Privacy policy

In this privacy policy:

• "TPAL" means the business Trade Promotions and Lotteries Pty Ltd (ACN 601 297 330); and
• "We" and "us" refer to TPAL and "our" has a similar meaning.

We are subject to the National Privacy Principles in the Privacy Act 1988 (Cth).

Gaining access to information we hold about you

We will, on request, provide you with access to the personal information we hold about you unless there is an exception which applies under the Privacy Act 1988 (Cth.) such as where we have a legal duty of confidentiality or non-disclosure as mentioned above.

Your request to obtain access will be dealt with in a reasonable time. We may recover from you our reasonable cost of providing you with access.

If we refuse to provide you with access to the information, we will provide you with reasons for the refusal and inform you of any exceptions relied upon under the Privacy Act.

How to contact us

If you wish to gain access to your personal information or make a complaint about a breach of your privacy or if you have any query on how your personal information is collected or used or any other query relating to our privacy policy, please contact our Privacy Officer:

• Email: privacy@tpal.com.au
• Post:
  The Privacy Officer
  Trade Promotions and Lotteries Pty Ltd
  GPO Box 43
  Sydney NSW 2001
  

We will respond to your query or complaint as soon as possible.

How we collect your personal information

We generally collect your personal information directly from you. For example, we may collect personal information about you when you deal with us over the telephone, send us correspondence (whether by letter or email) subscribe electronically to our publications or when you have contact with us in person.

Generally, the type of personal information we collect about you includes your name, mailing address, telephone number and e-mail address. We may also collect sensitive information about you such as information about membership of a professional or trade association. We will only collect sensitive information in limited circumstances including where you have consented to it, the collection is required by law, the collection is necessary for the establishment, exercise or defence of a legal or equitable claim.

There may be occasions when we need to source personal information about you from a third party. For example, we may collect personal information from a company for whom you work, other organisations with whom you have any dealings, a credit reporting agency, an information service provider or from a publicly maintained record.

Keeping your personal information up-to-date

We take reasonable steps to ensure that your personal information is accurate, complete, and up-to-date whenever we collect or use it.

If any of the personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us immediately and we will take reasonable steps to correct this information or, if necessary, we will discuss alternative action with you.

Our disclosure statement

TPAL collects personal information for the following purposes:

• to provide you (if a customer) or your organisation with a product or service via our website;
• to receive services from you or the organisation which employs you;
• to advise you of developments, seminars and events and to undertake other marketing activities relating to the industry we operate.

If you do not provide the information requested, we may not be able either to provide you with appropriate product or service or to fulfil another applicable purpose of collection. In some circumstances, we collect personal information about you from a third party source. If we collect personal information about you in this way, we will take reasonable steps to contact you and inform you of this.

If you are our customer or are employed by, contracted to, or an agent to a customer of TPAL we may disclose your personal information to third party partners, only with your express or implied consent.

Sharing of your personal information

Except as described in this statement, we will not disclose your personal information outside of TPAL and its controlled subsidiaries and affiliates without your consent. By opting in to sharing your information with select TPAL partners, you consent to TPAL to share your personal information with select TPAL partners so that they can contact you about their products, services or offers. Other websites may instead give you a separate choice as to whether you wish to receive communications from TPAL partner's particular offering (without transferring your personal information to the third party).

Some TPAL services are co-branded with another company (partner). If you register to or use such a service, both TPAL privacy statement and the partner's privacy statement may be displayed. If so, both TPAL and the partner will receive information you provide such as on registration forms.

TPAL occasionally hires other companies (vendor) to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, hosting websites, processing transactions, or performing statistical analysis of our services. Those service providers will be permitted to obtain only the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose than for delivering the service to us in accordance with TPAL's instructions and policies. However, our vendors may use aggregate data for fraud detection to help improve their services. This helps them to more accurately detect fraudulent transactions.

We may access or disclose information about you, including the content of your communications, in order to:

• comply with the law or respond to lawful requests or legal process;
• protect the rights or property of TPAL or our customers, including the enforcement of our agreements or policies governing your use of the services; or
• act on a good faith belief that such access or disclosure is necessary to protect the personal safety of TPAL employees, customers or the public.

We may also disclose personal information as part of a corporate transaction such as a merger or sale of assets.

Your ability to edit and delete your account information and preferences

You can edit your account information, at any time.

New categories of communications may be added to the subscription preferences page from time to time. Users who register and visit this page can opt out of receiving any communications from these categories or they can unsubscribe by following instructions contained in the messages they receive.

We reserve the right to send you certain communications relating to the TPAL service, such as service announcements, product updates, administrative messages and our newsletter, that are considered part of your account, without offering you the opportunity to opt out of receiving them. You can delete your account by contacting us. Please note certain information may possibly remain in our archived records after your account has been deleted in accordance with this privacy policy.

How we use or disclose your personal information

We will use and disclose personal information for the primary purpose for which it was collected.

We may also use and disclose personal information for purposes related or ancillary to the main reasons we collect it, such as invoicing, reminder notices, provision of information concerning developments, invitations to seminars and other events, market research, to improve our products or services and communications and in respect of other services offered by us. We do not disclose personal information we collect to third parties for the purpose of allowing them to direct market their products and services.

We engage third party contractors to perform services for us which involve the contractor handling personal information we hold. For example, we engage third party contractors to store and archive our completed customer files.

Other people's information which you provide to us

If you provide personal information to us about someone else (such as one of your directors or employees or someone with whom you have dealings) you must ensure that you are entitled to disclose that information to us and that, without us taking any further steps required by privacy laws, we may collect, use and disclose such information for the purposes described in this privacy policy.

For example, you should take reasonable steps to ensure the individual concerned is aware of the various matters detailed in this privacy policy as those matters relate to that individual, including our identity, how to contact us, our purposes of collection, our information disclosure practices, the individual's right to obtain access to the information and the consequences for the individual if the information is not provided.

Our duty of confidentiality and obligations of non-disclosure

We have a duty to maintain the confidentiality of our customers' affairs, including personal information. Our duty of confidentiality applies except where disclosure of a customer's personal information is:

• with that customer's consent;
• compelled by law; or
• for the sole purpose of avoiding the probable commission or concealment of a felony.

Security of your personal information

We protect any personal information that we hold from misuse and loss. We also protect it from unauthorised access, modification and disclosure.

Your personal information may be stored either in hard copy documents or as electronic data in our information technology systems.

We maintain physical security over our paper and electronic data stores and premises, such as locks and security systems. We also maintain computer and network security; for example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to our computer system.

Changes to this privacy policy

We may amend this privacy policy from time to time by posting an updated version of this policy on our web sites therefore we recommend that you review it regularly for any changes.

Additional information

For further information about privacy issues and the protection of privacy, visit the Australian Information Commissioner's website at www.oaic.gov.au.