At Commonry Pty Ltd Atf The Commonry Trust (ABN - 65 973 136 628) ("Commonry", "we", "us") your privacy is important to us. We are committed to protecting your privacy when managing your personal information. We have policies and procedures to ensure that all personal information is handled carefully and securely in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) ("Privacy Act").
- What kind of personal information we may gather about you;
- How we may use that information and the choices you have regarding our use of such information;
- Whether we disclose your personal information to anyone;
- How you may inquire, access and/or seek correction of your personal information and our access and correction handling procedure; and
- How you may alert us about an alleged breach of the APPs and our complaint handling procedure.
Collection of Information
The types of information that Commonry collects from you will depend on the circumstances of collection and on the service that we are providing to you.
The type of personal information collected will be directly related to the specified purpose it has been collected for. How much of your personal information that you choose to disclose to us is completely up to you. The only way we know something about you personally is if you provide it to us. However, failure to provide certain information may result in Commonry’s being unable to provide you with the relevant product or service. We will make you aware of the purpose for which we collect the personal information and, where possible, the consequences of not providing it at the time of collection.
- If you request products or services from us, we may collect information such as your name and contact details (i.e. billing and/or postal address, phone number(s) or email address), and/or credit card details
- If you sign up to use a particular service such as our newsletter(s) and e-newsletters, mail outs (about product updates and developments, special events or promotions), loyalty or rewards program(s) or enter into a competition operated by us, we may collect information such as your date of birth and your interests and any other information required to provide that service to you (in addition to your name and contact details)
- If you participate in any surveys we, or a third party service provider acting on our behalf, may conduct from time to time on our website, personal information relating to your survey responses
- If you make an inquiry, provide feedback or make a complaint to us, we may collect your name and contact details
- If you are applying for employment with us, we may collect any information that is relevant to such employment including:
- Your name and contact details (i.e. residential address, phone number(s) and/or email address); and
- Any other information relevant to the recruitment process (including any information contained in the application form and your resume).
You acknowledge that the personal information we collect from you is your own information or information which you have been authorised to provide us.
Commonry does not generally collect sensitive information as defined under the Privacy Act, such as racial or ethnicity information, political opinions or associations, criminal records or health information. However, subject to obtaining your prior consent, Commonry may collect sensitive information from you in the course of considering an application for employment.
Where unsolicited information is received by Commonry (such as through our Facebook page) we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information under the APPs. If it would not be permitted for Commonry to collect the information, we will destroy the information or ensure it is de-identified as soon as practicable. Otherwise, Commonry may retain the information in accordance with the terms of this policy.
We may also collect information about visitors to our website(s). For example, we may collect:
- Statistical information about the number of visitors to the websites and the date, time and duration of visits;
- The name of the domain/URL from which you access our websites;
- The internet protocol address.
However, we do not collect information about the identity of the visitors unless they voluntarily provide that information.
Method of Collection
This personal information will only be collected through lawful and fair means and not in an unreasonably intrusive way. Commonry collects your personal information when you deal with us directly, including via our website(s) or our Facebook page, via forms or correspondence (i.e. by mail or email), over the phone or in person. Commonry may also collect personal information through our related bodies corporate and our third party service providers (such as data relating to survey responses) so that we may provide a better or more relevant product to you.
Use of Information
Commonry will use the personal information you have chosen to provide us for the purpose for which you provided it or a related secondary purpose which you would reasonably expect. Commonry will not use it for any other purpose without your consent, unless permitted or required by law.
Generally, we will use your personal information for the following purposes:
- Direct marketing of products and services which we believe may interest you, including product updates and developments, special events or promotions;
- Assisting us to improve our products and services and making them more relevant to you;
- Assisting us to improve our website(s) or Facebook page;
- Processing and assessing employment applications for current and future positions; and
- Otherwise managing our internal business operations and processes
Providing the products and/or services you have requested from Commonry including for example:
- To process sales transactions (whether in store or online);
- To deliver the products or services to you;
- To register you for a service requested by you, such as our newsletter(s) and e-newsletters, mail outs, rewards program(s) or competitions and administering such services;
- To manage warranty claims;
- To respond to any inquiries, feedback or complaints made by you.
Commonry will only use your personal information for the purpose of direct marketing activities where we have obtained your consent to do so, or in circumstances where we have collected the information directly from you and you would reasonably expect that your personal information would be used or disclosed for this purpose. We may also share your personal information with our related entities, so that they can provide you directly with marketing material about their products and services. Commonry will provide you with the opportunity to “opt out” of receiving marketing materials at the time of collection and/or at any time afterwards by either unsubscribing from the email service or contacting our Privacy Officer via the contact details provided below.
Use of Anonymous Information
Commonry gathers anonymous information to:
- Monitor the use of our website(s);
- Help us make improvements to the website(s); and
- Offer relevant information and services to as many users as possible.
There will be occasions when it will be necessary for Commonry to disclose your personal information to third parties. Commonry may disclose your personal information to:
- Contractors and third party service providers on a confidential basis that we use in the ordinary course of our business to assist with the delivery of the product or service. This includes organisations such as marketing agencies, data processing companies, printing and mailing Commonry, delivery companies, data storage companies (which may use cloud computing storage systems which have the potential to make your personal information accessible by overseas entities) or finance agencies or debt collection agencies;
- Other members of Commonry’s corporate group for marketing purposes (subject to obtaining your prior consent if those entities are not related bodies corporate of Commonry);
- Government authorities or other third parties as required by law; or
- Any other purpose that you have consented to.
Transfer of Information Outside Australia
Otherwise, other than stated above, we do not disclose personal information that you may give us to any organisation or person outside of Commonry unless you have authorised us to do so.
No Sale of Personal Information
Under no circumstances will Commonry sell or receive payment for licensing or disclosing your personal information.
Security & Data Access
The security of your information is important to us. Commonry operates secure data networks that are designed to protect your privacy and security. When we have collected information about you it cannot be seen or modified by anyone else. Commonry has implemented generally acceptable standards of technology and operational security to ensure personal information (in both physical and electronic form) is protected against loss, misuse, interference and unauthorised access.
Only authorised Commonry personnel and contractors are provided access to personal information and have agreed to ensure the confidentiality of this information. Reasonable steps are taken to destroy or permanently de-identify any personal information that is no longer required.
We review and update our security measures in light of current technologies. You should however be aware that the internet is not a secure environment and information sent via the internet (including email) cannot be guaranteed to be totally secure.
If you are a subscriber to one of our online services or products or loyalty programs, you may access your personal information by accessing your subscriber/account details via the relevant facility on our websites. Otherwise, you may at any time, request access to personal information that Commonry holds about you by making a request to our Privacy Officer at the address or email address below.
We will endeavour to process any requests for access to personal information within a reasonable period of time. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested, or providing you with a summary of the information held. If we need to deny your request for access we will let you know why and inform you how you may lodge a complaint regarding this decision. Generally this will only be in cases where providing access would be unlawful or is subject to a potential legal claim or proceeding.
Commonry may charge a nominal fee for supplying personal information.
We will try to ensure that all information we collect, use or disclose about you is accurate, complete, up-to-date and relevant to the service being provided.
If you are a subscriber to one of our online services or products, you may change your personal information by accessing your subscriber/account details via the relevant facility on our website(s).
Otherwise, if you discover or suspect that there is an error or information is missing, please forward your request for correction to our Privacy Officer in writing at the address or email address below. Our Privacy Officer will consider your request and as soon as practicable manage the correction of your personal information and will update you in writing. If your correction request is refused, our Privacy Officer will provide you within a reasonable period of time the reasons for such refusal and inform you of the complaint process (see below).
Complaints & Contact Information
If you have any complaints relating to the management of your personal information or if you believe there has been a breach of the APPs by Commonry, please forward your complaint in writing to our Privacy Officer at the address or email address below.
Our Privacy Officer will consider the complaint and advise you of his/her decision in writing within a reasonable time from receipt of the complaint.
If our Privacy Officer decides that there has been a breach of the APPs, he or she will endeavour to ensure that the breach is rectified within 30 days from the date of the decision and will update you in writing. If the breach has not been rectified within 30 days, then our Privacy Officer will inform Commonry’s Managing Director in order to resolve the matter.
If you are still not satisfied after lodging a complaint with us and giving us a reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner by:
Phone: 1300 363 992 (local call cost, but calls from mobile and pay phones may incur higher charges). If calling from overseas (including Norfolk Island): +61 2 9284 9749
TTY: 1800 620 241 (this number is dedicated to the hearing impaired only, no voice calls.)
TIS: Translating and Interpreting Service: 131 450 (If you don’t speak English or English is your second language and you need assistance and ask for the Office of the Australian Information Commissioner)
Post: GPO Box 2999 Canberra ACT 2601
Fax: +61 2 9284 9666
Please contact our Privacy Officer on the contact details below if you would like to:
- Inquire about or request access and/or update your personal information; or
- Report an alleged breach of your privacy rights or make a complaint:
Post: Privacy Officer, Commonry, 425 St Kilda Road Melbourne VIC 3004
Telephone: (03) 9863 3200
“Personal information” has the same meaning as in the Privacy Act.
“Website(s)” refers to all websites and web pages which are owned, operated or under the control of Commonry including but not limited to www.commonry.com https://www.facebook.com/Commonry
For more information about your privacy rights in Australia, visit the Office of the Australian Commissioner’s website, www.oaic.gov.au