APN Newspaper Pty Ltd
2. WHAT INFORMATION DO WE COLLECT?
We collect personal information to provide Company Services and for our business operations. If you choose not to provide the information we request from you, we may not be able to provide you with the services you require. We describe the main types of personal information we collect and the main reasons why we collect that information below.
Registration Information is the information you provide to Company when you register for or acquire a Company Service. This may include information you provide us to:
Registration Information includes, for example, your name, delivery or postal address, email address, gender and birthday.
You are able to use some Company Services without providing any personal information (for example when browsing our digital products as a casual user) or by providing an alias. We usually tell you when you are able to use Company Services in this way.
Public Information and Posts include comments or content that you post to the online Company Services and the information about you that comes with those posts. This may include your name, user name, comments, likes, tweets, status, profile information and picture(s). Public Information and Posts are available to everyone who views our websites and may be displayed in search results on external search engines, even after you cancel your account with us.
Information from third party Social Media. If you access or log-in to a Company Service through a third party social media service or connect a Company Service to your social media profile, we may also include information from that social media service. This may include:
Activity Information – cookies and other technologies. When you visit Company's websites (including to access and use Company Services) we may collect information about your visit. For example, in order to connect you to the Company Services, our servers receive and record information about your computer, device, and browser, which may include your IP address, browser type, and other software or hardware information. If you access the Company Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data, or other transactional information from that device.
Information from Other Sources. We may supplement the information we collect about you with information from other sources. This may include information from publicly available sources (such as other published content) and data providers, as well as information from our business partners or related and affiliated companies in Australia or internationally.
where that collection, use or disclosure relates to your employee relationship with us and the records we hold about you as an employee.
Company also collects personal information about our suppliers and individuals employed by our suppliers (including service and content providers), contractors, dealers, related companies, agents and corporate customers. We will explain why we are collecting this information and how we will use that information, unless it obvious from the circumstances.
3. HOW DO WE USE YOUR INFORMATION?
We use the information we collect about you to provide Company Services to you. As part of our service to you we may use your personal information:
Where your personal information is contained in an advertisement which we publish for you, we may also use your information to publish that advertisement in other media. We do this in accordance with our terms and conditions for the initial publication. If you include personal information in any posts or in a letter, email or text message to an editor or journalist, we may publish your name and suburb to identify you as the author of that post if we publish it in any media.
When we collect your information, we may explain that we will use and disclose your information in other ways. For example, if you win a competition, we may disclose your information to relevant regulatory authorities and publish your details in accordance with the competition terms.
We may also remove certain information or alter the information we collect about you so you can no longer be identified from that information. We do this so that we can use it or disclose it to third parties for other purposes.
We use the information we collect about you for the following additional purposes:
Research and data analysis. We may also use your information for research and data analysis to improve Company Services. We may do this research or engage a service provider to do this.
To allow service and content providers to assist us in providing and managing the Company Services. We may make your information available to certain third party service and content providers who help us manage or provide the Company Services or provide Company with related services. This might include providers of cloud services, website hosting service providers, debt collection service providers and direct marketing service providers. These third parties may be located in a range of different countries including the United Kingdom, United States of America and Singapore. Our agreements with these third party providers require them not to use your information except for the purpose for which your information was provided. We also require them to comply with relevant privacy laws.
To allow social sharing functionality. If you log in with or connect a social media profile with your Company Services account, we may share your personal information (including your user name, picture, tweets, likes and posts) with other Company Services users and your friends or followers linked to your social media profile. We may also share the same information with the social media service provider.
To deliver relevant advertisements and content. Company and our advertisers may use the information we collect about you to provide you with relevant advertisements and content when you use Company Services. We may also use your personal information so that relevant advertising can be provided to you when you use services or visit websites of other organisations.
We may combine information that we hold about you with information about you that we collect from other trusted businesses with whom you also have a relationship or from public sources and we may associate your browser and/or device with other browsers or devices you use. We may also share information we hold about you with those trusted businesses so that they can do the same thing.
We and those trusted businesses do this in order to enable the development of consumer insights about you so that each of us can serve you better. This includes being able to better understand your preferences and interests, personalise your experience, enhance the products and services you receive, and to tell you about products and services. Where those insights are provided to others for their own marketing purposes, such insights do not contain any information that identifies you. We may also use third party service providers to undertake the process of creating these consumer insights.
For more information about this, please see our Data Usage Policy. In Section 6, below, we provide information about how to choose what advertisements you see when using the Company Services.
To contact you. From time to time, we may send you promotional materials or other information which we think may interest you. For example, we may send you an invitation to participate in various activities (such as customer surveys) or special offers.
To share with business partners. Company may share your information with business partners so they can send you marketing communications. This will only happen if you have expressly agreed to this.
To protect the rights of Company and others. We may share your information with other third parties where we are lawfully entitled to do so. This includes when we have a reasonable basis to believe that sharing your information is necessary to:
To complete a merger or sale of assets. If Company sells all or part of its business or assets, we may disclose your information to the party or parties involved in the sale transaction. We may also do this if Company is involved in a merger or transfer of all or a material part of its business. We may disclose your information prior to the sale, transfer or merger so that the party or parties involved can consider the transaction and complete any due diligence.
4. HOW DO WE PROTECT YOUR INFORMATION?
We use reasonable measures to safeguard the personal information we hold about you from loss, theft and unauthorised use, disclosure or modification, including:
System security We take reasonable steps to prevent unauthorised access to our online and computerised systems by using measures such as firewalls, data encryption, virus detection methods, and password restricted access.
Property security At our business premises, we may engage security personnel and use ID cards to restrict access to those premises.
Third parties We take reasonable steps to ensure that third parties who store or assist us to store your personal information adopt appropriate security measures.
5. HOW CAN YOU ACCESS YOUR INFORMATION?
If you would like to access, review, correct or update your personal information, you may contact us (see section 8). When you contact us, please provide your name and contact details (including your email address, address, and telephone number) and specify clearly what information you would like to access, review, correct or update. We will need to share your information with others who can help us respond to your request. We will try to respond to your request as soon as reasonably practicable. If we refuse your request we will generally tell you why.
6. HOW CAN YOU OPT OUT?
Direct marketing. If you do not want to receive promotional messages from us, you can change your account settings or follow the unsubscribe instructions which we include at the bottom of our emails and text messages. If you have installed our app, you can stop push notifications by changing the settings in the app or on your mobile device.
If you have linked any of your social media profiles to your account for any Company Service, you can cancel that link by changing your account settings. If you need any assistance with changing your account settings, please call us (see Section 8).
7. OTHER IMPORTANT INFORMATION FOR YOU
Location of Data. Some Company Services are hosted in and managed outside of Australia, including in the United Kingdom, the United States of America and Singapore. In dealing with Us, you consent to this practice, understanding that your personal information may be accessible from or transmitted outside Australia.
If you share your information with a social media service (including by posting information to that service), this information may not be removed even after you cancel your account. If you delete your account with us, your account information may still be accessible by others for a short period of time because of the way that your information is stored on the internet.
Complaint. If you think we have breached the Privacy Act 1988 (Cth) or other applicable privacy laws, you can contact us (see Section 8) to make a complaint. When you contact us, please include your name and contact details (including your email address, address, and telephone number) and clearly describe your complaint. We will need to share your information with others who can assist in responding to your complaint. We will contact you within 7 days to let you know the next steps in resolving your complaint and to obtain any further information we need to consider your complaint. As soon as reasonably practicable and in any event within 30 days, we will let you know our decision. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (www.oaic.gov.au).
8. HOW YOU CAN CONTACT US
9. LIST OF INCLUDED COMPANIES
APN Newspapers Pty Ltd and its related bodies corporate (ARM, our, us, we) respect your right to privacy.
We encourage you to check this policy regularly as this policy may change from time to time. If you have any suggestions or concerns that are not addressed in this policy, please contact us. Please take some time to read through this policy and understand our position on privacy before you provide us with any personal information.
Our commitment to privacy
Aside from the contents of this policy, the conduct of ARM is governed by the Privacy Act 1988 (Cth) and in particular the APPs. ARM also subscribes to the ‘Statement of Privacy Principles’ of the Australian Press Council. For more information, please click here.
Personal information we may collect
ARM will only collect personal information about you if it is reasonably necessary for our functions and activities. When submitting information to us, we may collect details such as your name, email, phone number and in some instances, your financial information (including credit card information) which may personally identify you. Some of this information is essential for us to be able to identify accurately who is using our services so that we may be able to respond to your requests and, as such, is indicated by mandatory fields. Mandatory information requirements are clearly identified and are denoted by an asterisk (*). When submitting a form, you will also be prompted if any mandatory data has not been completed. Other types of information are collected to help us provide better services. Information of this type is optional – you need only fill it in if you wish to do so.
You may be asked to provide ARM with personal information when you:
We also collect personal information in the normal course of business through meetings, phone calls, letters, faxes and emails, as well as via third party credit agencies, mailing lists, advertisers, commercial agreements, documents and dealings. All this information is subject to the APPs.
In addition, we may also collect information about you if you:
When you engage in the activities described above, you are authorising us to collect, store, use and disclose such information and content in accordance with this policy.
ARM will not collect sensitive information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation. However if we do collect sensitive information we will do so in compliance with the APPs.
You have the option of not identifying yourself or dealing with us using a pseudonym in relation to particular matters. We will endeavour to make it clear where you may withhold your name or use a pseudonym.
Non-personal information we may collect
available in most web browsers that enables the user to deny or accept cookies.
How we use your information
If we hold personal information about you that was collected for a particular purpose, we will not use or disclose it for another purpose unless: (a) you consent; (b) you would reasonably expect us to use or disclose it for that other purpose; or (c) it is required or authorised by law or a court/tribunal order.
ARM generally uses personal information, and you consent to us using your personal information, to:
We may also share your personal information with our Related Companies, Partners and others, as referred to below.
The information and feedback you provide through our websites may be used to identify ways of improving the websites and how we can make them more effective for your use.
Opting in or out and unsubscribing
At the time we collect information from you, you may be asked to "opt in" to consent to us using or disclosing your personal information, other than in accordance with this policy or any applicable law. For example, you may be asked to “opt-in” to receive further information or communications from us, our Related Companies or our Partners, as referred to below.
You will be given the opportunity to "opt out" or unsubscribe from receiving communications from us, our Related Companies or our Partners in accordance with this policy. Alternatively, you may contact us at the address below to “opt out” of, or unsubscribe from, any future communications.
ARM will use reasonable endeavours to comply as quickly as possible with that request, and in any event, within five business days.
If you receive communications purporting to be connected with us or our services that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact us.
Disclosure of your personal information
You consent to ARM disclosing your personal information to the authorised personnel of ARM and to:
as referred to further below.
You acknowledge and agree that we may collect and share personal information about you with related bodies corporate, joint venture partners and affiliated companies and businesses (Related Companies) so we can provide you with the products and services you request and bring you information about products and services we offer. We will inform our Related Companies that information shared with them must be collected, used, disclosed and stored in accordance with this policy.
In some cases, we contract with other companies or individuals to work with us or provide goods or services for us (Partners) including business partners, distributors, suppliers and advertisers. Examples of the goods and services our Partners may provide are electronic communications, data storage, deliveries, direct marketing services, market research, prizes, advertising, public relations, debt collection, legal advice, accounting and audits. We provide our Partners only with such information about you as they need to provide their goods or perform their services and we impose strict requirements of security and confidentiality on them in how they handle your personal information. We make it clear that our Partners are not permitted to use your personal information other than as permitted under this policy.
Related Companies and Partners may be located in Australia and/or overseas countries, including New Zealand, Hong Kong, Ireland and the United States of America. You hereby consent to the disclosure of your personal information to such Related Companies and Partners overseas (as referred to above) and you acknowledge that as a result of your consent to such disclosure, clause 8.1 of the APPs does not apply.
Credit information about you may be obtained from and provided to credit reporting agencies in accordance with applicable legislation.
Sale of business
If we sell all or part of our business, merge with another company or business, or restructure our business, we may transfer or disclose your personal information to the parties involved in the transaction.
Access and correction
ARM will take reasonable steps to ensure your personal information is accurate, up to date and complete.
Where ARM holds personal information about you, we will provide you with access to the information on request within a reasonable time. There are some exceptions to this where we may refuse to give you access and these are set out in clause 12.3 of the APPs. In that case, where required, we will give you written notice setting out the reasons for our refusal and the mechanisms available if you wish to complain about our refusal.
We will also give you access to the information in the particular manner you request if it is reasonable and practicable to do so. If we do not give you access in the manner requested, we will take reasonable steps to give you access in a way which meets both your needs and ours. We may also impose a reasonable charge for giving you access to your personal information.
If ARM is satisfied that your personal information is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct your personal information. In addition, if you request us to correct your personal information, we will take reasonable steps to do so within a reasonable time. If you request it, we will also take reasonable steps to notify any other Related Companies or Partners of the changes if we have previously provided your personal information to that entity. There is no fee for correcting your personal information. We may require you to provide particulars of your identity before providing you with access to, or making changes to, your personal information.
ARM will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access and modification or disclosure. Any personal information that we receive is securely stored and access is restricted to authorised personnel of ARM, its Related Companies and Partners, as described above. Please contact us immediately at the address listed below if you become aware of any unauthorised use of your personal information.
Third party websites
You may follow links on our websites to other third party websites (Other Sites). We encourage you to always read the privacy policies on those Other Sites as they may also collect your personal information. ARM is not responsible for the information on, and the contents of, those Other Sites or their practices or policies.
If you: (a) have any questions or comments on this policy; (b) would like to access or correct your personal information; (c) would like a hard copy of this policy; (d) would like to know how we received your personal information; or (d) would like to make a complaint about a breach of the APPs or the use or disclosure of your personal information, then please contact ARM’s Privacy Officer at:
APN Newspapers Pty Ltd
PO Box 1578
Milton QLD 4064
Phone: 1300 130 590
Fax: (07) 5456 6920
ARM takes complaints about breaches of the APPs seriously and will investigate any complaint we receive and respond to you as soon as reasonably practicable.