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Privacy Policy

Introduction

We are committed to protecting and maintaining your privacy and we are bound by the Australian Privacy Principles (APPs) and Privacy Act 1988 (Cth) (Privacy Act). As part of our business operations we may collect your personal information. This Privacy Policy describes the type of personal information we may collect and how we use, hold and disclose this personal information.

Please note that due to the nature of our business activities, from time to time we will handle personal information relying on the media exemption in the Privacy Act where appropriate and this is discussed in more detail below. We may also rely on the related bodies corporate, employee records and other exemptions that are included in the Privacy Act.

This Privacy Policy is in addition to the general Terms of Use governing our digital services and should be read in conjunction with such Terms of Use.

What is Personal Information?

When used in this policy, the term “personal information” has the meaning given to that term in the Privacy Act. In general terms, it is any information that can be used to personally identify you. This may include (but is not limited to) your name, age, address and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card, direct debit or PayPal account information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What Kind of Information Do We Collect and How Do We Collect It?

The type of personal information Initiative Media collects will vary depending on the nature of your dealings with us. We only collect personal information that we need for our business activities, or which is volunteered to us. In general, the type of personal information we collect and hold could include (but is not limited to) your name, address (postal and email), contact details, geographic location (including your suburb or post code), gender, date of birth, activity, photograph, payment details, drivers licence (where necessary to verify your identity) and transaction details relating to your use, enquiry or purchase of our products and services (or of those promoted by us) and any preferences you tell us about. We may collect your personal information via our websites, applications, chatbots and other digital services, when you email or write to us, when you subscribe to our services, when you attend an event or program run by us or participate in a survey, questionnaire, competition or other marketing campaign run by us and/or our partners.

In order to access some of our services and products, you will be asked to register with us by providing us with certain information about you which we refer to in this Privacy Policy as your Account. As part of creating your Account, you may also be requested to provide questions and secret answers, which we use to help verify your identity and assist in resetting your password, as well as an alternate e-mail address. Your account may, in some cases, also be created using your log-in details to third party platform providers like Facebook or Google.

Information we collect from other sources

We may access information, including personal information, about you across our platforms and from third-party sources and platforms (such as social networking sites, databases, recruitment platforms such as LinkedIn and Seek, online marketing companies, agents or representatives we have engaged via our digital services, Microsoft Products, third party digital services and data supply companies) and supplement the information we collect with information obtained from those third party sources.

When you connect with us through social networking services, you will be able to see the social sharing habits of your friends and connections and participate seamlessly in our social capabilities, including commenting, live blogging, reactions, ratings, gaming mechanics and sharing content. You can connect us to your third party social networking service by downloading an application and signing into the application. By connecting with us through these third-party social networking services, you are authorising us to access and use certain information from your social network profile.

If you do not provide and we do not collect your personal information in the ways we have described above, we may not be able to as effectively provide you with our products and/or services that you have requested. For example, if you do not register as a member of our news websites or applications, you may not be able to access features and services that are reserved for members or we may not be able to tailor the content of our websites or applications to your preferences so your experience of our websites or applications may not be as enjoyable or useful.

How will we use or disclose your information?

We only use or disclose personal information for the primary purpose for which we have collected it, or for another related secondary purpose, unless you have provided your consent for us to use it for another purpose. We may use or disclose your personal information for the following primary purposes:

  • contacting and/or communicating with you because you have requested to be part of a television or digital program (including by way of studio audience) or an on-air programme or have provided information about a news story or provided content for publication on our digital services;
  • conducting competitions or promotions either ourselves or for selected third parties such as our sponsors or advertiser customers;
  • for recruitment purposes, where you have shared personal information with us as part of a job application;
  • communicating with you, including by email, mail, chat, SMS or telephone in connection with our products and services and/or verifying your identity for these purposes;
  • operating and improving our digital services and providing you with more effective customer service;
  • allowing you to sign in or otherwise access products and/or services owned by Initiative Media;
  • making our digital services easier to use by eliminating the need for you to repeatedly enter the same information, allowing you to access protected parts of our digital services and/or allowing you to comment on content displayed on our digital services;
  • providing you with news and information about our products and services or those of our partners (including by direct marketing to you and sending you newsletters, product surveys and special offers);
  • sending you marketing and promotional material about other products and/or services of Initiative Media or our partners that we consider you may be interested in;
  • performing quality control, product development, customer research and other types of research and analysis aimed at improving our products, services and technologies;
  • displaying content and advertising that are personalised and customised to your interests, preferences and experiences, including by using aggregated information and data received from across our platforms and from third parties;
  • investigating any complaints about or made by you or assisting the police or any regulatory body to do so, or if we have reason to suspect that you are in breach of the terms and conditions of any of our products and services or that you are or have been otherwise engaged in any unlawful or prohibited activity;
  • sharing your personal information with the police and/or an appropriate government or community organisation if we consider you may be at risk of causing serious harm to yourself and/or a third party/s or would otherwise benefit from being contacted by the government or community organisation in relation to mental health information and/or support;
  • sharing with our employees, related bodies corporate, joint venture entities, partners, contractors or external service providers to fulfil any of these purposes. External service providers may include (without limitation) web hosting providers, IT systems administrators, production companies, casting agents, mailing houses, newsagents, couriers, payment processors, photographic analysers, data entry service providers, outsourcing service providers, debt collectors and professional advisers; and/or
  • using personal information as otherwise required or permitted by any applicable law (including the Privacy Act).

We also collect other information and data, such as anonymous data that we collect via your interaction with our digital services and third party digital services (where we provide digital analytics tools or deliver advertisements) using tracking technologies such as cookies and web beacons (this is described in further detail below). This information and data may not be considered personal information under the Privacy Act. This information and data may be used by us internally and/or provided by us to third parties including our partners, clients and service providers for purposes that may include, without limitation, providing you with more relevant advertising, preparing audience insights, customer research, campaign analysis, conducting launch surveys and modelling.

We will not provide any personal information to an advertiser or any other third party other than in accordance with the terms of our Privacy Policy without your express consent. However, to the extent that anonymous user data does not constitute personal information, we are entitled to deal with that information in any manner we see fit.

You expressly acknowledge and agree that information including your personal information may be shared within Initiative Media and with the third parties referred to in this Privacy Policy for use by those third parties for the purposes disclosed in this Privacy Policy.

Sensitive Information

We do not generally collect sensitive information as that term is used in the Privacy Act. This term applies to information such as your racial or ethnic origin, membership of political bodies, religion or trade unions, sexual preferences or activities, state of health or medical history and criminal record. If we hold any sensitive information about you, that information will only be used and disclosed by us if you have consented to such use and disclosure (your provision of that information will be taken to be consent but will only be used and disclosed for the purpose that it was provided by you).

What Marketing Communications Will You Receive?

Opting In

In certain contexts when we collect information from you, you may be asked to “opt in” to consent to us using or disclosing your personal information. For example, you may be asked to opt-in to receive further information or communications from our advertisers and partners. We do not provide your personal information to other organisations for the purpose of direct marketing unless expressly authorised by you.

We may send you direct marketing communications and information about products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, telephone, SMS or email, in compliance with applicable marketing laws, such as the Spam Act 2004 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.

Security and Management of your Information

We understand that the security of your personal information is important. Once collected, we may hold your personal information in a number of different formats, including (but not limited to) software programs (located both onsite and offsite, including in the cloud), databases, filing systems, in offsite backup storage and in other similar technology. We take all reasonable steps to protect your personal information (and your anonymous usage data) and to keep it secure from loss, unauthorised access, modification, disclosure, interference or other misuse and we have appropriate controls in place to limit who in Initiative Media can view, access and/or use your personal information and anonymous usage data.

We also impose strict requirements of security and confidentiality on all third parties (for example, those who provide us with technology services) as to how they store, handle and deal with the personal information and anonymous usage data that we hold.

Personal information and anonymous usage data collected by us may be stored, disclosed and processed both in Australia and/or overseas, including but not limited to the United States, New Zealand, China, India, Malaysia, the Philippines and Singapore. Our third party contractors and service providers may perform some of their services overseas and/or we may use data hosting and cloud based IP service providers whose operations are located overseas. In all instances where this occurs, we only disclose your personal information to them and authorise them to use it in accordance with the Privacy Act and this Privacy Policy.

Tracking Technologies Notice

We also collect anonymous usage data about your browsing activity on our platforms network via various tracking technologies (for example, via cookies, tags, pixels). Our third party service providers may also collect anonymous usage data on the terms of their privacy policies which will be disclosed to you where relevant. This anonymous usage data may be used to identify your device on third party digital services where we have an arrangement in place to serve ads on those third party digital services. We may also collect anonymous usage data from third party digital services. One of the reasons we collect usage data is to display to you more relevant advertisements or content on the Initiative Media network and also on third party digital services.

Tracking technologies contain information that can later be read by a web server in the domain that issued the tracking technology to anonymously identify your device. We use the following types of tracking technologies:

  • Strictly necessary tracking technologies. These are tracking technologies that are required for the operation of our digital services. They include, for example, tracking technologies that allow you to sign in and use our services and remember you when you sign in to secure areas of our digital services.
  • Analytics tracking technologies. These tracking technologies allow us to recognise and count the number of visitors and to see how visitors move around our digital services. Some of the tools we use only provide us with information about trends and aggregate user behaviour. Other tools we use enable us to see how each visitor engaged with our digital services. For example, we will be able to see what you clicked on and how you navigated through our digital services. We use this information to better understand how our visitors use our digital services, so that we may make the necessary improvements to enhance our visitors’ experience in the future. We do not attempt to identify you with this information.
  • Functionality tracking technologies. These are used to recognise you when you return to our digital services and they allow us to personalise our content for you, for example, by remembering your preferences.
  • Advertising tracking technologies. These tracking technologies record your visit to our digital services, the pages you have visited and the links you have followed. We will use this information to make our digital services and the content and advertising displayed on it more relevant to your interests. We also use this information to determine the effectiveness of advertising campaigns. We may also share this information with third parties for this purpose. We also permit advertisers to embed their own tracking technologies in their own advertisements. Generally, advertisers will embed tracking technologies in their own advertisements to monitor the performance of their advertising campaign.
  • Measurement tracking technologies. We also permit third party service providers to embed tracking technologies on our digital services to assist them to provide measurement and analytics services in relation to the use of our digital services.
  • Social media tracking technologies. We use these tracking technologies when you connect and share our content and information using a social media sharing button or “like” button on our digital services to keep track of the way end-customers engage with and share our content. The social network will record that you have done this and this information may be linked to their targeting/advertising activities.

Display of Advertisements

Many of the digital services we offer are supported by advertising. We may display advertisements on our digital services and on the digital services offered by our advertising partners. We place tracking technologies on your device when you interact with our digital websites and apps and this anonymous data may be used to group you into relevant audience segments so that we can deliver more relevant advertising to you. We may also use the tracking technologies to recognise your device each time we display an advertisement to your device. We are able to compile information over time about where you, or others who are using your device, saw and/or clicked on the advertisements we display. We may also associate this information with your visit, purchase or other activity on participating advertiser’s digital services in order to display relevant advertisements or to determine the effectiveness of the advertisements.

For example, if we inferred that you are interested in bicycles, you may see advertisements for different brands or types of bicycles whereas if we infer that someone else is interested in travel, they might see advertisements for flights and accommodation packages. It is this targeting which enables us to optimise our advertising and your user experience and to provide you with more relevant information about different products and services available to you. Advertisers may also embed their own tracking technologies in their advertisements on our digital services. Our third party service providers may also embed tracking technologies on our digital services to assist them to perform services for us. We encourage advertisers and such third party service providers to have a privacy policy that outlines their data collection activities and usage. Please refer to such third party privacy policies for more information.

Your advertising choices

When we display interest-based advertising, we take a number of steps designed to protect your privacy. We store content consumption data (eg page views) used for ad targeting separately from your contact information or other data that directly identifies you. We use interest-based advertising to make the ads you see on our network more relevant to you. Online advertisements on our digital services are served by ad servers and exchanges and/or by our other third party service providers to whom we may from time to time outsource the procurement of advertising. These companies may offer you a way to opt in or opt-out of ad targeting based on their tracking technologies. If you would like to opt out of interest based advertising please contact us. You can also manage certain tracking technologies in your web browser privacy settings.

Please note that even if you opt out of interest based advertising, anonymous usage data may however continue to be collected by us and/or our third party partners for other purposes.

Changes to this Privacy Policy

We may, from time to time, review and update this Privacy Policy to take account of new laws, technologies and changes to our business and operations. All personal information held by us will be governed by our most recent Privacy Policy which will always be available on our digital services. By using our digital services, you are deemed to have agreed to the terms of our Privacy Policy (as updated from time to time) and you should therefore ensure to review our Privacy Policy regularly to keep abreast of any changes that may have been made.

Procedure for Data Breaches

We do all we reasonably can do to ensure your data is collected, used and held securely in accordance with industry standards. If at any time we become aware of unauthorised access to or disclosure of personal information held by us and we consider this is likely to result in serious harm to any individual to whom the information relates we will follow the data breach notification requirements under applicable law including to notify the individual involved and the relevant regulator.

EU and Californian Residents

If you are based in the European Union or California, there are specific regulations that apply in relation to the collection, processing and storing of your personal information by organisations covered by those regulations. To the extent that we are legally required to comply with those regulations in relation to any personal information and/or anonymous usage data we collect, process, disclose or store about you, we will comply with those regulations. Please note that we do not develop, target or direct our websites, products or services towards individuals (including children) situated outside Australia. Our business is targeted at individuals who are domiciled in Australia even though you are able to subscribe for our services from outside Australia.

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