As the supplier of the Program, we recognise the importance of your privacy and understand your concerns about the security of the personal information you provide to us.
In the course of doing business with you, the collection of personal information in some instances is necessary or unavoidable. We are committed to protecting the privacy of all personal information that we collect and ensuring that your personal information is handled correctly.
All personal information collected by us will be treated in accordance with the Australian Privacy Principles (“APPs”) as contained in the Privacy Act 1988 (Cth). The APPs detail how personal information may be collected, used, disclosed, stored and destroyed, and how an individual may gain access to or make complaints about the personal information held about them.
This policy details the type of personal information we collect from our customers, how we manages personal information about you, with whom we may share it and the choices available to you regarding our use of the information. We also describe the measures we take to safeguard your personal information and tell you how to contact us regarding our privacy practices.
“Personal information” is information or an opinion about an identified individual, or about an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or now. Information where we have removed any reference to a person, so that the person cannot be reasonably identifiable from the information, is not personal information.
The kinds of personal information that we may collect and hold from you or about you include:
We do not collect sensitive information (such as relating to your ethnic origin, religious or philosophical beliefs, membership of a political or trade association, sexual preferences or health), and would not do so without your consent.
When you browse our website or contact us electronically, we may record geographical tagging, cookies and statistical data. This may include your IP address, date and time of your visit, operating system, language preferences, device characteristics, pages visited, information downloaded and type of browser used to access the website.
We use this information to help us to make decisions about maintaining and improving our website and online services.
While our website may contain links to other websites with the exception of our related entities, those websites are not subject to our privacy standards, policies and procedures. We recommend that you make your own enquires as to the privacy policies of these third parties and we are in no way responsible for the privacy practices of these third parties.
We aim to collect personal information only directly from you, unless it is unreasonable or impracticable for us to do so. For example, we collect personal information from you or about you from information you submit to us when:
However, in some circumstances, it is necessary for us to collect personal information through third parties or from a source of publicly available information.
If we receive personal information that we have not requested (unsolicited information) and we determine that we could not have collected that information under the APPs if we had requested it, then we will destroy or de-identify the information if it is lawful and reasonable to do so.
We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities and as necessary to provide our services to you. We also collect, hold, use and disclose your personal information for related purposes that you would reasonably expect, such as our administrative and accounting functions For example, we may use the information obtained from you:
If we do not collect, hold, use or disclose your personal information, or if you do not consent, then we may not be able to answer your enquiry, complete the transaction you have entered into, or provide our services to you to the best of our ability.
Your personal information is held and stored on paper, by electronic means or both. We have physical, electronic and procedural safeguards in place for personal information and take reasonable steps to ensure that your personal information is protected from misuse, interference, loss and unauthorized access, modification and disclosure.
We store personal information in a combination of secure Australian based computer storage facilities and paper based files and other records. We use industry accepted and compliant technology and security so that we are satisfied that your information is transmitted safely to us through the internet or other electronic means.
We also employ the following measures in order to safeguard your personal information:
We will retain your personal information whilst it is required for any of our business functions, or for any other lawful purpose.
We use secure methods to destroy or to permanently de-identify your personal information when it is no longer needed:
We respect the privacy of personal information and will take reasonable steps to keep it strictly confidential.
We may share the information you provide with companies that are related us, through common ownership (including other affiliated companies within or outside Australia).
We will disclose personal information to third parties if it is necessary for the primary purpose of collecting the information, or for a related secondary purpose, if the disclosure could be reasonably expected. Where such a disclosure is necessary, we will require that the third party undertake to treat the personal information in accordance with the APPs.
Generally, we may disclose personal information about you in the following circumstances:
We may share information about you with affiliated joint marketing partners and/or third parties whose products or services may be of interest to you. These third parties may contact you directly about their products and services in order to provide continuous improvement to the Program.
Where we use your personal information for marketing and promotional communications, you can opt out at any time by notifying us. Opt out procedures are also included in our marketing communications. If you do not want us to use your information for marketing purposes, or share your information with related companies for their own marketing purposes, please notify us by sending an email to the contact email listed below.
Otherwise, we will only disclose your personal information to third parties without your consent if the disclosure is:
Where we wish to use or disclose your personal information for other purposes, we will obtain your consent.
We impose strict requirements of security and confidentiality on all third parties as to how they handle personal information. We provide our outside contractors both locally and internationally, and retail affiliates only with information they need to perform their services - they are not permitted to use the information for any purpose except to provide the service to us. The Privacy Act also strictly controls the information we exchange with credit reporting agencies.
The types of credit information that we collect and use for the purpose of collecting payments and/or making payments include:
We do not disclose credit information to credit reporting bodies.
We have procedures in place for dealing with and responding to requests for access to, and correction of, the personal information held about you.
In most cases, we expect that we will be able to comply with your request. However, if we do not agree to provide you access or to correct the information as requested, we will give you written reasons why. For example, a request to access personal information may be rejected if:
To assist us to keep our records up-to-date, please notify us of any changes to your personal information.
We have procedures in place for dealing with complaints and concerns about our practices in relation to the Privacy Act and the APPs. We will respond to your complaint in accordance with the relevant provisions of the APPs.