Privacy Policy

APPCO GROUP AUSTRALIA PRIVACY POLICY

Appco Group Australia Pty Ltd(ABN 49 092 605 671) and its related bodies corporate (together “Appco”or “We/we”or“Our/our”or “Us/us”) is committed to respecting the privacy of your personal information.

This Privacy Policy explains our policy for dealing with personal information that we collect through the following channels (the “Collection Channels”):

  • our online properties (each, a “Website”), including:
  • any other means through which you provide personal information tous, including either physically or electronically; and
  • any other means through which we lawfully collect personal information about you.

You may contact us with any queries you may have in respect of this Privacy Policy or your personal information by contacting Appco’s privacy officer via email: theprivacyofficer@appcogroup.com.auor telephone:02 8219 7900.

GENERAL

  1. We are committed to safeguarding personal privacy. We recognise that you have a right to control how your personal information is collected and used. Providing personal information is an act of trust and it is taken seriously. Unless given consent to do otherwise, we will only collect and use personal information as set out below.
  2. Throughout this Privacy Policy, we refer to your ‘personal information’, which means information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address and workplace contact details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences.
  3. Appco has developed and implemented its Privacy Policy with respect to personal information to reflect best practice on privacy policies in accordance with the requirements of the Privacy Act 1988 (Cth) (as amended) and the 13 Australian Privacy Principles.
  4. In order to keep up with changing legislation and best practice, we may revise this Privacy Policy at any time without notice. We will post any changes to this Privacy Policy on our Websites, so we encourage you to check this Privacy Policy from time to time.
  5. In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

ANONYMITY AND PSEUDONYMITY

  1. Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our Collection Channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the information identified below. It will not be practicable to deal with you on an anonymous or pseudonymous basis when we wish to send you direct marketing materials or need to provide you with products or services requested by you.

KINDS OF PERSONAL INFORMATION THAT APPCO COLLECTS AND HOLDS

  1. Personal information that may be requested includes, but is not limited to:
    1. contact information such as your full name, date of birth, telephone number, mobile telephone number, current and valid email address, residential address and postcode;
    2. more detailed contact preferences including your workplace contact details;
    3. your gender;
    4. location information;
    5. personal identification numbers such as driver’s licence number;
    6. utility service provider identification number;
    7. your occupation and information regarding your professional historyand professional interests;
    8. information regarding your personal interests and interesting and relevant information about you;
    9. financial details including your bank account and credit card details;
    10. your online behaviour and interests based on your online browsing activity;
    11. demographic information such as age group and preferences;
    12. information about your preferences, interests, and experiences with our products and services. This information is collected in order to tailor our communications to you and continuously improve our products and services;
    13. information about your experience with our products or services or third party products or services, including products or services listed on a Website;
    14. the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to Appco and used for the purposes set out in this policy (which may include using their details for marketing purposes); and
    15. any other personal information which you provide directly to us. Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy).
  1. When you use a Website, we may also collect personal information about you in the following general categories:
    1. usage and preference information: we collect information about how you interact with a Website, including the pages you visit, your preferences and settings that you choose. We may do this through the use of cookies and other similar technologies that uniquely identify you;
    2. device information: we may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network; and
    3. other information: we may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a Website.

SENSITIVE INFORMATION

  1. We will only collect sensitive information with your consent and where you provide it to us directly. Where you provide us with any sensitive information (including, but not limited to,criminal history), we will only use this information for the purposes stated at the time of collection and will only share this information with our trusted third parties in the manner stated on the Website or in this Privacy Policy.

HOW APPCO COLLECTS AND HOLDS PERSONAL INFORMATION

  1. We will only collect or monitor any personal information about you with your consent including as provided in this Privacy Policy or if it is otherwise lawful to do so. The only personal information collected by us is what has been provided to or collected by us in accordance with this Privacy Policy or has been provided to us lawfully by third parties.

ACTIVE INFORMATION COLLECTION

  1. Personal information may be collected (and combined) via our Collection Channels if you:
    1. have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party;
    2. sign-up and/or register to become a member of any Collection Channel;
    3. subscribe to any newsletters, updates, alerts or news and media releases, or request information about our products and/or services as well as third party products or services;
    4. complete and submit any forms or applications to us;
    5. place an order for our products and/or services;
    6. contact us directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
    7. participate in any offers, promotions, competitions, rewards or marketing activities;
    8. interact with a Website for a specific purpose;
    9. interact with or browse a Website generally; or
    10. make a complaint to us.
  2. Personal information is requested in order to facilitate or provide you with certain content, products or services, and information about such content, products or services (including offers made available via our Collection Channels), marketing materials (including direct marketing materials and direct marketing phone calls), newsletters, electronic newsletters (e-newsletters), news and media releases / launch information, and also to advise you of other Appco or third party opportunities and products, services, offers, competitions or promotions which may be of interest. No one is obligated to provide personal information. However, failure to do so may result in Appco being unableto facilitate or provide you with certain content, products or services, products or services information, upcoming opportunities and promotion, competition, offer or event information or other content from you (where applicable).
  3. We may also obtain your personal information from legitimate third party sources and platforms including social media channels, commercial data providers, referral agents, marketing companies, targeting companies, list brokers and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so, including our service providers. For example:
    1. we may use services from other companies that enable us to derive a general geographic area based on your IP address in order to customise certain services to your geographic area; and
    2. we may obtain third party information relating to your advertisement interaction and viewing data, such as ad click-through rates and information about how many times you viewed a particular advertisement.

CHILDREN

  1. Personal information will not be collected by any person who is known by Appcoto be under the age of eighteen (18) without the consent of a parent or legal guardian. Persons under age eighteen (18) may only use our Websites with the involvement and consent of a parent or legal guardian.

PASSIVE INFORMATION COLLECTION

  1. As with many commercial websites, we may also collect information which tells us about visitors to our Websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a Website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally including when you are logged into an account, you consent to the collection of such information where it is personal information.When you receive newsletters or e-mails from Appco, we may use web beacons (described below), customised links or similar technologies to determine whether the e-mail has been opened and which links you click in order to provide you with more focused e-mail communications or other information.
  2. As you navigate through our Websites, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as Unique Device Identifiers (“UDI”), cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). In certain circumstances, this information may be considered anonymous information or personal information under the Privacy Act 1988 (Cth). This is dependent on the device used and the method by which an individual connects to the Internet. Your Internet browser automatically transmits to the Website you are browsing some of this anonymous information or personal information, such as the URL of the website you just came from, the Internet Protocol (“IP”) address, the UDI (if applicable) and the browser version your device is currently using. Our Websites may also collect anonymous information or personal information from your device through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of a Website might not work without cookies and this may limit the services provided by a Website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf.
  3. Our Websites may use and combine such passively collected anonymous information or personal information and/or information from various third party sources, including as described above, and may combine this anonymous information or personal information with other personal information collected from you to provide better service to Website visitors and users, customise a Website based on your preferences, compile and analyse statistics and trends, provide you with relevant advertising when you visit a Website or a third party website, and otherwise administer and improve a Website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website, you consent to information about you being collected, compiled and used in this way.
  4. For more information about cookies and how you can opt out, you can visit http://www.youronlinechoices.com.au/.

PLATFORM PERMISSIONS

  1. Mobile platforms such as iOS and Android generally define certain types of information or data that applications cannot access without your consent. Each platform has its own permissions system for obtaining your consent. For example, the iOS platform generally alerts you the first time an Appco app wants permission to access certain types of data, such as location services, and will let you choose if to consent to that request. Android devices will generally notify you of the permissions that an app seeks before you first use the app, and your use of the app constitutes your consent. You can generally manage your platform level permissions via the Settings section on your device. For more information, please contact our Privacy Officer at the details set out in this policy.

PURPOSES FOR WHICH APPCO COLLECTS, HOLDS, USES AND DISCLOSES PERSONAL INFORMATION

  1. Personal information collected will be used for the following primary purposes:
    1. 20.1. For the purposes stated in a privacy collection statement on a particular Collection Channel.
    2. 20.2.To maintain the functionality of a Website, including the provision of information to you relating to the content available on the Website and e-commerce transactions conducted via the Website.
    3. 20.3. To marketproducts or services related to Appco, our clients, suppliers, promotional partners and trusted third parties.
    4. 20.4. To respond to customer enquiries, complaints and complaints handling.
    5. 20.5. To send you any technical, administrative or legal notices important to our Websites.
    6. 20.6. To allow you to respond to and participate in offers and competitions.
    7. 20.7. To conduct competitions or promotions and communicate offers either for us or trusted third parties.
    8. 20.8. For internal record keeping including site usage, maintaining databases and administration of our products and services.
    9. 20.9. To procure applications for our clients, suppliers and trusted third parties’ services.
    10. 20.10. To procure donor pledges for charitable organisations.
    11. 20.11. To provide you with information about your transactions, content, services and products.
    12. 20.12. To provide direct marketing materials, events, offers, competitions and promotions, from Appco or third parties, in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email) or any other form of electronic, emerging, digital or conventional communications channel for us and our clients, partners, suppliers and trusted third parties.
    13. 20.13. To provide you with relevant advertising when you use our Websites or those of a third party.
    14. 20.14. To share reviews or testimonials provided by you.
    15. 20.15. To provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages.
    16. 20.16. To improve Website and system administration.
    17. 20.17. To obtain opinions or comments about products and/or services and to conduct other research and development.
    18. 20.18. To verify your identity.
    19. 20.19. To investigate complaints made by you.
    20. 20.20. To record statistical data for marketing analysis and to conduct market research.
    21. 20.21 To share, license or sell personal information with our service providers, promotional partners, and other trusted third parties (and their directors, servants, agents and contractors) in the manner described below.
    22. 20.22 Any other purpose as may be deemed reasonably necessary by Appco in the circumstances.
  2. For the purposes described above, personal information may be shared with selected Appco service providers, promotional partners and their related bodies corporate, and other trusted third parties (and their directors, servants, agents and contractors) either in Australia or overseas, including, but not limited to, Singapore and India. Failure to provide personal information may result in Appco being unable to provide you with certain services, content, information, upcoming opportunity, promotion, offer, event or product information and/or accept content (where applicable).
  3. In order to operate a Website, deliver a product or service or administer your donor pledge, personal information may also be shared with our selected service providers and their related bodies corporate, and/or other trusted third partieseither in Australia or overseas countries which may include, but are not limited to, Singapore and India. Appco selected service providers and/or other trusted third partiesmay be engagedby or contractedto Appco to perform a variety of functions or services, such aslist broking services, product marketing services, data pools,completing order forms, procuring applications for our clients, procuring donor pledges, email systems providers, legal and accounting services, data storage, fulfilling orders and providing client services, conducting market research, processing credit card payments, assisting with promotions or offers and providing technical services for our Websites. These companies may have access to personal information if needed to perform such functions.
  4. We recognise the trust with which you provide personal information, and except as stated in this Privacy Policy or as is otherwise lawful, such information will not be used or disclosed for any other purposes without consent. However, Appco reserves the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect the rights or property of Appco, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.

CONTACT BY APPCO

  1. Appco group companies (and their directors, servants, agents and contractors), our promotional partnersor trusted third parties (and other selected service providers and other non-Appco companies or professionals) either in Australia or overseas, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the purposes for collection of personal information as stated above.
  2. We do not send advertising or marketing information without obtaining prior consent, for example the consent contained within this Privacy Policy, or as is otherwise lawful to do so. If you receive communications from uswhich you do not wish to receive, you may remove your name from the database in the manner indicated in the communication, including by utilising the functional unsubscribe/opt-out facility (if the communication is via commercial electronic message) or by contacting usat the contact details in this Privacy Policy. Please allow 30 days for this request to be processed.
  3. Despite removing your name from the database from receiving future advertising and marketing information, wemay send you non-commercial “Administrative Emails”. Administrative Emails relate to a user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular user account.

ABILITY OF OTHERS TO VIEW INFORMATION

  1. We may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users,provide reviews for content, products and/or services, utilise functionalities that allow you to post content to your own social media channels, or interact with particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. Reviews and testimonials that you upload to our social media platforms may be shared on our Websites, including without limitation, other social media platforms and other public forums and may also be published in promotional materials including but not limited to emails, point of sale material and flyers. This information may become publicly available and may be read, collected and used by others either on our Websites or outside of our Websites. We are not responsible for the conduct of others who may read, collect and use this information.

YOUR RIGHT OF ACCESS

  1. You have the right to access and review your personal information that may be recorded on our database. Information may be reviewed by contacting our privacy officer at the contact details contained in this Privacy Policy. Please allow 30 days for this request to be processed.

CHANGING AND DELETING THE INFORMATION WE HAVE ABOUT YOU

  1. Information contained on the database may be amended, or your preferences for contact from us changed, by contacting our privacy officer at the contact details contained in this Privacy Policy. Please allow 30 days for this request to be processed.
  2. In the same way, a request may be made to delete personal information, and all reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in us being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), other content, services or product information, upcoming promotion, competition or event information, and/or provide certain content, goods or services.
  3. We are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy.

STORAGE AND SECURITY OF PERSONAL INFORMATION

  1. Appco will end eav our to take all reasonable steps to keep secure any personal information recorded and to keep this information accurate, up to date, complete and relevant. We ensure only those necessary have access to your personal information.Personal information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers.

DISCLOSURE OF PERSONAL INFORMATION TO OVERSEAS RECIPIENTS

  1. In some cases, we may disclose your personal information to overseas recipients, including but not limited to recipients in Singapore and India. Our employees, data processors, selected service providers and other trusted third parties are obliged to respect the confidentiality of any personal information held by us. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. We will not be held responsible for events arising from unauthorised access to personal information.

APPCO AND LINKS TO OTHER WEBSITES

  1. Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. Appco is not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.
  2. We may use third party advertisements on our Websites. All third party advertising, if paid for, is paid for by the relevant third party advertisers and are not recommendations or endorsements by Appcoor any of its affiliates. Appcois not responsible for the content (including representations) of any third party advertisement on a Website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties.

RELATED APPCOWEBSITES

  1. All Websites operated by uswill adhere to this Privacy Policy.

SALE OF THE COMPANY

  1. If our company merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

PROBLEMS OR QUERIES

  1. If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled and/or disclosed your personal information, please contact our privacy officer via one of the following channels:

Address: The Privacy Officer

Appco Group Australia Pty Ltd

Level 6, 80 Cooper Street

Surry Hills NSW 2010

Telephone: 02 8219 7900

Email: theprivacyofficer@appcogroup.com.au

Please allow 30 days for this request to be processed.On receipt of your complaint a review will be conducted and findings will be communicated to you were required. If you do not receive a satisfactory response to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at http://www.oaic.gov.au/about-us/contact-us-page.

CHANGES TO THIS STATEMENT

Appco may make changes to this Privacy Policy from time to time for any reason. We will publish those changes on our website www.appcogroup.com.au. For more information please email theprivacyofficer@appcogroup.com.au.