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PRIVACY POLICY
This Privacy Policy applies to the collection
of Personal Information by or on behalf of Austereo Pty Ltd,
Consolidated Broadcasting System (WA) Pty Ltd, Perth FM Radio
Pty Ltd and all other members of the Austereo Pty Ltd group
of companies ("Austereo").
On some occasions we may conduct a promotion
or other activity which has its own specific Privacy Policy.
In this case, notice of that policy will be provided at the
time any Personal Information is sought and that policy will
apply to that promotion or activity and will override this
policy to the extent of any inconsistency.
INTRODUCTION
Austereo operates a number of broadcast radio stations throughout
Australia. Through our varied operations, we gather information
for a variety of reasons, for example to enable us to improve
the nature of the services we provide and to facilitate the
running of various competitions.
We collect personal information from you in
various ways, for example, when you enter competitions, advertise
with us, supply goods or services to us or send us your comments
or other correspondence. For the purposes of this Privacy
Policy all parties we deal with are referred to as "Individuals".
The personal information we collect from you may include your
contact details, buying habits, opinions, product preferences,
transactional details or other information which may lead
you to be identified (herein referred to as "PI").
We are committed to the protection of PI in
a manner which is fair and unobtrusive. We meet the standards
set out in the Privacy Act 1988 (Commonwealth) ("the
Act") and the National Privacy Principles ("NPPs")
regarding the way in which we will collect, hold, use and
disclose PI and respond to your requests to access and/or
correct it. This policy sets out how we handle your PI and
the rights and obligations that we both have in relation to
that information.
This policy may be reviewed from time to time
so it is best to read it at any time you are proposing to
supply us with PI. By using our website or providing PI, you
agree to be bound by the terms of this Privacy Policy and
consent to any use of PI that is in accordance with this policy.
Any proposed use of PI that is not covered by this policy
will be disclosed at or prior to the time of collection and
where practicable, your consent will be obtained.
ANONYMITY
In accordance with the NPPs, you may deal with us on an anonymous
basis where practical. However, as a provider of a wide range
of services, we find that it is often necessary to collect
PI from you during the course of transactions, for example,
to facilitate the running of a competition.
CONSENT
Wherever practical, we will obtain your express consent when
collecting PI. In some situations, we will interpret your
actions as indicating your consent to the collection of PI.
For example, this may occur when you have provided PI for
a particular purpose and that purpose cannot be achieved without
using your PI.
WHY WE COLLECT PERSONAL INFORMATION
We collect PI for a number of reasons, including:
* to provide you with our products or services;
* to administer our relationship with you;
* to facilitate the running of trade promotions and other
competitions (see below);
* to facilitate the running of listener loyalty programs such
as the Freq Club;
* to monitor activity on our websites, for the purpose of
maintaining the security of those websites;
* to compile Individual and listener databases to enable us
to market goods and services more accurately;
* to provide advertisers with information to assist them in
their decision making processes and marketing of goods and
services;
* for internal administrative purposes, such as procedural
assessments, risk management, staff training, accounting,
billing and product and service reviews; and
* to identify and inform you about other products or services
that may be of interest to you.
If our relationship with you is not solely
one of broadcaster-listener, we may use your information in
other ways, for example, to assess goods or services that
you supply or to pay your account.
COMPETITIONS
If you provide us with PI as part of an entry into a competition
then we will use that information to contact you in connection
with the competition and in accordance with this Privacy Policy.
Depending on the nature of the competition
or offer, we will ask for your personal details such as your
name, address, email address, age, telephone number/s and/or
gender. Sometimes in relation to a particular competition
we may also seek additional information.
PI collected during competitions will be governed
by the terms set out in this Privacy Policy unless otherwise
stated in the conditions of entry for the competition, or
an alternate Privacy Policy applies.
CONSEQUENCES OF NOT PROVIDING ALL REQUIRED
INFORMATION
We may not be able to provide a complete service to you if
PI is not provided upon request. For example, providing incomplete
information could render a competition entry invalid.
HOW WE COLLECT PERSONAL INFORMATION
We primarily collect PI directly from you through written
and/or verbal means of communication. However, PI may be collected
in a variety of ways, including:
* competition entry forms;
* application forms;
* participation in the Freq Club or other listener loyalty
programs;
* email;
* posted mail;
* websites (including in some instances cookies);
* online transactions;
* networking functions (eg business cards);
* in person;
* over the telephone;
* credit card details via credit card purchases;
* public surveys;
* employee applications and surveys;
* business contacts (eg contractual documents);
* information collected from third parties (eg marketing databases);
* information collected from public sources (eg telephone
directories); and
* other forms of written and verbal communication.
We may also obtain details about you or your
business from sources that are publicly available such as
websites, journals, legal directories and phone books. We
will only collect information about you from third parties
in rare circumstances, for example where one of your friends
indicates to us that one of our services or products may be
of interest to you. If we do collect PI in this manner, it
will only comprise of your name and contact details and we
will endeavor to make you aware of the collection of this
information, the third party's contact details and this Privacy
Policy.
We may also collect anonymous information through
the use of cookies on our website. Cookies are pieces of information
that are stored on your computer's hard disk. Most web-browsers
are set to accept cookies but you can set your web-browser
to refuse cookies. Cookies themselves do not identify users
personally but they do allow the tracking of an Individual's
use of a website. Cookies have become commonplace.
THE TYPE OF INFORMATION WE HOLD ABOUT YOU
We only hold information about you that is relevant to our
relationship with you. Generally, the PI we hold will include
(where relevant) your name, contact details, membership/card/account
number/s, records of correspondence, subscription and payment
details, type of business and billing statements.
If our relationship with you is not solely
one of broadcaster-listener, we may collect other information
that we consider necessary in the circumstances, such as the
nature of the products or services that you supply, quotes
that you provide, your credit details and, if you are a non-profit
organisation that we have agreed to assist, how you make use
of the products or services that we provide you.
Sensitive Information
Sensitive information includes information about your race
or ethnic origins, political opinions, religious or philosophical
beliefs, trade union membership, or details of health, disability
or sexual activity or orientation. We rarely ask for sensitive
information, but may do so occasionally as part of competition,
promotion or survey, for example. We will not ask for sensitive
information unless:
* you have consented;
* the collection of the information is specifically authorised
by law;
* the collection is necessary to lessen a serious or imminent
threat to the health or safety or any person; or
* the collection of the information is necessary for the establishment,
exercise or defence of a legal claim.
HOW WE HOLD YOUR PERSONAL INFORMATION
Depending on the circumstances, we may hold PI in hardcopy
or electronic form, or both. Generally, we keep hardcopies
of all correspondence that we enter into and maintain details
about Individuals that we interact with in our electronic
database/s.
HOW WE SECURE YOUR PERSONAL INFORMATION
We hold all hardcopy and electronic records of PI in a secure
manner to ensure that it is protected from loss, misuse, unauthorised
access, modification or disclosure. PI held in hardcopy form
is, wherever practical, kept under lock and key. Pl held in
electronic form is, wherever practical, password protected
and/or encrypted.
Our staff follows strict information handling
procedures and only those whose tasks require use of your
information are able to access it.
We regularly de-identify and/or destroy PI
in a secure manner, for example by using shredding machines
and/or secure disposal units, once it is no longer needed
or required to be kept by law.
Where possible and practical, we endeavour to comply with
recognised Australian and international standards relating
to information security.
USE AND DISCLOSURE OF PERSONAL INFORMATION
We will only disclose your PI in certain, limited circumstances.
In general, only our officers, employees or
contractors who require the information in order to perform
their functions may access PI.
We will only disclose PI to parties other than
our officers, employees and contractors where:
* that disclosure is required to give effect
to the purpose/s for which we collected the PI, for example,
to provide you with a service you have requested, and we believe
that you would reasonably expect us to use the information;
or
* you have consented to that disclosure; or
* we believe that the disclosure may lessen a risk of harm
to the health or safety of any person; or
* we believe that the disclosure is required to protect our
rights or property or any other user of our services; or
* we believe an unlawful activity is being undertaken and
the PI is disclosed as part of our investigation into or reporting
of suspected unlawful activity; or
* we are required by law to disclose the PI; or
* the disclosure is required for the investigation of a possible
breach or enforcement of a criminal law or a law imposing
a pecuniary penalty, or for the protection of public revenue.
Generally, disclosure of PI will only be made
for a purpose that is directly related to the product or service
that we are providing you. This may include disclosure to
organisations that provide us with professional advice, such
as solicitors and accountants, and to contractors to whom
we outsource functions, such as mailing houses, collators,
electronic network administrators or debt collection agencies.
However, where possible, we take contractual measures and,
in all other circumstances, all reasonable measures with our
contractors to ensure that they comply with the standards
set out in the Act and the NPPs. Where practicable and appropriate,
we require our contractors to perform their work in-house
and do not permit them to disclose PI that we have disclosed
to them to their sub-contractors (if any).
The only other circumstances in which disclosure of PI may
occur are those which are expressly permitted under the Act.
For example, where the disclosure takes place with your consent
or where we are legally required to disclose the information,
such as under a court order or Australian taxation laws.
Overseas Transfers of Information
We will only transfer your Personal Information overseas if
the transfer is to yourself, to one of your authorised representatives,
or with your express consent.
If obtaining your consent is not practical,
then the information may still be transferred if, as part
of the agreement for the transfer of that information, the
other organisation agrees to comply with the privacy obligation
we owe to you.
PI may be transferred to our majority shareholder
Village Roadshow, for the purpose of providing you with information
regarding upcoming offers and opportunities offered by Village
Roadshow.
PI may be transferred to Fairwest Direct Inc
("Fairwest") and Level 3 Communications Inc ("Level
3") in the United States of America in order to facilitate
the listener loyalty program known as the Freq Club. By participating
in the Freq Club, you consent to the transfer of your PI overseas.
Fairwest and Level 3 do not have permission to use, sell,
transfer or access PI in any way except in connection with
facilitating the Freq Club. Our agreement in relation to the
Freq Club requires that all third parties adhere to the NPPs
in every respect.
We will not send your information outside of
Australia in any other circumstances, unless we have your
consent.
Aggregated Information
The demographic make-up of our database is researched on an
aggregated basis to see how successfully we are reaching our
target audience and providing services and items of interest
to them.
We will not sell your name or contact details
to a third party without your permission, but we may provide
advertisers with general information concerning, for example,
the demographic make-up of our listener base and/or traffic
to our website. This information does not enable you to be
identified as it is aggregated.
OTHER SITES
Please note that our website contains links to other websites
which are not administered by us. If you click on a link to
another website and subsequently leave our website, our Privacy
Policy will no longer apply, and we suggest that you refer
to the privacy policy relating to the other website.
ADVERTISEMENTS
Advertisers or sponsors on our websites may collect information
when you view or click on their advertisements. We do not
have any control over this data collection.
YOUR RIGHT OF ACCESS
You may request access to your PI at any time by written request
to Austereo's Privacy Officer by mail at GPO Box 107.1 Adelaide
South Australia 5000, or by email to privacy@austereo.com.au.
We may impose a reasonable charge for providing
access to Personal Information in accordance with the Act.
When we may withhold access to PI
Access to PI may be withheld in several circumstances, including
where:
* providing access would pose a serious and
imminent threat to the life or health of any person;
* providing access would have an unreasonable impact on the
privacy of others;
* the information is subject to confidentiality where the
person who provided the information to us did so expressly
on the condition that it remain confidential;
* the request is vexatious or frivolous;
* the information relates to current or anticipated legal
proceedings between Austereo and the person and the information
would not be required to be discovered to a court;
* we are in commercial negotiations with the person and the
information would reveal our intentions or otherwise prejudice
those negotiations;
* providing access would reveal information relating to our
commercially sensitive decision making processes;
* providing access would be unlawful or we are required by
law to withhold access; or
* providing access could prejudice the investigation, detection
or prosecution by Austereo or by a government body of possible
unlawful activity or serious or improper misconduct, or is
likely to cause damage to the security of Australia.
Where we are is unable to provide you with access to PI, we
will provide written reasons and may instead, at our discretion,
choose to give you a summary of that information. We may also
consider, at our discretion, whether the provision of access
to an independent third party will meet both of our requirements.
YOU MAY CORRECT YOUR PERSONAL INFORMATION
We regularly monitor the quality and accuracy of PI that we
maintain and, where practicable, update that information.
In addition, you may request that your PI be updated at any
time.
If your PI is out-of-date or otherwise incorrect,
please contact Austereo's Privacy Officer with your written
advice regarding the inaccuracy of the information and we
will endeavour to correct it for you wherever possible.
In the unlikely event that we disagree about
the accuracy of the information such that we are unable to
change it, you may provide us with a statement that you dispute
its accuracy and we will associate the statement with your
information in such a manner that it will be brought to the
attention of each person who uses that information.
YOUR RIGHT TO LODGE A COMPLAINT
If you are not satisfied with the manner in which we have
handled your PI, you may lodge a complaint in writing with
Austereo's Privacy Officer. We will inform you as to who will
handle your complaint.
PROMOTIONAL INFORMATION
We would like to send you promotional information about goods
and services that we believe may be of interest to you. However,
we understand that you may not wish to receive such material.
You will have an opportunity to "opt in" and/or
"opt out" (as applicable) in connection with promotions
except in some cases where you would be notified that opting
in was a condition of participation. If this is the case,
please inform our Privacy Officer and we will promptly remove
your name from our mailing list.
DIRECT MARKETING
PI collected for direct marketing purposes will only be collected,
used or disclosed with your consent as provided for in this
Privacy Policy.
In circumstances where we cannot practicably
obtain your consent, we may still engage in direct marketing
to that you, but will:
(a) advise you that you can be taken off the
mailing list at any time following receipt of a request from
you to that effect; and
(b) display our contact details clearly in
each direct marketing publication.
You may be removed from any Austereo mailing
list at any time. Simply send a written request to Austereo's
Privacy Officer.
WE MAY NEED TO CHANGE OUR PRIVACY POLICY
FROM TIME TO TIME
Due to changing business circumstances and legal requirements,
we may need to amend this Privacy Policy from time to time.
If so, we will publish the revised policy on our website/s.
Any action that was undertaken prior to the policy change
will continue to be regulated by the policy as it existed
at the time the action was taken.
FURTHER INFORMATION
Further information about privacy may be obtained from the
Office of the Federal Privacy Commissioner of Australia at:
http://www.privacy.gov.au.
CONTACT US
If you have any queries about this Privacy Policy, please
contact Austereo's Privacy Officer by mail at GPO Box 107.1
Adelaide South Australia 5000 or by email to privacy@austereo.com.au.
Contact details for of our radio stations can
be found below.
Copyright © 2003 Austereo Pty Ltd. All
rights reserved.
Austereo Pty Ltd (ACN 007 914 641) trading
as the following radio stations:
2DAY FM
GPO Box 22
Sydney NSW 2001
Ph: 02 9375 1041
Triple M Sydney
GPO Box 4442
Sydney NSW 2001
Ph: 02 9367 1000
FOX FM
PO Box 1019
St Kilda VIC 3182
Ph: 03 9205 1111
Triple M Melbourne
PO Box Triple M
St. Kilda VIC 3182
Ph: 03 9230 1051
B105 FM
GPO Box 105
Brisbane QLD 4001
Ph: 07 3837 1053
Triple M Brisbane
GPO Box 1041
Brisbane QLD 4001
Ph: 07 3361 0104
SA.FM
PO Box 107.1
Unley SA 5061
Ph: 08 8301 1071
Triple M Adelaide
PO Box 104.7
Unley SA 5061
Ph: 08 8290 1047
Consolidated Broadcasting System (WA) Pty Ltd
(ABN 17 008 670 460) trading as 92.9
PO Box 157
Subiaco WA 6904
Ph: 08 9382 0929
Perth FM Radio Pty Ltd (ABN 22 077 569 110)
trading as MIX94.5
PO Box 945
Subiaco WA 6904
Ph: 08 9382 0945
NXFM
PO Box 97
Charlestown NSW 2290
Ph: 02 4942 3333
KOFM
PO Box 606
Charlestown NSW 2290
Ph: 02 4942 1433 |
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