PRIVACY COLLECTION STATEMENT
Reasons for collection
We collect your personal information for various reasons, including to:
• provide you with news, event details, ticket deals and other special offers
• market products and services to you; and
• comply with our legal, moral and social obligations.
By providing us with your personal information, you give us your express consent to exchange your personal information with our related bodies corporate, agents and contractors (such as call centres and third-party suppliers), some of whom reside outside of Australia. If you provide us with personal information about another person (such as an additional family 46 of 55 member), please make sure that you tell that person about this privacy statement. To access any personal information that we hold about you, call us on 03 9825 0900.
If you no longer want to receive communications from us, you may request to opt-out from receiving such marketing communication by contacting us on 03 9825 0900 or by emailing us at email@example.com. We will not charge you for any request to opt-out and will process your request as soon as reasonably practicable.
PRIVACY LAWS THAT APPLY TO THE EMERSON CLUB
The Emerson Club is required to comply with the Privacy Act 1988 (Cth) and is bound by the Australian Privacy Principles (‘APPs’) set out in that Act. The APPs establish minimum standards for the collection, use, disclosure and handling of personal information. They apply to personal information in any form, including electronic and digital form. The APPs can be accessed at the website of the office of the Australian Information Commissioner: www.privacy.gov.au.
The Emerson is also subject to other laws relating to the protection of personal information. Amongst other things, The Emerson’s direct marketing activities must also comply with the Do Not Call Register Act 2006 (Cth) and the Spam Act 2010 (Cth)
• ‘Privacy Law’ refers to any legislative or other legal requirement that applies to The Emerson collection, use, disclosure or handling of personal information.
• ‘Personal information’ means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in material form or not. Personal information includes sensitive information; and
• ‘Sensitive information’ means personal information about an individual’s racial or ethnic origin, political opinions or memberships, religious beliefs or affiliations, philosophical beliefs, professional or trade association/union memberships, sexual preferences and practices or criminal record. It also includes information about a person’s health and medical history.
If it is reasonably necessary in the circumstances, The Emerson may also collect sensitive information.
WHY DOES THE EMERSON COLLECT PERSONAL INFORMATION?
The Emerson collects personal information to carry out its functions, including to provide you with requested products and services, news, special offers and other information that you requested as well as to facilitate the provisions of marketing and promotional services that may be of interest to you.
The Emerson uses personal information only for the purposes for which it was provided and for directly related purposes(unless otherwise required by or authorised under law). We may state a more specific purpose at the point we collect your information. If you do not provide us with the information that we request, we may not be able to provide you with our products or services.
WHOSE PERSONAL INFORMATION DOES THE EMERSON CLUB COLLECT?
The Emerson collects or holds personal information about individuals who are:
• People we think may be interested in our products and services as well as people who have expressed interest in obtaining or learning more about those products and services
• People who previously requested The Emerson products or services or who are followers of The Emerson.
The Emerson may collect personal information about associates of its customers, such as family members, employees, or agents. For example, we may collect personal information about nominated or authorised representatives, or the holder of a credit card that is used to pay for a service(s).
The Emerson may in rare circumstances collect personal information from people who are under the age of 18. If The Emerson does this, The Emerson may also collect personal information about the parent or guardian of that person.
The Emerson also collects personal information about all the individuals who are involved in providing us with products and services. This includes:
• Staff of The Emerson entities and associated clubs or venue
• Service providers and suppliers, agents and affiliates, and their staff.
CAN YOU DEAL WITH THE EMERSON CLUB WITHOUT IDENTIFYING YOURSELF?
In some limited situations, individuals may be able to deal with The Emerson anonymously or using a pseudonym. For example, if you make a general inquiry, or want to make a complaint (unless the inquiry or complaint relates to a particular person). However, if you do not wish to be identified we may not be able to provide the information or assistance you require.
WHAT PERSONAL INFORMATION DOES THE EMERSON CLUB USUALLY COLLECT?
The Emerson collects a wide range of personal information about its customers, but the type and amount of information collected depends on the context. However, The Emerson always seeks to ensure that it only collects the personal information that is necessary for the purposes of its business activities. The Emerson needs to collect basic identifying and contact information for all subscribers. This will usually include name, date of birth, email address, telephone number(s) and residential address.
The Emerson also collects information about purchasing patterns, consumer preferences and attitudes from prospective attendees for marketing purposes, including to analyse markets, develop marketing strategies and to identify and develop products and services that may be of interest to its customers.
We also collect information about the way our customers use The Emerson products and services. This includes information about:
• product and service usage;
• club affiliations;
• event participation;
• responses to offers made and/or promotions run by The Emerson or its affiliates; and inquiries and complaints.
• We collect information about our employees and prospective employees for the purpose of making employment decisions and managing our staff. We also collect information about suppliers, service providers, agents and affiliates, and their staff, for the purposes of conducting our day-to-day business activities.
HOW DOES THE EMERSON COLLECT PERSONAL INFORMATION?
Information may be collected when you:
• subscribe to any guest list
• subscribe to any publication of The Emerson, including electronic publications and social media.
• provide details to The Emerson in an application, consent form, competition, survey, feedback form or incident report.
• enter personal information into, or agree to having your personal information entered, one of The Emerson online systems or by completing a form at an activation site
• contact The Emerson via email, telephone or mail or engage with The Emerson via social media; participate in any program, activity, competition, or event run by The Emerson
• purchase a service(s) from The Emerson or an authorised agent or licensee.
• are elected or appointed to the Board or a committee of The Emerson; or apply for employment or a volunteer position with The Emerson.
• Personal information may also be collected where The Emerson is required to do so by law (for education, child protection, work health and safety laws, charitable collections, medical treatment or other legislation in Australia).
If you do not provide some or all the information that we request from you, this may affect our ability to communicate with you or provide the requested products or services.
By not providing requested information, you may jeopardise your ability to participate in programs or competitions or apply for employment or volunteer positions with The Emerson. If it is impracticable for The Emerson to deal with you as a result of you not providing the requested information or consent, we may refuse to do so.
Collection from third parties
In some circumstances, The Emerson collects information from other third parties.
Information storage and protection
The Emerson stores information in different ways, including in paper and electronic form.
Much of the information we collect from and about our subscribers and from or about people who register their interest in The Emerson is added to one of our databases. When your information is entered into our database, the information may be combined or linked with other information held about you.
Security of your personal information is important to The Emerson. The Emerson has taken steps to protect the information we hold from misuse, loss, unauthorised access, modification or disclosure. Some of the security measures we use includes strict confidentiality requirements of our employees, contractors, agents, volunteers, service providers, suppliers, security measures for system access, and security measures for our website and venue.
WHAT INFORMATION WILL THE EMERSON GIVE YOU WHEN IT COLLECTS YOUR PERSONAL INFORMATION?
The Emerson is required by Privacy Law to take reasonable steps to ensure that you are made aware of certain information when it collects personal information about you. For example, we are required to:
tell you which entity you are dealing with and how to contact it;
make sure you are aware that we have collected the information (if we collect it from a third party without your knowledge);
• identify any law that authorises or requires collection of the information;
For example: when personal information is collected via The Emerson website or any affiliate website that The Emerson may advertise on, a statement is displayed or a link provided to a statement that sets out the information we are required to provide;
a statement containing the required information is printed on the sign-up page of most of the standard forms we use to collect personal information; and when you deal with us on the telephone, this information is given to you by the operator or via a recorded message. If we collect personal information about you from a third party, we take reasonable steps to ensure you receive the information we are required to provide. However, we may do this by requiring the third party to provide the information, rather than us providing the information to you directly. We may also include information about our collection of personal information in notices and other documents we give to our customers, followers, and members.
THE EMERSON’S USE AND DISCLOSURE OF PERSONAL INFORMATION
• verify your identity.
• complete background checks.
• research, develop, run, administer, and market competitions, programs, activities and other events relating to our services and offerings.
• research, develop and market products, services, merchandise, and special offers made available by us and third parties, licensees, suppliers, and sponsors.
• respond to emergency situations involving or requiring medical treatment.
• keep you informed of news and information relating to various events, activities, and opportunities via various mediums.
The Emerson may use health information to ensure that programs we operate are run safely and in accordance with any special health needs participants may require. Health information may also be kept for insurance purposes. In addition, we may use pre-identified health information and other sensitive information to carry out research, to prepare submissions to government, or to plan events and activities.
The Emerson may disclose your personal information to a range of organisations which include, but are not limited to:
• other partnered venues in Australia.
• companies we engage to carry out functions and activities on The Emerson Club’s behalf, including direct marketing.
• our professional advisers, including our accountants, auditors and lawyers;
• relevant bodies; and
• in other circumstances permitted by law.
In some circumstances personal information may also be disclosed outside of Australia. In such circumstances, we will use our best endeavours to ensure such parties are subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are suitably similar to the Australian Privacy Principles.
We will use non-sensitive personal information to provide better services and for marketing purposes (including disclosure of such information to service providers).
If you do not wish to receive e-mail, SMS or posted offers from us, you may opt-out by using the link provided. Alternatively, you may advise us at any time by contacting us via the contact details set out in this policy.
In addition, The Emerson may also disclose your personal information:
• with your express or implied consent;
• when required or authorised by law;
• to an enforcement body when reasonably necessary; or
• to lessen or prevent a threat to an individual or public health or safety.
The Emerson website
When you visit our website, our systems may record certain information about your use of the site, including the web pages visited and the time and date of their visit as well as the IP address visited from. We use this information to help analyse and improve the performance of The Emerson website.
Websites linked to The Emerson website are not subject to our privacy standards, policies or procedures. We cannot take any responsibility for the collection, use, disclosure or security of any personal information that you provide to a third-party website.
HOW DOES THE EMERSON PROTECT YOUR PERSONAL INFORMATION?
The Emerson recognises the importance of protecting your personal information and of ensuring that it is complete, accurate, up-to-date and relevant. The Emerson will take all reasonable steps to ensure that the personal information it collects, uses or discloses is accurate, complete and up-to-date. However, we rely on the accuracy of personal information as provided to us both directly and indirectly.
Our staff are trained to properly handle the different types of information they receive, particularly sensitive information. We have quality assurance measures in place to monitor calls to ensure that our processes are being followed. While some of the personal information we collect is held in hardcopy form, most personal information is stored in electronic databases.
We have extensive processes in place to ensure that our information systems and files are kept secure from unauthorised access and interference.
CAN YOU ACCESS OR CORRECT PERSONAL INFORMATION THE EMERSON HOLDS ABOUT YOU?
We encourage you to regularly review and update your personal information. If you would like to access the personal information that we hold about you, please let us know by making a request via the contact details set out below. We will respond to your request for access within a reasonable period. If you find that the personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us immediately and we will correct it.
RESOLVING PRIVACY ISSUES AND COMPLAINTS
Any issues or complaints in relation to the collection, use, disclosure, quality, security of and access to your personal information may be made to The Emerson in one of the following ways:
By telephone on 03 9825 0900.
The Emerson, 143-145 Commercial Road
SOUTH YARRA VIC 3141
By email to firstname.lastname@example.org
We will respond to your complaint within a reasonable period and try to resolve your complaint for you. If we are unable to resolve your complaint or you are unhappy with the outcome, you can contact the Office of Australian Information Commissioner via its enquiries line 1300 363 992 or website http://www.oaic.gov.au/ to lodge a complaint.
For further information on The Emerson’s management of personal information, please contact The Emerson.