2. WHAT INFORMATION DO WE COLLECT?
We collect personal information to provide Company Services and for our business operations. If you choose not to provide the information we request from you, we may not be able to provide you with the services you require.
We describe the main types of personal information we collect and the main reasons why we collect that information below.
Registration Information is the information you provide to Company when you register for or acquire a Company Service. This may include information you provide us to:
create an account;
- become a subscriber;
- become an advertiser;
- post comments;
- receive a newsletter; or
- enter a competition.
Registration Information includes, for example, your name, delivery or postal address, email address, gender and birthday.
If you access or log-in to a Company Service through a third party social media service or connect a Company Service to your social media profile, we may also include information from that social media service. This may include:
- your user name for that service;
- any information or content you have permitted the social media service to share with us (such as your profile picture(s), email address, followers or friends lists); and
- any other information you have made public (including other posts you make using your social media profile).
Activity Information – cookies and other technologies: When you visit Company’s websites (including to access and use Company Services) we and certain third parties such as Facebook may collect information about your visit. For example, in order to connect you to the Company Services, our servers receive and record information about your computer, device, and browser, which may include your IP address, browser type, and other software or hardware information. If you access the Company Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data, or other transactional information from that device.
Information from Other Sources. We may supplement the information we collect about you with information from other sources. This may include information from publicly available sources (such as other published content) and data providers.
3. HOW DO WE USE YOUR INFORMATION?
We use the information we collect about you to provide Company Services to you. As part of our service to you we may use your personal information:
- to fulfill administrative functions associated with these services
- to enter into contracts with you or third parties;
- to measure and improve Company Services and their individual features;
- to improve your experience by delivering content (including editorial, marketing and advertising) we think you will find relevant and interesting;
- for other marketing and client relationship purposes;
- to provide you with customer support; and
- to respond to your enquiries.
When we collect your information, we may explain that we will use and disclose your information in other ways. For example, if you win a competition, we may disclose your information to relevant regulatory authorities and publish your details in accordance with the competition terms.
We may also remove certain information or alter the information we collect about you so you can no longer be identified from that information. We do this so that we can use it or disclose it to third parties for other purposes.
We use the information we collect about you for the following additional purposes:
Research and data analysis. We may also use your information for research and data analysis to improve Company Services. We may do this research or engage a service provider to do this.
To allow service and content providers to assist us in providing and managing the Company Services. We may make your information available to certain third party service and content providers who help us manage or provide the Company Services or provide Company with related services. This might include providers of cloud services, website hosting service providers, and direct marketing service providers. These third parties may be located in a range of different countries including Poland, Switzerland United Kingdom, United States of America and Singapore. Our agreements with these third party providers require them not to use your information except for the purpose for which your information was provided. We also require them to comply with relevant privacy laws.
To deliver relevant advertisements and content. Company and our advertisers may use your personal information so that relevant advertising can be provided to you when you use services or visit websites of other organisations.
We may combine information that we hold about you with information about you that we collect from other trusted businesses with whom you also have a relationship or from public sources and we may associate your browser and/or device with other browsers or devices you use. We may also share information we hold about you with those trusted businesses so that they can do the same thing.
We and those trusted businesses do this in order to enable the development of consumer insights about you so that each of us can serve you better. This includes being able to better understand your preferences and interests, personalise your experience, enhance the products and services you receive, and to tell you about products and services. Where those insights are provided to others for their own marketing purposes, such insights do not contain any information that personally identifies you. We may also use third party service providers to undertake the process of creating these consumer insights.
In addition, we engage third-party advertising networks to help us target our messaging to you through interest-based and contextual means. Through these ad networks, we can track your online activities over time and across third-party websites and apps by obtaining information through automated means, as described above. This data collection takes place both on our sites, apps and through marketing emails and newsletters which we send you and on third-party websites and apps that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts.
To contact you. From time to time, we may send you promotional materials or other information which we think may interest you. For example, we may send you an invitation to participate in various activities or special offers.
To share with business partners. Company may share your information with business partners so they can send you marketing communications. This will only happen if you have expressly agreed to this.
To protect the rights of Company and others. We may share your information with other third parties where we are lawfully entitled to do so. This includes when we have a reasonable basis to believe that sharing your information is necessary to:
- protect the safety, privacy, and security of users of the Company Services or members of the public;
- protect against fraud or for risk management purposes;
- comply with the law or legal process in any country; or
- respond to requests from public and government authorities.
To complete a merger or sale of assets. If Company sells all or part of its business or assets, we may disclose your information to the party or parties involved in the sale transaction. We may also do this if Company is involved in a merger or transfer of all or a material part of its business. We may disclose your information prior to the sale, transfer or merger so that the party or parties involved can consider the transaction and complete any due diligence.
4. HOW DO WE PROTECT YOUR INFORMATION?
We use reasonable measures to safeguard the personal information we hold about you from loss, theft and unauthorised use, disclosure or modification, including:
System security We take reasonable steps to prevent unauthorised access to our online and computerised systems by using measures such as firewalls, data encryption, virus detection methods, and password restricted access.
Property security At our business premises, we may engage security personnel and use ID cards to restrict access to those premises.
Third parties We take reasonable steps to ensure that third parties who store or assist us to store your personal information adopt appropriate security measures.
5. HOW CAN YOU ACCESS YOUR INFORMATION?
If you would like to access, review, correct or update your personal information, you may contact us (see section 8). When you contact us, please provide your name and contact details (including your email address, address, and telephone number) and specify clearly what information you would like to access, review, correct or update. We will need to share your information with others who can help us respond to your request. We will try to respond to your request as soon as reasonably practicable. If we refuse your request we will generally tell you why.
- HOW CAN YOU OPT OUT?
Direct marketing. If you do not want to receive promotional messages from us, you can change your account settings or follow the unsubscribe instructions which we include at the bottom of our emails and text messages. If you have installed our app, you can stop push notifications by changing the settings in the app or on your mobile device.
7.OTHER IMPORTANT INFORMATION FOR YOU
Location of Data. Some Company Services are hosted in and managed outside of Australia, including in Poland, Switzerland, the United Kingdom, the United States of America and Singapore. In dealing with Us, you consent to this practice, understanding that your personal information may be accessible from or transmitted outside Australia.
Complaint. If you think we have breached the Privacy Act 1988 (Cth) or other applicable privacy laws, you can contact us (see Section 8) to make a complaint. When you contact us, please include your name and contact details (including your email address, address, and telephone number) and clearly describe your complaint. We will need to share your information with others who can assist in responding to your complaint. We will contact you within 7 days to let you know the next steps in resolving your complaint and to obtain any further information we need to consider your complaint. As soon as reasonably practicable and in any event within 30 days, we will let you know our decision. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (www.oaic.gov.au).
8. HOW YOU CAN CONTACT US
If you would like to raise a privacy concern in relation to information (including photos or videos) which we have published in any of our print or digital publications, please email: firstname.lastname@example.org
9. LIST OF INCLUDED COMPANIES
Mana Group Oceania Pty Ltd (ACN 647 966 176) 21 Goobarah Road, Burraneer NSW 2230
Mana Global Pte Ltd of Pho3nix Global Ltd, (UEN 201942675M), 6 Jiak Chuan Road, #02-01 Singapore 089262
Pho3nix Foundation, ℅ Latesta AB (CHE 169 567 607) a charitable foundation wish registered office in Via Somplaz 1, 7500 St. Moritz, Switzerland.