At Global Retail Brands Australia Pty Ltd ACN 006 348 205 (“we” “us”) your privacy is important to us. We are committed to protecting your privacy when managing your personal information. We have policies and procedures to ensure that all personal information is handled carefully and securely in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (“Privacy Act”) .
Collection of information
The types of information that we collect from you will depend on the circumstances of collection and on the service that we are providing to you.
The type of personal information collected will be directly related to the specified purpose it has been collected for. How much of your personal information that you choose to disclose to us is completely up to you. The only way we know something about you personally is if you provide it to us. However, failure to provide certain information may result in us being unable to provide you with the relevant product or service. We will make you aware of the purpose for which we collect the personal information and, where possible, the consequences of not providing it at the time of collection.
We do not generally collect sensitive information as defined under the Privacy Act, such as racial or ethnicity information, political opinions or associations, criminal records or health information. However, subject to obtaining your prior consent, we may collect sensitive information from you in the course of considering an application for employment or an application for a franchise.
Where unsolicited information is received by us (such as through our Facebook page) we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information under the APPs. If it would not be permitted for us to collect the information, we will destroy the information or ensure it is de-identified as soon as practicable. Otherwise, we may retain the information in accordance with the terms of this policy.
We may also collect information about visitors to our website(s). For example, we may collect:
However, we do not collect information about the identity of the visitors unless they voluntarily provide that information.
Method of collection
Personal information will only be collected through lawful and fair means and not in an unreasonably intrusive way.
We collect your personal information when you deal with us directly, including via our website(s) or our Facebook page, via forms or correspondence (ie by mail or email), over the phone or in person.
We may also collect personal information through our related bodies corporate and our third party service providers (such as data relating to survey responses) so that we may provide a better or more relevant product to you.
Use of information
Use of personal information
We will use the personal information you have chosen to provide us for the purpose for which you provided it or a related secondary purpose which you would reasonably expect. We will not use it for any other purpose without your consent, unless permitted or required by law.
Generally, we will use your personal information for the following purposes:
We will only use your personal information for the purpose of direct marketing activities where we have obtained your consent to do so, or in circumstances where we have collected the information directly from you and you would reasonably expect that your personal information would be used or disclosed for this purpose. We may also share your personal information with our related entities and our franchisee network, so that they can provide you directly with marketing material about their products and services.
We will provide you with the opportunity to “opt out” of receiving marketing materials at the time of collection and/or at any time afterwards by either unsubscribing from the email service or contacting our Privacy Officer via the contact details provided below.
Use of anonymous information
We gather anonymous information to:
There will be occasions where it will be necessary for us to disclose your personal information to third parties.
We may disclose your personal information to:
Transfer of information outside Australia
Otherwise than stated above, we do not disclose personal information that you may give us to any organisation or person outside of us unless you have authorised us to do so.
No sale of personal information
Under no circumstances will we sell or receive payment for licensing or disclosing your personal information.
The security of your information is important to us. We operate secure data networks that are designed to protect your privacy and security. When we have collected information about you it cannot be seen or modified by anyone else. We have implemented generally acceptable standards of technology and operational security to ensure personal information (in both physical and electronic form) is protected against loss, misuse, interference and unauthorized access.
Only authorized personnel and contractors are provided access to personal information and have agreed to ensure the confidentiality of this information. Reasonable steps are taken to destroy or permanently de-identify any personal information that is no longer required.
We review and update our security measures in light of current technologies. You should however be aware that the internet is not a secure environment and information sent via the internet (including email) cannot be guaranteed to be totally secure.
Data quality, access and correction
If you are a subscriber to one of our online services or products or loyalty programs, you may access your personal information by accessing your subscriber/account details via the relevant facility on our websites.
Otherwise, you may at any time, request access to personal information that we hold about you by making a request to our Privacy Officer at the address or email address below.
We will endeavour to process any requests for access to personal information within a reasonable period of time. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested, or providing you with a summary of the information held. If we need to deny your request for access we will let you know why and inform you how you may lodge a complaint regarding this decision. Generally this will only be in cases where providing access would be unlawful or is subject to a potential legal claim or proceeding.
We may charge a nominal fee for supplying personal information.
We will try to ensure that all information we collect, use or disclose about you is accurate, complete, up-to-date and relevant to the service being provided. If you are a subscriber to one of our online services or products, you may change your personal information by accessing your subscriber/account details via the relevant facility on our website(s).
Otherwise, if you discover or suspect that there is an error or information is missing, please forward your request for correction to our Privacy Officer in writing at the address or email address below. Our Privacy Officer will consider your request and as soon as practicable manage the correction of your personal information and will update you in writing. If your correction request is refused, our Privacy Officer will provide you within a reasonable period of time the reasons for such refusal and inform you of the complaint process (see below).
Complaints about privacy and our complaint handling procedure
If you have any complaints relating to the management of your personal information or if you believe there has been a breach of the APPs by us, please forward your complaint in writing to our Privacy Officer at the address or email address below.
Our Privacy Officer will consider the complaint and advise you of their decision in writing within a reasonable time from receipt of the complaint. If our Privacy Officer decides that there has been a breach of the APPs, s/he will endeavour to ensure that the breach is rectified within 30 days from the date of the decision and will update you in writing. If the breach has not been rectified within 30 days, then our Privacy Officer will inform our Managing Director in order to resolve the matter.
If you are still not satisfied after lodging a complaint with us and giving us a reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner by:
Phone: 1300 363 992 (local call cost, but calls from mobile and pay phones may incur higher charges). If calling from overseas (including Norfolk Island): +61 2 9284 9749 TTY: 1800 620 241 (this number is dedicated to the hearing impaired only, no voice calls.) TIS: Translating and Interpreting Service: 131 450 (If you don’t speak English or English is your second language and you need assistance and ask for the Office of the Australian Information Commissioner)
Post: GPO Box 2999 Canberra ACT 2601
Fax: +61 2 9284 9666
Contact Privacy Officer
Please contact our Privacy Officer on the contact details below if you would like to:
Post: Privacy Officer, Global Retail Brands Australia Pty Ltd, Level 2 425 St Kilda Road Melbourne VIC 3004
Telephone: 1300 136 936
Facsimile: (03) 9863 2380
“Personal information” has the same meaning as in the Privacy Act.
“Website(s)” refers to all websites which are owned, operated or under the control of us including www.baccarat.com.au.