1 Openness and transparency
We are committed to protecting your privacy and respecting and upholding your rights under and the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Law). We ensure that we will take all necessary and reasonable steps to comply with the relevant Privacy Law and to deal with inquiries or complaints from individuals about compliance with the relevant Privacy Law.
1 Personal information
Personal information is any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
The type of personal information we may collect from you includes, without limitation, the following:
– your full name;
– email address;
– telephone number(s);
– date of birth;
– your job title;
– the organisation/s where you work or volunteer;
– credit card information;
– your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
– details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
– any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
– information you provide to us through customer surveys;
– billing information (including credit and bank details); or
– any other personal information that may be required in order to facilitate your dealings with us.
We will collect Personal Information only by lawful and fair means and not in an unreasonably intrusive way. Generally, we will collect personal information directly from you, and only to the extent necessary to provide our products and services requested or ordered by you and to carry out our administrative functions or as required by a relevant Privacy Law. We will not collect sensitive personal information (as defined under the relevant Privacy Law) from you. We also do not knowingly seek or collect Personal Information from children below the age of 16 years.
We may also collect Person Information from you when you fill in an application form, communicate with us, visit our website, provide us with feedback, complete online surveys or participate in competitions. We may collect Personal Information about you that you have provided to our business partners or from third parties and in respect of which you have given the third-party permission to share with us.
If you use a pseudonym when dealing with us or you do not provide identifiable information to us, we may not be able to provide you with any or all of our services as requested. If you wish to remain anonymous when you use our website, do not sign into it or provide any information that might identify you.
We require individuals to provide accurate, up-to-date and complete Personal Information at the time it is collected.
3 What do we do with your Personal Information?
We use, process and disclose your Personal Information for the purposes for which the information is collected, or for a directly related purpose, including (but not limited to):
providing our website, products and services to you;
administering, protecting, improving or optimising our website, products and services (including performing data analytics, conducting research and for advertising and marketing purposes);
billing you for purchasing or using our website, products and services;
informing you about our website, products, services, rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
responding to any inquiries or comments that you submit to us;
verifying your identity;
any other purpose you have consented to; and
any use which is required or authorised by a relevant Privacy Law.
4 How we protect your information
We may hold your Personal Information in either electronic or hard copy. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information. For example, we:
use password-protected electronic folders in which your personal information is stored;
keep passwords to electronic folders private that contain your personal information and only provide access to staff at TS who require your information to perform their role or provide a service to you;
avoid printing or storing your personal information in hard copy;
have internal policies which require any of TS’s staff members if they reasonably believe that your personal information has been unreasonably or unnecessarily disclosed to someone who is not authorised to receive it, must report it to the Head of Operations as soon as reasonably possible; and
ensure that if an unauthorised disclosure of personal information is likely to result in serious harm to one or more individuals, the Head of Operations will report it to the Office of the Australian Information Commissioner (OAIC) and the affected individuals in compliance with the Privacy Amendment (Notifiable Data Breaches) Act 2017.
However, we cannot guarantee the security of any Personal Information transmitted over the internet and therefore you disclose information to us at your own risk. We will not be liable for any unauthorised access, modification or disclosure, or misuse of your Personal Information.
5 Disclosure of Personal Information
We may disclose your Personal Information to:
third-parties we ordinarily engage from time to time to perform functions on our behalf for the above purposes (eg: our Customer Relationship Management software, which is highly secure);
any person or entity to whom you have expressly consented to us disclosing your Personal Information to;
our external business advisors, auditors, lawyers, insurers and financiers; and
any person or entity to whom we are required or authorised to disclose your Personal Information to in accordance with the relevant Privacy Law.
6 Access and management
Subject to some exceptions provided by the relevant Privacy Law, you may request access to your Personal Information in our Customer Relationship Management database, or seek correction of it, by contacting us. See ‘Section 10: Contact information’. Should we decline you access to your Personal Information, we will provide a written explanation setting out our reasons for doing so.
If you believe that we hold Personal Information about you that is not accurate, complete or up-to-date then you may request that your Personal Information be amended. We will respond to your request to correct your Personal Information within a reasonable timeframe and you will not be charged a fee for correcting your Personal Information.
7 Direct marketing
have your express consent (which you may withdraw at any time by contacting us);
have a legal basis; or
are otherwise permitted by relevant Privacy Law,
we may use and process your Personal Information to send you information about products and services we believe are suited to you and your interests or we may invite you to attend special events.
At any time you may opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your Personal Information as detailed above, will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us in writing at email@example.com
9 TeenSeen website
When transmitting Personal Information from your computer to the TS website, you must keep in mind that the transmission of information over the Internet is not always completely secure or error-free. Other than liability that cannot lawfully be excluded, we will not be liable in any way in relation to any breach of security or any unintended loss or disclosure of that information.
The TS website may use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but if you do so, you may not be able to fully experience the interactive features of the website.
10 Contact information