Campaign Agent Pty Ltd ACN 608 962 812 (‘CampaignAgent’, ‘Our’, ‘Us’ and ‘We’), our Related Companies and third parties who provide services to Us or on Our behalf collect your personal information to provide and offer you Our products and services, or otherwise as permitted by law. Without this information, We may not be able to provide you with Our products or services. This policy sets out the reasons why CampaignAgent collects your information and importantly how We protect your privacy and the confidentiality of your personal information.
‘Personal Information’ is any ‘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.
‘Related Companies’ has the same meaning as related bodies corporate as defined in section 50 of the Corporations Act 2001 (Cth).
‘Sensitive Information’ is a sub set of Personal Information defined as:
- information or an opinion about an individual’s:
- racial or ethnic origin;
- political opinions;
- membership of a political association;
- religious beliefs or affiliations;
- philosophical beliefs;
- membership of a professional or trade association;
- membership of a trade union;
- sexual orientation or practices;
- criminal record;
- health information about an individual;
- genetic information about an individual that is not otherwise health information;
- biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
- biometric templates.
‘You’ refers to our customers and prospective customers. It also refers to users of our web site.
We will be fair and open about the way We collect information about you and what We intend to do with the information.
We recognise that your privacy is very important to you. We are committed to protecting the privacy of your Personal Information in accordance with the Privacy Act 1988 (Cth).
The Privacy Act details the Australian Privacy Principles which set minimum standards for how government agencies and private sector organisations may collect, use, disclose, store, provide access to and correction of Personal Information. We are committed to complying with the Australian Privacy Principles.
Personal Information we collect
The Personal Information We collect depends on the products and services We offer you or you use or apply for. Typically, the information we collect and hold may include your name, contact details (address, phone, email address), date of birth, gender and account payment details. We may also collect information that is specific to a particular product.
We do not collect ‘Sensitive Information’.
How we collect your Personal Information
We collect Personal Information in various ways, including via telephone, our website, hard copy forms or email and from real estate agencies that you are a customer of.
Whenever you deal with Us we will collect this information directly from you unless it is unreasonable or impracticable for Us to do so. In some instances, We may collect your information from someone else. This may include our authorised representatives, our distributors or referrers, agents or related entities, anyone you have authorised to deal with Us on your behalf, and/or Our legal or other advisers.
If you provide Personal Information to Us about another person, We rely on you to have made or make them aware that you will, or may, provide their information to Us and the types of third parties we may provide it to, the relevant purposes We and any of the third parties will use it for and how they can access it. If you have not done, or will not do, so, you must tell Us before you provide the relevant Personal Information.
From time to time We may request Personal Information from you through competitions or surveys. Participation in these competitions or surveys is completely voluntary and you, therefore, have the choice of whether or not you disclose the Personal Information requested.
Why we collect and How we use Personal Information
We collect Personal Information to provide or offer you the various products and services We administer, or otherwise as permitted by law. Such purposes include responding to your enquiries, providing you with assistance you request, maintaining and administering Our products and services; processing your survey or questionnaire responses; market research and the collection of general statistical information using common internet technologies such as cookies; providing you with marketing information regarding other products and services; quality assurance and training purposes; performing administrative operations (including accounting and risk management) and any other purpose identified at the time of collecting your information.
If you do not consent to Us collecting and using all or some of the Personal Information We request, We may not be able to provide you with Our products or services such as processing your application for Our products and services.
We use Personal Information collected through competitions to determine prize winners, award prizes and notify winners. We use Personal Information collected through surveys or questionnaires to assess your satisfaction with Our products and services and to determine how We may better service your needs. We, and our Related Companies, may also use Personal Information you provide for research and statistical analysis.
We may use your Personal Information to confirm your identity for the purposes of anti-money laundering and counter-terrorism laws to assess your eligibility for Our products.
On occasion, We, and Our Related Companies, or other third parties with whom we have a relationship, may use your Personal Information to offer you products and services which We believe may be of interest to you.
Sharing and Disclosing your Personal Information
We may share your Personal Information with our Related Companies, other third parties and unrelated parties from time to time.
Details of who they are may change from time to time. You can contact us for details. In some cases, We may not be able to take reasonable steps to ensure they do not breach the Privacy Act and they may not be subject to the same level of protection or obligations that are offered by the Privacy Act. By proceeding to acquire Our services and products you agree that you cannot seek redress under the Privacy Act or against Us (to the extent permitted by law) and may not be able to seek redress overseas.
Related and unrelated third parties to whom your Personal Information is disclosed are required to keep the information confidential and only use it for the same purposes We are permitted to use it.
Quality of your Personal Information
We aim to ensure that your Personal Information is accurate, complete and up to date.
During the course of your relationship with Us we will ask you to inform Us of any changes to your Personal Information. You should, however, contact us at any time to update your Personal Information or advise Us that the information We have is not accurate or complete.
Security of your Personal Information
We are committed to keeping your Personal Information secure and will use all reasonable precautions to protect it from loss, misuse or interference and unauthorised access, modification or disclosure, including:
- physically securing external and internal premises;
- maintaining computer and network security such as user identifiers and passwords to control access to computer systems;
- restricting access to your Personal Information to employees or those who perform services on Our behalf who are authorised to handle your Personal Information and on a ‘needs to know’ basis;
- entering into confidentiality agreements with relevant employees and third parties;
- appropriate training of staff;
- retaining your Personal Information for no longer than it is reasonably required to provide any products and services to you, unless We are required by law to retain it for longer; and
- taking reasonable steps to destroy or de-identify Personal Information that We no longer require or which was unsolicited and We identify that We would not have otherwise collected it from you.
Access to and Correction of your Personal Information
You may generally access the information We hold about you and request corrections. This right is subject to the exceptions detailed in the Australian Privacy Principles. For example, We may refuse access where the:
- information may have an unreasonable impact on the privacy of others;
- request is frivolous or vexatious;
- information relates to existing or anticipated legal proceedings and would not be accessible by the process of discovery in those proceedings; or
- information would reveal Our intentions in relation to negotiations in such a way as to prejudice those negotiations.
If We refuse access or to give access in the manner requested by you, We will let you know why in writing.
Where providing access would reveal evaluative information in connection with a commercially sensitive decision-making process, We will provide an explanation for the decision rather than direct access to the information.
In most cases, you may access your Personal Information at no cost to you by contacting Our Privacy Officer by sending an email to firstname.lastname@example.org.
For access to complex information or more detailed requests for access to your Personal Information, for example, access to information that is archived, We may require you to place your request in writing and charge you a fee for Our reasonable costs of retrieving and supplying the information to you.
In all cases you will be asked to verify who you are before your Personal Information is provided.
All requests for Personal Information will be handled in a reasonable period of time.
How to contact us
Depending on the nature of your enquiry We may ask you to put your request in writing. To contact the Privacy Officer you can send an email to email@example.com or write to:
PO Box 1338
Collingwood VIC 3066
If you are not satisfied with Our response to your enquiry or complaint you can contact the Privacy Officer and request that it be reviewed by a senior staff member who will endeavour to resolve your dispute within 30 days. If you are still not satisfied We will tell you about any options you have to refer the matter to a recognised external dispute resolution scheme of which we are a member or to the Office of the Australian Information Commissioner.