If You are located within the European Union, we will comply with the EU’s General Data Protection Regulation (GDPR) in respect of your personally identifiable information, BUT it is your responsibility to alert us to your location within the EU.
1 Open and transparent management of personal information
1.1 We intend to manage all personal information that We collect in an open and transparent
1.2 We will take reasonable steps to comply with the Australian Privacy Principles and to deal
with inquiries or complaints from individuals about Our compliance with the APP.
personal information We collect from You
disclosure of personal information:
(a) the kinds of personal information we handle;
(b) how We collect and hold personal information;
(c) the purposes for which We collect, hold, use and disclose personal
(d) how person can access their personal information held by Us and request
(e) how a person can complain about a breach of the APP, and how We
deal with such complaints;
(f) whether We are likely to disclose personal information to overseas
entities, and if so, where those entities are likely to be located,
2.1 We will answer questions about our Services from persons using email nicknames
without requiring them to reveal their full legal names.
2.2 We may be required to insist on a person providing us with their personal information in the following situations:
(a) where We are required or authorised by or under an Australian law, or a court/
tribunal order, to deal only with individuals who have identified themselves; or
(b) where it is impracticable for Us to deal with individuals who have not
identified themselves or who have used a pseudonym, in that particular
3 Collection of requested personal information
3.2 We will not collect personal information from You unless the information is reasonably necessary for Us to perform Our functions or activities, or provide our Services.
3.3 Furthermore, We will not collect sensitive information about You unless:
(a) You consent to the collection; or
(b) paragraph 3.4 applies.
3.4 We may collect sensitive information about You if:
(a) the collection is required or authorised by or under an Australian law or a
court/tribunal order; or
(b) the information is health-related information that the Privacy Act authorises Us to collect.
3.5 We will not collect personal information by unlawful or unfair methods.
3.6 Normally, We will collect personal information about You only from You, unless You authorise Us to collect it from another source. We may receive personal information about you from other Members, especially in the context of a complaint made about Your misuse of the Services.
4 Unrequested personal information
4.1 If We receive personal information about You and We did not request the information,
We will determine as promptly as We whether We should retain and use the information and/or should consult You about the information.
4.2 Any personal information We receive under paragraph 4.1 is subject to the same rules that apply to personal information We receive directly from You.
4.3 We will not retain and use personal information We could not have obtained ourselves directly, unless there is a lawful reason to do so, e.g. to discharge Our duty of care protect the safety of Members and staff.
5 Notification of collection of personal information
5.1 If We are collecting personal information from You for the purposes of providing our services, We will alert You that We are doing so.
5.2 When We collect Your personal information under clause 5.1, we will notify You of the following things, as required by the APP:
(a) Our identity and contact details;
(b) how We are collecting the information;
(c) why We are collecting the information;
(d) the main consequences for You if You refuse to provide the information, or to allow Us to collect it; and
(d) If the server containing the information is moved outside of Australian soil.
(f) if we are likely to share that information with another entity, and, if so, whether that entity is located outside Australia.
6 Use or disclosure of personal information
6.1 If We hold personal information about You that was collected for a particular purpose,
We will not use or disclose the information for another purpose unless You agree,
(a) You would reasonably expect us to use or disclose the information, and the other purpose is related to the original purpose for which We collected the information; or
(b) the use or disclosure of the information, including health-related information, is required or authorised by or under an Australian law or a court/tribunal order; or
(c) We reasonably believe that the use or disclosure of the information is reasonably necessary for one or more law enforcement related activities.
6.2 We will keep a record of any disclosures by Us of Your personal information.
7 Direct marketing
We will not use or disclose Your personal information for the purpose of direct marketing, except with Your consent. This limitation does not apply to notifications and offers that We normally provide to Members as agreed to by them in Our TOS.
8 Cross-border disclosure of personal information
8.1 We do not normally share Your personal information with persons located outside Australia, but may do so in the following situations:
(a) where data storage facilities used by Us or by a third party service provider such as a web host or payment services provider are located overseas; or
(b) where We receive a lawful request from the government of a foreign country to
assist in law enforcement processes.
8.2 We may not be aware whether a third-party service provider that We rely on is sending information outside Australia for processing. Please refer to paragraph 3.7 above.
9 Government-issued identifiers
9.1 We will not insist that You provide a government-issued identifier, such as Your driver’s licence unless that action is authorised by law. You may volunteer to provide such information, in which case it will be treated the same as any other personal information that We collect.
10 Quality of personal information
10.1 We will make a reasonable effort to ensure that the personal information that We hold
is accurate, up-to-date and complete. For example, We may invite You to check and update that information, in which case it is Your responsibility to do so.
11 Security of personal information
11.1 We will take reasonable steps to protect Your personal information:
(a) from misuse, interference and loss; and
(b) from unauthorised access, modification or disclosure.
11.2 We will delete or destroy any of Your personal information that We no longer need but may retain, use and share de-identified information for business analysis and statistical purposes.
12 Access to personal information
12.1 On request by You, We will give You access to the personal information We hold about You unless there is a lawful reason not to do so.
12.2 We may charge You a reasonable amount for work required in producing Your personal information in a format suitable for review by You, but will not charge You for attending to Your request for access.
12.3 If We refuse to give You access to personal information, We will provide You with an explanation.
13 Correction of personal information
If You review Your personal information in Our possession and request that we make a correction, We will do so unless we have a lawful reason not to do so. Where We make a correction, We may be legally required to retain the previous version of the information, e.g. under data retention laws. If We have disclosed personal information to another person that You subsequently correct, We will contact the other person to inform them of the correction if You request Us to do so.
15 Contacting us
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