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Policy last updated: June 2024
1. Purpose and nature
We recognise the importance of your privacy. This Privacy Policy explains how we intend to collect, store, use, disclose, protect and otherwise handle your personal information having regard to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).
This Privacy Policy does not constitute a contractual representation, promise, guarantee or warranty by us to you as to the manner in which we will or may collect, store, use, disclose, protect or otherwise handle your personal information.
2. Which Group entities does this Privacy Policy apply to?
This Privacy Policy applies to View Media Group Pty Ltd ACN 619 657 680 and all of its wholly owned subsidiaries, partnerships, joint venture entities and brands in Australia (Group), including AD Group (Australia) Pty Ltd (ACN 601 035 125), The Today Business Pty Ltd ACN 627 299 889 and view.com.au Pty Ltd (ACN 088 369 395) and their platforms, apps and employees (referred to as the we, us and our in this Privacy Policy). Each of us comply with the same obligations to protect your personal information under this Privacy Policy.
This Privacy Policy does not cover the privacy practices of third parties that we do not own or control, such as our third-party advertising and commercial partners including 20 Cashews Pty Ltd their related bodies corporate and service providers, Australia and New Zealand Banking Group Limited, their related bodies corporate and service providers, Seven West Media Limited and their related bodies corporate and service providers (Partners).
When you sign up to our platforms or use our products and services, your information will be collected by us in accordance with this Privacy Policy and may be shared with and processed by our Partners and other third parties as set out in this Privacy Policy, in accordance with their own privacy policies and terms and conditions. You should review the policies of our Partners before submitting personal information to us.
3. What is personal information?
Personal information is information or an opinion about you, whether true or not and whether recorded in a material form or not, from which you can be reasonably identified.
4. Why do we collect personal information?
We collect personal information in connection with providing, administering, improving and personalising our products and services, improving your experience with us, notifying you about our new products and services, discounts, promotions or upcoming events and to support our business functions.
As part of providing our products and services, we may provide your personal information to our Partners. If we do not do so, they may not be able to provide you with their related services or we may not be able to maintain our commercial relationship with that Partner.
If we do not collect your personal information, we may not be able to provide you with our products and services.
5. What personal information do we collect?
The types of personal information collected by us include:
(a) names;
(b) contact details such as mailing or street address, email address and telephone number;
(c) age or date of birth;
(d) profession, occupation or job title;
(e) browser history and IP address;
(f) billing information (such as credit card and bank account details);
(g) financial information (such as income, expenses, savings balance and outstanding debt);
(h) method of payment;
(i) social media account details;
(j) information or data which we automatically collect from you through the use of cookies or similar technologies, such as location data and online identifiers;
(k) details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
(l) any additional personal information relating to you that you provide to us directly through our websites or indirectly through use of our website or online presence through our representatives or otherwise;
(m) information you provide to us through any of our service centres, customer surveys or visits to our websites or platforms, or by our representatives from time to time; and
(n) other information you provide to us which is reasonably necessary for us to carry out our functions and activities.
6. How do we collect your personal information?
We will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner. When you provide us with personal information you consent to the use, disclosure and handling of your personal information in accordance with this Privacy Policy and any subsequent amendments (see clause 0).
6.1 Collecting information from you
If it is reasonable and practical to do so, we will collect personal information directly from you. Depending on how you choose to interact with us, we may collect your personal information when you contact, or are contacted by, any of us or our service providers by telephone (including by text messaging), by email, through any of our websites, apps, social media accounts, platforms and other digital services or when you complete a form or document and provide it to us.
6.2 Collecting information from third parties
We may also collect information about you from other people (e.g., third-party administrators, our referral partners or agents or one of our Partners) or independent sources. For example, each of the entities in the Group may collect your personal information from other entities in the Group and we may collect personal information about you from our Partners. Where we have collected your information from a third party, such personal information will be held, used, and disclosed by us in accordance with this Privacy Policy.
6.3 Collecting information about someone else
If you provide us with the personal information of someone else (as their authorised representative), we rely on you to inform them that you are providing their personal information to us and to advise them that we can be contacted for further information.
You must take reasonable steps to ensure the individual concerned is aware of and consents to the various matters detailed in this Privacy Policy, including the fact that their personal information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual's right to obtain access to that information, our identity, and how to contact us.
6.4 Collecting information from visits to our websites
We may collect information about how you use and visit our websites, apps and other digital services. For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.
We use and disclose this information only in anonymous, aggregated form for purposes including statistical analysis and to assist us to improve the functionality and usability of our website. You are not individually identified, however we reserve the right to use or disclose such information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.
We may also collect information based on how you use any of our websites, including through 'cookies', web beacons and other similar technologies.
Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable our systems to recognise your browser and record information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie Information).
We use cookies to provide you with a more consistent experience across our services. No attempt is made by us to use Cookie Information to personally identify you. However, if Cookie Information is linked with personal information as set out above, this Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.
You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of our websites may not function fully for users that disable cookies.
6.5 Google Analytics information
We use Google Analytics and the Cookie Information it collects to better understand the behaviour of our customers and provide targeted advertising to suit customers' interests and preferences. We also use this information to help measure and research the helpfulness of website features and offers and serve relevant ads to our users.
We have implemented a range of Google Analytics Advertising Features on our website and may include additional Google Analytics Advertising Features in the future. You can opt out of the Google Analytics Advertising Features by downloading the Google Analytics Opt-out Browser Add-on .
6.6 Unsolicited information
If we receive personal information that we have not requested and determine that the personal information received is not reasonably necessary to provide our services, we will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.
6.7 Anonymity/pseudonymity
Where practicable, you may be able to interact with us anonymously or by using a pseudonym. Circumstances where it is not practicable, however, include where personal information is required to complete a credit card transaction or to contact you about our services or services you might be interested in.
7. How do we hold your personal information?
The security of your personal information is important to us. Accordingly, we take reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification or disclosure. These steps include the implementation of the following safeguards:
(a) access controls;
(b) system firewalls and network security;
(c) data encryption;
(d) regular security audits;
(e) employee training; and
(f) regular software updates.
We will take reasonable steps to permanently de-identify or responsibly destroy personal information if it is no longer needed for the purpose for which the information was used or disclosed.
7.1 Security breach procedures
Our data security practices have been adopted with a view to protecting the data held by our Group. Notwithstanding this, individuals should be aware that there are inherent risks associated with the transmission of data over the internet and other mediums. Accordingly, we cannot guarantee any transmission will be completely secure.
8. How do we use and disclose your personal information?
We may hold, use or disclose your personal information for a range of purposes so that we can provide products and services that you request, give you access to our products or platforms, identify and promote products or services that may be of interest to you, respond to your enquires and to share with our Partners for marketing and analytics purposes.
For example, we may hold, use or disclose your personal information to:
(a) provide or deliver our products and services to you and to respond to your enquiries;
(b) share to other entities in our Group to support each of our business functions or for marketing purposes;
(c) administer, improve, develop and manage our products and services (including maintaining, testing and upgrading our platforms and systems);
(d) inform you about our products, services, offers, competitions, promotions, questionnaires or surveys or other matters which we believe are of interest to you;
(e) charge and bill you for the use of our products and services;
(f) customise the advertising and content on our platforms and to contact you about specials deals;
(g) share with our Partners for them to conduct marketing and data analytics and to conduct marketing and data analytics on behalf of our Partners;
(h) verify your identity;
(i) perform research and analysis;
(j) consider any concern or complaint that you raise against us or to manage any legal action between you and us;
(k) prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;
(l) enforce legal rights; or
(m) comply with any relevant laws, regulations, codes of practice and court orders.
8.1 Direct Marketing
As set out above, we may use your personal information to identify and promote products or services that may be of interest to you. We may also disclose your personal information to our Partners for them to undertake marketing or analytics.
At the time of making an enquiry, signing up to any of our platforms or subscribing for any updates you agree to the terms of this Privacy Policy and provide your consent to us sending you commercial electronic messages containing marketing or promotional materials and other information about our products. We may also seek your consent for us and/or our Partners to send you marketing or promotional materials and other information.
You may by notifying the contact person in clause 14 request us not to disclose your personal information to our Partners for the purpose of facilitating direct marketing by that Partner.
Where we have obtained your prior consent or as otherwise permitted by any applicable privacy laws, we may, from time to time:
(a) use your personal information to send you information about the promotions, deals, competitions, products or services we offer, and any other information that we consider may be relevant to you; and
(b) disclose your personal information to our Partners for the purpose of that Partner contacting you for promotional or marketing purposes. For example, a specified Partner may send you information about special deals, products or services they offer and other information that may interest you.
At any time, you may opt out of receiving direct marketing communications from us. To do so, use the unsubscribe or opt-out link that is contained within an email from us, or contact the person in clause 14. You may also opt out of direct marking communications from our Partners by using the opt-out link in their communications or contacting them directly.
9. How is personal information disclosed to others?
We do not sell, rent or trade personal information to, or with third parties without your knowledge or consent, or as otherwise set out in this Privacy Policy.
9.1 Disclosure to service providers
In order to provide our products and services or to support our business functions, we may disclose your personal information to third parties in limited circumstances, including to external providers that perform services on behalf of our Group.
9.2 Disclosure to Partners and entities in the Group
We may also disclose personal information to any of our Partners to enable them to conduct marketing and analytics, with other entities in our Group or to media publishers, agencies and partners, for the purpose of providing you with any agreed products or services.
9.3 Cross-border disclosure
We generally do not disclose any personal information to entities located overseas. However, we may transfer your personal information to an entity which is in a foreign country to assist us in providing our products and services. For example, your personal information may be stored on servers located overseas by our third-party cloud storage providers, or it may be provided to current or potential contracted overseas services providers or partners where the provision of our products or services requires the transfer of the information. Such foreign countries may include Bangladesh, Singapore, the Philippines, India, Indonesia, New Zealand, and the United States.
In these circumstances, we will take such steps as are reasonable in the circumstances to ensure that the information that is transferred to third parties located outside of Australia will not be held, used or disclosed by the recipient of the information in a manner that is inconsistent with the APPs.
9.4 Third Party Links
Our websites and digital platforms may contain links to other websites. We do not share your personal information with those websites and we are not responsible for the privacy practices applying in respect of those websites.
10. Age restriction
We do not knowingly process the personal information of children under the age of 16. If you are under the age of 16, we need the consent of your parent or guardian to process your personal information.
If you are under the age of 16, please do not use any of our websites, products or services without your parent or guardian’s consent. If you suspect that a child under the age of 16 has provided personal information to us, please notify us via the e-mail address in clause 14 below.
11. Change of control
If any one of us in the Group sell, assign or otherwise transfer part or the whole of our business to a third party, your personal information, which was collected by the Group through that entity’s service, may be among the items transferred or sold to the extent that it is relevant to that entity’s business.
12. How you may access or correct your personal information
You may contact us to request access to the personal information we hold about you at any time. You may also ask us to correct information about you that you may believe is inaccurate, incomplete or out of date.
Please contact us using the contact details in clause 14. We will need to verify your identity before giving you access to, or correcting, your personal information. We will respond to the request within a reasonable period after the request is made. There is no charge to make a request. However, we may charge a reasonable fee to cover the administrative costs of retrieving your personal information.
In certain circumstances, we may refuse, or be unable, to correct or provide you with access to your personal information. In these circumstances, we will write to you to explain the reasons why this is the case.
13. How you may complain if you have concerns about how we have managed your personal information
If you have a complaint related to how we have managed your personal information, please contact us using the contact details in clause 14. We may ask you to place your concerns in writing so that our compliance staff can fully understand and investigate your complaint.
We will provide you with an estimated response timeframe in relation to your complaint. In any event, we will endeavour to respond to your complaint within 30 days.
If a complaint remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.auto have the complaint heard and determined.
14. How to contact us
If you have any questions about or requests in connection with this Privacy Policy or our management of your personal information, please contact us on:
Attention: Privacy Officer
Email: communications@vmg.com.au
15. Changes to our privacy policy and information handling practices
This Privacy Policy is subject to change at any time, so we encourage you to review this Privacy Policy at regular intervals. If we change this Privacy Policy, an updated version will be posted on our website and we will notify you of this change. By continuing to use our services after that time, you will be deemed to have accepted any changes to our Privacy Policy.