Effective: 10 January 2022
1. Our collection, use and disclosure of personal information
Generally, we collect personal information about individuals (‘you’ or ‘your’):
- In the course of providing our services to our clients – this may include information about individuals who are actual or potential customers of one of our clients; or
- In the course of otherwise operating our business – this may include information about individuals who interact with our website, attendees at events, employees of our clients, or job applicants or contractors who work with us.
2. When do we collect personal information?
(a) Information we collect to provide services to our clients
We generally recommend that our clients exclude or limit the sharing of personal information with us, and we regularly work with clients to help them do so. However, as part of providing our services, we may receive personal information from our clients directly or indirectly (for example, via collection tags implemented by our clients).
In such cases, because we have no direct relationship or contact with the relevant individuals, we rely on the client to have obtained the required consents for us to collect, use and disclose that information. Nevertheless, we handle such personal information in accordance with applicable privacy laws and we take steps (including through contractual requirements) to ensure our clients do the same.
(b) Information we collect when otherwise operating our business
Information we collect in our general business operations
We collect personal information to provide our clients and their representatives with access to our products and services and to maintain contact with those clients and inform them of our products and services, or otherwise to undertake business to business marketing activities to our clients.
In addition, we may collect personal information at other times in connection with our business, including when you:
- contact us via our website;
- communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
- interact with our services or advertising; or
Information we collect through our website (including through cookies)
We may collect personal information about you when you use or access our website (including information collected from cookies).
While we don’t use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your device.
We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
3. What personal information do we collect?
The types of information (including personal information) we collect will vary depending on the nature of our relationship or interactions with you and our clients (as described above), but may include:
- contact details, including mailing address, email address and telephone number;
- device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- details of the products and services we or our clients have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- any additional information relating to you that you provide to us or our clients;
- information provided to us through customer surveys; or
- any other information that our clients provide to us or that may be required in order to facilitate your dealings with us or our clients or for us to provide our services to you or our clients.
4. How do we use your personal information?
(a) Client Provided Information
We have an agreement in place with each client that describes the services to be provided by us, which governs the provision of those services and which details the purposes for which we may use any Client Provided Information. While the services we provide differ from client to client, for example, we may collect, hold, use and disclose Client Provided Information for the purposes of:
- advising our clients on digital media and loyalty strategy;
- measuring and analysing the effectiveness of digital marketing conducted by our clients, including marketing conducted using our first party digital solution; and
- combining that information with other third party information in order to enable us or our client to develop consumer insights so that our client may better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
(b) CB Collected Information
We may collect, hold, use and disclose CB Collected Information for the following purposes:
- to enable you to access and use our website, products or services;
- to operate, protect, improve and optimise our website, products or services, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing and promotional messages and other information that may be of interest to you;
- to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
- to consider your employment application.
5. Do we use your personal information for direct marketing?
(a) Client Provided Information
No. While we provide services that assist our clients to understand and connect with customers and potential customers, including advising on marketing strategies and facilitating, measuring and analysing marketing (including direct marketing) conducted by our clients, we don’t use Client Provided Information for direct marketing.
Our clients obviously use your personal information in different ways, so if you have a query about how our clients use your personal information then we will typically refer you to our client in the first instance. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any information provided to us by, our clients, and have no control over Client Provided Information. We encourage you to read the privacy policies of our clients, as applicable.
(b) CB Collected Information
We may send you direct marketing communications and information about our products and services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).
6. Who do we disclose your personal information to?
- our employees;
- our clients, for purposes of providing them with our services;
- third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you or our clients);
- professional advisers;
- anyone to whom our assets or businesses (or any part of them) are transferred;
- specific third parties authorised by you to receive information held by us; and/or
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
7. Disclosure of personal information outside Australia
We don’t host or store your personal information outside Australia.
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we use secure databases and password protect our IT systems. However, we cannot guarantee the security of your personal information.
10. Accessing or correcting your personal information
You can access the personal information we hold about you by contacting us using the information below or the contact us function on our website. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.
If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.
If you have a query about Client Provided Information, we will typically refer you to our client in the first instance.
11. Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us via email to [email protected]. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
12. Contact Us
Our preferred method for receiving questions about privacy is for you to email our Privacy Officer at [email protected], but you may also write to us at:
c/o Harbour City Labs
Level 27, Tower 1, International Towers
100 Barangaroo Ave
Barangaroo NSW 2000