1. Privacy Act
This Policy is intended to cover most personal information handled by us, but is not exhaustive. If you have any queries about our handling of your personal information, please contact us for further information.
No general exemptions under the Act apply to us, or to any of our acts or practices.
3. How We Collect, Hold and Use Personal Information
We will collect your personal information directly from you unless it is unreasonable or impracticable to do so, and will limit the personal information we collect to that which is reasonably necessary for our functions or activities.
The personal information about you we may collect and hold includes but is not limited to your name and address, contact telephone number(s) and/or email address(es). We may also hold other personal information that you volunteer to us.
We may collect this information when:
- you sign up and create an account using the VAMP application (App);
- you send us an e-mail or otherwise contact us (eg, using a comment or feedback form or feature of our website or App); or
- you post a message to our website (eg, any message board forum we may operate).
We do not generally collect (or, if it is provided by you to us, retain) any sensitive information about you.
If you fail to provide personal information requested by us, there may be a range of consequences, for example, you may not be able to use the App or be included in a campaign. There will not usually be Australian laws or court/tribunal orders which require or authorise us to collect your personal information.
We may, in some circumstances, collect personal information about you from third parties, in which case we will take reasonable steps to notify you of that information and the circumstances of its collection. Some specific circumstances where we collect personal information from third parties includes from your Instagram Account and/or Personal Blog.
We will generally only use your personal information for the purpose for which we collectedit, and for related purposes we consider would be within your reasonable expectations.
We generally use your personal information to:
- contact you in relation to services that you may provide to us, such as informing you of a social media campaign that we consider to be of interest to you;
- provide the service requested, respond to your enquiries, send you information that you request, or otherwise achieve the purpose for which the information was submitted to us;
- allow you to use the App and interact with us and our services;
- engage in other activities where required or permitted by law;
- provide you with services;
- provide you with products;
- provide you with payment for any services you provide us, for example, in connection with the App; and
We may use personal information to contact you for marketing and promotional purposes (such as to provide you with information about our products and services, special offers and promotions). You may request not to receive these communications by contacting our Privacy Officer (see section 10 below), or by using the opt out function provided for in those communications or the App. If you do not opt out in either of these ways you will be taken to have consented to receiving such communications from us.
There are no consequences of opting out of receiving our marketing and promotional communications except that you will no longer receive them, and you may elect to rejoin our marketing list at a later stage if you wish.
Where we propose to use your personal information for another purpose other than as outlined above, we will seek your permission (unless we are required or permitted by law to do so without seeking consent).
We will take reasonable steps to protect your personal information from misuse, interferenceand loss as well as unauthorised access, modification or disclosure.
For example, information stored on our computer network is protected by the system design, security access policies and procedures. We undertake regular monitoring of our practices and systems to ensure the effectiveness our security policies and identify and implement improvements where appropriate.
We will endeavour to destroy or de-identify your personal information as soon as it is no longer required by us (where permitted by law).
4. Access to and Correction of Personal Information
You may contact us to request access to or correction of the personal information about you that we hold. We may refuse to allow access or to amend your personal information if we are legally required or entitled to do so. If we do so, we will provide you with written reasons for the refusal (unless it is unreasonable to do so) together with information about the options available to complain about the refusal.
We may require you to pay certain costs in order to access your personal information held by us. We will advise the amount payable (if any) once we have assessed your application for access. We will not however charge a fee for you to lodge a request for access to or correction of your personal information.
If you lodge a request for access to your personal information, we may fulfil that request in any of a range of ways (for example, by supplying you with a copy of that personal information or providing you with the opportunity to inspect our records). We may require you to comply with certain procedures before we allow access to or amendment of your personal information to ensure the integrity and security of information that we hold. Depending on the nature of your request, this may include verifying your identity to our satisfaction.
We will take reasonable steps to ensure that the personal information that we collect is accurate, up-to- date and complete and the personal information we use and disclose is accurate, up-to-date, complete and relevant. If we are satisfied that any personal information we hold about you is inaccurate, out-of- date, incomplete, irrelevant or misleading, we will amend our records accordingly.
Please notify us if your personal details change so that we may keep our records current.
5. Disclosure of Personal Information to Other Organisations and Overseas
We will generally only disclose your personal information for the purpose for which we collected it, and for related purposes we consider would be within your reasonable expectations.
We may disclose your personal information to:
- certain contractors or subcontractors of ours that provide administrative or promotional services (for example, mail processing businesses, printers, market research companies or other service providers). We generally ensure such organisations are contractually required to ensure that information we disclose is used only for the limited purposes for which we provide it;
- VAMP may at times disclose limited personal information including Instagram account and name details to the customers it manages social media campaigns for others.
We may disclose your personal information to overseas recipients if it is required to fulfil the purpose for which we collected it, in which case we must take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles as required by Australian Privacy Principle 8. However, we are not generally likely to disclose personal information to overseas recipients.
6. Online Privacy
6.1. Automatic Server Logs
- your IP (Internet Protocol) address (generally being an identifier assigned to your computer or access device when it is connected to the Internet);
- the operating system and browser software you are currently using; and
- the data you access (such as web pages or other document files or software), and thetime that you download it.We do not attempt to identify individuals using this information, and only use it for statistical analysis, system administration, and similar related purposes. This information is not disclosed to any other party.
We do not attempt to specifically identify or track individuals using cookies.
6.3. Email and Message Forms
We may collect personal information from you (such as your name, address, telephone number and email address, and any other personal information you volunteer) if you send us email or if you submit information to us using a message or feedback form. We will use this personal information to contact you to respond to your message, to send you information that you request, and for other related purposes we consider are within your reasonable expectations. We will not use or disclose any such information for any other purpose without your consent.
6.4. Storage and Transmission of Personal Information Online
If you provide any personal information to us via our online services (including email) or if we provide such information to you by such means, the privacy, security and integrity of this information cannot be guaranteed during its transmission unless we have indicated beforehand that a particular transaction or transmission of information will be protected (for example, by encryption).
If we receive your personal information, we will take reasonable steps to store it such that unauthorised access, modification, disclosure, misuse and loss are prevented.
6.5. Other Online Services
If you believe that a breach of your privacy has occurred, we encourage you to contact us todiscuss your concerns. Our contact details can be found in section 10 below.Your complaint will be considered and dealt with by our Privacy Officer. The Privacy Officer may escalate the complaint internally within our organisation if the matter is serious or if necessary to resolve it.Please allow us a reasonable time to respond to your compliant. If you are not satisfied with our resolution, you may make a complaint to the Office of the Australian Information Commissioner, whose contact details can be found at: http://www.oaic.gov.au/.9. Further Information
You may contact us if you require further information about the ways we manage your personal information.
Level 1, 15-17 Young Street
Sydney, New South Wales 2000
Phone: 1300 606 614 , or email: email@example.com 30th October 2015