecting information when we collect it and how we plan to use it or these things will be obvious when we collect the information.We usually collect personal information directly from you although sometimes we may use agents or service providers to do this for us. We may also acquire lists from other sources, both from other companies and from other public documents.It is your responsibility to ensure your personal information held by the Company is accurate, up to date and complete.
2. Collection of information
2.1 What kind of personal information does the Company collect and hold?
The kinds of personal information that we collect will vary depending on the type of interaction with you and the purpose for collection but may include:
- your name, address and other contact details (including telephone number);
- your email address;
- your date of birth;
- transaction details relating to any payment that you have made to us or that have been made on your behalf;
- credit card details, if you make a payment to us;
- your username and password to access your account you may have with us;
- any preferences that you select; and
- any other personal information which may be required in order to facilitate your dealings with us.
2.2 How does the Company collect personal information?
Generally, we collect personal information when you:
- register as a member;
- participate in a Company survey, competition, promotion or other marketing campaign;
- indicate that you wish to receive news, offers or other marketing material from the Company;
- make an enquiry or a complaint; or
- have other dealings with us.
‘Cookies’ are small packages of data generated by a website that are transferred and saved to an individual’s hard drive. Its purpose is to remember information about you, similar to a preference file created by a software application. If you use our Website, we may utilise cookies to enable us to monitor traffic patterns and to serve you more efficiently. A cookie does not identify you personally but may identify your internet service provider or computer. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance.
3. Use of information
3.1 What are the purposes for which the Company may collect, hold, use and disclose person information?
Generally, the Company only uses personal information for the primary purpose for which we have collected it, or for another closely related secondary purpose. Our potential uses of personal information which the Company collects (and for which you consent to us using your personal information for) may include:
- to process and fulfil your advertising or other service requirements;
- to get a better understanding of you, your needs, your behaviours and how you interact with us in order to identify ways in which we can provide you with a better service, or enhance your experience of our website and mobile site or other services;
- managing your dealings with us;
- so that we can promote our products and services to you and the products and services of third parties with whom we deal;
- to allow our related companies to promote their products and services to you and those of their partners;
- for business research and development of new products and services;
- to facilitate the competitions, special offers and promotions that we or our partners may run;
- displaying content and advertising that is customised to your interests, preferences and experiences, including through online targeted marketing, data and audience matching and market segmentation activities;
- verifying your identity;
- so that we can respond to enquiries and complaint handling;
- for the purpose of data analytics and predicting trends;
- marketing services in connection with the products and services we provide; and
- to comply with our legal and regulatory obligations and enforce our legal rights.
Sometimes the Company will produce aggregated data. The Company may also receive aggregated data from its third party suppliers and contractors or business customers. This aggregated data does not identify individuals. The Company uses, and may combine, the aggregated data it produces and receives for research purposes and in connection with products and services we provide to our business clients.
From time to time, there may be other purposes for which we collect, hold, use and disclose your personal information. We will tell you about these at the point of collection.
3.2 Direct marketing and research
As set out above, the Company may use personal information about you for marketing and research purposes (Direct Marketing Communications). If at any time you do not wish to receive any further Direct Marketing Communications from us you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the email, managing your subscriptions via your member account or by contacting us via the details set out in Section 7 below.
4. Disclosure of information
4.1 The types of organisations to which we may disclose your personal information
The Company may disclose your personal information to organisations outside of the Company. Such organisations and/or parties may include:
- industry partners;
- offshore service providers, if any;
- related entities and subsidiaries of the Company;
- third parties, such as financial institutions (banks); and
- our contractors and agents, including but not limited to our IT service providers, or other companies who assist us in providing our products and services to you.
Otherwise, the Company will only disclose your personal information where we are required to do so by law.
4.2 Cross border disclosure
Any personal information provided to the Company may be transferred to, and stored at, a destination outside Australia. Personal information may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.
If you do not agree to the transfer of your personal information outside Australia, please contact us via the details set out in Section 7 below.
5. Data quality and security
We have taken a number of physical, electronic and procedural steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure.
6. Access to personal information
Under the Australian Privacy Principles, you are entitled to have access to any personal information relating to you which we possess, except in some exceptional circumstances provided by law. You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.
If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out in Section 7 below.
If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information, please contact us by using the ‘Contact Us’ facility on the Website.
We will always endeavour to investigate your complaint and respond to you as soon as practicable after receipt, generally within 30 days. If you are not satisfied with our response, you may refer the matter to the Office of the Australian Information Commissioner.