As journalism and publishing forms a large component of our business, we may rely on certain exemptions in the Privacy Act with respect to the handling of your personal information, including the exemptions with respect to journalism. In this regard, we will comply with the Australian Press Council Privacy Standards. We may also rely on other exemptions in the Privacy Act, including the related bodies corporate and employee records exemptions. Information on the collection and use of Personal Information in the course of journalism can be found at the Australian Press Council Privacy Standards website at: http://www.presscouncil.org.au/privacy-principles.
1. COLLECTION OF YOUR INFORMATION
1.1 We collect personal information about customers, prospective customers and website users which is reasonably necessary for, or directly related to, one or more of our functions or activities.
1.2 An example of the personal information that we might collect from you includes your name; your postal address or street address; your age or date of birth; your profession, occupation or job title; your contact number; information you provide to us from any customer surveys that we may conduct from time to time; information that you might provide to us through the use of our website; and details of any products or services that you purchase from us and enquired about and any additional information necessary to fulfil your request for those products and services.
1.4 We may be required from time to time to collect Sensitive Information from you, but will not collect Sensitive Information from you without your consent. Sensitive Information is given its meaning in the Privacy Act but generally includes information or an opinion about an individual’s racial or ethnic origin, health information or political/ philosophical beliefs.
Cookies and Other Technologies
1.5 Subject to our obligations under the Privacy Act, when you visit any of our websites or use any of our applications or related digital properties (individually and collectively, “Services”) we may collect information about your usage and the Services performance.
Such information may include your browser type, operating system, IP address, and the referring domain name from which you access this site (e.g. www.google.com).
We may collect information about your browsing behaviour, such as the number of times you have visited, the date you visited and the amount of time you spent using our Services.
We may also receive anonymised data about performance and errors that occur while you use our Services.
The information collected pursuant to this point 1.5 is used solely for our internal purposes in managing our Services and improving their functionality and reliability, as well as to assist us in better targeting interactive advertising, thereby enhancing customer support and site usability.
1.6 We may track your response to our advertisements, e-mails and content, determine your ability to receive HTML-based e-mail messages, learn how many users open an e-mail and allow our service providers to compile aggregated statistics about an e-mail campaign that we are running. This information may be shared, only when anonymised, with third parties to assist them in understanding the performance of advertising in our Services.
2. HOW WE USE YOUR INFORMATION AND WHEN WE MAY DISCLOSE IT
2.1 We collect personal information from you so that we can carry out our business activities and functions as well as to provide you with a high standard of customer service. In order to do this, we collect, hold, use and/or disclose your personal information for the following primary purposes:
(a) to provide you with the products and services ordered from us or provide you with news, information or advice about our existing or new products and services;
(b) to answer your inquiry and communicate with you generally, including by email, mail or telephone;
(c) to send you additional materials relating to us and services that may be of interest to you;
(d) to conduct competitions or offer you promotions on our behalf or on behalf of third parties that we may contract with from time to time;
(e) to provide your updated personal information to us, our contractors or third party service providers;
(f) to investigate any possible breaches by you of any of our terms and conditions; and
(g) to otherwise provide you with effective customer service.
2.2 We also hold personal information which we use and/or disclose for purposes other than our primary purposes (“secondary purposes”). You provide your consent to us using your personal information for the following secondary purposes:
(a) billing and account management;
(b) business planning and product development;
(c) providing you with relevant information, including promotions, about our products and services, the products and services of our related bodies corporate and/or the products and services of our business partners or joint venturers;
(d)enabling us to better understand your needs and interests;
(e)improving the content, functionality and usability of our website;
(f) improving our marketing and promotional efforts;
(g) displaying personalised advertising when you visit our website;
(h)for any other purpose identified in any other agreement between you and us;
(i) issues, news or other information relevant to your dealings with us, or about us generally, or the industries in which you or we operate; and
2.4 In accordance with the Privacy Act, please note that we may use and/or disclose personal information without your consent for those reasons described in the Privacy Act, including reasons relating to the protection of public safety or the avoidance of an imminent threat to an individual’s life.
2.5 From time to time we may also disclose your personal information to those bodies described in point 2.6 below in order to assist us to deliver the services you require. These organisations carry out, amongst other services, our:
(a) billing and debt- recovery functions;
(b) customer inquiries;
(c) information technology services;
(d) marketing services (including market research);
(e) product delivery services;
(f) the operation of our website and fulfilment of your requests and orders;
(g) website usage analysis; and
(h) the support or facilitation of any of those activities described in points 2.1 and 2.2.
We will take reasonable practicable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
2.6 Some of the parties that we may disclose your Personal Information to include our employees, related bodies corporate; contractors; newsagents; external service providers; our existing or prospective agents business partners or joint ventures; our sponsors or promoters of any competition that we conduct via our services; specific third parties authorised by you to receive information from us; and any other body for those reasons described in point 2.5 above.
3. DIRECT MARKETING
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, over the phone, via SMS or via email, in accordance with applicable marketing laws, such as the Spam Act 2004 (Cth) and the Do Not Call Register Act 2006 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
In addition, at any time, you may opt-out of receiving marketing communications from us by contacting us (details provided in point 10 below) or by using the opt-out facilities provided (e.g. an unsubscribe link), or by updating your personal details on our website using the link provided on this page (if available). We will then ensure that your name is removed from our mailing list.
If you receive communications from us that you believe has been sent to you other than in accordance with this policy, or in breach of any law, please contact us using the details provided in point 10 below.
4. ENSURING INFORMATION IS ACCURATE AND UP-TO-DATE
We take reasonable precautions to ensure that the personal information we collect, use and disclose is complete, relevant and up-to-date.
However, the accuracy of that information depends to a large extent on the information you provide. That's why we recommend that you:
· let us know if there are any errors in your personal information; and
· keep us up-to-date with changes to your personal information such as your name or address. You may change your personal details by using the relevant facility on our website or by contacting us care of the contact details provided in point 10.
5. HOW WE PROTECT YOUR INFORMATION
5.1 We will take reasonable steps to protect the personal information from misuse, interference, loss and unauthorised access or disclosure. This may include taking reasonable steps to destroy or permanently de-identify personal information once it is no longer needed for any purpose for which the information may be used or disclosed.
5.2 We will not attempt to match de-identified or anonymous data collected through surveys or such online devices as "cookies", with information identifying an individual, without the consent of the relevant individual.
6. HOW YOU CAN ACCESS OR CORRECT YOUR INFORMATION
6.1 We will permit records containing your personal information to be accessed by you when you contact us c/o the contact details at point 10 below. We may, however, refuse to provide you with access to your personal information if, for instance, granting you such access would pose a serious threat to your life or to the health and safety of any individual or have an unreasonable impact on the privacy of any other individual.
6.2 If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request 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.
6.3 If you:
(a) wish to lodge a request to access and/or correct your Personal Information; or
(b) have been refused access to your Personal Information by us for any reason described in this Policy and you wish to challenge that refusal;
you may do so by contacting the office of Schwartz Media’s Privacy Officer as per the details in in point 10. The procedure for challenging such a refusal is also set out in point 10.
6.4 We will not normally charge a fee for processing an access request unless the request is complex or is resource intensive. We do, however, reserve the right to charge an administration fee if an individual requests access to their personal information more than once in a three month period.
6.6 Where we offer online account management facilities, customers can use this capability to control aspects of their account, including amending or updating certain personal information.
The office of Schwartz Media’s Privacy Officer will be the first point of contact for inquiries about privacy issues. If you wish to make an inquiry or complaint regarding privacy you should do so by contacting this office as per the details in Point 10.
8. STAYING ANONYMOUS
8.1 We will not make it mandatory for visitors to our website to provide personal information unless such information is required to answer an inquiry or provide a service. We may, however, request visitors to provide personal information voluntarily to us (for example, as part of a competition or questionnaire).
8.2 We will allow our customers to transact with us anonymously or by using a pseudonym wherever that is reasonable and practicable.
9. TRANSFERRING INFORMATION OVERSEAS
9.1 If we send personal information overseas, we will take steps which are both reasonable and practicable to ensure that the overseas recipient handles such information in accordance with the Privacy Act.
9.2 We may disclose your personal information to entities located outside of Australia, including the following:
(a) our data hosting and Cloud based IT service providers;
(b) external service providers located in New Zealand, North America, Europe; and/or
(c) other third parties operating in jurisdictions including New Zealand, North America, Europe.
11. CONTACTING US
Level 1, 221 Drummond Street
Carlton VIC 3053
Phone +61 3 9486 0288
Fax +61 3 9011 6106
Email: [email protected]
Once the Privacy Officer receives a complaint from you, the Privacy Officer will within a reasonable time after receiving the complaint begin investigating the complaint. In investigating the complaint the officer may use additional resources within our organisation to determine the nature of the complaint. We may contact you during this investigation if necessary. If a breach is found, the Privacy Officer will escalate the matter to management to ensure that the process which caused the breach is remedied. We will also contact you to inform you of the outcome of the investigation within a reasonable time after the conclusion of the same. We will treat your complaint during the investigation period confidentially and aim to resolve your complaint in a timely fashion and a satisfactory manner.
This policy was last updated on 19 July 2018.