Privacy Policy
Compco Retail Marketing Pty Ltd ABN: 95 627 560 285 trading as Compco Digital of PO BOX 3325 Tamarama NSW 2026. (The Company or We/we or Our/our or Us/us) is committed to respecting the privacy of your personal information.
This Privacy Policy is available free of charge and explains our policy for dealing with personal information that we collect through the following channels (here and after, the Collection Channels):
our online properties (here and after, each a “Website”), including:
our websites, including, but not limited to, compcodigital.com
any of our related websites, social media pages, internal websites, applications; and
any other means through which an individual provides personal information to The Company, including either physically or electronically; and
any other means through which we lawfully collect personal information about you.
You may contact us with any queries you may have in respect of this Privacy Policy or your personal information by contacting The Company’s privacy officer via email: info@compcodigital.com or mail: 18/198 Young Street, Waterloo NSW 2017
PROTECTING YOUR PERSONAL INFORMATION IS IMPORTANT TO US
1. We are committed to safeguarding personal privacy. We recognise that you have a right to control how your personal information is collected and used. Providing personal information is an act of trust and it is taken seriously. Unless given consent to do otherwise, we will only collect and use personal information as set out below.
2. Throughout this Privacy Policy, we refer to your 'personal information', which 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 a material form or not. Your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address and workplace contact details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences.
3. The Company has developed and implemented its Privacy Policy with respect to personal information to reflect world best practice on privacy policies. These principles meet and exceed the requirements of the Privacy Act 1988 (Cth) (as amended) and the 13 Australian Privacy Principles.
4. In order to keep up with changing legislation and best practice, we may revise this Privacy Policy at any time without notice. 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.
5. 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. 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.
ANONYMITY AND PSEUDONYMITY
6. Where practicable, we 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 information identified below. 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.
Kinds of Personal Information that The Company Collects and Holds
7. Personal information that may be requested includes, but is not limited to:
a.contact information such as your full name, date of birth, telephone number, mobile telephone number, current and valid email address, residential address and postcode;
b.more detailed contact preferences;
c. your gender;
d.location information;
e. your occupation and information regarding your professional history and professional interests;
f. information regarding your education and qualifications;
g. information regarding your personal interests and interesting and relevant information about you;
h. financial details including your bank account or PayPal details;
i. your online behaviour and interests based on your online browsing activity;
j. demographic information such as age group, preferences and interests;
k. information about your preferences, interests, and experiences with our products or services. This information is collected in order to tailor our communications to you and continuously improve our products and services;
l. information about your experience with our products or services or third party products or services listed on a Website;
m. 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 Company and used for the purposes set out in this policy (which may include using their details for marketing purposes); and
n. any other personal information which 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).
8. When you use a Website, we may also collect personal information about you in the following general categories:
a. usage and preference information: we collect information about how you interact with a 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;
b. 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
c. 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.
How The Company Collects and Holds Personal Information
9. We will only collect or monitor any personal information about you with your consent including as provided in this Privacy Policy 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.
Active Information Collection
10. Personal information may be collected (and combined) via our Collection Channels if you:
a. 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;
b. sign-up and/or register to become a member of any Collection Channel;
c. submit any content to or participate in any way via a Collection Channel, including engaging with other users or taking part in campaigns or offers;
d. 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;
e. complete and submit any forms or applications to us;
f. contact us 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 offers, promotions, competitions, rewards or marketing activities;
h. interact with a Website for a specific purpose; or
i. interact with or browse a Website generally.
11. Personal information is requested in order to allow you to participate in a Collection Channel, to facilitate or provide you with certain content, products or services, and information about such content, products or services (including offers made available via our Collection Channels), marketing materials (including direct marketing materials), newsletters, electronic newsletters (e-newsletters), news and media releases / launch information, and also to advise you of other The Company or third party opportunities and products, services, offers, competitions or promotions which may be of interest. No one is obligated to provide personal information. However, failure to do so may result in you being unable to participate in a Collection Channel and The Company being unable facilitate or provide you with certain content, products or services, products or services information, upcoming opportunities and promotion, competition, offer or event information or accept competition entries or other content from you (where applicable).
12. We may also obtain your personal information from legitimate third party sources and platforms including social media channels, marketing companies, targeting companies, list brokers 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. For example:
a. we may use services from other companies that enable us to derive a general geographic area based on your IP address in order to customise certain services to your geographic area.
b. we may obtain third party information relating to your advertisement interaction and viewing data, such as ad click-through rates and information about how many times you viewed a particular advertisement.
13. To customise your user experience on our Websites we provide you with the opportunity to connect, access and/or interact with third-party social networking services, such as Facebook and Twitter. When you connect through these third-party social networking services, you are authorising The Company to access and use certain information from your social network profile. Of course, you can cancel this service at any time by deleting The Company from your social network account.
Children
14. The collection of personal information is neither intended for, nor directed to, persons who are under the age of sixteen (16) years old. Personal information will not be collected by any person who is known by The Company to be under the age of sixteen (16) without the consent of a parent or legal guardian. Persons under age sixteen (16) may only use our Websites with the involvement and consent of a parent or legal guardian.
Passive Information Collection
15. As with many commercial websites, we 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. When you receive newsletters or promotional e-mails from The Company, we may use web beacons (described below), customised links or similar technologies to determine whether the e-mail has been opened and which links you click in order to provide you with more focused e-mail communications or other information.
16. 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). This is 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. 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.
17. 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.
18. For more information about cookies and how you can opt out, you can visit http://www.youronlinechoices.com.au/.
Purposes for which The Company collects, holds, uses and discloses personal information
19. Personal information collected will be used for the following primary purposes:
a. For the purposes stated in a privacy collection statement on a particular Collection Channel.
b. To maintain the functionality of a Website, including the provision of information to you relating to the content available on the Website and e-commerce transactions conducted via the Website.
c. To send you any technical, administrative or legal notices important to our Websites.
d. To allow you to create an account, sign in and use the functionality of a particular Collection Channel.
e. To allow you to respond to and participate in offers and competitions.
f. To conduct competitions or promotions and communicate offers either for us or third parties.
g. For internal record keeping including site usage and administration of our products and services.
h. To facilitate payments to you via a Collection Channel.
i. To provide you with information about your transactions, content, services and products.
j. to provide direct marketing materials, events, offers, competitions and promotions in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email) or any other form of electronic, emerging, digital or conventional communications channel.
k. To provide you with relevant advertising when you use our Websites or those of a third party.
l. To render services related to our company (such as after sales services and enquiries).
m. To provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages.
n. To respond to customer enquiries, complaints and complaints handling.
o. To improve Website and system administration.
p. To obtain opinions or comments about products and/or services and to conduct other research and development.
q. To verify your identity.
r. To investigate complaints made by you or if we have reason to believe that you are in breach of our Terms or otherwise engaged in unlawful activity.
s. To record statistical data for marketing analysis and to conduct market research.
t. To share personal information with our group companies, our promotional partners, trusted brands using a particular Collection Channel and their related bodies corporate and agents, and other trusted third parties in the manner described below.
u. Any other purpose as may be deemed reasonably necessary by The Company in the circumstances.
20. For the purposes described above, personal information may be shared with The Company group companies, The Company promotional partners and their related bodies corporate, and other trusted third parties (and their directors, servants and agents) either in Australia or overseas. Failure to provide personal information may result in The Company being unable to provide you with certain content, information, upcoming opportunity, promotion, offer, event or product information and/or accept content and promotion entries (where applicable).
21. In order to operate a Website or deliver a service (including for example, processing of credit card payments), personal information may also be shared with The Company group companies, selected service providers and their related bodies corporate, and/or other trusted third parties either in Australia or overseas countries. The Company group companies, selected service providers and/or other trusted third parties may be engaged by The Company to perform a variety of functions, such as email systems providers, legal and accounting services, data storage, fulfilling orders, conducting market research, processing credit card payments, assisting with promotions or offers and providing technical services for our Websites. These companies may have access to personal information if needed to perform such functions.
22. We recognise the trust with which you provide personal information, and except as stated in this Privacy Policy or as is otherwise lawful, such information will not be used or disclosed for any other purposes without consent. However, The Company 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 Company, any member of the The Company group, 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.
Contact by The Company
23. The Company and its group companies (and their directors, servants and agents), The Company promotional partners and clients and their related bodies corporate or trusted third parties and other selected service providers 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.
24. The Company does not send advertising or marketing information without obtaining prior consent, for example the consent contained within this Privacy Policy, or as is otherwise lawful. If you receive communications from The Company which you do not wish to receive, you may remove your name from the database in the manner indicated in the communication, including by utilising the functional unsubscribe/opt-out facility (if the communication is via commercial electronic message) or by contacting The Company at the contact details in this Privacy Policy. Please allow 30 days for this request to be processed.
25. Despite removing your name from the database from receiving future advertising and marketing information, The Company may send you non-commercial “Administrative Emails”. Administrative Emails relate to a The Company user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular The Company user account. If you do not wish to receive such communications from The Company, you may remove your name from the database by utilising the functional unsubscribe facility.
Ability of others to view information
26. The Company may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users, utilise functionalities that allow you to post content to your own social media channels, or interact with 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 either on our Websites or outside of our Websites. The Company is not responsible for the conduct of others who may read, collect and use this information.
Your right of access
27. You have the right to access and review your personal information that may be recorded on the The Company database. Information may be reviewed by contacting The Company’s privacy officer at the contact details contained in this Privacy Policy. Please allow 30 days for this request to be processed.
28. On a case by case basis The Company may determine that it is not required to give an individual access to personal information to the extent that it is lawful for The Company to do so. If such a determination is made then The Company will provide you with a written notice.
29. Where you are seeking information held on electronic file, or where you are seeking hard copies of personal information, we reserve the right to charge reasonable handling/ postage fees as appropriate.
30. With some personal information that may be stored, for example where it is held on program tapes, it is not practical to provide this information to you without charging an appropriate fee as we deem reasonable in those circumstances.
Changing and deleting the information we have about you
31. Information contained on the database may be amended, or your preferences for contact from us changed, by contacting The Company’s privacy officer at the contact details contained in this Privacy Policy. Please allow 30 days for this request to be processed.
32. In the same way, a request may be made to delete personal information, and all reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in us being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), other content, services or product information, upcoming promotion, competition or event information, and/or provide certain content, goods or services.
33. We are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this policy.
Storage and security of personal information
34. The Company will endeavour to take all reasonable steps to keep secure any personal information recorded and to keep this information accurate, up to date, complete and relevant. We 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.
Disclosure of personal information to overseas recipients
35. In some cases, The Company may disclose your personal information to overseas recipients. The Company employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by The Company. 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 Company will not be held responsible for events arising from unauthorised access to personal information.
The Company and links to 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 Company 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 Company or any of its affiliates. The Company 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.
Related The Company Websites
38. All Websites operated by The Company will adhere to this Privacy Policy. The policies on the Websites of some members of the The Company group may vary, however, because of local customs, practices or laws.
Sale of the Company
39. If The Company 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.
Problems or queries
40. If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled and/or disclosed your personal information, please contact our privacy officer via one of the following channels:
Address: The Privacy Officer, PO BOX 3325 Tamarama NSW 2026.
Telephone: 1800 002 099
Email: info@compcodigital.com
Please allow 30 days for this request to be processed. If you do not receive a satisfactory response from The Company 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 http://www.oaic.gov.au/about-us/contact-us-page.