Issue date: 17/08/2016
The Trustee for The STAN Enterprises Discretionary Trust ABN 79 275 347 233 ("we" and/or "us" and/or "our") is committed to compliance with privacy laws which apply to its businesses. In providing our services to you, we will be transparent about how and why we collect and use your information.
- The kind of information we may collect about you, how we collect it, and how we use it;
- How we may disclose that information;
- How you can access the information we hold about you;
- When we may use your information to contact you;
- The protection of your personal information;
This policy applies only to us. It does not apply to any other company or organisation, including those whose digital services have links to our content or services. Third party services which have links to our content or services will govern the use of personal information you submit to them, which may also be collected by cookies when you visit or use them. We do not accept any responsibility or liability for the privacy practices of such third party digital services.
We will review this policy regularly, and may update it from time to time. If we make changes, we will post those changes on the privacy page of our website.
COLLECTION OF PERSONAL INFORMATION
Why we collect personal information
We collect personal information about you:
- Because you have provided it to us, for instance if you contact us to make comments, complaints or to ask us questions, or you have interacted with one of our digital services (including online and mobile services), for instance by participating in forums, polls or competitions;
- Because we need it to provide a product or service that you have requested, for instance, if you subscribe to an email list or loyalty program, opt-in to direct marketing, enter a competition or promotion, purchase products or request home deliveries;
- Because we would like to improve our services, for instance through the collection and analysis of statistical and research data and use of ‘cookies’;
- For purposes directly related to any of the above.
Privacy law requires us to only collect personal information about you if it is reasonable and practical to do so. You have the right to tell us that you do not want us to send information to you other than for the main purpose for which we have collected your personal details.
Generally, you have no obligation to provide any information requested by us. If you choose to withhold requested information however, we may not be able to provide you with the goods and services that depend on the collection of that information, particularly if the collection of that information is required by law.
Types of personal information we collect
We may collect the following types of personal information from you:
- Personal information, such as when you provide your name, address, telephone number or e-mail address when subscribing or signing up to a service.
- Data that tracks your activity, such as your server address, domain name, the date and time of your visit to our website and the information downloaded (see below for information on cookies).
In the event that we receive or come across personal information about you which we have not requested, we will take all reasonable steps to check that the information is necessary for our activities and business and that you have provided consent for the information to be used/collected/disclosed. If deemed not appropriate and in line with your consent, we will destroy or de-identify the information received.
Anonymity and pseudonymity
To access our service and the respective products you may choose to register your details on the respective product anonymously or under a pseudonym. Note however that there will be instances where we will need to identify you and we will need to collect and record your personal information to provide you with the service you expect.
DISCLOSURE OF PERSONAL INFORMATION
Disclosure of personal information to third parties
Where possible, we try to ensure that our disclosure of information to other organisations is in a way which does not personally identify individuals.
We may disclose your personal information to third parties for the following purposes:
- to provide the service you wish to use;
- for research purposes relating to the performance, quality, maintenance and improvement of the our services and products;
- for the purposes of direct marketing of our services;
- to provide technical support to you to use our services;
- if permitted or required by law; or
- otherwise with your consent.
We are assisted by a variety of third parties to deliver the services offered by us. These third parties may include:
- Technology service providers including:
- Internet service providers
- App service providers
- Cloud service providers
- Promotion or marketing service providers
- Subscription service providers and their mailing houses.
Under no circumstances will we sell or receive payment for licensing or disclosing your personal information.
Disclosure of personal information to overseas recipients
We may allow your personal information to be shared with those who are in countries other than your own location. We do this where we have made a business decision to store our data with a trusted service provider who is in the business of providing data storage and processing services. Examples are those who store and process our email and mobile application data. These services commonly involve diverse geographic locations which change from time to time for reasons which include data protection and processing efficiency. Where these services are used by us, it is not practical for us to notify you of which country your personal information may be located in.
Third party compliance
We will take reasonable steps to ensure that the above overseas recipients do not breach the APPs in relation to the disclosed personal information.
In many cases, we impose contractual restrictions in respect of collection and use of personal information by those third parties. In some cases, such as social media networks, our ability to impose contractual restrictions is limited. In those circumstances, we will carefully consider the risks to the protection of personal information when entering into arrangements with third parties.
Opt out of direct marketing
You will be able to opt-out of direct marketing at any time if you so choose by:
- Clicking ‘unsubscribe’ on the email marketing received; or
- Emailing us at: firstname.lastname@example.org
However, you should be aware that we may continue to store personal information provided by you prior to you opting-out.
Your ability to opt-out of a third party tool or platform will depend on the conditions governing your agreement with that third party.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You have the right to request access to personal information that is held by us about you. Requests for access will be dealt with by us in accordance with the Freedom of Information Act 1982.
You also have the right to request the correction of any of your personal information that we hold. We will take reasonable steps to make appropriate corrections to personal information so that it is accurate, complete and up-to-date.
To seek access to, or correction of, your personal information please contact as follows:
By email: email@example.com
To help us to properly identify you, we will require some proof of identity. For most requests, your information will be provided free of charge, however we may charge a reasonable fee if your request requires a substantial effort on our part.
PROTECTION OF YOUR PERSONAL INFORMATION
We will take reasonable and practicable measures to ensure your personal information is protected from unauthorised access, loss, misuse, interference, loss, disclosure or alteration. We also take measures to destroy or permanently de-identify personal information when it is no longer required. The types of measures we take vary with the type of information, and how it is collected and stored.
We encourage you to be vigilant about the protection of your own personal information when using third party digital services (such as social media platforms).
When you browse websites maintained by us, information about your activity may be stored on your computer in a file known as a “cookie”. A cookie allows our servers to identify and interact more efficiently with your computer device by:
- maintaining the continuity of your browsing session (e.g. if you are looking at multiple products on our website); and
- remembering your details and preferences when you return.
Our cookies do not store personal information that can be retrieved to identify you.
You can also control your activity preferences regarding Adobe Flash, local shared objects (LSOs). You can find out more at: http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.
When you interact with us, other information which may be recorded includes software versions you are using, your IP address, information regarding location (if this is not disabled), dates, times, file metadata, data which you have entered and user activity such as links you have visited.
ACCESS TO INFORMATION WE HOLD ABOUT YOU
If you request access to the personal information we hold about you, we will respond to your request within a reasonable period of time, where reasonable and practicable. This will be subject to any exemptions allowed under the Privacy Act. You may request this information sending an email to us at: firstname.lastname@example.org. Alternatively, you can write to us at: 3/362 Military Road, Cremorne, NSW, 2090.
You have the option to either not identify yourself or to use a pseudonym when you contact us, unless it is impracticable for us to communicate with you in that manner or unless we are required or authorised under Australian law, or a court or tribunal order, to deal with individuals who have identified themselves.
More information about privacy law and principles is available from the Privacy Commissioner. The Privacy Commissioner may be contacted at www.oaic.gov.au (email@example.com).