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Borough Markets Privacy Policy

Privacy Policy

Privacy Act

Borough Markets Pty Ltd (ABN 60 641 411 047) and its Australian related bodies corporate (we, us, our) are organisations and “APP Entities” for the purposes of the Privacy Act 1988 (Cth) (Act), and are bound by the Australian Privacy Principles (APPs) contained in the Act.  We understand that your privacy is important and we are committed to safeguarding personal information that we handle about individuals.  This Privacy Policy describes generally how we manage this personal information and protect privacy, including how we comply with the Act and the APPs.

This Privacy Policy is intended to provide a general overview of our policies in respect of the handling of your personal information.  “Personal information” is essentially information or an opinion about an identified or reasonably identifiable individual.

This Privacy Policy is intended to cover most personal information handled by us, but is not exhaustive.  Other policies may override or complement this Privacy Policy in certain circumstances.  For example, when we collect personal information from you, we may advise a specific purpose for collecting that personal information, in which case we will handle your personal information in accordance with that purpose.  If you have any queries about our handling of your personal information, please contact us for further information using the contact information below or using the contact form on our website.

Collection of personal information

We may collect your personal information throughout the course of your interaction with us (for example, if you register your interest for our services, request our services, subscribe to any mailing list we operate, fill out an online contact form, engage with our online marketing or submit an enquiry to us).  The personal information that we may collect and hold about you depends on your dealings with us.  Generally, we may collect:

  • your name and address, email address and telephone number;
  • payment details if you acquire paid services from us;
  • business details of you or the organisation you represent; and
  • other personal information that we require or that you volunteer to us (such as your resume, details of your qualifications, skills, education provider, work history and residency status in the event that you apply for employment).

Generally speaking, we collect personal information so that we can provide our services to you and ensure that you have convenient access to our products and services.

We will collect your personal information directly from you unless it is unreasonable or impracticable to do so.  If circumstances require, we may collect personal information about you from third parties (such as your employers, representatives or personal referees) or publicly available resources.  All personal information we collect is limited to that which is reasonably necessary for our functions or activities.

We receive any personal information that you provide to us about third parties on the understanding that we have the relevant individual’s consent for us to collect and handle their personal information in accordance with this Privacy Policy.

When collecting your personal information, we will take reasonable steps to make you aware of the purposes for which we are collecting it, the types of organisations to which we would usually disclose it, whether we are likely to disclose it to overseas recipients (and where practicable the countries in which they are located), whether there are laws or court/tribunal orders which require or authorise us to collect it, and the main consequences for you if you fail to provide it to us.  This Privacy Policy provides these details as they typically apply in most cases, however different details may apply depending on our specific interaction with you.  If we do not notify you of such other details, the information in this Privacy Policy applies.

If you fail to provide personal information requested by us, or if the personal information you supply is incorrect or incomplete, there may be a range of consequences, for example we may be unable to process or respond to your request or provide services to you.  There will not usually be Australian laws or court/tribunal orders which require or authorise us to collect your personal information.

We do not generally collect sensitive information.  If we do collect sensitive information (which may include race, ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships or details of health or disability) from you, we will only do so with your consent and if the information is reasonably necessary for one of our functions or activities.  We will assume you have consented to us collecting, using and disclosing (in accordance with this Privacy Policy) all information that you provide to us, including any sensitive information, unless you tell us otherwise at the time of collection.

Use of personal information

We will generally only use your personal information for the purpose for which we collected it, and for related purposes we consider would be within your reasonable expectations.

We generally use personal information for the following purposes (as applicable in the circumstances):

  • to provide services to you, your organisation or for your or its benefit;
  • to provide information that you request, to respond to your enquiries, or otherwise achieve the purpose for which you have contacted us;
  • to handle payments for services we provide;
  • to provide you with marketing and promotional material regarding our services, including newsletters or other materials;
  • to improve and personalise your experience and content when interacting with our website;
  • to evaluate and improve our services;
  • to seek feedback from you and perform market research, so that we can gauge your satisfaction with our services;
  • for our general business operations (such as maintenance of our business records and compliance with our legal obligations); and
  • to engage in other activities where required or permitted by law.

By providing us with your personal information, you consent to us using your personal information for these purposes.

You agree that we may send you marketing or promotional material by post or by electronic means (including email and SMS).  You may request not to receive such material from us by contacting us via the contact information below, using the contact form on our website or by using the opt-out function provided for in those communications.  If you do not opt-out in either of these ways you will be taken to have consented to receiving such communications from us.

There are no consequences of opting-out of receiving our marketing and promotional communications except that you will no longer receive them, and you may elect to re-join our marketing list at a later stage if you wish.

Where we propose to use your personal information for a purpose other than as outlined above, we will seek your permission (unless we are required or permitted by law to do so without seeking consent).

Storage of personal information

We take reasonable steps to protect your personal information from misuse, interference and loss as well as unauthorised access, modification or disclosure.

For example, information stored on our computer network is protected by security features and procedures.  We undertake regular monitoring of our practices and systems to ensure the effectiveness our security policies and identify and implement improvements where appropriate.

Generally, we will take reasonable steps to destroy or permanently de-identify your personal information as soon as it is no longer required by us.  We may retain your personal information where we are required or permitted to do so by law, such as for insurance, legal or corporate governance purposes and for the prevention of fraud.  Your personal information may also be retained in our back-up records.

Disclosure of personal information

We will generally only disclose your personal information for the purpose for which we collected it, and for related purposes we consider would be within your reasonable expectations.

We may disclose your personal information to certain suppliers that provide services to us (for example, hosting providers, market research companies, data processing companies or other service providers).  We generally ensure such organisations are contractually required to ensure that information we disclose is used only for the limited purposes for which we provide it.

We are not likely to disclose personal information to overseas recipients, except with your consent or where we are required to or authorised to do so by law.

Access to and correction of personal information

You may contact us to request access to personal information we hold about you, or correction of that personal information if you believe it is inaccurate, out-of-date, incomplete, irrelevant or misleading.

We may refuse to allow access or to amend your personal information if we are legally required or entitled to do so.  If we do so, we will provide you with written reasons for the refusal (unless it is unreasonable to do so) together with information about the options available to complain about the refusal.

We may require you to pay certain costs in order to access your personal information held by us.  We will advise the amount payable (if any) once we have assessed your application for access.  We will not however charge a fee for you to lodge a request for access to or correction of your personal information.

If you lodge a request for access to your personal information, we may fulfil that request in any of a range of ways (for example, by supplying you with a copy of that personal information or providing you with the opportunity to inspect our records).  We may require you to comply with certain procedures before we allow access to or amendment of your personal information to ensure the integrity and security of information that we hold.  Depending on the nature of your request, this may include completing a personal information request form or otherwise verifying your identity to our satisfaction.

We will take reasonable steps to ensure that the personal information that we collect is accurate, up-to-date and complete and the personal information we use and disclose is accurate, up-to-date, complete and relevant.  If we are satisfied that any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will amend our records accordingly.

Please notify us if your personal details change so that we may keep our records current.

Online privacy

This section of our Privacy Policy sets how we handle your personal information in respect of online services provided by us (which includes any services provided by us via the Internet, such as our website, and also includes email communications).

Automatic server logs

Our servers automatically collect various details when you use our website, including:

  • your IP (Internet Protocol) address (generally, an identifier assigned to your computing device when it is connected to the Internet);
  • the operating system, computing device hardware and Internet browser software you are currently using; and
  • the data you access (such as web pages or other document files or software), and the time that you access it.

We do not attempt to identify individuals using this information, and only use it for statistical analysis, system administration, and similar related purposes.  This information is not disclosed to any other party.

Cookies

Our website uses “cookies”, which identify your computing device to our servers when you visit our website.  Our website may store cookies on your computing device in order to improve and customise your future visits to the website.  By using cookies, our website can provide customised content to you.  If you do not want information collected through the use of cookies, you may be able to configure your Internet browser to disable cookies.

We may also use cookies that enable collection of data which is linked to your account and may be considered personal information.  We will handle any such personal information in the same manner as other personal information in accordance with this Privacy Policy.

Email and messages

We may collect personal information from you (such as your name and email address, business details and any other personal information you volunteer) if you send us an email.  We will use this to contact you to respond to your message, to send you information that you request, and for other related purposes we consider are within your reasonable expectations.  We will not use or disclose any such personal information for any other purpose without your consent.

Storage and transmission of personal information online

If you provide any personal information to us via our online services (including email) or if we provide such information to you by such means, the privacy, security and integrity of this information cannot be guaranteed during its transmission unless we have indicated beforehand that a particular transaction or transmission of information will be protected (for example, by encryption).

Other online services

If any of our online services (including any email we send to you) contain links to other online services that are not maintained by us, or if other services link to our online services, we are not responsible for the privacy practices of the organisations that operate those other services, and by providing such links we do not endorse or approve the other services.  This Privacy Policy applies only in respect of our online services.

Data breach

If a data breach or suspected data breach occurs, we will undertake a prompt investigation, which will include an assessment of whether the incident is likely to result in serious harm to any individuals.  In such a situation we will comply with the requirements of the Act which may require notification to the Office of the Australian Information Commissioner (OAIC) and affected individuals. Please contact us if you have reason to believe or suspect that a data breach may have occurred, so that we can investigate and, if necessary, undertake appropriate containment, risk mitigation and notification activities as required.

Complaints

If you have a complaint about the way in which we handle your personal information, or you believe that a breach of your privacy has occurred, please contact us using the contact information below or using the contact form on our website.

Your complaint will be considered and dealt with by our nominated representative, who may escalate the complaint internally within our organisation if the matter is serious or if necessary to resolve it.

Please allow us a reasonable time to respond to your compliant.  If you are not satisfied with our resolution, you may make a complaint to the OAIC whose contact details can be found at: http://www.oaic.gov.au/.

Changes to our Privacy Policy

We reserve the right to amend this Privacy Policy at any time.  We publish our current Privacy Policy on our website, and you may obtain a copy of our Privacy Policy from our website or by contacting us.

Contact information

If you would like further information about the ways we manage your personal information, please contact us at the email address info@boroughmarkets.com.au.