The purpose of this Privacy Statement is to tell you what kind of information we may gather about you when you visit or contribute to our site or purchase off-line from us, how we may use that information, whether we disclose it to anyone, and the choices you have regarding our use of, and your ability to correct this information.
In this policy, "us", "we" or "our" means Virtual War Memorial Ltd (ACN 613 555 347) and its related bodies corporate.
This policy sets out:
• what is considered personal information;
• what personal information we collect and hold;
• how we collect, hold, use or disclose personal information;
• the purposes for which we collect personal information;
• what happens if we are not able to collect personal information;
• how to seek access to and correct your personal information;
• whether we disclose personal information outside Australia; and
• how to contact us.
We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and are strongly committed to protecting any personal information you disclose to us.
We may, from time to time, review and update this policy. All personal information held by us will be governed by the most recently updated policy.
2. What is personal information?
The term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include (but is not limited to) your name, age, gender, postcode and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card, direct debit or PayPal account information.
3. What personal information do we collect and hold?
We may collect the following types of personal information:
• mailing or street address (including post code);
• email address;
• telephone number;
• age or birth date;
• profession, occupation or job title;
• payment details, including credit card number, PayPal account details etc;
• details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
• any information that you contribute to our website, including images, addresses, occupation, involvement in armed conflicts or armed forces;
• any additional information relating to you that you provide to us directly through our website or indirectly through use of our website or online presence through our representatives or otherwise;
• information you provide to us through our customer centre or customer surveys; and
• any donations you may have given.
Our website uses a technology called 'cookies'. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer's hard drive to facilitate your shopping experience. The cookies used by us do not collect personal information and we do not combine information collected through cookies with other personal information to tell us who you are, your screen name or e-mail address. Credit card information is never stored in the cookie.
We may also collect anonymous data (which is not personal information) relating to your activity on our website (including IP addresses) via cookies, or we may collect information from you in response to a survey. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our products and services. To the extent this information does not constitute personal information because it does not identify you or anyone else, the Australian Privacy Principles do not apply and we may use this information for any purpose and by any means whatsoever.
5. How we collect personal information
We collect your personal information directly from you unless it is unreasonable or impractical to do so.
We do this in ways including:
• through your access and use of our website including material you contribute to the website;
• through someone else who has provided us with your information (e.g. a gift or voucher);
• during conversations between you and our representatives; and
• when you complete an application or purchase order.
We may also collect personal information from third parties including:
• third party companies such as credit reporting agencies, law enforcement agencies and other government entities; and
• contractors and business partners.
6. Why do we collect, hold, use, and disclose personal information?
The primary purpose for which we collect information about you is to enable us to perform our business activities and functions, to add material to the Virtual War Memorial Australia (VWMA), and to provide best possible quality of customer service. We collect, hold, use and disclose your personal information for the following purposes:
• to provide products and services to you;
• to process relevant payments relating to the provision of products and services;
• to provide you with news, information or advice about our existing and new products and services;
• to communicate with you including by email, mail or telephone;
• to manage and enhance our products and services;
• to personalise and customise your experience;
• to provide you with access to protected areas of our website;
• to conduct competitions or promotions;
• to verify your identity;
• to provide as part of business data to third parties if you have authorised us to do so;
• to conduct business processing functions for operation of our website or our business;
• for our administrative, marketing (including direct marketing), promotional, planning, product/service development, quality control and research purposes, or those of our contractors or external service providers;
• to solicit and process donations from you;
• to provide your updated personal information to us, our contractors or external service providers;
• to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and/or
• as required or permitted by any law (including the Privacy Act).
7. What happens if we can't collect your information?
If you do not provide us with the personal information described in this policy, some or all of the following may happen:
• we may not be able to provide you with the products or services you requested, either to the same standard, or at all (for example, if you do not register as a user of the website, you will not be able to access features or services that are reserved for registered users only);
• we may not be able to provide you with information about products and services that you may want; or
• we may be unable to tailor the content of our website to your preferences and your experience of our website may not be as enjoyable or useful.
8. How do we disclose your personal information?
We may disclose your personal information to:
• our employees, related bodies corporate, contractors or external service providers for the operation of our website or our business, fulfilling requests by you, and otherwise provide products and services to you, including without limitation, web hosting providers, IT systems administrators, mailing houses, newsagents, couriers, payment processors, photographic analysers, data entry service providers, electronic network administrators, debt collectors, and professional advisers such as accountants, solicitors, business advisors and consultants;
• our existing or potential agents, business partners or joint venture entities or partners;
• our sponsors, or promoters of any competition that we conduct or promote via our services;
• specific third parties authorised by you to receive information held by us;
• the police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator, for example, if we have reason to suspect that you have committed a breach of any of our terms and conditions, or have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary; or
• as required or permitted by any law (including the Privacy Act).
9. Direct marketing materials
We may send you direct marketing communications and information about products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS or email, in accordance with applicable marketing laws. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
In addition, at any time, you may opt-out of receiving marketing communications from us by contacting us (details below) or by using the opt-out facilities provided (e.g. an unsubscribe link).
10. Access and correction - personal data
If we hold your personal information we will where possible provide you with access to the information. We will take reasonable steps to correct the information so that it is accurate, complete and up to date, when informed of any errors in the information.
11. Complaints about privacy
If you have any complaints relating to privacy issues, please notify us and we will address them. While we accept no liability for any material on website linked to ours or information contributed to our website by third parties, we will investigate all complaints.
You can contact us at [email protected]
12. Disclosure of personal information outside of Australia
We may disclose personal information to our related bodies corporate and external service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
We may disclose your personal information to entities located outside of Australia, including the following:
• our data hosting and Cloud-based IT service providers; and
• other external service providers.
We will take all reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorised access, including by means of firewalls, password access, secure servers and encryption of credit card transactions.
If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.
Our website may contain links to other website operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.