Zoo Business Media Pty Ltd (ZBM) understands that your privacy is important and recognises the importance of respecting customer and employee privacy.
ZBM must comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection/receipt to use and disclosure, storage, accessibility and disposal.
The purpose of this Policy is to answer the following questions:
- What personal information does ZBM collect?
- How is personal information collected and stored?
- How is personal information used?
- Will personal information be given to anyone else?
- Collection of other information;
- Security of personal information;
- Employee records;
- How can you access and correct your personal information?
- Opting Out; and
- Complaints and the complaint process.
1. What personal information does ZBM collect?
Personal information is any information, including an opinion, which can be used to identify an individual or linked to an individual. Examples include an individual's name, address, contact number and email address.
Subject to legislative requirements, ZBM will only collect personal information relevant to its business or employment relationship with you. Depending upon the service ZBM is providing to you, we may ask you to provide us with certain details including, for example, your name and contact information, birth date, employment information and financial information such as your income and information about your use of our products and services.
The collection of sensitive personal information is restricted by the provisions of the Privacy Act. This means that generally we will not collect any sensitive information about you — for example, personal information relating to your religious views, ethnicity, political opinion, health, criminal record or sexual preference, unless this is necessary to provide you with a specific product or services and you have consented to that collection.
If ZBM receives any personal information from you that we did not request, then as soon as practical after ZBM becomes aware, and if ZBM may lawfully do so, ZBM will destroy or de-identify that information and will not keep any record of it.
You are free to ask ZBM at any time to delete your personal information from ZBM's database as explained in the Opting-out section below.
2. How is your personal information collected and stored?
If it is reasonable and practicable, we will collect personal information directly from you. How we collect your personal information will depend upon how you interact with us. We may collect it through application forms, service agreements, telephone, email and internet contact, from correspondence with you and in person through meetings with you.
Where ZBM collects personal information directly from you, ZBM's policy is to take reasonable steps to notify you of certain matters. ZBM will do this at or before the time of collection, or as soon as practicable afterwards. The matters include:
- our identity and how to contact us;
- the purposes for which we are collecting the information;
- whether the collection is required or authorised by or under by or under an Australian law or a court or tribunal order;
- the third parties (or types of third parties) to whom we would normally disclose information of that kind;
- whether any of those third parties are located overseas and, if practicable to specify, the countries in which they are located; and
We will generally include these matters in a collection notice. For example, where personal information is collected on a paper or website form, we will generally include a collection notice, or a clear link to it, on the form.
There may be occasions where we need to collect personal information from other parties with or without your direct involvement, for example, publicly available sources of information, market research organisations, your legal or financial representative and/or your employer.
ZBM may collect personal information from the following web sites:
through receiving emails. We may also use third parties to analyse traffic at those websites. Information collected through such analysis is anonymous.
ZBM takes reasonable steps to ensure the security of personal information held by it from such risks as loss or unauthorised access, destructions, use, modification or disclosure.
ZBM may need to maintain records for a significant period of time. However, when we consider information is no longer required, we will remove any details that identify you or we will securely destroy the record.
3. How is personal information used?
ZBM's policy is to use personal information for the main business purpose for which it was collected. This may include:
- to conduct our business;
- to provide and market our services;
- to communicate with you;
- to purchase from you;
- to comply with our legal obligations;
- to manage our relationship with you;
- to give you ongoing information or opportunities that we believe may be relevant to your financial needs; and
- to help us manage and enhance our services.
ZBM will not use or disclose personal information for direct marketing purposes, unless:
- you would reasonably expect us to use such information for that purpose:
- we have provided a simple method by which you can request not to receive direct marketing communications from us; and
- you have not made such a request to us.
4. Will personal information be given to anyone else?
Generally, ZBM will not share with, rent, sell or otherwise disclose your personal information to any other company or organisation without your consent. At times, however, it is necessary for us to disclose your personal information to other persons or organisations. However, we will only disclose your personal information where we are allowed to by law and have your express or implied consent, or where we are obliged to by law.
You can give express consent verbally or in writing. Implied consent is where we have reasonably assumed you have given consent from your conduct. For example, consent can be implied when a person continues with a telephone conversation after being informed the telephone conversation may be recorded for training purposes.
Where ZBM discloses personal information to organisations that perform specific essential services for us, we limit this disclosure to the information they need to perform that service. This may include mailing houses or printing companies.
Depending upon the products/services we are providing to you, ZBM may disclose personal information to, for example (but not limited to):
- agents, contractors and external service providers of ZBM who perform functions on our behalf;
- authorised representatives of ZBM;
- payment systems operators;
- regulatory bodies, government agencies and law enforcement bodies;
- agents acting on your behalf, including your legal or financial advisor;
- your executor, administrator, trustee, guardian or attorney;
- superannuation funds;
- your employer;
- other companies or individuals who assist us in providing services;
- Courts, tribunals, commissions, regulatory authorities and their officers; and
- anyone else you may authorise us to disclose this information to.
Generally, where reasonably practicable, we require organisations or persons outside of ZBM who handle personal information as service providers to ZBM to acknowledge the confidentiality of the information, undertake to respect any individual's right to privacy and comply with the Australia Privacy Principles and this Policy.
ZBM does not provide any personal information to third parties located overseas. If it does so, ZBM's policy is to comply with the requirements of the Privacy Act that apply to cross border disclosures of personal information, as well as with any legal requirements applicable in the relevant jurisdiction.
5. Collection of other information
When you visit any of ZBM's websites, some of the information that is collected about your visit is not personal information, because it does not reveal your identity.
A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies used by ZBM may identify individual users who log into our websites.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our websites (such as preventing users from logging on and making purchases).
6. Security of personal information
ZBM will take reasonable steps to keep your personal information confidential and to protect it from misuse, unauthorised access, modification or disclosure. We have implemented and will maintain current standards of technology and operational security to protect your personal information from any such interference.
We hold personal information in a number of ways, including in electronic databases, email contact lists, and in paper files held in drawers and cabinets, locked where appropriate. Paper files may also be archived in boxes and stored offsite in secure facilities. ZBM's policy is to take reasonable steps to:
- make sure that the personal information that ZBM collects, uses and discloses is accurate, up to date and complete and (in the case of use and disclosure) relevant; and
- protect the personal information that ZBM holds from misuse, interference and loss and from unauthorised access, modification or disclosure
The steps we take to secure the personal information we hold include ICT security (such as encryption, firewalls, anti-virus software and login and password protection), secure office access, personnel security and training and workplace policies.
While ZBM strives to protect the personal information and privacy of website users, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact ZBM by telephone or post.
You can also help to protect the privacy of your personal information by keeping passwords secret and by ensuring that you log out of the website when you have finished using it. In addition, if you become aware of any security breach, please let us know as soon as possible.
7. Employee records
ZBM is generally exempt from the Privacy Act when it collects and handles employee records. However, ZBM's policy is to protect the personal information of its employees as it does other personal information.
8. How can you access and correct your personal information?
Under the Privacy Act, you have a right to seek access to information which ZBM holds about you, although there are some exceptions to this. You also have the right to ask us to correct information about you which is inaccurate, incomplete or out of date. ZBM will consider any request for access or correction in a timely way.
To provide you with personal information that we hold, ZBM will usually provide you with a print-out of your personal information from its computer database, or with photocopies of records which are held only on current paper files.
However, will also generally provide access in the manner that you have requested (e.g. allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask ZBM to correct personal information that ZBM holds about you, or if ZBM is satisfied that the personal information it holds is inaccurate, out of date, incomplete, irrelevant or misleading, ZBM's policy is to take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
If ZBM corrects personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask ZBM to notify that other entity. If so, ZBM's policy is to take reasonable steps to do so, unless this would be impracticable or unlawful.
Except in the case of more complicated requests, ZBM will endeavour to respond to access and correction requests within 30 days.
If ZBM refuses your access or correction request, or if ZBM refuses to give you access in the manner you requested, ZBM's policy is to provide you with a written notice setting out:
- the reasons for the refusal (except to the extent that it would be unreasonable to do so); and
- available complaint mechanisms.
In addition, if ZBM refuses to correct personal information in the manner you have requested, you may ask ZBM to associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, and ZBM will take reasonable steps to associate the statement in such a way that will make it apparent to users of the information.
9. Opting Out
Where you have consented to receiving direct marketing communications from ZBM, your consent will remain current until you advise us otherwise. However, you can opt out at any time, in the following ways:
- send a letter to the General Manager, Zoo Business Media Pty Ltd, PO Box 2325, Burleigh BC Qld 4220;
- or send an email to firstname.lastname@example.org
- advise us if you receive a marketing call that they no longer wish to receive these calls; and
- use the unsubscribe facility that we include in our commercial electronic messages (such as emails and SMSs) to opt out of receiving those messages
10. Complaints and the complaint process
ZBM will endeavour to answer your complaint within 7 working days.
If your complaint cannot be resolved at the first instance, we will ask you to complete a Privacy Complaint Form, which details (for example) the date, time and circumstances of the matter that you are complaining about, how you believe your privacy has been interfered with and how would you like your complaint resolved.
We will endeavour to acknowledge receipt of the Privacy Complaint Form within five business days of receiving it and to complete our investigation into your complaint in a timely manner. This may include, for example, gathering the facts, locating and reviewing relevant documents and speaking to relevant individuals.
In most cases, we expect that complaints will be investigated and a response provided within 30 days of receipt of the Privacy Complaint Form. If the matter is more complex and our investigation may take longer, we will write and let you know, including letting you know when we expect to provide our response.
Our response will set out:
- what action, if any, ZBM will take to rectify the situation.
If you are unhappy with ZBM's response, you can refer your complaint to the Office of the Australian Information Commissioner.
If you have any questions about privacy-related issues please contact Vicki Travers, General Manager of ZBM Pty Ltd on +61 7 5587 7222.
Review of Policy