The privacy of your personal information is afforded the highest level of importance by Solstice Media Pty Ltd (ACN 105 598 187).
Collection of Information
We will only collect personal information where it is reasonably necessary to do so for the conduct of our business. The kinds of personal information that we collect and hold may include:
- your name and birth date;
- your contact information, including postal and residential addresses, telephone and facsimile numbers, and email addresses;
- details of your superannuation fund; and
- details of your employer.
Any collection of personal information by us will be fair and lawful and will not be intrusive. Upon request you will be told the identity of the collecting entity, the purpose of the collection, details on how you can gain access to your personal information and any consequences of failing to give the information.
If it is reasonable and practical do so, we will collect personal information about you only from you. In the course of operating the business, however, it may be necessary to collect personal information from various external sources, including government agencies and other third parties such as advertisers, mailing lists, recruitment agencies, contractors and business partners. You authorise us to collect information from external sources as and when required.
If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information. We will not, however, make any such request to any third party in circumstances where it would not be practical to do so.
We may collect and hold other information, including:
- data relating to your activity on our websites via tracking technologies such as Google and cookies;
- the identity of your Internet browser, the type of operating system you use, your IP address and the domain name of your Internet service provider; and
- details of any survey responses you provide.
We may use this information for internal purposes, including administering our services, diagnosing problems, generating statistics and trends, and improving the quality of our products and services.
Your information may also be collected by Netratings Australia Pty Ltd via cookies and an online auditing system to assist us in gathering statistical information for the above purposes. Details of the use of your information by Netratings Australia Pty Ltd and how to opt-out are available here.
We will hold personal information as either physical records, records on our servers, and in some cases, records on third party servers, which may be located overseas.
Use and Disclosure of Information
In general, we will collect, hold, use and disclose personal information for the purposes of providing or offering goods and services to you, any purposes that you may reasonably expect, for any other purpose authorised by law, or for any other purposes disclosed to or authorised by you. This may include disclosures to organisations that provide us with technical and support services, and professional advice, such as solicitors, accountants and business advisors.
By providing us with personal information, you consent to us using your personal information for:
- providing you with news and information about our products and services;
- purposes necessary or incidental to the provision of our products and services;
- sending you marketing and promotional material that we believe you may be interested in, either from any of our related entities or a third party business which we consider may be of interest to you;
- personalising your experience with our products and services, for example, via connectivity with social media services;
- communicating with you, including by email, mail or telephone; and
- conducting competitions or promotions on behalf of us and selected third parties.
Where it is possible, we will use reasonable endeavours to de-identify your personal information before using it for these purposes. We will also, wherever possible, keep all personal information strictly confidential.
If you do not want to receive promotional material from us, please let us know.
A number of laws require the provision of personal information to third parties, including the Corporations Act 2001 (Cth). The precise information required to be provided will vary depending on the circumstances requiring disclosure of that information.
We may also use or disclose personal information about you to avoid, lessen or prevent a serious emergency or crime. If we use or disclose personal information about you in those circumstances we will make a written record of such use or disclosure.
Any disclosure that is required to be made to any third party will be made primarily for the purpose of providing or offering goods and services to you. If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.
Any personal information submitted via our online form may need to be processed by a third party. By submitting personal information via an online form, you consent to the disclosure of that information to a third party, which may be located overseas, for the sole purpose of processing the online form.
We will take reasonable steps to hold all hard copy and electronic records of your information in a secure manner to ensure that they are protected from misuse, interference and loss, and unauthorised access, modification or disclosure. We will destroy or de-identify your personal information once it is no longer needed for a valid purpose or required to be kept by law. Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure.
Data Access & Correction
You may request access to your personal information at any time by sending a written request to our Privacy Officer by mail at Solstice Media Pty Ltd, Ground Floor, 165 Grenfell Street, Adelaide SA 5000, or by email to firstname.lastname@example.org.
You do not need to provide a reason for your request. We may charge a small fee for providing access if it requires a significant amount of time to locate or collect your information or to present it in an appropriate form.
In rare circumstances, and only where it is permitted under the Act, we may not be able to provide you with access to your information. For example, we may refuse access where the requested access will have an unreasonable impact upon the privacy of others or where we are required by law to withhold the information.
We will take reasonable steps to ensure that the personal information we collect about you is accurate, up-to-date and complete, and ensure that the personal information we use or disclose is accurate, up-to-date, complete and relevant. If your personal information is out of date or incorrect, you may inform us of this and we will correct it for you.
If we are unable to provide you with access to your information, or make any amendments which you have requested, we will provide you with reasons for our refusal.
Where practicable, we will provide the option for you to deal with us anonymously or under a pseudonym. This option will not be available where we are required or authorised by law to deal with individuals who have identified themselves, or if we need to verify your identity in order to provide products or services to you.
Importantly, cookies do not need to identify the user or record any personal information. No attempt is made to identify you or your browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the service provider’s logs, or where your usage is causing technical issues for the Website that may need to be resolved and Solstice Media Pty Ltd needs to contact you. A notice will be posted on the Website if the Website attempts to identify individuals from their cookies unless that identification is required by law or to assist in law enforcement.
The default settings of most internet browsers allow cookies. However, users may change their browser settings to disallow cookies. Please note that some parts of the Website may not function fully for users that disallow cookies.
Third Party cookies
Some of the cookies stored on your computer belong to, and are managed, by third parties.
How to change your preferences
You have the right to decide whether to accept or block cookies that we use on our website. However, please be aware that if all cookies are blocked (particularly any essential cookies), the functionality of our website may be impaired.
You can exercise your cookie preferences by adjusting your browser settings. The links below set out information about how to change your browser settings for some of the most commonly used web browsers:
• Cookie settings in Internet Explorer
• Cookie settings in Firefox
• Cookie settings in Chrome
• Cookie settings in Safari web and iOS
You should be aware that most browsers automatically accept cookies.
Information for residents of the European Union
As set out above, The Lead South Australia’s website is unlikely to use any Cookies that store personally identifiable information. However, to the extent that any cookies placed by The Lead South Australia or a third party can uniquely identify a resident of the European Union, the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR) will be adhered to. In particular, we will ensure that:
• your consent is obtained prior to the setting of the cookies
• you can withdraw your consent at any time by changing the relevant settings;
• we document your consent and store it securely; and
• we delete your personal data upon request.
If you believe that we may have breached the Australian Privacy Principles, or failed to comply with this policy, you may make a written complaint addressed to:
Solstice Media Pty Ltd
Ground Floor, 165 Grenfell Street
ADELAIDE SA 5000
We take all complaints seriously, and will respond to your complaint within a reasonable period.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
Last updated: 22/01/2020