The Privacy Act 1988 (Cth) (“Privacy Act”) governs the way private sector organisations collect, use, keep secure and disclose personal information.
This PPS applies to personal information collected by us and sets out:
how and when we collect personal information;
how we use and disclose personal information;
how we keep personal information secure, accurate and up-to-date;
how individuals can access and correct their personal information; and
how we resolve privacy complaints.
What is personal information?
The Privacy Act defines “personal information” as “information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is reasonably identifiable, from the information or opinion”.
What is Sensitive Information?
Sensitive information is a subset of personal information. It is personal information about an individual concerning that person’s racial or ethnic origin, political opinions, political affiliations, religious beliefs or affiliations, philosophical beliefs, professional or trade or trade union membership or association, gender or sexual orientation or practices, criminal record, health information, genetic information, biometric information intended to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
We will not collect sensitive information from you without your consent and we attempt to limit the extent of sensitive information we collect from you and record, based upon the use you make of our services and/or products.
The use we make of sensitive information we collect from you or record about you is limited to the purpose(s) for which it was collected, which is principally to enable Synkronos to the services and/or products you request.
We do not use sensitive information to send you Direct Marketing Communications without your express consent.
Collection of your personal information
3.1. We only collect personal information that is necessary for what we do and we hold the personal information we collect within our own data storage devices or with a third party provider of data storage. The type of information we may collect from you depends ultimately upon the purpose of collection.
3.2. The personal information we may collect from you includes (but is not limited to) the following:
- your name;
- age or date of birth;
- postal address;
- e-mail address;
- telephone number;
- wireless device address;
- text message address;
- screen name or username;
- geolocation information;
- payment card and other payment information;
- event dates and related information; or
- interests, hobbies and demographic information.
3.3. We collect Personal Information via the Site in a variety of circumstances, such as when you:
- conduct a transaction on our Site;
- create or edit a profile on our Site;
- sign up for our newsletters and other services;
- make online purchases;
- enter sweepstakes and contests;
- complete surveys;
- contribute to a social forum on the Site; or
- submit a comment or question to us by using a “contact us” or similar feature on the Site.
3.4. As much as possible or unless provided otherwise under this PPS, we will collect your information directly from you. If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless:
we have collected this information from publicly available sources;
we have taken reasonable steps to ensure the organisation who has provided us with this information has complied with the Australian Privacy Principles; or
as otherwise required by law.
3.5. When you engage in certain activities, such as entering a contest or promotion, filling out a survey or sending us feedback, we may ask you to provide certain information. It is completely optional for you to engage in these activities.
3.6. Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory data or any other information we require in order for us to provide our services to you, we may be unable to effectively provide our services to you.
3.7. If you use our website, we may utilise “cookies” which enable us to monitor traffic patterns and to serve you more efficiently if you revisit our website. A cookie does not identify you personally but may identify your internet service provider or computer. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance.
3.8. We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.
How we may use and disclose your personal information
4.1. We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to and/or as set out below.
4.2. You consent to us using and disclosing your personal information to facilitate a purpose in connection with:
if required, the verification of your identity and other personal information;
the administration and management of our services, including billing, credit card authorisation and verification;
marketing and promotional activities by us and our related bodies (including by direct mail, telemarketing, email, SMS and MMS messages) including information about products, services, and events, of ours and of others, that we think might interest you. You may opt out of receiving such notices from us;
the improvement of our services (including to contact you about those improvements and asking you to participate in surveys about our products and services);
to provide customer service functions, including handling customer enquiries and complaints;
our compliance with applicable laws;
processing and fulfilling your transactions;
protecting our rights and property;
customising the Site and third-party ads displayed to you on our Site and elsewhere to your interests and history with us;
other purposes described at the time you choose to provide Personal Information to us; or
any other matters reasonably necessary to continue to provide our products and services to you.
4.3. We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:
when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose;
if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
if it is required or authorised by law.
4.4. In the event we propose to use or disclose such personal information other than for reasons in 4.1, 4.2, and 4.3 above, we will first seek your consent prior to such disclosure or use.
4.5. If you have received communications from us and you no longer wish to receive those sorts of communications, you should contact us via the details set out at the top of this document and we will ensure the relevant communication ceases.
How we may share Personal Information and Site usage information with others
5.1. We may share the information we collect on the Site with others for a variety of reasons. In addition to the kinds of information sharing you might expect, such as sharing with our subsidiaries, affiliates and third-party providers who need your information in order to provide services to us or on our behalf, and sharing what you voluntarily post to public areas on the Site with other Site users, we may share your information:
with our affiliates and other third parties for their marketing and other purposes, unless you tell us not;
with our co-sponsor(s) if we obtain your information in connection with a contest, sweepstakes, offering, or other promotional activity that is jointly offered by us and any third parties, unless you tell us not to;
when we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law;
in connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets, or wind-down of a business.
5.2. Your personal information is disclosed to these organisations and/or parties only in relation to the goods or services we provide to you or for a purpose permitted by this PPS.
5.3. We take such steps as are reasonable to ensure that these organisations and/or parties are aware of the provisions of this PPS in relation to your personal information.
6.1 We may incorporate some third party social networking features onto our Site or utilise third-party provided platforms to publish or manage the Site or portions thereof. Through these platforms and features, we receive some Personal Information and some Site usage information about you, and this PPS applies to that information as well. In addition, some providers of third party social networking platforms have their own privacy policies which they may collect, use and protect your information.
7.1 We may make available mobile applications (or “apps”) that you are able to download to and use from your mobile device. Depending on the nature and functionality of the app, we may collect Personal Information and non-personally identifiable usage information through the app. The app also may collect information about your mobile device, such as your device’s unique device ID (UDID), the IP address of your mobile device, device type, operating system and connection information. If you opt-in, some of our apps may collect your device’s precise real-time location, and in such cases, you may be able to opt out from further allowing us to have access to such location data by managing your location preferences in the app and/or on your device. This Policy may be supplemented from time to time with additional terms applicable to individual apps, or individual apps may be subject to separate privacy policies of which we will notify you by posting them on such apps.
8.Data quality and security
8.1. We have taken steps to help ensure your personal information is safe. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information, especially where the Internet is involved.
8.2. Notwithstanding the above, we will take reasonable steps to:
make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.
8.3. However, the accuracy of personal information depends largely on the information you provide to us, so 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).
Access to and correction of your personal information
9.1. You are entitled to have access to any personal information relating to you which we possess, except in some exceptional circumstances provided by law. You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.
9.2. If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out at the top of this document.
Resolving Privacy Complaints
10.1. We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.
10.2. If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information, please contact us by:
10.3. Please mark your correspondence to the attention of the Privacy Officer.
10.4. In order to resolve a complaint, we:
will liaise with you to identify and define the nature and cause of the complaint;
may request that you provide the details of the complaint in writing;
will keep you informed of the likely time within which we will respond to your complaint; and
will inform you of the legislative basis (if any) of our decision in resolving such complaint
10.5. We will keep a record of the complaint and any action taken in a Register of Complaints.
11.1. By using our website or by accepting the terms of one of our terms and conditions which refer to this PPS, you are agreeing to the terms of this PPS.
11.2. We reserve the right to modify our PPS as our business needs require. We will notify you of such changes (whether by direct communication or by posting a notice on our website), after which, your continued use of our products, services or website or your continued dealings with us shall be deemed to be your agreement to the modified terms. If you do not agree to our continued use of your personal information due to the changes in our PPS, please contact us via the details set out at the top of this document.