Southern Cross Austereo operates a number of commercial radio stations, television stations, websites, and other media platforms throughout Australia.
We are committed to the protection of your PI and meeting the standards set out in the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles (APPs).
1. Collection of Information
1.1 What kinds of Personal Information we collect and hold
We may collect various types of PI including but not limited to your name, address, email, phone number, age, payment details, gender, interests or other information relevant to promotions and activities that SCA runs and to your engagement with SCA.
1.2 Why we collect Personal Information
Generally we collect your PI to provide you with products and services and to administer our relationship with you. We also collect PI for research and for marketing purposes and to provide you with information about events, products and services (both our own and those of other companies) that may be of interest to you, to improve the services we provide, to run various competitions and to provide you with payment receipts.
1.3 How we collect Personal Information
We primarily collect PI directly from you when you interact with us, for example when:
(a) you submit an entry into a competition or trade promotion;
(b) you participate in listener loyalty programs;
(c) you subscribe to a member database or email newsletter;
(d) you send us an email or make a post on any of our websites (including social media assets and platforms);
(e) you purchase products from us by credit card or otherwise;
(f) you stream our products from a website, or via a mobile App;
(g) you call us; or
(h) you attend an event or activity that we organise, sponsor, or are otherwise affiliated with.
1.4 Apps on mobile devices
On some occasions we may transfer or transmit data (including your PI) for the purposes of administering a mobile app of ours that you have installed on your Apple or other brand of mobile device, or a streaming service
Any questions, comments or complaints regarding our handling of your PI for these purposes us must be directed to us and not to Apple or other brand of mobile device.
1.5 Trade promotions (contests, promotions, competitions, sweepstakes, lotteries, and raffles)
If we conduct trade promotions (which include activities such as contests, promotions, competitions, sweepstakes, lotteries and raffles), we may collect PI for administrative purposes, and possibly to fulfil the prize for the trade promotion. We may also store the PI that you provide to us for the trade promotion on our customer information database for use for promotional, marketing and product development purposes in relation to any of our products or services, including direct marketing via any medium (including SMS and email).
On some occasions we may conduct a trade promotion that has its own specific privacy terms. In this case, notice of those terms will be provided at the time that PI is sought and those terms will apply to the PI collected as part of that trade promotion.
If we conduct a trade promotion on a social media platform (such as Facebook) we generally do not require you to share PI with us (although you may choose to do so).
We acknowledge that where we conduct a trade promotion on a social media platform:
(a) The trade promotion is not administered by the social media platform unless we expressly state that it is.
(b) Any PI provided by the User in connection with the trade promotion or activity, is provided to us and not to the social media platform.
(c) Any questions, comments or complaints regarding the trade promotion, or collection of PI in connection with the trade promotion, must be directed to us, not to the social media platform.
2. Use and disclosure
By submitting your PI to us you consent to us using your PI in the following ways and for the following purposes:
(a) to provide you with our products or services;
(b) to administer our relationship with you;
(c) to administer online and App based services and products;
(d) to facilitate the administration of, and your participation in, a trade promotion or other activity;
(e) to facilitate the administration of, and your participation in, a listener loyalty program;
(f) to facilitate the administration of, and your participation in, a member database;
(g) to facilitate the administration of, and your participation in, an online subscription newsletter;
(h) to monitor your activity on our websites or App products and services;
(i) to monitor your purchase history and or relationship with you;
(j) to compile listener databases and profiles to enable us to market goods and services more accurately;
(k) for internal administrative purposes, such as procedural assessments, risk management, staff training, accounting, billing, product and service reviews;
(l) to identify and inform you about other products or services that may be of interest to you;
(m) to market, improve and add to our products and services including our websites and our radio broadcasts;
(n) where there is a serious threat to an individual's life or to public health or safety;
(o) where there is reason to suspect unlawful activity has been engaged in;
(p) where required or authorised by law; or
(q) where required by an enforcement body.
If you do not wish to receive marketing or other communications from us, please contact us on the details below so that we can update your preferences.
If you provide us with your mobile telephone number, email address, IM address or other such personal information, you authorise us to send you promotional messages related to our products and services and the products and services that we promote. Such messages will be accompanied by a functional unsubscribe facility.
(a) engaged by us to provide functions on our behalf such as storing and managing databases, processing credit card information, mailouts, debt collection, marketing research and advertising;
(b) authorised by you to receive PI held by us;
(c) where that disclosure is reasonably required to obtain advice, prepare or conduct legal proceedings, investigate suspected improper conduct or wrongdoing or assist a lawful authority in the discharge of its duties; and
(d) where permitted or required by law.
Where we hold trade promotions in conjunction with other companies, we will offer you the opportunity to be contacted by our promotions partner(s) or sponsor(s). We will not provide your PI to the promotions partner(s) unless you have expressly consented ('opted in').
To protect your privacy, wherever practical we impose contractual requirements of security and confidentiality on third parties as to how they handle any PI that we disclose to them. However, except to the extent that liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any misuse or unauthorised disclosure of your PI by these third parties.
3. Data quality
We take reasonable steps to ensure that the PI we collect, use or disclose is accurate, complete, relevant and up-to-date. If the PI that we hold about you is incorrect or changes, please contact us on the details below so that we can update our records.
4. Data security
Your PI is stored in a number of secure computer storage facilities and paper based files, and in other records. We may also engage third party service providers to assist in storing and processing certain types of personal information for us.
We have taken reasonable precautions to ensure that your PI is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
However, except to the extent that liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to your PI. Please notify us immediately if you become aware of any breach of security.
If you have any questions in relation to our handling of your PI, or the kind of PI we hold about you, please contact us on the details below and we will endeavour to assist you with your request.
6. Access and correction
You have rights under the Act to access and correct the PI that we hold about you. If you wish to access, correct or update any personal information we may hold about you, please contact us as set out below.
The APPs set out some circumstances in which we are not required to provide you with such access. If you ask for your PI and any of these circumstances apply, we may, if reasonable, give you access to the PI in a way that meets our needs and yours (for example by giving you access through a mutually agreed intermediary).
We may charge a fee for giving access to PI, in which case we will inform you of the fee (which will not be excessive) in advance of providing the information.
Where practical, you may deal with us on an anonymous basis or by using a pseudonym. In some instances, because of the services we provide, if you do not provide us with your PI we may not be able to provide you with the requested product or service (for example, if we require your details in connection with a competition we are running, we cannot provide you with a prize should you be a prize winner and we cannot contact you).
8. Overseas transfers of information
We do not generally disclose PI to overseas recipients in the ordinary course of our business. Where we disclose PI to recipients located outside of Australia we will do so in accordance with the requirements of the Act and in accordance with the terms of this policy.
9. Sensitive information
Sensitive information includes information about your race or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation. We generally do not ask for sensitive information, but may do so where it is reasonably necessary for our functions and activities and it is permitted by law. Generally we will only collect sensitive information where:
(a) you have consented to providing sensitive information (if you voluntarily submit such information to us you will be deemed to consent to us collecting that information);
(b) the collection of the sensitive information is specifically authorised or required by law.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint to the Office of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia).
11. Contact us
For all privacy inquiries and complaints, please contact Southern Cross Austereo's Privacy Officer by mail at GPO Box 22 Sydney NSW 2001, email at firstname.lastname@example.org or phone on 02 8437 9481.
© Southern Cross Austereo Pty Ltd 2014 Version last updated 15 May 2014