PERSONAL INFORMATION WE COLLECT
Information you give us
- The types of personal information that we collect about you will depend on our relationship with you, the circumstances of collection and / or the type of products and services you request from us. The personal information may include (but is not limited to):
- your name, gender and date of birth;
- your contact details including your email address, postal / delivery address and telephone / mobile number;
- billing information and credit card information;
- photographs and videos;
- details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
- information you provide to us through our service centre, customer surveys or discussions with our representatives from time to time; and / or
- additional information relating to you that you provide to us directly or indirectly through our Platforms or otherwise.
- If you apply for a job with us, we may collect the following personal information, in addition to the information referred to in paragraph 2.1:
- citizenship status;
- curriculum vitae or resume;
- employment history;
- academic records and qualifications; and
- referee details and comments made by referees about you.
Information you disclose using Interactive Services
- The Platforms include user-generated profiles, interactive messaging services and webcam services (“Interactive Services”). These are designed to enable you to communicate with other users of the Platforms (“Other Users”).
- Information that is disclosed by you during your use of the Interactive Services may be seen, copied and used by us and Other Users. There is no expectation of privacy when using the Interactive Services and we have no control over how Other Users may use the information you disclose. You should exercise caution and discretion before deciding to disclose that information.
Information given to us by third-parties
- We may collect information about you which we have received from third-parties. For example, if you access a Platform through a third-party connection or log-in, such as Facebook Connect, that third-party may pass some information about your use of its services to us. This information may include (but is not limited to):
- an ID associated with your third-party account;
- any information you have permitted the third-party to share with us; and/or
- any information you have made public in connection with the third-party provider.
- We may collect additional information from you. For example, we may collect your device’s operating system, the name of your mobile carrier and network, details of your location, and with your permission your GPS/geo-location.
- The degree to which your location can be identified depends on the device you are using (e.g. smart phone, tablet, laptop or desktop). We collect this information in order to provide you with the best level of service. If you enable location services, we may collect location data periodically as you use or leave open your access to a Platform. We may also use this data internally or in conjunction with our third-party service providers to customise your experience and provide offers that may be relevant to you. Depending on the service you use (e.g. Apple OSX iOS, Windows, Android etc) to access a Platform you may be able to control, from within your device’s settings, whether you wish to share your location data with us.
HOW WE COLLECT PERSONAL INFORMATION
- We may collect personal information about you:
- if you register an account (“Account”), including by creating a username and password, on a Platform;
- through your access and use of the Platforms and our services;
- if you send us an email / message or otherwise interact with us including during conversations between you and our representatives; and / or
- if you apply for a job with us.
- We may also collect personal information from third-parties including:
- agents, contractors and business partners; and/or
- third-party companies, like Facebook, who share your information with us in order to make your online experience more seamless.
- We use a range of social media channels (“Social Media”) to distribute news, announcements, promotions and to address community enquiries. If you submit or post comments, images, tweets, recordings or other personal content for public display on Social Media, that information may be available for anyone in the world to read, view or comment on. We are not responsible to you for the information handling practices of Social Media.
HOW WE USE YOUR PERSONAL INFORMATION
- We may use your personal information for the following purposes:
- to set up and administer your Account;
- to provide our products and services to you;
- to provide you with news, information or advice about our existing and new products and services;
- to communicate with you including by email, mail or telephone;
- to manage and enhance our products and services;
- to personalise and customise your experience;
- to process any job application you submit;
- to provide you with access to protected areas of our websites and applications;
- to conduct competitions or promotions on our behalf or that of selected third-parties;
- to verify your identity;
- to conduct business processing functions for operation of our websites or our business;
- for our administrative, marketing (including direct marketing), promotional, planning, product / service development, quality control and research purposes, or those of our contractors or external service providers;
- to investigate any complaints about you or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity;
- to prevent, detect and fight fraud or other unauthorised activities;
- to maintain records and comply with our legal obligations;
- to assist law enforcement personnel including police;
- as required or permitted by any law (including the Privacy Act); and/or
- for any other use that you authorise in writing.
DISCLOSURE OF PERSONAL INFORMATION
We may disclose your personal information to:
- our employees, related bodies corporate, contractors or external service providers, existing or potential agents, business partners or joint venture entities or partners that perform services for us in connection with the Platforms and in connection with the sale and provision of our products and / or services, including third-parties who:
- fulfil requests by you;
- provide information technology services such as data storage, website hosting, software and system development, maintenance and support, and information processing, analysis and reporting (e.g. “Google Analytics” and “Facebook Pixel”);
- assist us in providing delivery of products and/or services to you including third-party providers who provide information, data and documentation to us under licence;
- conduct or promote competitions via the Platforms;
- assist us in processing credit / debit card payments;
- provide marketing services; and/or
- provide services in the course of investigating a complaint or a security incident;
- specific third-parties authorised by you to receive information held by us;
- the police, any relevant authority or enforcement body, or your internet service provider or network administrator, for example, if we have reason to suspect that you have committed a breach of any of our terms and conditions, or have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary;
- to comply with our legal obligations;
- to comply with judicial proceedings or a court order;
- to assist in locating a missing person;
- to establish, exercise or defend a legal or equitable claim;
- for the purposes of a confidential alternative dispute resolution; and/or
- as otherwise required or permitted by any law (including the Privacy Act).
WHAT IF WE CAN’T COLLECT YOUR PERSONAL INFORMATION
- We may not be able to provide you with the products or services you requested, either to the same standard, or at all;
- We may not be able to provide you with information about products and services that you may want, including information about discounts sales or special promotions; and/or
- We may be unable to tailor the content of our Platforms and your preferences and your experience of our websites and applications may not be as enjoyable or useful.
ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
- You may request access to any personal information we hold about you at any time by contacting us (details at section 9 below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We will not charge for simply making a request and will not charge for making any corrections to your personal information. If you make an access request, we will ask you to verify your identity. There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you reasons for any refusal.
- If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may ask us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.
- Account holders will generally be able to access and update their details online. We request that you keep your information as current as possible so that we may continue to improve our service to you.
DELETION OF PERSONAL INFORMATION
- We keep your personal information only as long as we need it for legitimate business purposes (as laid out in section 4 above) and as permitted by applicable law.
- Even though our systems are designed to carry out information deletion processes according to the guidelines in paragraphs 8.1 above, we cannot promise that all information will be deleted within a specific timeframe due to technical constraints.
HOW CAN YOU COMPLAIN ABOUT A BREACH OF PRIVACY?
Attention: Privacy Officer
Postal address: Level 1, 222 Queen Victoria Street, North Fremantle 6159
- We have a formal procedure for investigating and dealing with privacy breaches. Once the Privacy Officer receives a complaint in writing the Privacy Officer will commence an investigation. The investigation will endeavour to determine whether there has been a breach, the nature of the breach and how it occurred. We may contact you during the process to seek any further clarification if necessary. If a breach is found, the Privacy Officer will escalate the matter to management so that the process can be rectified to prevent any further breaches from taking place. We will also contact you to inform you of the outcome of the investigation. We will endeavour to resolve all investigations within a reasonable time.
We may collect personal information regarding a child under 18 years of age from a parent or legal guardian. You must not provide personal information to us about a child or another person unless you are authorised to do so by law. If you are under 18 years of age and you provide us with your personal information, your parent or legal guardian must approve, on your behalf, the provision of your personal information to us.
- If you do not wish to receive cookies, you should set your browser so that your computer or device does not accept them.
- We may collect information from you in response to a survey. We generally use this information to get your feedback, report statistics, analyse trends, administer our services, diagnose problems and improve the quality of the Platforms.
- If you do not want us to collect information provided by you during the course of a survey, then refrain from completing the survey.
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 or email, in accordance 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.
OFFERS AND PROMOTIONAL MESSAGES
- We may use your email address or mobile phone number to send you updates and communications about our products and services or other messages, such as newsletters, text messages, changes to features of the Platforms, or special offers.
- You will be given the opportunity, in any promotional email or text message that we send to you, to opt-out of receiving such messages in the future.
- Our applications may include a function that allows us to use push notifications to send you updates, communications and other messages about the Platform.
- To opt-out of getting these push notifications or other messages you must terminate the applicable service. We do not send promotional messages about other products or services through these push notifications.
THIRD PARTY OFFERS
- We may use the information you have given us about your interests, and other profile or personal information, to develop and display tailored third-party content and advertising.
- At any time, you may opt-out of receiving marketing communications from us by contacting us (details at section 9 above) or through the privacy settings on the website or application you are using.
CROSS BRODER DISCLOSURE OF PERSONAL INFORMATION
- The Platforms operate in several international jurisdictions including Australia, New Zealand, the USA and the UK.
- As a result, your personal data may be transferred, stored and processed in another country in which we or our subsidiaries, partners or agents maintain facilities. These data processors, acting under our instructions, may be engaged in, among other things, the fulfilment of your information requests and the provision of support tools and services on the Platforms. They may also help us maintain the integrity and security of the Platforms, including emails and messaging services on the Platforms.
SECURITY – HOW WE STORE AND PROTECT YOUR INFORMATION
- We will take reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorised access, including by means of firewalls, password access, secure servers and encryption of credit card transactions.
- If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.
- In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
The Platforms may contain links to other websites operated by third-parties. We make no representations or warranties in relation to the privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third-party website. Third-party websites are responsible for informing you about their own privacy practices.
THE SALE OR TRANSFER OF OUR BUSINESS OR ASSETS
- If the business of Viewport is sold or disposed of as a going concern, whether by merger, sale of assets, change of ownership of operating entity or otherwise, or in the event of an insolvency, bankruptcy or receivership, the personal information of our customers may be one of the assets dealt with in connection with that transaction.
- Information about our customers may also need to be disclosed in connection with a commercial transaction where we or any of our businesses are seeking finance or investment, support or funding.
ADDITIONAL RIGHTS UNDER EU LAW
(This section 20 applies if you are located in the European Union (EU))
- provide you with further details on how we use and process your personal information;
- delete personal information we no longer have grounds to process; and
- restrict how we process your personal information while we consider an enquiry you have raised.
- In addition, under certain conditions, you have the right to:
- where processing is based on consent, withdraw the consent;
- lodge a complaint with the appropriate data protection authority if you have an issue with how we process your personal data;
- object to any processing of personal information that we process on the “legitimate interests” or “public interests” grounds, unless our reasons for the underlying processing outweighs your interests, rights and freedoms; and
- object to direct marketing (including any profiling for such purposes) at any time.
- You can exercise these rights by contacting us (details at section 9 above).
- These rights are subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege).