Privacy Policy
This Privacy Policy sets out the approach which RedBox Hardware will take
in relation to the treatment of Personal Information. It includes information
on how RedBox Hardware collects, uses, discloses and keeps secure, individuals'
Personal Information. It also covers how RedBox Hardware makes the Personal
Information it holds available for access to and correction by the individual.
This policy has been drafted having regard to RedBox Hardware's
obligations under Australian privacy legislation.
1. COLLECTION
1.1 RedBox Hardware will only collect Personal Information where
the information is necessary for RedBox Hardware 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 RedBox Hardware collects Personal Information primarily to
supply customers with the products and services ordered from
it and its related companies.
RedBox Hardware also collects and uses Personal Information for secondary
purposes including:
- billing and account management
- business planning and product development; and
- To provide individuals with information about promotions,
as well as the products and services of RedBox Hardware
affiliated companies and other organisations.
- 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 RedBox Hardware will not collect Sensitive Information from individuals
except with consent and only where it is necessary for RedBox Hardware
to collect such information for an activity or function.
1.4 RedBox Hardware will not collect Personal Information secretly
or in an underhanded way.
1.5 RedBox Hardware 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 RedBox Hardware 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 RedBox Hardware Uses Personal Information primarily for the purposes
listed in 1.2 above.
2.3 If RedBox Hardware relies on the Direct Marketing exception
to Direct Market to individuals it will ensure that:
- the individual is clearly notified of their right to Opt Out from
further Direct Marketing;
- there is only one Use of the information before the Opt
Out right is given and this Use applies across all RedBox
Hardware Related Bodies Corporate (if the information is shared
between those Related
Bodies Corporate);
- the individual is given an Opt Out in all further instances
of Direct Marketing if they have not previously chosen to
Opt Out; and
- If the individual Opts Out of all Direct Marketing the
Opt Out will be respected by RedBox Hardware and all
its Related Bodies Corporate.
2.4 RedBox Hardware will not use Sensitive Information for Direct
Marketing.
2.5 RedBox Hardware 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 RedBox Hardware 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 RedBox Hardware may Disclose Personal Information to related
or unrelated third parties if consent has been obtained from the
individual.
3.2 RedBox Hardware 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 RedBox Hardware may Disclose Personal Information to unrelated
third parties to enable outsourcing of functions (such as billing,
customer relations management and order fulfilment), 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 RedBox Hardware 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 Australian
Privacy Legislation.
3.5 RedBox Hardware may Disclose Personal Information to law enforcement
agencies, government agencies, courts or external advisers where
permitted or required by law.
3.6 If a Disclosure is not for a Primary Purpose; is not for a related
Secondary Purpose; or upfront consent has not been obtained, RedBox
Hardware will not Disclose Personal Information otherwise than in
accordance with the
exceptions set out at 3.1 to 3.6 above.
3.7 RedBox Hardware does not sell or share its customer lists on
a commercial basis with third parties.
4. INFORMATION QUALITY
4.1 RedBox Hardware will review, on a regular and ongoing basis,
its collection and storage practices to ascertain how improvements
to accuracy can be achieved.
5. INFORMATION SECURITY
5.1 RedBox Hardware requires employees and contractors to perform
their duties in a manner that is consistent with RedBox Hardware's
legal responsibilities in relation to privacy.
5.2 RedBox Hardware 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 RedBox
Hardware who have
a genuine "need to know" as well as "right to know".
5.3 RedBox Hardware 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 RedBox Hardware will allow its records containing Personal Information
to be accessed by the individual concerned in accordance with Australian
Privacy Legislation.
6.2 RedBox Hardware will correct its records containing Personal
Information as soon as practically possible, at the request of the
individual concerned.
6.3 Individuals wishing to lodge a request to access and/or correct
their Personal Information should eithr through the facilities provided
on the website to do so or by contacting RedBox Hardware. RedBox
Hardware 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 RedBox Hardware General Manager 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
RedBox Hardware General Manager, as per the details on the RedBox
Hardware website.
7.3 RedBox Hardware websites will contain this privacy policy.
8. ANONYMOUS TRANSACTIONS
8.1 RedBox Hardware 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. RedBox Hardware
may however request visitors to provide Personal Information voluntarily
to RedBox
Hardware (for example, as part of a competition or questionnaire).
9. TRANSFERRING PERSONAL INFORMATION OVERSEAS
9.1 RedBox Hardware will not send Personal Information to unrelated
organisations overseas.
9.2 If Personal Information must be sent by RedBox Hardware overseas
for legal reasons, RedBox Hardware will require the overseas organisation
receiving the information to provide a binding undertaking that it
will handle that information in line with the Australian privacy
legislation, 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 RedBox Hardware
or a Related Body Corporate or those of an independent third party organisation.
Disclosure generally means the release of information outside RedBox
Hardware, including under a contract to carry out an "outsourced function".
Health Information means:
- information or an opinion about:
- i. the health or a disability (at any time) of an individual;
or
- an individual's expressed wishes about the future
provision of health services to him or her; or
- a health service provided or to be provided to an
individual; that is also personal information; or
- other personal information collected to provide or in
providing a health service; or
- 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.
RedBox Hardware means all companies owned wholly or partially
by RedBox Hardware.
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:
- a holding company of another body
corporate;
- a subsidiary of another body
corporate; or
- 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:
- information or an opinion about
an individual's:
- racial or ethnic origin;
or
- political opinions;
or
- membership
of a political
association; or
- religious
beliefs or
affiliations; or
- philosophical
beliefs;
or
- membership
of
a professional or trade association; or
- membership of a trade union;
or
- sexual preferences or practices;
or
- criminal record;
that is also personal information or
- Health Information
about an individual.
Use means the handling
of Personal
Information within RedBox Hardware.
Contacting RedBox
Hardware
If you require
further information
regarding RedBox Hardware's
Privacy Policy,
you can contact
RedBox Hardware.
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