In this policy “we”, “us’ and “our” means Trade Promotions Pty Ltd. Please read this policy carefully as it describes the way in which we collect and handle your personal information. We may update or revise this policy from time to time. If we elect to update or revise this policy, we will post the date on which that revision takes effect at the end of this policy. Please be aware that you have no obligation to provide any personal information requested by us. However, if you choose to withhold your personal information, we may not be able to provide you with the services or products that depend on the collection and use of that information.
1 OUR PRIVACY COMMITMENT
We recognise the importance of, and are committed to, managing any personal information that we collect in compliance with the Privacy Act 1988 (Cth), which includes the Australian Privacy Principles, and other Australian privacy laws (together, “Privacy Laws”).
2 HOW DO WE COLLECT PERSONAL INFORMATION?
Where possible, we collect your personal information directly from you. This collection includes through your:
registration when you purchase a magazine or digital subscription;
entry into promotions or competitions;
answers to surveys;
signing up notifications from our magazines;
signing up to join our online communities;
communications with us such as letters, telephone calls, text messaging and emails regarding services and products;
download and use of our digital publications and mobile applications (“apps”).
In some circumstances, however, we may also collect your personal information from third parties or public agencies where it is unreasonable or impracticable for us to collect the personal information directly from you. For example, if you subscribe to one of our magazines through a third party that is authorised to take subscriptions for us, we will collect your personal information from that third party. If we have difficulty in delivering a magazine to you, we may make enquiries in an effort to locate your address or correct any error in our recorded address details for you.
In some circumstances, we may provide you access to our online communities through the option of a third party platform sign on (including but not limited to, social sign ons). In this instance we will be accessing and collecting the personal information which you have authorised the third party platform to pass on to us. Where we collect personal information from third parties, we will ensure that the collection is conducted in a fair and lawful manner and the information is reasonably necessary for our functions or activities.
3 WHAT PERSONAL INFORMATION DO WE COLLECT?
The personal information we collect varies depending upon the purpose of the collection and the product or service we are providing you. Generally, we collect and hold the following types of personal information:
your name and address;
your telephone / e-mail / contact details;
your date of birth;
other information you may make publicly available online (including but not limited to on social media platforms);
transaction details, if you make a purchase with us or choose to store details in your online profile; and
any other personal information which may be required in order to facilitate and where possible improve your dealings with us.
In the event that we are required to collect sensitive personal information, we will notify you of this at the point of collection and obtain your consent to collect and hold this sensitive personal information.
4 WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?
We will collect your personal information if it is reasonably necessary for the performance of our business activities and functions, which includes providing a range of products and services to you, some of which are listed below.
4.1 Registration for magazine subscriptions
We collect personal information from individuals who subscribe to our magazines in order to process their payments
4.2 Sales Promotions, Competitions and Surveys
We collect personal information when you respond to one of our promotions, competitions or in order to inform you if you have won a prize, and to help us better understand what products and services you would like to receive information about in the future.
4.3 Our mobile apps
We, or a service provider, may collect information through our apps to assist us in understanding how you use our apps, how the apps are performing across different handsets and to assist us in the selection of advertisements for groups of individuals. Our access to this information, is as you have agreed to with the respective app store from which you download our app.
4.5 Our online communities
We collect personal information from you when you participate in any activity on our online communities. By providing personal information to us during such activity, we can assist in identifying ways in which we can provide you with a better service, or enhance your online experience.
5 WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?
We provide your personal information to third parties where you have consented to such disclosure.
In certain circumstances, we may disclose your personal information where required or authorised to do so by law, including in emergency situations and to assist law enforcement agencies. We will always ensure that those to whom we disclose your personal information have the legal right to receive it.
6 HOW IS YOUR PERSONAL INFORMATION SECURED?
We understand that the security of your personal information is important. As such, we take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. We store information both at an onsite secure server and at trusted third party storage providers. We undertake regular training of our staff to ensure that they are aware of our privacy commitments and our obligations in the collection, use and disclosure of personal information. Our staff is also required to sign in and use a password when accessing our secure systems.
We, and our service providers, use the information collected from cookies for a number of reasons:
for statistical purposes in order to track how many users we have and how often they visit our website or apps;
to provide statistical data, ratings and other information for industry and other public reporting;
to track who has viewed an advertisement or clicked-through an advertisement; and
to provide you with a more targeted advertising experience both on and off our websites or apps, allowing us to impose restrictions where appropriate and monitor how effective an advertising campaign has been.
9 THIRD PARTY WEBSITES
10 ANONYMITY AND USE OF A PSEUDONYM
You may request at any time that you remain anonymous, or choose a pseudonym, when dealing with us. To the extent that it is lawful and practicable for us to enable you to do so, we will grant such a request.
11 HOW TO MAKE A COMPLAINT
If you wish to make a complaint about the way in which we handle your personal information, please contact our Privacy Officer using the contact details set out below.
We undertake to acknowledge and investigate any complaint promptly and will respond to written complaints within a reasonable time from the date of receipt.
If you are dissatisfied with our response, you may refer the matter to the Australian Information (Privacy) Commissioner (see www.oaic.gov.au). If you are dissatisfied with our response in relation to the way in which we handle your personal information in the course of our journalistic activities, you may refer the matter to the Australian Press Council (see www.presscouncil.org.au).
12 CONTACT DETAILS
The Privacy Officer
Trade Promotions Pty Ltd
PO Box 2345
Mount Waverley Vic 3149