QUICK GUIDE TO CONTENTS
- Information we collect on our platforms
- How we use the information we collect
- Sharing of your personal information
- Information we receive from third parties
- Your privacy rights, choice and access; how to opt-out
- Advertising/behavioural targeting;
- Security of your information
- Other sites
- Consent to processing and transfer of information internationally
- Contact us
- INFORMATION WE COLLECT ON OUR PLATFORMS
Information You Provide To Us
We may collect personal information (information that can be used to identify you as an individual or information by which your identity can reasonably be ascertained) such as your name, email, telephone number, home address, and demographic information (such as zip code, age) (“Personal Information”). The types of Personal Information we collect may vary depending on your use of the features of the Platforms.
We do not generally collect “sensitive information” as defined by the Privacy Act (such as information about ethnic origin, religious or political views, health information, tax fil numbers etc) from you.
You have the option of not disclosing Personal Information to us or to use a pseudonym when dealing with us in relation to a particular matter. If you choose to withhold any Personal Information, we may not be able to provide you with part or all of our products or services or resolve a particular matter raised by you.
Information We Collect Automatically
Usage Information. Whenever you visit or interact with the Platforms, we, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Platforms are accessed and used (“Usage Information”). Usage Information may include browser type, device type, operating system, application version, the page served, the time, the preceding page views, and your use of features or applications on the Platforms, interaction with friends and group activities. This information helps us keep our Platforms fresh and interesting to our visitors and allows us to tailor content to a visitor’s interests.
Device Identifier. We automatically collect your IP address or other unique identifier (“Device Identifier”) for the Device (computer, mobile phone, tablet or other device) you use to access the Platforms. A Device Identifier is a number that is assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier. We may use a Device Identifier to, among other things, administer the Platforms, help diagnose problems with our servers, analyze trends, track users’ web page movements, help identify you, and gather broad demographic information for aggregate use.
Cookies; Pixel Tags. The technologies used on the Platforms to collect Usage Information, including Device Identifiers, may include but are not limited to: cookies (data files placed on a Device when it is used to visit the Platforms), mobile analytics software and pixel tags (transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed). Cookies may also be used to associate you with social networking sites like Facebook and Twitter and, if you so choose, enable interaction between your activities on the Platforms and your activities on such social networking sites. We, or our vendors, may place cookies or similar files on your Device for analytics and security purposes, to facilitate site navigation and to personalize your experience while visiting our Platforms (such as allowing us to select which ads or offers are most likely to appeal to you, based on your interests, preferences, location, or demographic information). A pixel tag may tell your browser to get content from another server.
To learn how you may be able to reduce the number of cookies you receive from us, or delete cookies that have already been installed in your browser’s cookie folder, please refer to your browser’s help menu or other instructions related to your browser. If you do disable or opt out of receiving cookies, please be aware that some features and services on our Platforms may not work properly because we may not be able to recognize and associate you with your account(s). In addition, the offers we provide when you visit us may not be as relevant to you or tailored to your interests.
Google Analytics. Our Platforms use Google Analytics, including certain advertising features (Google Analytics Demographic and Interest Reports, Google Remarketing with Analytics, Google Segments, Double Click by Google and Adwords). These features use third party cookies to collect information about our website traffic by tracking users across websites and across time and generating reports for us to better understand our Platform users and to create audiences for our advertisements based on such understanding. These features also enable Google Analytics to collect data about our traffic through cookies and anonymous identifiers. We use this information to better understand our users and to optimize our Platforms. For more information on how to opt out of our use of Google Analytics, including advertising features, please visit https://tools.google.com/dlpage/gaoptout and http://www.google.com/safetycenter/tools/#manage-your-ads-preferences.
- HOW WE USE THE INFORMATION WE COLLECT
We use the information we collect about and from you for a variety of business purposes such as to respond to your questions and requests; provide you with access to certain areas and features of the Platforms such as your favorite products; verify your identity; communicate with you about your activities on the Platforms and, in our discretion, changes to any of our policies; tailor content, advertisements, and offers we serve you; improve the Platforms; comply with license obligations; and for purposes disclosed at the time you provide your Personal Information or otherwise with your consent. We may also collect your location based information for the purpose of providing you with certain services.
We may also use your Personal Information for purposes authorised by laws, or regulations, such as to prevent or investigate alleged crime or fraud.
- SHARING OF YOUR PERSONAL INFORMATION
Except as described here, we will not provide any of your Personal Information to any third parties without your specific consent. We may share non-Personal Information, such as aggregate data and Usage Information with third parties. We may also share your information as disclosed at the time you provide your information, as set forth in this Privacy Notice and in the following circumstances:
Third Parties Providing Services On Our Behalf. We may share your Personal Information with third parties that perform functions on our behalf (or on behalf of our partners) such as service providers that host or operate our Platforms, analyze data, or provide customer service; advertisers; sponsors or other third parties that participate in or administer our promotions, contests, sweepstakes, surveys or provide marketing or promotional assistance and “powered by” partners or partners in co-branded sites. Your Personal Information may also be used by us or shared with our subsidiaries, affiliates, sponsors, partners, advertisers or other third parties to provide you with product information and promotional and other offers.
Business Transfers. We may share your Personal Information with other entities and our affiliates primarily for business and operational purposes. In the event that we are involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction.
- INFORMATION WE RECEIVE FROM THIRD PARTIES
We may receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from us, that website will submit to us your email address and other information about you so that we may contact you as requested. You may also choose to participate in a third party application or feature (such as one of our Facebook or Twitter applications or a similar application or feature on a third party website) through which you allow us to collect (or the third party to share) information about you, including Usage Information and Personal Information such as lists of your friends, “likes”, comments you have shared, groups and location. In addition, we may receive information about you if other users of a third party website give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third party website or interactive service. We may supplement the information we collect about you through the Platforms with such information from third parties in order to enhance our ability to serve you, to tailor our content to you and/or to offer you opportunities to purchase products or services that we believe may be of interest to you.
- YOUR PRIVACY RIGHTS, CHOICE AND ACCESS, AND HOW TO OPT OUT.
You may always direct us not to share your Personal Information with third parties, not to use your Personal Information to provide you with information or offers, or not to send you newsletters, emails or other communications by: (i) sending us an email at email@example.com; or (ii) following the removal instructions in the communication that you receive. Your opt-out request will be processed within 30 days of the date on which we receive it.
If you wish to modify, verify, correct, or delete any of your Personal Information collected through the Platforms, you may contact us at the above telephone number or email. In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Platforms. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. It may not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other reasons. We will retain your information (including geo-location data) for as long as needed to provide you services. If you wish to cancel your account or request that we no longer use your information to provide you services contact us at the above telephone number or email. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We do not control certain privacy settings and preferences maintained by our social media partners like Facebook and Twitter. If you wish to make changes to those settings and preferences, you may do so by visiting the settings page of the appropriate social media site. We do not respond to “do not track” signals communicated to us by a browser.
Our objective is to respond to any request to access personal information within a reasonable timeframe and no later than thirty (30) days. We will endeavour to inform you if this timeframe is not achievable.
In some circumstances, we may not be in a position to grant access to your Personal Information, such circumstances include:
(a) providing access is likely to pose a serious threat to the safety of an individual or the public;
(b) providing access is likely to unreasonably impact on the privacy of others;
(c) the request for access is frivolous or vexatious;
(d) providing access would reveal information which relates to existing or anticipated legal proceedings or otherwise impact on any negotiations;
(e) providing access is unlawful (including being unlawful as directed by a court or tribunal order) or is likely to impact on actions being taken in relation to alleged unlawful activities relating to our functions and activities; or
(f) granting access would impact on a commercially sensitive decision making process.
- ADVERTISING/BEHAVIORAL TARGETING.
We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. The Platforms are not directed to children under 15. We do not knowingly collect, use or disclose personally identifiable information from anyone under 15 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 15, we will make reasonable efforts to delete such information from our records. A parent or legal guardian can notify us of an inadvertent collection of Personal Information from a child under the age of 15 and request that we remove such information by sending an email to or by contacting us at the contact information below. Any such request must contain the child’s name and email address so we can locate such child’s Personal Information
- SECURITY OF YOUR INFORMATION.
We take information security seriously and use certain reasonable security measures to help protect your Personal Information. We conduct various physical, electronic, administration and managerial security procedures in order to protect Personal Information from loss and misuse, and from unauthorised access, modification, disclosure and interference.
All information you provide to us is stored on our secure servers.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Platforms; any transmission of your Personal Information to us, or the disclosure of or use of your Personal Information on our Platform is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We regularly review security and encryption technology and will strive to protect your Personal Information as fully as we protect our own confidential information.
- OTHER SITES.
The Platforms may contain links to other sites that we do not own or operate. This includes links from advertisers, sponsors and/or partners that may use our logo(s) as part of a co-branding or co-marketing agreement. We do not control, recommend or endorse and are not responsible for these sites or their content, products, services or privacy policies or practices. These other sites may send their own cookies to your Device, they may independently collect data or solicit Personal Information and may or may not have their own published privacy policies. You should also independently assess the authenticity of any site which appears or claims that it is one of our Platforms (including those linked to through an email or social networking page).
The Platforms may make available chat rooms, forums, message boards, and news groups. Remember that any information that you disclose in these areas becomes public information and is not subject to the provisions of this Privacy Notice.
- CONSENT TO PROCESSING AND TRANSFER OF INFORMATION INTERNATIONALLY.
Personal Information, including Personal Information obtained from our Platforms, may be stored, disclosed, processed in or transferred in France from time to time. The Platforms are governed by and operated in, and in accordance with the laws of France. France and other countries in which the Personal Information is received may not have data protection laws equivalent to those in force in Australia and we make no representation that the Platforms are governed by or operated in accordance with the laws of any other nation.
By using the Platforms, or providing us with any information, you acknowledge and agree to such international data and information transfers with respect to your Personal Information.
Clause 8.1 of the Australian Privacy Principles contained in Schedule 1 of the Privacy Act 1988 (Cth) provides that if we disclose Personal Information about an individual to an overseas recipient, then we must take such steps as are reasonable in the circumstances to ensure the overseas recipient does not breach the Australian Privacy Principles in relation to such information. An exception to this is if we obtain your consent. We intend to rely on this exception in the following way. Unless you notify us in writing to the contrary, you will be taken to have consented to the disclosure by us of Personal Information to overseas recipients on the basis that:
(a) clause 8.1 of the Australian Privacy Principles will not apply to such disclosure;
(b) if the overseas recipient engages in any act that contravenes the Australian Privacy Principles, you will not be able to seek redress under the Privacy Act 1988 (Cth);
(c) the overseas recipient may not be subject to any privacy obligations or to any principles similar to the Australian Privacy Principles;
(d) you may not be able to seek redress in the overseas jurisdiction; and
(e) the overseas recipient is subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.
In addition, you also agree and acknowledge that:
(a) the Platforms are subject to the laws of France;
(b) you consent to the collection, processing, maintenance and transfer of such information in and to France and other applicable territories in which the privacy laws may not be as comprehensive as or equivalent to those in the country where you reside and/or are a citizen; and
(c) you waive any claims that may arise under those laws.
We may update this Privacy Notice to reflect changes to our information practices. If we make any material changes we will notify you by either email (sent to the e-mail address you have provided) or by means of a notice on our Platforms prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.
- CONTACT US.
You have a right to complain about our handling of your Personal Information if you believe that we have breached the Australian Privacy Principals. If you wish to make such a complaint to us, you should first contact our Privacy Officer in writing. Your complaint will be dealt with in accordance with our complaints procedure. We will try to resolve the complaint within 30 days. When this is not possible, we will endeavour to contact you within that time to let you know how long it will take to resolve the complaint.
If you are unhappy with our response to your complaint, you may refer your complaint to the office of the Australian Information Commissioner, whose contact details are found on their website http://www.oaic.gov.au/.
If you have any questions or concerns about this Privacy Notice, the practices of the Platforms, or your experiences with the Platforms, please contact our Privacy Compliance Officer: firstname.lastname@example.org.