INTRODUCTION
This Privacy Statement explains in general terms how Compaigns collects, holds, uses and discloses your personal information under the Australian Privacy Principles.
We may amend this Privacy Statement as our business requirements or the law changes. Any changes to this Privacy Statement will be updated on compaigns.com.au. We may also issue specific privacy collection notices from time-to-time relating to particular products or services.
This Privacy Statement does not apply to Compaigns’s employee records.
1 INFORMATION WE COLLECT
The types of personal information that we collect about you will depend on our relationship with you, the circumstances of collection and the type of service you request from us. The personal information may include:
1.1 In the course of business it is necessary for us to collect Personal Information. This information allows us to identify who an individual is for the purposes of our business, share Personal Information when asked of us, contact the individual in the ordinary course of business and transact with the individual. Without limitation, the type of information we may collect is:
(a) Personal Information. We may collect personal details such as an individual’s name, location, date of birth, nationality, family details and other information defined as “Personal Information” in the Privacy Act that allows us to identify who the individual is;
(b) Contact Information. We may collect information such as an individual’s email address, telephone & fax number, third-party usernames, residential, business and postal address and other information that allows us to contact the individual;
(c) Financial Information. We may collect financial information related to an individual such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our services;
(d) Statistical Information. We may collect information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information for statistical purposes; and
(e) Information an individual sends us. We may collect any personal correspondence that an individual sends us, or that is sent to us by others about the individual’s activities.
1.2 We may collect other Personal Information about an individual, which we will maintain in accordance with this Privacy Policy.
1.3 We may also collect non-Personal Information about an individual such as information regarding their computer, network and browser. This may include their IP address. Where non-Personal Information is collected the Australian Privacy Principles do not apply.
2 HOW WE COLLECT INFORMATION
We may collect personal information about you when you use our products and services, register to receive our newsletters or other communications, register to be part of one of our programs, tell us about your preferences of content, rewards and communication, register to enter prize draws, competitions and collect reward offers, participate in online surveys or question polls or purchase goods through our partners. As well as collecting information directly from you, there may be occasions when we collect information about you from a third party. These third parties may include:
2.1 Most information will be collected in association with an individual’s use of Compaigns, an enquiry about Compaigns or generally dealing with us. However we may also receive Personal Information from sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners. In particular, information is likely to be collected as follows:
(a) Registrations/Subscriptions. When an individual registers or subscribes for a service, list, account, connection or other process whereby they enter Personal Information details in order to receive or access something, including a transaction;
(b) Accounts/Memberships. When an individual submits their details to open an account and/or become a member with us;
(c) Supply. When an individual supplies us with goods or services;
(d) Contact. When an individual contacts us in any way;
(e) Access. When an individual accesses us physically we may require them to provide us with details for us to permit them such access. When an individual accesses us through the internet we may collect information using cookies (if relevant – an individual can adjust their browser’s setting to accept or reject cookies) or analytical services; and/or
(f) Pixel Tags. Pixel tags enable us to send email messages in a format customers can read and they tell us whether mail has been opened.
2.2 As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their Personal Information is being collected.
2.3 Where we obtain Personal Information without an individual’s knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information,
3 WHEN PERSONAL INFORMATION IS USED AND DISCLOSED
3.1 In general, the primary principle is that we will not use any Personal Information other than for the purpose for which it was collected other than with the individual’s permission. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted.
3.2 We will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
3.3 It may be necessary for us to disclose an individual’s Personal Information to third parties in a manner compliant with the Australian Privacy Principles in the course of our business.
3.4 We will not disclose or sell an individual’s Personal Information to unrelated third parties under any circumstances.
3.5 Information is used to enable us to operate our business, especially as it relates to an individual. This may include:
(a) The provision of goods and services between an individual and us;
(b) Verifying an individual’s identity;
(c) Communicating with an individual about:
i Their relationship with us;
ii Our goods and services;
iii Our own marketing and promotions to customers and prospects;
iv Competitions, surveys, prize draws and questionnaires;
(d) Investigating any complaints about or made by an individual, or if we have reason to suspect that an individual is in breach of any of our terms and conditions or that an individual is or has been otherwise engaged in any unlawful activity; and/or
(e) As required or permitted by any law (including the Privacy Act).
3.6 There are some circumstances in which we must disclose an individual’s information:
(a) Where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
(b) As required by any law (including the Privacy Act); and/or
(c) In order to sell our business (in that we may need to transfer Personal Information to a new owner).
3.7 We will not disclose an individual’s Personal Information to any entity outside of Australia that is in a jurisdiction that does not have a similar regime to the Australian Privacy Principles or an implemented and enforceable privacy policy similar to this Privacy Policy. We will take reasonable steps to ensure that any disclosure to an entity outside of Australia will not be made until that entity has agreed in writing with us to safeguard Personal Information as we do.
3.8 We may utilise third-pay service providers (such as Gmail from Google, Inc., and MailChimp from The Rocket Science Group LLC) to communicate with an individual and to store contact details about an individual. These service providers are located in the United States of America.
3.9 We may also disclose your personal information to our suppliers and third parties that perform other services for us in connection with the sale and provision of all our goods and services, including third parties who:
4 HOW INFORMATION IS STORED AND KEPT SECURE
4.1 We may appoint a Privacy Officer to oversee the management of this Privacy Policy and compliance with the Australian Privacy Principles and the Privacy Act. This officer may have other duties within our business and also be assisted by internal and external professionals and advisors.
4.2 We will take all reasonable precautions to protect an individual’s Personal Information from unauthorised access. This includes appropriately securing our physical facilities and electronic networks. We hold your personal information in a combination of hard copy and electronic files. We use third party information system providers who may store or have access to your personal information. We may combine personal information we receive about you with other information we hold about you. This includes information received from our partners or third parties.
4.3 The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet or by post does so at their own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.
4.4 We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s Personal Information to in accordance with this policy or any applicable laws). The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.
4.5 If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.
4.6 We are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information.
5 REMOVAL OF DATA
5.1 If an individual has signed up for our service and would like us to remove their Personal Information from our systems, they should address their request in writing to the privacy office at [email protected], or by using the details found in the conact us section.
5.2 We aim to process all data requests within seven days and will send you a confirmation email once the deletion has taken place.
5.3 Data may still remain in the systems back-up files, which will be deleted periodically.
6 COMPLAINTS AND DISPUTES
6.1 If an individual has a complaint about our handling of their Personal Information, they should address their complaint in writing to the details below.
6.2 If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.
6.3 If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
7 CONTACTING INDIVIDUALS
7.1 From time to time, we may send an individual important notices, such as changes to our terms, conditions and policies. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications.
7.2 Subscribers understand that they have joined our mailing list and consent to receiving email communications. The majority of communication will be in regards to the prize draw they have entered and offered opportunities to increase their entries in the draw.
8 GENERAL DISCLAIMERS
8.1 This Website is provided by Compaigns on an “as is” basis without any express or implied warranty of any kind.
8.2. The World Wide Web exists across open public networks that are neither secure nor private. Accordingly you acknowledge and accept the risk that any communication to or from the Website may be intercepted, used or modified by third parties.
8.3. Compaigns does not warrant that access to or use of the Website will be uninterrupted or error free or that the Website or any material on or accessible through the Website is free from errors or viruses, worms, trojan horses or other harmful components.
8.4. You acknowledge that your access to and use of the Website (including the software operating in connection with the Website) may be interfered with by numerous factors outside of Compaigns’s control.
8.5 Compaigns does not warrant anything about the reliability, accuracy, completeness, timeliness, quality, physical state or suitability for a particular purpose of any material on or accessible through the Website.
8.6 Compaigns makes no commitment to update any material on the Website.
8.7 You are responsible for assessing the accuracy, reliability, suitability and currency of the material on or accessible through the Website.
8.8 You accept all risks and responsibility for all loss, damage, costs and other consequences resulting from using the Website or the material on or accessible through the Website.
9 ADDITIONS TO THIS POLICY
9.1 If we decide to change this Privacy Policy, we will post the changes on our webpage at www.compaigns.com.au . Please refer back to this Privacy Policy to review any amendments.
9.2 We may do things in addition to what is stated in this Privacy Policy to comply with the Australian Privacy Principles, and nothing in this Privacy Policy shall deem us to have not complied with the Australian Privacy Principles.
10 CONTACTING US
You can contact us by:
Our address is Level 2, 11 York St, Sydney NSW 2000