1.1. Modern Standard Pty Ltd (ACN 605 705 520) ATF the Modern Standard Trust t/as Assembly Label (Assembly Label) is committed to ensuring your privacy through compliance with the Privacy Act 1988 (Cth)(Privacy Act) and the Australian Privacy Principles (APPs).
1.3. The purpose of this Policy is to outline how we collect and handle personal information in the course of our dealings with you.
1.4. Your privacy is very important to us. For that reason, please read the following details carefully and contact us if you have any questions or queries.
2. What personal information do we collect and how do we collect it?
2.1. Personal information will ordinarily only be collected directly from you when you visit our websites and/or social media pages (collectively, the Sites), through direct face-to-face contact (i.e. when you visit our stores in person), by telephone, by correspondence, through online competitions and attendance at our events.
2.2. Personal information may also be collected about you from a third party, such as one or more of our service providers.
2.3. The type of personal information we collect will depend on the circumstances of its collection and the nature of the dealings you have with us. For example:
- a) when you make a purchase in store, we may collect your name, date of birth, contact details (such as email address, phone number and residential address) and your financial and credit card details;
- b) when you attend one of our retail or concession stores in person, we or a third party acting on our behalf, may capture your image and/or sound recordings on Closed Circuit Television (CCTV) footage;
- c) when you make a purchase online, we may collect your name, gender, date of birth, contact details (such as email address, phone number and residential address) and your financial and credit card details;
- d) when you visit any of our Sites using an electronic device, we may collect your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address, standard web log information and cookies from your computer, which tells us when you visit the Sites and may remember your preferences;
- e) when you attend an event run by us, we may collect your name and contact details; and
- f) when you enter a competition or trade promotion run by us or on our behalf, we may collect your name, contact details and your preferences and opinions about types of products and/or services.
- Why do we collect your personal information?
3.1. We only collect personal information that is reasonably necessary for one or more of our functions or activities.
3.2. We only collect sensitive information if it is reasonably necessary for our functions or activities, or an exception applies under the PrivacyAct and the individual to whom the information relates has given their express consent to the collection.
3.3. You can choose not to provide us with certain information. However, if you do not provide us with certain types of personal information, we may be unable to provide you with our services, supply you with our products or otherwise transact with you.
4. How do we use your personal information and under what circumstances will it be disclosed?
4.1. We will only use or disclose your personal information for a purpose for which it was collected (or for a secondary purpose if an exception applies), including things such as supplying you with our products and/or services, managing our relationships, performing administrative functions, conducting marketing activities (including direct marketing) and complying with legal requirements.
4.2. Where we use personal information other than for a purpose for which it was collected, we do so in accordance with the Privacy Act and APP 6.
4.3. We may disclose personal information to our professional advisors (including lawyers) and contracted third party service providers and partners, including marketing and advertising agencies and information technology service providers. However, we will never disclose your personal information to an unknown third party, unless you have given your consent to such a disclosure.
4.4. We may disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable us to develop consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and/or services that you receive.
5. To whom do we disclose your personal information?
5.1. We may disclose your personal information for the purposes described in this policy to:
- a) our related bodies corporate and employees;
- b) our existing or potential agents, business partners or partners;
- c) our professional advisers, dealers and agents;
- d) payment systems operators;
- e) third party suppliers and service providers;
- f) anyone to whom our assets or businesses (or any part of them) are transferred;
- g) our sponsors or promoters of any competition that we conduct via the Sites;
- h) specific third parties authorised by you to receive information held by us; and/or
- i) other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
6. Direct Marketing
6.1. We may engage in direct marketing of our products and/or services from time to time.
6.2. We only use personal information for direct marketing in circumstances where we have collected the information directly from the individual and that individual reasonably expects to receive direct marketing material from us (for example, where an individual has signed up to receive direct marketing material from us).
6.4. Direct marketing may be in the form of email or SMS messages. You can opt-out of receiving direct marketing messages by following the unsubscribe link in the message.
7. Access to and accuracy of personal information
7.1. We take all reasonable steps to ensure that the personal information we collect, use and/or disclose is accurate, complete, up to date and relevant.
7.2. You have the right to ensure that your personal information which is held us is accurate. To make a request to access and/or correct your personal information, please contact Assembly Label’s Privacy Officer using the contact details provided below.
7.3. While we will always endeavour to give access to personal information free of charge, we reserve the right to charge individuals for access to personal information to cover costs associated with:
- a) searching for, locating and retrieving personal information and deciding which information to provide to the individual;
- b) using an intermediary; and
- c) reproducing and sending the information.
7.4. We are entitled to refuse to give access to personal information in certain circumstances. For further information, please contact Assembly Label’s Privacy Officer using the contact details provided below.
8. How secure is your personal information?
8.1. We take all reasonable steps to ensure that information held by us is safe and secure, and that it is protected from misuse, loss, unauthorised access, modification and disclosure.
8.2. While we take all reasonable steps to ensure the security of your personal information, data protection and security measures can never be guaranteed and, accordingly, we cannot guarantee the security of your personal information.
9. Destruction and de-identification of personal information.
We will take reasonable steps to de-identify or destroy personal information when it is no longer needed by us, except where the information forms part of a Commonwealth record or we are required, by law or a court or tribunal order, to retain the information.
10. Anonymity and pseudonymity.
Individuals have the option of dealing anonymously or by pseudonym with us, unless it is impracticable to do so or we are required, by law or a court or tribunal order, to deal with identified individuals.
11. Overseas disclosure of your information
11.1. We may disclose your personal information outside of Australia to entities of the kind listed in paragraph 5 of this Policy.
11.2. By providing your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge APPs 8.1, as outlined in Schedule 1 to the Privacy Act, will not apply to the use of the information.
11.3. You further acknowledge we are not responsible for privacy practices of the overseas entities to whom we may disclose your information and acknowledge we are not required to ensure that overseas recipients handle your personal information in compliance with the Privacy Act and the APPs.
11.4. We will, however, take reasonable steps to ensure that any overseas recipient will deal with your personal information in a way that is consistent with the APPs.
12. Third Party Links
12.1. The Sites may contain links to websites or products operated by third parties.
12.2. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites or products, and have no control over or rights in those linked websites.
12.3. The privacy policies that apply to those other websites may differ substantially from this Policy, so we encourage individuals to read them before using those websites or products.
13. Changes to the Policy
13.1. We reserve the right to amend this Policy from time to time. Changes will be posted on any one or more of the Sites.
13.2. You should regularly check the Sites to see if there have been any recent changes.
14.1. If you believe there has been a breach of the Privacy Act or the APPs, please contact Assembly Label’s Privacy Officer using the details provided below.
14.2. We take privacy complaints very seriously. If you make a complaint, we will respond within five (5) calendar days to advise you of who is responsible for managing your complaint. We will try to resolve your complaint within ten (10) calendar days. When this is not possible, we will contact you within that time to let you know how long we will take to resolve your complaint.
14.3. We will investigate your complaint and, where necessary, consult with third parties about your complaint. We will make a decision about your complaint and write to you to explain your decision.
14.4. Individuals can also complain directly to the Office of the Australian Privacy Commissioner. Details about how to file a complaint can be found at www.oaic.gov.au or by calling 1300 363 992
15. Contact Assembly Label
All questions or queries about this Policy and complaints should be directed to the Assembly Label Privacy Officer, whose details are as follows:
Contact Name: The Privacy Officer