1. What personal information do we collect?
1.1 Personal information
“Personal Information” is any information that can be used to personally identify you. The types of personal information (as defined under the Privacy Act 1988 (Cth) (the “Act”)) Company collect depends on your dealings with us. We primarily collect and store information when you provide it to us voluntarily – this may be in the form of directly supplying the information to us when prompted to do so as part of registering for or using our Services, or indirectly supplying the personal information through the use of any features on our website. We may collect personal information from you when you:
• use our Services;
• join or participate in any features or functions available via our Services or website;
• use, access or browse our website (including through technological tools including “Log Data” and “Cookies” which collect certain information, as explained below);
• provide feedback in relation to the Services or our website; and/or
• provide it to us as part of your dealings with us.
The personal information that we collect may generally include:
• contact details, including name, address, location, phone number, profile information, age, gender, occupation, title, email address, usernames and other contact information;
• financial and/or other confidential information relating to you that you choose to provide to us;
• a record of your IP address;
• the date and time of your visits to our website;
• details of the Services you have used and additional information necessary to deliver our Services to you; and/or
• any additional information relating to you where you are identifiable that you provide to us directly in communications with us.
1.2 Sensitive information
If we collect “sensitive information” from you, we will seek your consent to do so. Sensitive information is defined in the Act and is a subset of personal information and includes health information, information about a person’s racial or ethnic origin, religious beliefs or affiliations, membership of a professional or trade association, membership of a trade union, sexual orientation, or criminal record. You may choose to withdraw your consent in respect of our collection and use of your sensitive information. Please note that if you withdraw your consent to the Company collecting your sensitive information then we may not be able to provide you with some or all aspects of the Services. Contact us using the contact information in section 10below to withdraw your consent to our collection and use of your sensitive information.
1.3 Non-Identifying Information
In all other cases where information we collect cannot reasonably be used to identify you or allow a holder of such information to contact you directly, that information will not be personal information (“Non-Identifying Information”).
A type of Non-Identifying Information that we may collect and store is statistical, analytical and other usage information and data derived from your use of our Services (usage data includes, for example, the date and time of your visits to our website, geographical location, the features or functions of our Services that you use, information or data sent to us via ‘cookies’ sent to us via your Internet browser, and aggregated quantitative information about active users and user activities).
1.4 Log data
When you use our Services, we may automatically record information regarding your use of our Services (‘Log Data’). This Log Data may include information such as the device through which you are using our Services, the features of our Services which you have use, the pages or menus of our Services that you visit and the time spent, information you search for on our Service, access times and dates, and any other statistics (commonly referred to as ‘meta-data’). We use this information to monitor and analyse use of our Services and its technical administration, to increase our Service’s functionality and usability, and to better tailor our Services to our users’ needs.
2. Why Company collects, holds, uses and discloses personal information
We need to collect personal information so that we can provide our Services, and conduct our business, including but not limited to the following:
• to provide you with our Services and provide any support to you;
• to communicate with you including by email, text, mail or telephone;
• to verify your identity;
• to operate any features or functions of the Services;
• to maintain the integrity and security of our Services;
• for research, analysis and profiling;
• to market, promote and advertise our business and our Services to you;
• to market, promote and advertise the goods and/or services of our associates and affiliates to you that we believe you may be interested in;
• to assist our internal administration and daily operations;
• to allow us to better understand your use of our products and Services;
• to improve, upgrade, repair, maintain or monitor our Services;
• to investigate or deal with any disputes or complaints with you in connection with our Services;
• to communicate with you in the event that there has been a data breach involving your personal information; and/or
• to comply with any other obligations that we may have under the law or otherwise.
We may combine your personal information with Non-Identifying Information and aggregate it with any other information to attempt to provide you with a better experience of our Services, to improve the quality and value of the Services and to analyse and understand how the Services are used.
We keep your personal information for as long as we need it to provide our services to you. We may retain your personal information if it is necessary for us to comply with our legal obligations, to resolve disputes with you or third parties and/or to enforce our legal rights.
3. Collection of personal information from members under the age of 18
The Company maintains a strict position with respect to collecting personal information from Members under the age of 18. If you are under the age of 18 and wish to provide personal information to us, you must obtain your parent’s or guardian’s consent before providing us with that information. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us immediately using the contact information in 10 below. Company reserves the right to delete your information, if appropriate.
4. Will your personal information be disclosed to anyone else?
When you use our Services, we may need to disclose your personal information to third parties who require such information and/or who are the intended recipients of such information based on our understanding through your use of our Services. For example, we may disclose personal information to third parties for the following purposes:
(a) We may disclose your information to a third party who is assisting us with any of the matters referred to above where we have set out why we collect, hold, use and disclose personal information.
(b) We may engage third parties to facilitate the provision of the Services, to perform related services (e.g. maintenance services, database management, web analytics, improvement of a service feature and marketing of our business) or to assist us in analysing how our Services are used. These third parties may have access to your information to perform these tasks. We will ordinarily require third parties not to use or disclose any personal information that we disclose to them for any purpose other than to provide or perform the relevant services for us.
(c) We may disclose your information to third parties for the purposes of assisting us with marketing, promoting and advertising our business and Services to you.
(d) We may disclose your information to our related entities which perform certain aspects of the Services or which perform other services that may be of interest to you.
(e) We may disclose your information if this is required by law, to assist with any law enforcement activities of a government entity or agency, to take professional legal, financial or taxation advice, to deal with any disputes with you in connection with our Services or to deal with (including to pursue or defendant against) any legal claims.
5. What happens if we cannot collect your personal information?
If you do not provide us with certain personal information, some or all of the following may occur:
• we may not be able to provide you with some or all aspects of our Services;
• we may not be able to provide you with information about our Services that you may want, including information regarding any complaints you may have regarding the Service; and/or
• we may be unable to tailor the content of our Services to your preferences and your experience of our Services may not be as enjoyable or useful.
6. Other matters
You also need to be aware of the following matters:
6.1 Direct marketing.
Like many websites, we use “cookies” to collect a variety of website usage information and data. A cookie is a small data file that is transferred to your computer’s hard disk. We use a range of cookies so we can better understand how you interact with our Services and to monitor web traffic routing with the aim of improving or monitoring our Services. The types of cookies that we use include analytics cookies, social advertising cookies and targeted advertising cookies. Most Internet browsers automatically accept cookies, however, you can instruct your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit, however, doing so may mean you will not be able to use all or parts of our Services.
Our Services may contain links to other third party websites and their services. If you choose to visit another website or online service by clicking on a link on our Services, you will be directed to that third party’s website or online service. The fact that we may link to a website or online service is not an endorsement, authorisation or representation of our affiliation with the operator of that website or online service, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites and online services. We encourage you to read the privacy policies and terms and conditions of use on those websites or online services that you visit before providing any information or using such websites or services.
6.4 International users
Please note that the personal information that you provide to us will be transferred to, and processed in Australia, where laws regarding the processing of personal information may be different than those in your country. By using our Services, you hereby consent to this transfer and processing of your personal information, and you should familiarise yourself with the applicable law in your jurisdiction in relation to personal information.
7. Access to your personal information; Changing or deleting your personal information.
7.1 If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, you may contact us to update, correct or delete the personal information by contacting us using the contact information in section 10 below. We request that you provide us with personal information that is as current as possible so that we may continue to improve our Services provided to you. However, if you ask us to delete your personal information then we may not be able to provide our Services to you. We may retain an archived copy of your records as required by law or for legitimate business purposes.
7.2 You have the right to request access to your personal information that we hold. You may send us a request using the contact information in section 10 below to access the personal information about you that we have collected. If you seek access to your personal information from us, we will ask you to verify your identity and we may charge a fee for providing you with your personal information, in which case we will inform you of the fee in advance of providing the information. There may be instances where we cannot grant you access to the personal information we hold, including:
(a) we reasonably believe that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or
(b) we reasonably believe that the request for access is frivolous or vexatious; or
(c) the information relates to existing or anticipated legal proceedings between us and you, and would not be accessible by the process of discovery in those proceedings; or
(d) giving access would result in a breach of confidentiality; or
(e) giving access would be unlawful or likely prejudice one or more law enforcement activities of a government entity; or
(f) denying access is required or authorised by or under a law or a court/tribunal order; or
(g) giving access would reveal evaluative information generated by us in connection with a commercially sensitive decision-making process.
8. Security of information
We will take reasonable steps to ensure the protection and security of your personal information from misuse and loss, and from unauthorised access (including by means of firewalls, password access, secure servers and encryption of any credit card transactions), modifications or disclosure. We will adopt reasonable safeguards to preserve the integrity and security of personal information collected to prevent unauthorised access, modification or disclosure, misuse or loss, including by encrypting of your personal information with high-grade commercial encryption technology. However, we cannot ensure or warrant the absolute security of any such information you provide to us or guarantee that information may not be subject to unauthorised access, disclosure, alteration or destruction. We do not warrant that our Services will be without error or interruption, or will be free from unauthorised or fraudulent third party access as a result of the nature of Internet transmissions. If you suspect any misuse or loss of, or unauthorised access to, your personal information, please contact us immediately using the contact information in section 10 below.
9. Complaints about Your Personal Information
If you are concerned about how we collect, hold, store, use or disclose your personal information, please contact us using the contact information in section 10 below. We will use reasonable endeavours to address your enquiry or complaint and will endeavour to respond to you within 60 days of receipt of your initial enquiry or complaint (to the extent that we feel your complaint is complex or that we require further time to provide a substantive response, we will send you a notice to that effect).
You must provide all reasonable assistance to us to allow us to address your enquiry or complaint, including providing us with all appropriate and relevant information and feedback on request.
If you feel your enquiry or complaint has not been adequately addressed by us, you may contact the Office of the Australian Information Commissioner. However, we would advise you to notify us beforehand of why you feel we have not adequately addressed your enquiry or complaint and allow us an opportunity to respond to you.
If you would like any further information about your rights to privacy, please contact or visit the regulator in your jurisdiction. The regulator in Australia is:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Tel: 1300 363 992
10. Contact Us
Address: Level 3, 2 Martin Place, Sydney NSW 2000
Phone: 1300 WE ASSIST