Effective: 13 April 2018
1.1 Finnigan Investments (Australia) Pty Ltd ABN 70155 747 765 trading as OneAffiniti (“we, us or our”) recognises the importance of protecting your privacy.
1.2 We comply with our obligations under the Privacy Act 1998 (Cth) (“Privacy Act”), including the Australian Privacy Principles (“APPs”) concerning personal information of individuals.
(a) to business information (unless it is also about any identifiable person); or
2. Collection of Information
2.1 Personal information is any information about you, from which you can be identified. The personal information we collect from you will depend on our relationship with you, the circumstances of collection and the types of services we provide. We may collect your name, address, email address, telephone number and employment information. We may collect additional personal information from you from time to time.
2.2 We may collect your Personal Information directly from you when we communicate by email or by telephone or when you access and use our Sites and Marketing Materials. For example, we may collect your personal information when you:
(a) participate in and respond to any polls or surveys;
(b) subscribe to receive communications from us or notifications about offers;
(c) enter into any competitions;
(d) respond to our lead qualification calls;
(e) provide feedback on any of the products or services;
(f) interact with our Marketing Materials or Sites;
(g) complete a form to request pricing or more product information; or
(h) otherwise interact with us or disclose your personal information to us.
2.3 On some occasions, we may collect your personal information from third parties such as from a third party provider where you are a customer of that third party provider, or from your employer where they have arranged for us to facilitate the provision of offers to you.
2.4 You don’t have to give us all the information we request. You may engage with us anonymously or using a pseudonym if it is feasible to do so. For example, if you wish to give feedback without requiring a response from us, you won’t need to provide a full name or email address. However, if you do not provide us with some or all of the personal information required, we may not be able to provide you with our services or information you request, to the requested standard or at all, and you may also miss out on receiving valuable information about us and our and our client’s products and services.
3.1. We collect general information from your device when you interact with our Sites and Marketing Materials. This might include your geo-location, IP address, device identifier, the browser and operating system you are using, and details of website that IP address has come from, the pages accessed on our website and the next website visited.
3.3. We may use and combine information collected using cookies and tools with information we already have about you to maintain, secure and improve our website, enhance your experience when using our website, display and deliver relevant information and advertising (including direct marketing and targeted ads on third party websites and social media sites) and understand the effectiveness of our marketing and advertising.
3.4. If you want to prevent cookies being used, you can change your browser settings to disable cookies or to notify you when you receive a new cookie. However, you may not be able to access all or parts of our website, or you may experience reduced functionality when accessing certain services (for example, automatic log in may not function properly). For more information, visit www.youronlinechoices.com.au. Third party service providers may have their own privacy policies in relation to their cookies and tools.
3.5. Pages of our Sites and Marketing Materials may contain Web Beacons, small electronic files, such as tracking pixels, that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics. We, or third parties acting on our behalf, may use web beacons or related technology on our Sites, in our communications, or on other sites including our Marketing Materials. A web beacon is an electronic image that can be used to recognize a cookie on your equipment when you view a web page or online communication. The information we collect may include Personal Information, and web beacons allow us to recognize users by accessing cookies. Web beacons help us measure the effectiveness of our Marketing Materials and Sites and our interactions with you in various ways, for example, by counting the number of individuals who visit our Sites and Marketing Materials from a particular communication or make a purchase from our Sites and Marketing Materials after viewing a particular message as well as by telling us when a web page is viewed and providing a description of the page where the web beacon is placed. Web beacons also help us measure the effectiveness of our communication campaigns, for example, by counting the number of individuals who open or act upon a message, determining when a message is accessed and determining how many times a message is transmitted onwards. We may also combine the information that we collect through web beacons with other Personal Information we have collected from you. We, or third parties acting on our behalf, or third parties on whose behalf we are acting, use all of this information to better tailor interactions with you and may use this information for other purposes, such as to customize content on our website, serve advertising to you and for internal research purposes.
3.7. We use Google Display Advertising, and other third party providers, for re-marketing purposes. In addition to using cookies and related technologies as described above, we also may permit certain third party companies to help us tailor and serve advertising that we think may be of interest to users and to collect and use other data about user activities on our Sites and/or Services. These companies may deliver ads that might also place cookies, and related technologies as described above, and otherwise track user behavior. This means we will continue to show ads to you across the internet, specifically, but not limited to, on the Google Content Network (GCN). As always, we respect your privacy and are not collecting any identifiable information through the use of Google’s or any other 3rd party remarketing system. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Preferences Manager.
4. Use of Personal Information
4.1. We collect, use, hold and disclose your Personal Information for purposes reasonably necessary for or related to one or more of our functions or activities. Such purposes include:
(a) to provide and administer our products and services, including to send digital marketing material on behalf of our clients or third party suppliers, including marketing emails and, posts on social media platforms or display advertising and following up on leads from our digital marketing activities on our clients’ behalf;
(b) to provide customer support and respond to questions, queries, requests for information and applications;
(c) to operate our competitions and promotions including determining entry eligibility, awarding prizes and publishing or otherwise making available a list of prize winners;
(d) to conduct marketing and advertising activities, including displaying content on our Sites and Marketing Materials and serving display advertising on third party websites;
(e) to provide information about our products and services, including through distributing newsletters and other communication on information about us and our related services and your use of our services;
(f) to develop and improve our products and services, including our Sites and Marketing Materials and to provide a more personalized service;
(g) to analyze the effectiveness and optimize the performance of any specific marketing campaign we undertake, including on behalf of our clients;
(h) to create aggregated, de-identified profiling data, by combining your Personal Information with information from other users of our Sites or Marketing Materials including statistical and analytical data; and
(j) to manage and carry out our business and operational functions, including business decisions and technical operations.
4.2 In addition to the matters set out at the paragraph above, we may collect, hold and use your personal information:
(a) when you give us express or implied consent to do so;
(b) for purposes related to the reason for which you gave us the personal information, but only if you would reasonably expect us to use it for those purposes; and
(c) as otherwise permitted or required by or under any law, including to comply with any court order, law or legal process, including to respond to any government or regulatory request.
4.3 We will take all reasonable steps to destroy or permanently de-identify personal information if we no longer need it for any purpose for which we have collected, used or disclosed your personal information.
5. Direct Marketing
5.1 We will not send any direct marketing to you unless you have opted-in to receive direct marketing communications from us, our clients or our third party suppliers. If we do send you direct marketing information:
(a) such direct marketing will generally be sent on behalf of our clients or our third party suppliers; and
(b) we will also give you the opportunity to opt-out of receiving any further direct marketing information from us.
5.2 Every time that we send emails or other materials for marketing or promotional purposes, our communications will contain instructions on how you may opt out of receiving direct marketing.
5.3 You can also opt out of receiving direct marketing from us by contacting our Privacy Officer, details below.
5.4 Please note, however, that certain of our distribution lists are managed by third parties with whom you have a relationship (such as your IT supplier, your insurance provider or your employer). In cases where you have a relationship with more than one of our clients, you may need to separately opt out of receiving direct marketing from us on behalf of each of those organisations.
6. Disclosure of Personal Information
6.1 In order to carry out the above purposes, we may disclose your personal information:
(a) to our clients and our third party suppliers to analyse the effectiveness and optimise the performance of a marketing campaign, provide information to you, draw a prize, validate a sale, register a sales opportunity or assist with or fulfil a transaction or provide a quotation to you in respect of the products or services of such third parties;
(b) to service providers who help us deliver, administer and support our functions and activities, including to help maintain our Sites, Marketing Materials and corresponding databases, conducting data analysis, serving advertising, providing IT services, data processing, storage and backup and telemarketing services;
(c) to our related companies (as identified on our Sites or Marketing Materials), but only for purposes reasonably necessary for or directly related to one or more of our functions or activities;
(d) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Sites and Marketing Materials is among the assets transferred;
(f) in circumstances permitted or required by or under any law.
7.1 We take the security of your personal information seriously and we take reasonable steps to ensure that all Personal Information we collect or use:
(a) is stored in a secure environment;
(b) is safeguarded from misuse, interference, loss and unauthorised access, modification or disclosure; and
(c) is accessed only by authorised personnel for permitted purposes.
7.2 We have implemented procedures to safeguard the security and confidentiality of your personal information such as electronic and physical restrictions to files containing personal information and ensuring encryption of personal information sent and received. However, because of the nature of the Internet and modern computer systems, we cannot guarantee that it is totally protected from malicious hackers or misuse.
7.3 Once your personal information is no longer required by us, including under any contractual or legal requirement, we will take all reasonable steps to ensure that it is either destroyed or de-identified in a secure manner.
8. Access, correction and removal of your personal information
8.1 It is important to us that the information we hold about you is up-to-date, accurate and complete, and we will try to confirm your details through our communications with you and promptly add updated or new personal information to existing records when we are advised.
8.2 Please contact our Privacy Officer, via the contact details below, if you:
(a) wish to request the source of personal information which we hold about you;
(b) wish to seek access to or request that we modify personal information which we hold about you;
(c) wish to request the removal of personal information about you from our records; or
(d) believe personal information about you is inaccurate, outdated, incorrect or is misleading because it is incomplete and you wish to change it.
8.3 After verifying your identity, we will generally provide you with access to your personal information if practicable and will take reasonable steps to amend any personal information about you which is inaccurate or outdated. In some circumstances and in accordance with the Privacy Act, we may not permit you access to your personal information, or may refuse to correct your personal information, in which case we will provide you with reasons for this decision unless we have a legally permitted reason not do to so.
9.1 We take your complaints seriously and we will attempt to resolve any issues quickly and fairly. If you think that an act or practice has interfered with your privacy in relation to your personal information, you can contact us using the details below.
9.2 Within 5 business days of receiving a complaint we will seek to contact you to confirm that we have commenced an investigation, and we will endeavor to complete our investigation within a further 28 days from the date of confirmation. We will let you know the outcome of our investigation once it is complete, including any actions that we will take to address your complaint.
9.3 If you believe that your complaint has not been satisfactorily addressed by us, you can make a complaint to the Office of the Information Commissioner (“OAIC”). The OAIC’s contact details are here: http://www.oaic.gov.au
10. Amendments to this policy
11. Contact Details