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This Privacy Policy sets out the approach
which Custom Carmats will take in relation to the treatment of Personal
Information. It includes information on how Custom Carmats collects, uses,
discloses and keeps secure, individuals' Personal Information. It also covers
how Custom Carmats makes the Personal Information it holds available for access
to and correction by the individual.
This policy has been drafted having regard
to Custom Carmats 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
1.1 Custom Carmats will only collect
Personal Information where the information is necessary for Custom Carmats 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.
1.2 Custom Carmats collects Personal Information primarily to supply customers
with the products and services ordered from it and its related companies.
Custom Carmats also collects and uses Personal Information for secondary
purposes including:
1.
billing and account management
2.
business planning and product development; and
3.
to provide individuals with information about
promotions, as well as the products and services of Custom Carmats affiliated
companies and other organisations.
4.
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.
1.3 Custom Carmats will not collect
Sensitive Information from individuals except with consent and only where it is
necessary for Custom Carmats to collect such information for an activity or
function.
1.4 Custom Carmats will not collect Personal
Information secretly or in an underhanded way.
1.5 Custom Carmats will take steps to ensure
that individuals on purchased lists are or have been notified of the
information as outlined at 1.3.
2.
Use
2.1 Custom Carmats 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.
2.2 Custom Carmats Uses Personal Information
primarily for the purposes listed in 1.2 above.
2.3 If Custom Carmats relies on the Direct
Marketing exception to Direct Market to individuals it will ensure that:
1.
the individual is clearly notified of their right to Opt Out
from further Direct Marketing;
2.
there is only one Use of the information before the Opt Out
right is given and this Use applies across all dStore
Related Bodies Corporate (if the information is shared between those Related
Bodies Corporate);
3.
the individual is given an Opt Out in all further instances of
Direct Marketing if they have not previously chosen to Opt Out; and
4.
if the individual Opts Out of all Direct
Marketing the Opt Out will be respected by Custom Carmats and all its Related
Bodies Corporate.
2.4 Custom Carmats will not use Sensitive
Information for Direct Marketing.
2.5 Custom Carmats 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.
2.6 Custom Carmats will not use Personal
Information without taking reasonable steps to ensure that the information is
accurate, complete and up to date.
3.
Disclosure
3.1 Custom Carmats 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.
3.2 Custom Carmats 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.
3.3 Custom Carmats 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.
3.4 Custom Carmats 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.
3.5 Custom Carmats may Disclose Personal
Information to law enforcement agencies, government agencies, courts or
external advisers where permitted or required by law.
3.6 Custom Carmats may Disclose Personal
Information to avoid an imminent threat to a person's life or to public safety.
3.7 If a Disclosure is not for a Primary
Purpose; is not for a related Secondary Purpose; or upfront consent has not
been obtained, Custom Carmats will not Disclose Personal Information otherwise
than in accordance with the exceptions set out at 3.1 to 3.6 above.
3.8 Custom Carmats does not generally sell
or share its customer lists on a commercial basis with third parties but if it
did, it would only do so if we had the appropriate consent of the individual
involved. If the consent provided is conditional, Custom Carmats will take
steps to ensure (by contract) that the use of its customer list by third
parties does not exceed the scope of the consent.
4.
Information Quality
4.1 Custom Carmats will review, on a regular
and ongoing basis, its collection and storage practices to ascertain how
improvements to accuracy can be achieved.
4.2 Custom Carmats 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
5.1 Custom Carmats requires employees and
contractors to perform their duties in a manner that is consistent with Custom
Carmats legal responsibilities in relation to privacy.
5.2 Custom Carmats 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
Custom Carmats who have a genuine "need to know" as well as
"right to know".
5.3 Custom Carmats 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
6.1 Custom Carmats will allow its records
containing Personal Information to be accessed by the individual concerned in
accordance with the Privacy Act.
6.2 Custom Carmats 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.
6.3 Individuals wishing to lodge a request
to access and/or correct their Personal Information should do so by contacting
Custom Carmats Customer Service, as per the details on the website.
6.4 Custom Carmats 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
7.1 Custom Carmats Customer Service
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 Custom Carmats Customer Service, as per the details
on the Custom Carmats website.
7.3 Custom Carmats websites will contain a
prominently displayed privacy statement and will include a copy of this Custom
Carmats Privacy Policy.
8.
Anonymous Transactions
8.1 Custom Carmats will not make it
mandatory for visitors to its web sites to provide Personal Information unless
such Personal Information is required to answer an inquiry or provide a
service. Custom Carmats may however request visitors to provide Personal
Information voluntarily to Custom Carmats (for example, as part of a
competition or questionnaire).
9.
Transferring Personal Information Overseas
9.1 Custom Carmats will take reasonable
steps to limit the amount of Personal Information it sends to unrelated
organisations overseas.
9.2 If Personal Information must be sent by
Custom Carmats overseas for sound business reasons, Custom Carmats will require
the overseas organisation receiving the information to provide a binding
undertaking that it will handle that information in accordance with the
National Privacy Principles, preferably as part of the services contract.
10.
Glossary
Collection Information means the information
outlined in 1.3 notified to individuals prior to, or as soon as practical
after, the collection of their Personal Information.
Direct Marketing means the marketing
of goods or services through means of communication including written, verbal
or electronic means. The goods or services which are marketed may be those of
Custom Carmats or a Related Body Corporate or those of an independent third
party organisation.
Disclosure generally means the
release of information outside Custom Carmats, including under a contract to
carry out an "outsourced function".
Health Information means:
1.
information or an opinion about:
1.
the health or a disability (at any time) of an individual; or
2.
an individual's expressed wishes about the future provision of
health services to him or her; or
3.
a health service provided or to be provided to an individual;
that is also personal information; or
2.
other personal information collected to provide or in providing
a health service; or
3.
other personal information about an
individual collected in connection with the donation; or intended donation by
the individual of his or her body parts or body substances.
Opt Out means an individual's expressed
request not to receive further Direct Marketing.
Custom Carmats means all companies in the
Custom Carmats group.
Personal Information means information or
an opinion (including information or an opinion forming part of a database),
whether true or not and whether recorded in a material form or not, about an
individual whose identity is apparent, or can reasonably be ascertained from
the information or opinion.
Primary Purpose is the dominant or
fundamental reason for information being collected in a particular transaction.
Reasonable Expectation means a reasonable
individual's expectation that their personal information might be Used or
Disclosed for the particular purpose.
Related Body Corporate means that where a
body corporate is:
o
a holding company of another body corporate;
o
a subsidiary of another body corporate; or
o
a subsidiary of a holding company of another body corporate,
the first mentioned body
corporate and the other body corporate are deemed to be related to each other.
Sensitive Information means:
1.
information or an opinion about an individual's:
1.
racial or ethnic origin; or
2.
political opinions; or
3.
membership of a political association; or
4.
religious beliefs or affiliations; or
5.
philosophical beliefs; or
6.
membership of a professional or trade association; or
7.
membership of a trade union; or
8.
sexual preferences or practices; or
9.
criminal record;
that is also personal information or
2.
Health Information about an individual.
Use means the handling of Personal Information
within Custom Carmats.
Contacting Custom Carmats
If
you require further information regarding Custom Carmats Privacy Policy, you
can contact Custom Carmats Customer Service through the contact us page on our
website.
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