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Privacy Policy

Introduction 

1. The Media Precinct Pty Ltd ABN 51 619 008 043 (“The Media Precinct”, “we”, “our”, or “us”) are committed to respecting the privacy of your personal information. This Privacy Policy explains how we deal with your personal information that we collect, use, hold, disclose or process. 

2. We will update this Privacy Policy from time to time when we change how we deal with personal information. We will post any changes to this Privacy Policy on our Websites, so we encourage you to check this Privacy Policy from time to time. 

3. In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain collection channels of personal information. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

Definition of personal information

Throughout this Privacy Policy, we use the term 'personal information' to refer to information or an opinion that identifies or locates a natural person, including when combined with other reasonably available data (including but not limited to when combined with other data using available technologies, Artificial Intelligence, or information to identify or locate a natural person), can be used to identify or locate a natural person whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not. For example, your full name, date of birth, address, mobile telephone number, email address, location settings, and credit card details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences. However, personal information does not include information that is appropriately de-identified or made anonymous and cannot be combined with other data using available technologies, Artificial Intelligence, or information to identify or locate a natural person.


Problems, Complaints or Queries

4. If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled, disclosed and/or processed your personal information, please contact our privacy officer via: 

Mail: Privacy Officer 
48/48 Kensington St Chippendale NSW 2008
Email: gwynyard@mediaprecinct.com.au

5.    Please allow 30 days for this request to be processed. On receipt of your query, problem or complaint a review will be conducted and findings will be communicated to you where required. If you do not receive a satisfactory response to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at https://www.oaic.gov.au/about-us/contact-us/, or to the data protection supervisory authority in your country. 


On what basis do we process your data?
Lawful basis of processing
6.    The Media Precinct will only collect, monitor, use, disclose, or process any personal information about you with your consent (which we endeavour to obtain at the same time as collecting your personal information) or if it is otherwise lawful to do so. The only personal information collected by us is what has been provided to or collected by us in accordance with this Privacy Policy or has been provided to us lawfully by third parties. We will generally deal with your personal information for the primary purposes set out in this Privacy Policy.
7.    The Media Precinct may also rely on the lawful bases of contract and legitimate interest. That is, where you enter into a contract with us, The Media Precinct will process your personal information because it is necessary for the performance of that contract with you. In some circumstances, such as fraud prevention, The Media Precinct may also have a legitimate commercial interest in processing your personal information. The Media Precinct may also request your explicit consent to process your personal data from time to time for various purposes. 
8.    The Media Precinct reserves the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect the rights or property of The Media Precinct, any member of the The Media Precinct, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.
When and how do we collect personal information?


Collection Channels
9.    We (or our subcontractors) collect and combine personal information in a number of ways through the following channels (each, a Collection Channel):
a.    through our clients and service providers as a result of the provision of professional services to our clients, and other legitimate third party sources; 
b.    through physical and other ad-hoc channels of collecting personal information in relation to events, activations, or promotions (such as through paper forms or tablets); 
c.    our online properties (here and after, each a “Website”), including: 
i.    our websites, including but not limited to https://www.mediaprecinct.com.au/, 
ii.    any related The Media Precinct website, social media page, internal website, intranet and any The Media Precinct mobile or tablet applications, and
d.    any other means through which an individual provides personal information to The Media Precinct, including either physically or electronically.
Active Information Collection
10.    Personal information may be collected and combined via our Collection Channels if you:

a.    sign-up and/or register to become a member of any Collection Channel, or provide your details to us or our clients via any Collection Channel;

b.    subscribe to any newsletters, updates, alerts or news and media releases, or request launch or event information or information about our products or services or other information services as well as third party products or services; 
c.    have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party;
d.    complete and submit any forms or surveys provided to The Media Precinct, either physically or electronically;
e.    conspicuously publish or provide on request your personal information to The Media Precinct;
f.    contact us or our clients directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
g.    participate in any events, offers, promotions, competitions or marketing activities of The Media Precinct, or our clients or service providers;  
h.    interact with a Website for a specific purpose; or
i.    interact with or browse a Website generally. 

11.    We may also collect your information through other legitimate third party sources including list brokers, social media organisations, and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so.  
12.    We may collect personal information from you in a passive manner including through the use of cookies and other tracking tools such as internet tags, tracking pixels, web beacons and unique device identifiers. For further information about the use of passive personal information collection, see paragraph 36 below.  


What kinds of personal information does The Media Precinct collect?
13.    We may collect personal information including:

a.    your full name, contact details (such as your email address, phone number, address, contact preferences), location, and passwords you create;
b.    information about your preferences, interests, opinions, feedback and experiences with our products or services or the products and services of our clients;
c.    social media account usernames and information published on your social media accounts;
d.    information regarding your personal and professional interests and your networks; 
e.    information regarding your relationship history with The Media Precinct and The Media Precinct’ clients; 
f.    information about your employment history and future plans, and documents relating to your employment;
g.    information about your education and qualifications, skills and experience;
h.    enquiry and complaint details; 
i.    information about your experience with The Media Precinct’ products or services or third party products or services. This information is requested including in order to tailor our subsequent communications to you and continuously improve our products and services; 
j.    the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to The Media Precinct and used for the purposes set out in this policy (which may include using their details for marketing purposes);
k.    financial details, if you have provided them to us, such as your bank account, credit card, Paypal or other online payment system details (where you purchase any products or services from us);
l.    When you visit a Website, we may also collect personal information about you in the following general categories:
i.    usage and preference information: we collect information about how you interact with the The Media Precinct website, including the pages you visit, your preferences and settings that you choose. We may do this through the use of cookies and other similar technologies that uniquely identify you;
ii.    device information: we may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network; and
iii.    other information: we may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a website.
m.    any other personal information you provide directly to us. Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy). 
n.    any other personal information requested or required by a Collection Channel.


Sensitive Information
14.    We do not seek to collect sensitive information (which includes information or an opinion about an individual’s; racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, that is also personal information, health information about an individual, genetic or biometric information). 
15.    If we do collect sensitive information, we will only do so with your consent and where you provide it to us directly. Where you provide us with any sensitive information (including, but not limited to, information about your sexual orientation, religious beliefs, medical and/or criminal history), we will only use this information for the purposes stated at the time of collection and will only share this information with our trusted third parties in the manner stated in this Privacy Policy.
Consequences of not providing personal information
16.    No-one is obliged to provide personal information. However, failure to do so may result in The Media Precinct or our clients being unable to provide you with The Media Precinct’ or our clients’ goods, services, information, upcoming opportunity, promotion, event or product information, and other content, including as requested by you.
For what purposes does The Media Precinct collect, hold, use and disclose your personal information?
17.    Personal information that The Media Precinct collects will be used for the following primary purposes:
Providing services to The Media Precinct’ clients

a.    To fulfil obligations in respect of any contract between you and The Media Precinct, or you and our clients, or The Media Precinct and our clients; 

b.    To render services related to The Media Precinct or our clients, including providing our professional services to our clients;
Managing relationships
c.    to carry out any purchases you make and otherwise manage our or our clients’ commercial and trading relationship with you including identifying you in our system and contacting you, invoicing you correctly, sending you our products and to address your expectations of us in respect of how we conduct our business;
d.    to ensure that your personal information remains up-to-date and complete;
e.    to provide you with information about your accounts, transactions, content, services and products involving The Media Precinct or The Media Precinct’ clients;
f.    to facilitate payments from you;
g.    to contact you, including sending you any technical, administrative or legal notices relevant to The Media Precinct, our clients or a Website;
h.    to otherwise maintain our relationship with you or the relationship between you and our clients, including providing after sales services and responding to enquiries;
Special offers, marketing and advertising
i.    to provide you with early access to new releases, exclusive events, special offers, newsletters, events, promotions and activations of The Media Precinct, its clients or its trusted partners;
j.    to otherwise market to you (with direct marketing materials), via any medium including mail, telephone, commercial electronic messages (such as SMS, MMS, instant messaging, email, social media, mobile applications), or any other form of electronic, emerging, digital or conventional communications channel.;
k.    to provide you with relevant and targeted advertising, including when you browse third party websites; 

The Media Precinct’ Website
l.    to maintain the functionality of a Website, including customising the Website based on your preferences; providing information to you relating to the content available on a Website; to improve the Website and system administration;
Improving offerings to you and conducting research
m.    to better understand and meet your needs and interests, to enable us to improve the nature of the goods and services we or our clients provide, to more accurately market our or our clients’ goods and services, and to research our or our clients’ customers;
n.    to obtain opinions or comments about products and/or services and to conduct other research and development;
o.    to record and analyse statistical and de-identified data for analysis including marketing analysis;
p.    to conduct market research including identifying likeminded individuals including through third party vendors such as Facebook or other social media websites;
Miscellaneous
q.    to share personal information with our group companies and their related bodies corporate and agents, and other trusted third parties in the manner described in this Privacy Policy;
r.    for any further purposes stated in a particular Collection Channel;
s.    to undertake recruitment for The Media Precinct (if applicable);
t.    any other purpose as may be deemed reasonably necessary by The Media Precinct in the circumstances;
u.    as needed to satisfy any law, regulation or legal request; to protect the rights or property of The Media Precinct, The Media Precinct’ clients’, or any member of the public; to protect the integrity of Websites; to fulfill your requests; or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.


Contact by The Media Precinct
18.    The Media Precinct (and their directors, servants and agents), The Media Precinct’ promotional partners, The Media Precinct’ clients or trusted third parties (and other selected service providers and other non-The Media Precinct companies or professionals) either in Australia or overseas, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the primary purposes for collection of personal information as stated above.
19.    The Media Precinct does not send advertising or marketing information without obtaining prior consent unless it is lawful to do so, for example consent provided by you when you accept this Privacy Policy. If you receive communications from The Media Precinct which you do not wish to receive, you may remove your name from the database either by using the functional unsubscribe facility (if the communication is via commercial electronic message) or by contacting The Media Precinct‘ Privacy Officer as described above. Please allow 30 days for this request to be processed.
20.    Despite removing your name from the database from receiving future advertising and marketing information, The Media Precinct may send you non-commercial “Administrative Emails”. Administrative Emails relate to your account with The Media Precinct or The Media Precinct’ clients (if applicable) and may include administrative and transaction confirmations, requests and inquiries or information about a particular account. If you do not wish to receive such communications from The Media Precinct, you may remove your name from the database by contacting The Media Precinct’ Privacy Officer. Please allow 30 days for this request to be processed.
Automated decision-making
21.    The Media Precinct does not make decisions that produce significant effects on you which are solely based on automated decision making. 
How do we share your personal information?
22.    For the purposes described above, personal information may be shared with the entities below including their directors, servants and agents and related bodies corporate:
a.    our clients; 
b.    our or our clients’ marketing and email sending partners;
c.    technical service providers, such as mail carriers, hosting providers, IT companies and communications agencies; and 
d.    other trusted service providers, promotional partners and third parties. 
23.    These recipients may be engaged by The Media Precinct to perform a variety of functions, such as legal and accounting services, data storage, support services, conducting market research, processing credit card payments, assisting with promotions and providing technical services for our websites. These companies may have access to personal information if needed to perform such functions. Your credit card details are only used to facilitate your purchases. They are not used for any other purpose and will never be supplied to a third party other than The Media Precinct, The Media Precinct’ client from whom you are purchasing products or services or our relevant service provider. If you are a business we trade with, we may disclose your information to debt recovery agents or credit reporting bodies if necessary.
24.    Some of the recipients of your personal information may be located overseas. The Media Precinct employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by The Media Precinct. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. The Media Precinct will not be held responsible for events arising from unauthorised access to personal information except to the extent required by the relevant privacy laws. 
25.    The recipients of your personal information may be located in Australia or overseas
How do we hold, and how long do we hold your personal information?
Security
26.    The Media Precinct takes appropriate security measures to keep personal information secure and to prevent unauthorised access, disclosure, modification, misuse, interference or loss of personal information. The Media Precinct, its employees and its subcontractors are obliged to respect the confidentiality of any personal information held by The Media Precinct. 
27.    The Media Precinct also takes reasonable steps to keep personal information accurate, up to date, complete and relevant. The Media Precinct takes reasonable steps to ensure only those necessary have access to your personal information.  Personal information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas, including in as described above. The Media Precinct retains your information only for as long as necessary for the purposes listed in this Privacy Policy. The Media Precinct will inform you about serious data breaches in accordance with the Privacy Act.

Your privacy rights
28.    You have a number of rights under the Australian Privacy Law. These include: 

a.    (access) to request access to your personal information from us, in a commonly used electronic format. On a case by case basis, The Media Precinct may determine that it is not legally required to give an individual access to personal information, in which case The Media Precinct will provide you with a written notice of its refusal to provide access; 
b.    (correction) to request that we correct your personal information; 
c.    (withdrawing consent) to withdraw your consent for us to use your personal information. Please note that you can also opt-out of online marketing communications at any time by using the unsubscribe feature in each electronic commercial message;
d.    (complaint) to complain about a breach of the Australian Privacy Principles. 

29.    (informed) to be informed about how your personal information is and will be used. To exercise these rights, please contact us at the contact details listed at the beginning of this Privacy Policy. Please allow for a reasonable amount of time for us to process your request, which will generally be up to 30 days.


Miscellaneous
Anonymity and Pseudonymity 
30.    Where practicable, The Media Precinct will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our collection channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the personal information identified above. It will not be practicable to deal with you on an anonymous or pseudonymous basis when we wish to send you direct marketing materials or need to provide you with goods or services requested by you.
Sale of the company
31.    If The Media Precinct merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy, any revised Privacy Policy and the Australian Privacy Principles.
Children
32.    Personal information will not be collected from any person who is known by The Media Precinct to be under the age of sixteen (16) without the consent of a parent or legal guardian or as has been provided to us lawfully by third parties, including our clients. Persons under age sixteen (16) may only use our Websites with the involvement and consent of a parent or legal guardian. 
Passive Information Collection
33.    As with many commercial websites (and mobile and tablet applications), The Media Precinct and The Media Precinct’ clients may also collect information which tells us about visitors to our websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally including when you are logged into an account, you consent to the collection of such information where it is personal information.
34.    As you navigate through our websites, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as Unique Device Identifiers (UDI), cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). In certain circumstances, this information may be considered anonymous information or personal information under the Privacy Act 1988 (Cth), dependent on the device used and the method by which an individual connects to the Internet. Your Internet browser automatically transmits to the website you are browsing some of this anonymous information or personal information, such as the URL of the website you just came from, the Internet Protocol (IP) address, the UDI (if applicable) and the browser version your device is currently using. Our websites may also collect anonymous information or personal information from your device through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of a website might not work without cookies and this may limit the services provided by a website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf.
35.    Our Websites may use and combine such passively collected anonymous information or personal information and/or information from various third party sources, including as described above, and may combine this anonymous information or personal information with other personal information collected from you to provide better service to website visitors and users, customise a website based on your preferences, compile and analyse statistics and trends, provide you with relevant advertising when you visit a Website or a third party Website, and otherwise administer and improve a Website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website, you consent to information about you being collected, compiled and used in this way.
The Media Precinct and other websites
36.        Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. The Media Precinct is not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.
37.        We may use third party advertisements on our Websites. All third party advertising, if paid for, is paid for by the relevant third party advertisers and are not recommendations or endorsements by The Media Precinct or any of its affiliates. The Media Precinct is not responsible for the content (including representations) of any third party advertisement on a website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties. 
User submissions
38.    The Media Precinct may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users, provide reviews for content, products and/or services or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others outside of our Websites. The Media Precinct is not responsible for the conduct of others who may read, collect and use this information.

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