This Policy contains important information about how we manage personal information. It applies to all of the services offered by CHARELLE AINSLIE as an independent candidate (Charelle Ainslie, we, us, our) and the platforms through which we interact with you, including through the Charelle Ainslie website, and Charelle Ainslie social media accounts (social media).
We may modify this Policy at any time, and if we do, we’ll publish it on the websites. We are bound by the Privacy Act 1988 (Cth) and the Australian Privacy Principles contained within that Act.
The services we offer may change from time to time.
PERSONAL INFORMATION WE COLLECT
Depending on your interaction with us, the information that we collect may include (but is not necessarily limited to) your name, address, contact details, date of birth, and gender.
In some cases, we may collect information that is usually non-personally identifiable (such as location data, data about personal attributes, or online identifiers) but that, taken together with other collected data, may identify you, either directly or indirectly.
HOW WE COLLECT AND HOLD PERSONAL INFORMATION
We collect personal information from you:
- Directly and voluntarily;
- Via third-party sources.
- Information provided voluntarily by you
Information provided voluntarily by you
We collect personal information you provide to us, including when you:
- Create or use a customer account on our website or through our mobile application;
- Interact with our website or call centre;
- Interact with our social media, including communicating with us via social media platforms;
- Subscribe to electronic communications;
- Enter promotions or competitions, depending on the entry requirements;
- Submit an enquiry or complaint, provide feedback or make a customer service request;
- Download software and mobile applications, where you may provide your name, contact details, and other information to access and use the service;
- Participate in surveys, market research, or audience testing.
Any personal information that you provide to purchase products or services on the websites or through the call centre is collected and managed by Charelle Ainslie.
Personal information that you provide to purchase products or services on third-party websites which are linked to our website is collected and managed by those third parties.
Information collected automatically
We may track activity relating to your interaction with our email communications and with links embedded in email communications and our website or social media.
This type of information is usually collected, used, and stored by Charelle Ainslie or its marketing company to measure the effectiveness of our advertising and how visitors use the website in order to:
- provide you with a better and more customised service and a more effective website;
- collect information on how many visitors the websites receive, how those visitors use the websites, where they came from and where they go; and
- determine whether you have made purchases of certain products elsewhere, after using the websites.
You can configure your browser so it does not accept cookies, but this may affect the functionality of the websites. We may also collect and store information on your personal device using browser web storage and data caches
Information provided by or collected from third parties
We may be provided with or collect information from third parties about you. This can include where:
- we engage organisations to collect personal information directly and voluntarily from you on our behalf. Where reasonably possible, we require organisations engaged on our behalf to comply with this Policy and all applicable privacy laws and regulations.
- we receive information from our participating partners of Charelle Ainslie, for example, after you purchased a product from the partner after interacting with Charelle Ainslie;
- we engage an organisation to conduct market research or audience testing; or
We may use analytics tools, web beacons, and other technology to obtain aggregated and non-identifiable information such as usage and user metrics collected by third parties when you interact with our website and social media. Organisations who collect such information may aggregate information collected from your interactions with us with other information they have also collected elsewhere. Third-party organisations typically collect and use information under their own privacy policies. We currently obtain such information via Google Analytics and our third-party ad servers.
If we collect information about you from a third party, we will determine whether we could have lawfully collected that information directly from you and, if not, we will destroy or de-identify that information (provided it’s lawful to do so).
WHY WE COLLECT, HOLD AND USE PERSONAL INFORMATION
We generally collect, hold, and use personal information for four purposes:
- service provision;
- optimisation and enhancement; and
- marketing and advertising.
We may notify you that we also collect, hold and use personal information for other purposes from time to time.
Where required or authorised by law, we may also share your personal information with third parties if we genuinely believe that the sharing of that personal information is required or authorised under law.
Provision of services and products to you
We use your personal information to:
- to provide you with services and products including via our website or via our call centre;
- to provide to our business partners or participating suppliers so that they can (where you have agreed) provide you with updates or information about their products and services and provide you with reminders;
- to provide to our service providers so that they can provide us with services that assist us to run our business and the websites;
- to reconcile transactions with our business partners or participating suppliers that supply you products because of our services;
- to provide to our service providers who we engage to provide you with your prize if you win a promotion.
In some cases, if you do not provide the information, we will not be able to provide our services to you and you may not be able to claim your prize.
We use your personal information to provide you with customer support, including dealing with complaints and enquiries. We may also use your information for activities including:
- to administer competitions and promotions;
- to send special offers or reminders;
- to seek your opinions and feedback; and
- to telephone you about the services and products we offer.
If you win a competition that we (or our agents) run, we may also seek your consent to use your name, image (e.g. photograph), and/or voice recordings for the purpose of promoting or marketing the competition and/or our services.
Optimisation and enhancement
We use your personal information to provide, improve and maintain our website and call centres and the Services we offer, including developing new products and services. Your information may also be used:
- to prevent abuse and fraud;
- in conjunction with other information, for analytical and statistical purposes;
- to personalize and customise your online experience, including advertisements and content; and
- for other administrative and internal business purposes.
Charelle Ainslie may record details or block particular I.P. addresses (and where required provide those details to third parties to assist us) to maintain the integrity of the website where there is suspicious or excessive use of the websites.
Marketing & Advertising
We use your personal information to market and advertise our business and products and services to you. Your information may also be used to customise and display advertisements and content for you.
We may use various services or organisations to analyse collected data about your interaction with our website, services, or other aspects of our business. The information that is collected is not generally personally identifiable as it is aggregated data that does not identify any individual user.
Third-party organisations may share user information they collect from our website with other analytics companies that collect, analyse and report on data obtained from their clients. In some cases, the non-personally identifiable information collected from our website or services may be linked with information collected by a third-party source to become personally identifiable. We will not link, or merge information collected by us with information collected by third-party organisations without your consent. However, Google, Facebook, or other third parties may merge or link your information if you have provided your consent for them to do that.
By using our website, call centre, and services, you consent to:
a) the collection of data by our ad servers or third-party affiliates, or the transfer of information to them, wherever necessary, for optimisation and enhancement of our website and services and to tailor the content and advertising that is delivered to you; and
b) receiving email or SMS communications from us. To safeguard the personal information that may be accessible from communications from us, we recommend that you only provide us with contact details over which you maintain access and control.
You can opt-out of marketing and advertisements at any time. The process for unsubscribing from our communications is set out below.
KEEPING YOUR PERSONAL INFORMATION SECURE
We generally store personal information on networks in Australia.
We will take reasonable precautions to ensure that the personal information that we have about you is protected against any unlawful use, unauthorised access, modification, or disclosure and these precautions include:
- using appropriate information technology and processes;
- using computer and network security systems with appropriate firewalls, encryption technology, and passwords for the protection of electronic files;
- securely destroying or “de-identifying” personal information if we no longer require it subject to our legal obligations to keep some information for certain prescribed periods; and
- restricting access to your personal information to our employees and those who perform services for us who need your personal information to do what we have engaged them to do;
- requesting certain personal information from you when you wish to discuss any issues relating to the products and services, we provide to you.
While we undertake reasonable steps to protect your personal information, no guarantee can be given that information sent over the internet is always 100% secure. Sending and receiving information over the internet is at the user’s own risk, however, we will take all reasonable steps to ensure your data security once we receive it.
If we believe or suspect that the security of your Personal Information has been compromised, we may attempt to notify you electronically so that you can take steps to protect yourself from harm.
Where reasonably possible, we will destroy or de-identify your information if it is no longer required for the purpose for which it was collected or any related purpose (subject to any relevant record-keeping obligations under Australian law).
Transfer of information outside Australia
In some cases, your information may be transferred or stored outside Australia as some of our service and software providers and/or business partners may be in overseas locations.
We hold personal information in data storage and cloud computing facilities operated by us (or by third parties for us) that may be in overseas locations.
As some of our internal business systems are supported by cloud computing facilities there is also potential for personal information to be incidentally transferred to our overseas providers.
WHEN WE DISCLOSE PERSONAL INFORMATION
Participating suppliers and partners
We may provide your information to participating suppliers and partners to them to provide products and services to you. This may include providing your information to a supplier or partner:
- if you decide to enter into an agreement with that supplier or wish to obtain further information.
Third-party affiliates and service providers
We may provide your information to our third-party affiliates who carry out services on our behalf or to the service provider to enable service providers to perform business functions for us. Whenever possible, we require such third parties to only collect and use Personal Information in accordance with this Policy, and for no purpose other than providing us with our requested services. This may include service providers we engage to supply prizes to you on our behalf.
We may disclose your information if in our reasonable opinion, we are legally bound to do so or if such disclosure is necessary to prevent harm to ourselves, other users, or third parties. We will notify you of such disclosures.
ACCESS TO YOUR PERSONAL INFORMATION
You have the right to access and correct your personal information we hold. In certain situations (e.g. if required or permitted by law), we can deny access to some or all the personal information we hold. We will always provide reasons in writing if access is refused. We may charge you a reasonable fee for access to your personal information, but we will advise you of the fee before we process your request. We will always respond to requests for access and/or corrections within a reasonable period and we will give access in the manner requested if it is reasonable and practicable to do so. Please email me (see Contact Information) if you wish to access or correct your personal information.
If you provide us with information about another person, you must have that person’s consent before you provide the information to us. You must also tell the person we have collected their personal information; the person is entitled to access the information we hold, and he or she should refer to this document to understand how we manage their personal information.
UNSUBSCRIBE FROM MARKETING COMMUNICATIONS
If you no longer wish to receive marketing communications from the Charelle Ainslie, please use the unsubscribe link contained in all of our email communications. If you use the unsubscribe link in our email communications, you will be removed from the distribution list for email communications, but you may continue to receive communications from us by SMS or phone.
If you have a complaint about the way we manage your personal information, including any decision made regarding a request for access or correction of your personal information, please contact us by email (see Contact Information):
We will endeavour to resolve any privacy complaints and will respond in writing to you regarding the outcome of any investigation. If your privacy concerns are not resolved satisfactorily or you wish to obtain more information on the privacy legislation, you can contact the Office of the Australian Information Commissioner (see Contact Information).
Charelle Ainslie – firstname.lastname@example.org