In this policy “we”, “us” and “our” means Paragon DCN Pty Limited, its subsidiaries and affiliated companies. Please read this policy carefully as it describes the way in which we collect and handle your personal information. We may update or revise this policy from time to time. If we elect to update or revise this policy, we will post the date on which that revision takes effect at the end of this policy. Please be aware that you have no obligation to provide any personal information requested by us. However, if you choose to withhold your personal information, we may not be able to provide you with the services or products that depend on the collection and use of that information.
1. OUR PRIVACY COMMITMENT
We recognise the importance of, and are committed to, managing any personal information that we collect in compliance with the Privacy Act 1988 (Cth), which includes the Australian Privacy Principles, and other Australian privacy laws (together, “Privacy Laws”). As a member of the Australian Press Council (“APC”), we also ensure any personal information we collect in the course of our journalistic activities is managed in accordance with the APC Statement of Privacy Principles.
2. HOW DO WE COLLECT PERSONAL INFORMATION?
Where possible, we collect your personal information directly from you. This collection includes through your:
· registration when you purchase a product, magazine or digital subscription;
· entry into promotions or competitions;
· answers to surveys;
· signing up to newsletters and other notifications from our magazines and other brands;
· signing up to join our online communities;
· registration to attend events;
· provision of express permission when accessing applications sitting on Paragon brand social media accounts;
· application for an internship or employment with us;
· communications with us such as letters, telephone calls, text messaging and emails regarding services and products;
· registration for our loyalty clubs; and
· download and use of our digital publications and mobile applications (“apps”).
In some circumstances, however, we may also collect your personal information from third parties or public agencies where it is unreasonable or impracticable for us to collect the personal information directly from you. For example, if you subscribe to one of our magazines through a third party that is authorised to take subscriptions for us, we will collect your personal information from that third party. If we have difficulty in delivering a magazine to you, we may make enquiries in an effort to locate your address or correct any error in our recorded address details for you.
In some circumstances, we may provide you access to our online communities through the option of a third party platform sign on (including but not limited to, social sign ons). In this instance we will be accessing and collecting the personal information which you have authorised the third party platform to pass on to us. Where we collect personal information from third parties, we will ensure that the collection is conducted in a fair and lawful manner and the information is reasonably necessary for our functions or activities.
3. WHAT PERSONAL INFORMATION DO WE COLLECT?
The personal information we collect varies depending upon the purpose of the collection and the product or service we are providing you. Generally, we collect and hold the following types of personal information:
· your name and address;
· your telephone number;
· your e-mail contact details;
· your date of birth;
· your gender;
· other information you may make publicly available online (including but not limited to on social media platforms);
· transaction details, if you make a purchase with us or choose to store details in your online profile;
· bank account/credit card numbers and associated details as reasonably required in relation to processing payments at your request; and
· any other personal information which may be required in order to facilitate and where possible improve your dealings with us.
However, for certain purposes, such as where you apply for employment with us, we will collect additional personal information such as your employment history, educational history and employment references. We generally do not collect sensitive information that is associated with an identifiable individual.
We may from time to time collect information that would be sensitive personal information about you with your consent where the collection is related to provision of a service or other benefit to you. For example, we collect information from expectant mothers in relation to them and their families with their consent, in order to provide them with baby products and associated maternity benefits.
We may collect information from you about particular health concerns, gender orientation or other sensitive information with your consent, in order to provide you with offers or promotions related to your concerns or status.
In the event that we are required to collect sensitive personal information, we will notify you of this at the point of collection and obtain your consent to collect and hold this sensitive personal information.
If you provide us with sensitive information on an unsolicited basis, we assess whether such information is reasonably necessary for one or more of our functions or activities. The unsolicited sensitive information you disclose to us may be used and disclosed for the purpose for which you provided such information or, where you would reasonably expect us to, we may use the information for a directly related secondary purpose. We may also disclose or use the information for other purposes with your consent or if required to by law.
4. WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?
We will collect your personal information if it is reasonably necessary for the performance of our business activities and functions, which includes providing a range of products and services to you, some of which are listed below.
4.1 Registration for magazine subscriptions
We collect personal information from individuals who purchase products or subscribe to magazines that we publish in order to process their payments, fulfill their order and to confirm whether they would like to receive promotional materials in the future.
We will also seek your consent to send to you promotional material and special offers. Where you have a subscription for a magazine published by us or purchased from us through a third party, then we will also send you renewal notices and that magazine’s regular newsletter as well as promotional material. Occasionally (where notice has been given) you may also be sent special offers from third parties associated with that magazine.
4.2 Sales Promotions, Competitions, Surveys and registration to attend our events
We collect personal information when you respond to one of our promotions, competitions or surveys or when you register to attend an event in order to inform you if you have won a prize, to place you on a guest-list to the event and to help us better understand what products and services you would like to receive information about in the future.
4.3 Our mobile apps
We, or a service provider, may collect information through our apps to assist us in understanding how you use our apps, how the apps are performing across different handsets and to assist us in the selection of advertisements for groups of individuals. Our access to this information, is as you have agreed to with the respective app store from which you download our app.
4.4 Registration for our newsletters, online communities and/or loyalty clubs
We collect personal information when you sign up to register for our newsletters or join one of our online communities or loyalty clubs. By providing this personal information we are able to keep you updated on special offers and events that you may be interested in and to reward your commitment to the brands.
4.5 Our online communities
We collect personal information from you when you participate in any activity on our online communities. By providing personal information to us during such activity, we can assist in identifying ways in which we can provide you with a better service, or enhance your online experience.
4.6 Employment or internship
We collect personal information from applicants who are seeking employment or an internship with us as part of the recruitment process. In circumstances where you do not provide the mandatory personal information, we will be unable to consider you for a position with us.
4.7 Membership-based websites
We collect your personal information when you register with one of our membership-based websites, including Bounty Rewards, beautyheaven and Beauty Directory, in order to keep you informed of upcoming offers, new products and services and periodically you may be sent newsletters, communications or special offers directly from third party clients.
We also use your personal information to help us verify your identity, display content and advertising that are customised to your interests, preferences and experiences and for business research and product development.
From time to time there may be other purposes for which we collect, hold, use and disclose your personal information. We will tell you about these at the point of collection.
4.8 Direct Marketing and Research
As set out above, we may use personal information about you for marketing and research purposes. However, you can manage your communication preferences with us in a number of ways, eg if you are an online customer, you will be provided options to manage your own online profile; you may also contact our Privacy Officer. In addition, the marketing communications that we send to you will also contain information on how to unsubscribe from those communications.
You can also tell us at any time if you do not want us to disclose your details to other organisations such as our related companies or third parties for marketing purposes. To do this, you just need to contact our Privacy Officer.
Sometimes we extract information from our collected records to produce aggregated data. This aggregated data does not identify individuals. We use the aggregated data for research purposes, product development and may share the data with third parties.
1. WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?
We provide your personal information to third parties where you have consented to such disclosure. We also provide your personal information to third parties in order to carry out our business activities and functions. This may include:
· organisations who are sponsoring or otherwise involved with or participating in a promotion, offer, competition or survey;
· other companies or individuals we engage to perform functions on our behalf, such as mailing a subscription, processing credit card information, mailing information or prizes, data analysis, telemarketing, research and advertising, IT support services; and
· with your specific and prior consent, to other companies or individuals for the purposes you have consented to.
We disclose your personal information offshore to our joint venture partners, service providers and agents. It is not practicable to specify all countries to which we may disclose your personal information. The countries your personal information will be disclosed to include New Zealand, the USA and the Philippines. We ensure that any organisation which we disclose your personal information to is subject to appropriate contractual obligations to safeguard and protect your personal information and comply with all Privacy Laws.
In certain circumstances, we may disclose your personal information where required or authorised to do so by law, including in emergency situations and to assist law enforcement agencies. We will always ensure that those to whom we disclose your personal information have the legal right to receive it.
2. HOW IS YOUR PERSONAL INFORMATION SECURED?
We understand that the security of your personal information is important. As such, we take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. We store information both at an onsite secure server and at trusted third party storage providers. We undertake regular training of relevant staff to ensure that they are aware of our privacy commitments and our obligations in the collection, use and disclosure of personal information. Our staff is also required to sign in and use a password when accessing our secure systems.
3. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
In certain circumstances where you have a sign in to your customer details and/or you can access your own personal information via your membership you will be required to follow prompts to access, correct or update your personal information. If this option is available to you directly, we will clearly mark it for ease of access.
You can access or correct your personal information by contacting us using the ‘Contact Details’ set out below. Please provide us with as much detail as you can about the particular information you wish to access or correct, in order to help us retrieve it. We may charge you an access fee to cover our costs of providing that information to you. We will inform you of applicable fees before they are incurred.
In certain circumstances, we may refuse your request to access, or correct, your personal information. If that is the case, we will provide you with reasons for that decision unless it is unreasonable for us to do so.
We take reasonable steps to make sure that the personal information we collect is accurate, complete and up-to-date including updating personal information when we are advised by you that your personal information has changed.
If you wish to delete the personal information we hold about you, please let us know by contacting us using the ‘Contact Details’ set out below and we will take reasonable steps to delete the information, unless we are required to retain it for legal reasons.
We, and our service providers, use the information collected from cookies for a number of reasons:
· for statistical purposes in order to track how many users we have and how often they visit our website or apps;
· to provide statistical data, ratings and other information for industry and other public reporting;
· to provide you with a more personalised, convenient and interactive experience on our websites or apps;
· to track who has viewed an advertisement or clicked-through an advertisement; and
· to provide you with a more targeted advertising experience both on and off our websites or apps, allowing us to impose restrictions where appropriate and monitor how effective an advertising campaign has been.
We sometimes use services, including Google Adsense, DoubleClick, Adobe, Nielsen and Facebook, in activities such as analytics and online behavioural advertising, to provide you with more relevant messages. You can find more information on these services and choose to opt-out from services of your choice by using this website http://optout.networkadvertising.org. You will still see advertising after opting out, however it won’t be tailored to your likely interests. Opt-outs only apply to online behavioural advertising and do not apply to other technologies such as email and social advertising.
5. THIRD PARTY WEBSITES
6. ANONYMITY AND USE OF A PSEUDONYM
You may request at any time that you remain anonymous, or choose a pseudonym, when dealing with us. To the extent that it is lawful and practicable for us to enable you to do so, we will grant such a request.
7. HOW TO MAKE A COMPLAINT
If you wish to make a complaint about the way in which we handle your personal information, please contact our Privacy Officer using the contact details set out below.
We undertake to acknowledge and investigate any complaint promptly and will respond to written complaints within a reasonable time from the date of receipt.
If you are dissatisfied with our response, you may refer the matter to the Australian Information (Privacy) Commissioner (see www.oaic.gov.au). If you are dissatisfied with our response in relation to the way in which we handle your personal information in the course of our journalistic activities, you may refer the matter to the Australian Press Council (see www.presscouncil.org.au).
8. CONTACT DETAILS
The Privacy Officer
Paragon DCN Pty Limited
14/174 Willoughby Road
Crows Nest NSW 2065
Alternatively, you can send an email to our Privacy Officer at firstname.lastname@example.org.