1. Types of personal information we collect and hold
Generally, the types of personal information we collect are the following:
- year of birth
- email address(es)
We do not actively collect sensitive information and where you provide us sensitive information on an unsolicited basis (such as health information) you consent to our collection of such information.
2. Website cookies
We use Google Analytics to collect anonymous information and data whenever you access and navigate through our website. The types of anonymous information we collect is the time and date which you accessed our website and the specific page you accessed. We collect this information for operational maintenance and statistical purposes to assist us in improving our website. When you access our website, your browser automatically sends certain information to Google which in included in our analytical reports. For more information on how Google Analytics operates, see “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/) . Through our email mailing platform we are also able to track if, and when, you open our newsletter and your interactions with the content of our emails.
3. How we collect and hold personal information
We, or third parties on our behalf, may collect your personal information from third parties where it is impracticable to collect such information directly from you. The third parties we may collect your personal information from include:
- our related companies (including Hoyts Group companies);
- our business partners including advertising agencies and client companies; and
- our service providers, including third party database list providers.
4. The purposes for which we collect, hold, use and disclose personal information
We, or third parties on our behalf, collect, hold, use and disclose your personal information for the following purposes:
- to communicate with you directly or through our marketing agencies we engage to keep you informed of competitions, upcoming activities and events by any means including email, post and telephone;
- to deliver to you our services and to facilitate any e-commerce transactions;
- to perform statistical analysis of user activity and characteristics in order to measure interest in and use of the various areas of our website;
- to inform others, including our clients, of any statistical data, as well as the number of users who have been exposed to or have clicked on any particular areas in our website.
- to publish via email newsletter or on the website your name if you are a winner in any of our competitions; and
- to disclose to our related bodies corporate, which includes companies within the Hoyts Group.
5. Direct Marketing -how to opt-out
Where you have expressly consented, we will use your email address to send you relevant marketing materials and offers. You can always opt out of this through the functionality provided in each marketing communication (e.g. by clicking “unsubscribe” at the bottom of an email).
6. Overseas disclosure of personal information
We generally hold your personal information internally in our database at our offices in Australia. However, our email database, which on occasion may contain your personal information, is stored on an external server by a trusted third party whose server is located in the United States.
7. Access to, and correction of, personal information
We will take reasonable steps to ensure that the personal information we collect, hold, use or disclose is accurate, complete, up to date, relevant and is not misleading. You have a right to request access and/or the correction of any personal information we hold or control. Requests for access or correction are to be directed to our Privacy Officer whose contact details are provided below. We may ask you to answer a simple question, such as providing your address, to confirm we are providing access to the correct individual. We endeavour to respond to any request within a reasonable time period.
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 sending the information to you. We will inform you of applicable fees before they are incurred.
In certain circumstances, such as where access would have an unreasonable impact on the privacy of other individuals, we may refuse to provide you access to your personal information. If we refuse to provide you access, we will provide you with a written notice that sets out the reasons for the refusal except to the extent it would be unreasonable to do so.
Where we correct personal information we hold about you, you have a right to request that we notify any other third parties to which we disclosed the inaccurate information. We will provide such notice to any third parties where it is practical and lawful for us to do so.
In the unlikely event that we refuse to correct your personal information as requested by you, we will provide you with reasons for the refusal except to the extent that it is unreasonable to do so.
8. Contact Us Making a complaint
Privacy Officer – Val Morgan
Level 50, 680 George Street
Sydney NSW 2000
We will promptly investigate your complaint and provide you a response with our findings within a reasonable period of time. If you are dissatisfied with our response, you may complain to the Australian Information Commissioner (www.oaic.com.au).
9. Anonymous and pseudonyms
You may request to remain anonymous, or seek to use a pseudonym, in your dealings with us. We will honour any such request to stay anonymous or use a pseudonym where it is lawful and practicable to do so.