This Privacy Policy sets out the approach which Captune Partners will take in relation to the treatment of Personal Information. It includes information on how Captune Partners collects, uses, discloses and keeps secure, individuals’ Personal Information. It also covers how Captune Partners makes the Personal Information it holds available for access to and correction by the individual.
This policy has been drafted having regard to Captune Partners’ obligations under the Privacy Act 1988 (including the new National Privacy Principles) (the Privacy Act). This Policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.
1. COLLECTION
1.1 Captune Partners will only collect Personal Information where the information is necessary for Captune Partners to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 Captune Partners collects Personal Information primarily to supply customers with the products and services ordered from it and its related companies. Captune Partners also collects and uses Personal Information for secondary purposes including:
- billing and account management
- business planning and product development; and
- to provide individuals with information about promotions, as well as the products and services of Captune Partners affiliated companies and other organisations.
- Remarketing – At times, Captune Partners uses third-party vendor re-marketing tracking cookies, including the Google Adwords tracking cookie and various social media remarketing cookies. This means we will continue to show ads to you across the internet, such as social media platforms or the Google Content Network. As always we respect your privacy and are not collecting any identifiable information through the use of Google’s, or any other third party, remarketing system. These third-party vendors will place cookies on web browsers in order to serve ads based on past visits to our website. This allows us to make special offers and continue to promote Captune Partners to those who have shown interest. If you have concerns, visitors can opt out of Google’s use of cookies by visiting Google’s Ads Settings.
- Third parties, including Facebook, may use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the internet and use that information to provide measurement services and target ads.
- You can opt-out of the collection and use of information for ad targeting. A mechanism for exercising such choice can be found on the following sites http://www.youronlinechoices.com.au/ . More information can be found about cookies at http://www.aboutads.info/choices and http://www.youronlinechoices.eu/).
- You can change your browser settings to limit which cookies can be set. These settings are usually found in the ‘options’ or ‘preferences’ menu for your browser. Further information can be found here or in the ‘Help’ menu of your browser:
Cookie settings in Internet Explorer
Cookie settings in Chrome
Cookie settings in Firefox
Cookie settings in Safari
However, if you change your settings and block cookies, this will mean that certain features on our Site cannot be provided to you and you may not be able to take full advantage of all of our Site’s features.
1.3 Captune Partners will not collect Sensitive Information from individuals except with consent and only where it is necessary for Captune Partners to collect such information for an activity or function.
1.4 Captune Partners will not collect Personal Information secretly or in an underhanded way.
1.5 Captune Partners will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.3.
2. USE
2.1 Captune Partners will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual’s Reasonable Expectations.
2.2 Captune Partners Uses Personal Information primarily for the purposes listed in 1.2 above.
2.3 If Captune Partners relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:
- the individual is clearly notified of their right to Opt Out from further Direct Marketing;
- there is only one Use of the information before the Opt Out right is given and this Use applies across all Captune Partners and Related Bodies Corporate (if the information is shared between those Related Bodies Corporate);
- the individual is given an Opt Out in all further instances of Direct Marketing if they have not previously chosen to Opt Out; and
- if the individual Opts Out of all Direct Marketing the Opt Out will be respected by Captune Partners and Related Bodies Corporate.
2.4 Captune Partners will not use Sensitive Information for Direct Marketing.
2.5 Captune Partners may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 Captune Partners will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
3. DISCLOSURE
3.1 Captune Partners may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual. This will include obtaining the individual’s consent for Disclosures made under the credit reporting requirements of the Privacy Act.
3.2 Captune Partners may Disclose Personal Information between Related Bodies Corporate. Where information is Disclosed to such a Related Body Corporate, that Related Body Corporate is bound by the original Primary Purpose for which the information was collected.
3.3 Captune Partners may Disclose Personal Information to unrelated third parties to enable outsourcing of functions (such as billing, customer relations management and order fulfilment), where that is Disclosure or Use for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations.
3.4 Captune Partners will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
3.5 Captune Partners may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.
3.6 Captune Partners may Disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.
3.7 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, Captune Partners will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
3.8 Captune Partners does not generally sell or share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved. If the consent provided is conditional, Captune Partners will take steps to ensure (by contract) that the use of its customer list by third parties does not exceed the scope of the consent.
4. INFORMATION QUALITY
4.1 Captune Partners will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 Captune Partners will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years from the date of the last customer interaction, unless the law requires otherwise.
5. INFORMATION SECURITY
5.1 Captune Partners requires employees and contractors to perform their duties in a manner that is consistent with Captune Partners’ legal responsibilities in relation to privacy.
5.2 Captune Partners will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Captune Partners who have a genuine “need to know” as well as “right to know”.
5.3 Captune Partners will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6. ACCESS AND CORRECTION
6.1 Captune Partners will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 Captune Partners will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting Captune Partners Customer Service, as per the details on the website.
6.4 Captune Partners can charge a fee for processing an access request but will generally not do so unless the request is complex or is resource intensive.
7. OPENNESS
7.1 The Captune Partners Office Manager will be the first point of contact for inquiries about privacy issues. Individuals wishing to make an inquiry or complaint regarding privacy, should do so by contacting the Captune Partners Office Manager, as per the details on the Captune Partners website.
7.2 Captune Partners websites will contain a prominently displayed privacy statement and will include a copy of Captune Partners Privacy Policy.
8. ANONYMOUS TRANSACTIONS
8.1 Captune Partners will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. Captune Partners may however request visitors to provide Personal Information voluntarily to Captune Partners (for example, as part of a competition or questionnaire).
9. TRANSFERRING PERSONAL INFORMATION OVERSEAS
9.1 Captune Partners will take reasonable steps to limit the amount of Personal Information it sends to unrelated organisations overseas.
9.2 If Personal Information must be sent by Captune Partners overseas for sound business reasons, Captune Partners will require the overseas organisation receiving the information to provide a binding undertaking that it will handle that information in accordance with the National Privacy Principles, preferably as part of the services contract.
GLOSSARY
Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.
Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of Captune Partners or a Related Body Corporate or those of an independent third party organisation.
Disclosure generally means the release of information outside Captune Partners, including under a contract to carry out an “outsourced function”.
Opt Out means an individual’s expressed request not to receive further Direct Marketing.
Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.
Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.
Reasonable Expectation means a reasonable individual’s expectation that their personal information might be Used or Disclosed for the particular purpose.
Related Body Corporate means that where a body corporate is:
- a holding company of another body corporate;
- a subsidiary of another body corporate; or
- a subsidiary of a holding company of another body corporate, the first mentioned body corporate and the other body corporate are deemed to be related to each other.
Sensitive Information means:
- information or an opinion about an individual’s:
- racial or ethnic origin; or
- political opinions; or
- membership of a political association; or
- religious beliefs or affiliations; or
- philosophical beliefs; or
- membership of a professional or trade association; or
- membership of a trade union; or
- sexual preferences or practices; or
- criminal record;
- Health Information about an individual.
Use means the handling of Personal Information within Captune Partners.
Contacting Captune Partners
If you require further information regarding Captune Partners’ Privacy Policy, you can contact the Captune Partners Office Manager by:
Telephone: 03 9021 2577
Email: admin@captunepartners.com.au
Captune Partners
Pacific Tower, 502/737 Burwood Rd, Hawthorn East VIC 3123
L1, 111 Lonsdale Street, Melbourne VIC 3000