In handling your personal information, we are regulated by and are committed to complying with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (Privacy Law).
2. Personal information
Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.
3. What personal information do we collect?
We may collect the following types of personal information:
- billing, mailing and/or street address;
- email address;
- telephone number and other contact details;
- age or date of birth;
- financial information, including credit card information;
- drivers licence details and other forms of personal identification;
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- any additional information relating to you that you provide to us directly through the Services (including our website) or indirectly through your use of our Services, the App, online presence or through other websites or accounts from which you permit us to collect information;
- information you provide to us through customer surveys; or
- any other personal information that may be required in order to facilitate your dealings with us.
We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:
- register to use the Services (including the website and App);
- complete registration or enquiry forms, order any products or services from us or third-party merchants, publish reviews, upload content, participate in message boards, blogs and/or any other user generated content facilities or send emails to us;
- request, purchase, process, enquire or register and confirm any services and products in connection with the Services from us or any of our related bodies corporate, agents, suppliers, contractors or users;
- communicate with us or any of our related bodies corporate, agents, suppliers, contractors or merchants or any of the users of the Services through correspondence, chats, email, or when you share information with such persons from other applications, services or websites; or
- interact with the sites, services, content and advertising of us or any of our related bodies corporate, agents, suppliers, contractors or users.
We will generally collect personal information directly from you. We may also collect personal information from third parties (including third-party data analytic service providers), third-party social-networking sites (including but not limited to Facebook, Twitter, or Google+) and publicly available sources of information. We may use personal information supplied by you or a third party to source additional personal information from publicly available sources of information.
Where lawful and practical, you have the right to remain anonymous or to make use of a pseudonym, however if you choose to remain anonymous or to use a pseudonym, we and our third-party contractors and merchants may not be able to provide you with access to some or all of our products or services (including information products and services). Please do not submit your personal information to us if you do not wish for us to collect it.
4. Sensitive information
Some personal information (for example, race, ethnicity, and health information) is sensitive and requires a higher level of protection under the Privacy Law. We will not generally collect any sensitive information from you which we consider are unnecessary to our Services. We will only collect such sensitive information when we have your express consent for us to do so and the collection is reasonably necessary for us to provide our products or services, or where the information is required or authorised by law or necessary for the establishment, exercise or defence of a legal claim.
5. Why do we collect, use and disclose personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
- to enable you to access and use, and to enhance and improve your use of, our Services and products and services contained within the Services, including in relation to our App, and applications of us or any of our related bodies corporate, agents, suppliers, contractors or users;
- to operate, protect, improve and optimise the Services and products and services, website, applications, business and user experience of us or any of our related bodies corporate, agents, suppliers, contractors or users, such as to perform analytics, conduct research and for advertising and marketing;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you personalised recommendations and submission of feedback;
- to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
- to send you registration confirmation details or to contact you if there is a problem with a transaction, enquiry or registration;
- to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
- to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;
- to personalise your use of the Services (including visits to our website) and developing the design and style of the Services (including our website and App) to improve the Services;
- to inform you about the latest changes to our website, App, products, services (including the Services) or promotional offers that you may be interested in;
- for the purpose of providing you with the Services (including via our App) and for communicating (and personalising such communication) with you;
- in order to enable you to share our content with others, for example, by using an ‘Email a friend’ or ‘Share this’ functionality feature; and
- carrying out technical and statistical analysis to measure the performance of our products and services and the website.
If we receive unsolicited personal information about or relating to you and we determine that such information could have been collected in the same manner as if we had solicited the information, then we will treat it in the same way as solicited personal information and in accordance with the Privacy Law. Otherwise if we determine that such information could not have been collected in the same manner as solicited personal information, and that information is not contained in a Commonwealth record, we will, if it is lawful and reasonable to do so, destroy the information or de-identify the information.
6. Do we use your personal information for direct marketing?
We or our related bodies corporate, agents, suppliers or contractors may send you direct marketing communications and information about our services or products. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth) and the Privacy Law. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (for example, via an unsubscribe link).
7. To whom do we disclose your personal information?
- our employees and related bodies corporate, agents and contractors;
- third-party suppliers and service providers (including providers for or in connection with the operation of the Services, our website, our business or in connection with providing our products and services to you);
- professional advisers and agents;
- payment systems operators (for example, merchants receiving card payments);
- our existing or potential agents, business partners or partners;
- our sponsors or promoters of any competition that we conduct via the Services;
- organisations to whom we outsource functions (including information technology providers, print service providers and mail houses);
- anyone to whom our assets or businesses (or any part of them) are transferred;
- specific third parties authorised by you to receive information held by us;
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law; and
- trusted third parties who also hold other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
We reserve the right to disclose your personal information without your consent if the disclosure is:
- to comply with applicable laws and government or regulatory bodies’ lawful requests for information;
- required in order to investigate an unlawful activity;
- required by an enforcement body to investigate activities; or
- necessary to prevent a serious and imminent threat to a person’s life, health or safety, or to public health or safety.
8. Disclosure of personal information outside Australia
We may disclose personal information outside of Australia to related bodies corporate, employees, agents or contractors, third-party suppliers, service providers and information technology and cloud services providers located in countries other than Australia, including in China, New Zealand and the United States of America.
When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with Australian Privacy Law. Further, the overseas recipient of personal information may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority. In such case, we will not be responsible for that disclosure. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Australian Privacy Principles.
9. Using the Services and cookies
We may collect personal information about you when you use and access our Services (including our website and App).
In addition to personal information, we may collect information about you automatically when you use our Services or visit our website. While we may not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
If you choose not to receive our cookies, we cannot guarantee that your experience with the website will be as quick or responsive as if you do receive cookies.
The information collected by cookies and web beacons is not personally identifiable, it includes general information about your computer settings, your connection to the internet, for example, the operating system and platform, IP address, your browsing patterns and timings of browsing on the website and geographical location.
We may hold your personal information in either electronic or hard copy form. We take the security of your personal information very seriously and will use reasonable commercial endeavours to take reasonable and appropriate steps to have appropriate physical (such as the use of secure storage facilities), technical (such as firewalls) and administrative procedures (such as a user ID/password system and employee restrictions) in place to help protect your personal information from unauthorised access, use or disclosure as required by law in Australia. However, we cannot guarantee the security of your personal information.
We only retain your personal information for as long as is necessary for the purposes for which it was collected and we are required to keep it to comply with any laws. We will take such steps as are reasonable in the circumstances to destroy or de-identify personal information which we no longer need. These measures may vary depending on the personal information held.
In the unlikely event that there is an unauthorised use or disclosure of your personal information (Data Breach), we will notify you of the Data Breach and will undertake an investigation into how the Data Breach occurred and its likely severity. As part of this, we will use commercially reasonable endeavours to work with you and the Office of the Australian Information Commissioner to limit the impact, and any reoccurrence, of such Data Breach.
12. Accessing or correcting your personal information
You can access the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. Such circumstances include the following:
- access would create a serious threat to safety;
- providing access will have an unreasonable impact upon the privacy of other individuals;
- denying access is required or authorised by law;
- the request is frivolous or vexatious;
- legal proceedings are underway or anticipated, and the information would not be accessible through the process of discovery in the proceedings;
- negotiations may be prejudiced by such access;
- providing access is likely to prejudice law enforcement; or
- access would reveal a commercially sensitive decision making process.
We may also need to verify your identity when you request your personal information. If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.
13. Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
If you believe we have not adequately dealt with your complaint, you may complain to the Office of the Australian Information Commissioner about the way we handled your personal information. The Commissioner can be contacted at:
15. Contact Us