CBM operates a number of offices throughout the world. Through our varied operations, we gather information for a variety of reasons, for example to enable us to improve the nature of the services we provide and to facilitate the development of future services.
We are committed to the protection of your PI and meeting the standards set out in the Privacy Act 1988 (Commonwealth) ("the Act") and the National Privacy Principles ("NPPs"). This policy sets out how we handle your PI and the rights and obligations that we both have in relation to that information.
1. COLLECTION OF INFORMATION
1.1 Why We Collect Personal Information
Generally we collect your PI to provide you with products and services and to administer our relationship with you. We also collect PI for marketing purposes and to provide you with information about our products and services (both our own and those of other companies) that may be of interest to you.
1.2 How We Collect Personal Information
We primarily collect PI directly from you through written, electronic and/or verbal means of communication when you interact with us for example when:
(a) you submit an entry into a trade promotion;
(b) you participate in our loyalty programs;
(c) you send us an email or post an entry on any of our websites;
(d) you purchase products from us by credit cards or otherwise.
2. USE AND DISCLOSURE
Your personal information may be used for a number purposes including but not limited to the following purposes :
(a) to provide you with our products or services;
(b) to administer our relationship with you;
(c) to facilitate the running of and your participation in trade promotions;
(d) to facilitate the running of and your participation in loyalty programs;
(e) to monitor activity on our websites, for the purpose of maintaining the security of those websites;
(f) to compile client databases to enable us to market goods and services more accurately;
(g) for internal administrative purposes, such as procedural assessments, risk management, staff training, accounting, billing, product and service reviews; and
(h) to identify and inform you about other products or services that may be of interest to you.
If you do not wish to receive marketing or other communications from us, please contact us on the details below so that we can update your preferences.
If you provide us with your mobile telephone number, email address, IM address or other such personal information, you authorise us to send you promotional messages related to our products and services and the products and services that we promote.
(a) third parties engaged by us to provide functions on our behalf such as processing credit card information, mailouts, debt collection, marketing research and advertising; and
(b) third parties authorised by you to receive PI held by us.
We may also disclose PI to unrelated third parties (for example, our professional advisers and government authorities or agencies) where that disclosure is reasonably required to obtain advice, prepare legal proceedings, investigate suspected improper conduct or wrong doing, to assist a lawful authority in the discharge of its duties and/or by law.
Where we hold promotions in conjunction with other companies, we will offer you the opportunity to be contacted by our promotions partner. We will not provide your PI to the promotions partner unless you have opted in to having such PI passed on.
To better protect your privacy, we impose strict requirements of security and confidentiality on all third parties as to how they handle your PI. Notwithstanding this, we cannot be held responsible for any misuse or unauthorised disclosure of your PI by these third parties.
3. DATA QUALITY
We take reasonable steps to ensure that the PI we collect, use or disclose is accurate, complete and up to date. If your PI is incorrect or changes, please contact us on the numbers below so that we can update your PI and continue providing you with our services.
4. DATA SECURITY
Your PI is stored in a number of secure computer storage facilities and paper based files, and in other records. We have taken precautions to ensure that your PI is protected from misuse, loss and unauthorised access, modification or disclosure.
Once we no longer need your PI, we take reasonable steps to de-identify your PI.
If you have any questions whatsoever on our handling of your PI or the kind of PI we hold about you please contact us on the number below and we will endeavour to assist you with your request.
6. ACCESS AND CORRECTION
You generally have the right to access your personal information and we will provide you with a copy of any personal information we hold on request. The NPPs set out some circumstances in which we are not required to provide you such access and if you ask for your PI and any of these circumstances apply, we will, if reasonable, agree with you on an intermediary which would allow sufficient access to your PI to meet your needs.
We may charge a fee for retrieving PI, in which case we will inform you of the fee in advance of providing the information.
As required by the NPPs, we do not collect or use Commonwealth government identifiers when interacting with you.
Where practical, you may deal with us on an anonymous basis however, because of the services we provide, if you do not provide us with your PI we may not be able to provide you with the requested product or service (for example, if we require your details in connection with a promotion we are running, we cannot provide you with an additional offering that is on offer should be unable to contact you).
9. OVERSEAS TRANSFERS OF INFORMATION
PI may be transferred to an Australian company, PX Webdesign (“PX”) which stores our online databases. PX does not have permission to use, sell, transfer or access PI in any way.
We will not send your information outside of Australia in any other circumstances, unless we obtain agreement from the recipient to protect your information in accordance with Australian privacy law including to abide by the terms of this policy or we have your consent.
10. SENSITIVE INFORMATION
Sensitive information includes information about your race or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation. We rarely ask for sensitive information, but may do so occasionally as part of a promotion or survey, for example. We will not require you to provide sensitive information unless:
(a) you have consented; or
(b) the collection of the information is specifically authorised or required by law.