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This Privacy Policy sets out the approach that Broadway on the Mall will take in relation to the treatment of Personal Information. It includes information on how Broadway on the Mall collects, uses, discloses and keeps secure, individuals' Personal Information. This policy has been drafted having regard to Broadway on the Mall obligations under the Privacy Act 1988 (including the new National Privacy Principles) (the Privacy Act). This Policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.
1. COLLECTION
Broadway on the Mall will only collect Personal Information where the information is necessary for it to perform one or more of its functions or activities. In this context, "collect" means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
Broadway on the Mall collects Personal Information primarily to supply customers with the products and services ordered from it and its related companies. It also collects and uses Personal Information for secondary purposes including:
I) billing and account management
ii) business planning and product development; and
iii) to provide individuals with information about promotions, as well as the products and services of The Wintergarden affiliated companies and other organisations.
iv) to enhance the online shopping experience by displaying products and/or services that match the personal preferences of individuals based on their previous website browsing history and/or buying activity.
Broadway on the Mall will not collect Sensitive Information from individuals except with consent and only where it is necessary for Broadway on the Mall to collect such information for an activity or function.
Broadway on the Mall will not collect Personal Information secretly or in an underhanded way.
Broadway on the Mall will take steps to ensure that individuals on purchased lists are or have been notified.
2. USE
Broadway on the Mall will obtain an individual's consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual's Reasonable Expectations.
Broadway on the Mall uses Personal Information primarily for the purposes listed above.
If Broadway on the Mall relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:
i) the individual is clearly notified of their right to Opt Out from further Direct Marketing;
ii) there is only one Use of the information before the Opt Out right is given;
iii) the individual is given an Opt Out in all further instances of Direct Marketing if they have not previously chosen to Opt Out; and
iv) if the individual Opts Out of all Direct Marketing the Opt Out will be respected by Broadway on the Mall.
Broadway on the Mall will not use Sensitive Information for Direct Marketing.
Broadway on the Mall may use Personal Information to avoid an imminent threat to a person's life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
Broadway on the Mall will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
3. DISCLOSURE
Broadway on the Mall may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual. This will include obtaining the individual's consent for Disclosures made under the credit reporting requirements of the Privacy Act.
Broadway on the Mall may Disclose Personal Information between Related Bodies Corporate. Where information is Disclosed to such a Related Body Corporate, that Related Body Corporate is bound by the original Primary Purpose for which the information was collected.
Broadway on the Mall may Disclose Personal Information to unrelated third parties to enable outsourcing of functions (such as billing, customer relations management and order fulfillment), where that is Disclosure or Use for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual's Reasonable Expectations.
Broadway on the Mall will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
Broadway on the Mall may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.
Broadway on the Mall may Disclose Personal Information to avoid an imminent threat to a person's life or to public safety.
If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, Broadway on the Mall will not Disclose Personal Information otherwise than in accordance with the exceptions set out above.
Broadway on the Mall does not sell or share its customer lists on a commercial basis with third parties.
4. INFORMATION QUALITY
Broadway on the Mall will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
Broadway on the Mall will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years from the date of the last customer interaction, unless the law requires otherwise.
5. INFORMATION SECURITY
Broadway on the Mall requires employees and contractors to perform their duties in a manner that is consistent with its legal responsibilities in relation to privacy.
Broadway on the Mall will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Broadway on the Mall who have a genuine "need to know" as well as "right to know".
Broadway on the Mall will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6. ACCESS AND CORRECTION
Broadway on the Mall will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
Broadway on the Mall will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting Broadway on the Mall centre management, as per the details on the website.
Broadway on the Mall can charge a fee for processing an access request but will generally not do so unless the request is complex or is resource intensive.
7. OPENNESS
Broadway on the Mall representatives will be the first point of contact for inquiries about privacy issues. Individuals wishing to make an inquiry or complaint regarding privacy, should do so by contacting Broadway on the Mall centre management, as per the details on the website.
The Broadway on the Mall website will contain a prominently displayed privacy statement and will include a copy of this Privacy Policy.
8. ANONYMOUS TRANSACTIONS
Broadway on the Mall will not make it mandatory for visitors to its website to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. Broadway on the Mall may however request visitors to provide Personal Information voluntarily to Broadway on the Mall (for example, as part of a competition or questionnaire).
Broadway on the Mall is concerned to ensure that your Internet experience is a safe and enjoyable one. If you have any questions or comments about this Privacy Statement you can contact Broadway on the Mall on:
- Telephone: (07) 3229 5233
- By email: info@broadwayonthemall.com.au
- By Fax: (07) 3229 5166
- By mail: Level M, 170 Queen Street, Brisbane QLD 4000
This Privacy Policy may change from time to time. Any changes will be highlighted in this area from time to time. This policy was last updated on 14th June 2007
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