- © 2019 I.M Advertising Pty Limited. All rights reserved in original content created by I.M Advertising Pty Limited.
- I.M Advertising Pty Limited may refer to third party material in this publication. I.M Advertising Pty Limited acknowledges that, if any material is subject to copyright, copyright remains vested in the third party whose material is featured in this publication. Any reproduction of such material by I.M Advertising Pty Limited is for the purposes of review only.
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PRIVACY COLLECTION STATEMENT (JUNE 2019)
I.M Advertising Pty Limited and its operating subsidiaries (ABN 98 108 292 324) (together, IM Advertising or We/we or Our/our or Us/us) is committed to respecting the privacy of your personal information and abiding by the Privacy Act 1988 and the Australian Privacy Principles.
- our online properties (here and after, each a “Website”), including:
- our websites, including but not limited to www.imab2b.com; www.imadvertising.com.au; www.imadigital.com.au; www.imavideoproduction.com.au; www.thepunchagency.com;
- any related IM Advertising or client websites, social media pages, internal website or intranet and any IM Advertising or client mobile or tablet applications;
- personal information provided to us by our clients, customers and service providers and personal information collected by us on behalf of our clients and customers as a result of the provision of professional services to our clients and customers;
- through physical and other ad-hoc channels of collecting personal information in relation to events, activations, or promotions (such as through paper forms or tablets), data providers and other personal information data owners or organisations that share personal information in circumstances where it is lawful and/or consent has been obtained for such organisations to do so; and
- any other means through which an individual provides personal information to IM Advertising and its clients, including either physically or electronically.
Contact us about privacy matters
Personal information is important to IM Advertising
- IM Advertising is committed to safeguarding personal privacy. It recognises that you have a right to control how your personal information is collected and used. Providing personal information is an act of trust and it is taken seriously. Unless given consent to do otherwise. IM Advertising will only collect and use personal information as set out below.
Anonymity and pseudonymity
- Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our Collection Channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the information identified below. It will not be practicable to deal with you on an anonymous or pseudonymous basis when we wish to send you direct marketing materials or need to provide you with goods or services requested by you.
Kinds of Personal Information that IM Advertising Collects and Holds
- Personal information that may be requested or collected by us includes:
- contact information such as your full name, date of birth, current and valid email address, telephone number, mobile telephone number, residential address and postcode;
- information about your preferences, interests, opinions, feedback and experiences with our products or services or the products and services of our clients;
- financial details, if you have provided them to us, such as your bank account, credit card, Paypal or other online payment system details (where you purchase any products or services from us);
- recruitment and employment details;
- more detailed contact preferences;
- social media account details including usernames and information published on your social media accounts;
- information regarding your personal and professional interests and your networks;
- information regarding your relationship history with IM Advertising and its clients;
- if you are an employee or prospective employee, information about your employment history and future plans, and documents relating to your employment;
- information about your education and qualifications, skills and experience;
- enquiry and complaint details;
- information about your personal preferences and opinions;
- location information;
- information about your usage of and experience with our products or services (including our Websites) client’s products or services, or third party products or services listed on a Website. This information is requested and collected for reasons including in order to tailor our subsequent communications to you and continuously improve our products and services;
- products owned and operated in your business; and
- any other personal information requested or required by a Collection Channel.
- When you use a Website, we may also collect personal information about you in the following general categories:
- device information: we may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network; and
- other information: we may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a Website.
- We do not collect sensitive information (or “special categories” of information under the GDPR).
How IM Advertising Collects and Holds Personal Information
- For individuals in the European Union, IM Advertising may also rely on the lawful bases of contract and legitimate interest. That is, where you enter into a contract with us, IM Advertising will process your personal information because it is necessary for the performance of that contract with you. In some circumstances, such as fraud prevention, IM Advertising may also have a legitimate commercial interest in processing your personal information that is not outweighed by your interests, rights and freedoms. IM Advertising may also request your explicit consent to process your personal data from time to time for various purposes.
Active Information Collection
- Personal information may be collected (and combined) via our Collection Channels if you:
- sign-up and/or register to become a member of any Collection Channel, or provide your details to us, our clients or our sponsors via any Collection Channel;
- subscribe to any newsletters, updates, alerts or news and media releases, or request launch or event information or information about our products or services or other information services as well as third party products or services;
- complete and submit any forms or surveys to us, our clients or our sponsors, either physically or electronically;
- conspicuously publish or provide on request your personal information to IM Advertising;
- contact us, our clients or our sponsors directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
- provide your personal information to a third party and consent to that third party sharing your personal information with personal information data brokers (which would include IM Advertising), or if it was otherwise lawful for such third party to share your personal information with personal information data providers brokers (which would include IM Advertising);
- participate in any competitions, offers, promotions or marketing activities of IM Advertising, or our clients or service providers;
- provide us with your personal information including opinions and preferences when we contact you by telephone;
- participate in any surveys or questionnaires;
- interact with a Website for a specific purpose;
- interact with or browse a Website generally;
- Personal information is requested in order to facilitate or provide you with certain content, products or services, and information about such content, products or services (including the uploading, access to, and receipt of content on a Website); marketing materials; newsletters; electronic newsletters (e-newsletters); news and media releases; launch information, and also to advise you of other IM Advertising client or third party products, services, offers, competitions or events which may be of interest. No one is obligated to provide personal information. However, failure to do so may result in IM Advertising or its clients being unable to facilitate or provide you with certain content, products or services; products or services information; upcoming promotion, competition, offer or event information; or accept competition entries (where applicable).
- We may also obtain your personal information from legitimate third party sources including list brokers, personal information data providers, referral agents, our clients, social media organisations and other data providers or organisations that share personal information data in circumstances where it is lawful and/or you have given permission for them to do so, including our service providers and retail partners.
- Personal information will not be collected by any person who is known by IM Advertising to be under the age of fifteen (15) without the consent of a parent or legal guardian or as has been provided to us lawfully by third parties, including our clients. Persons under age fifteen (15) may only use our Websites and provide personal information with the involvement and consent of a parent or legal guardian.
Passive Information Collection
- As with many commercial websites, we may also collect information which tells us about visitors to our Websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a Website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally, you consent to the collection of such information where it is personal information.
- Our Websites may use and combine such passively collected anonymous information or personal information from various third party sources, including as described in paragraph 14, to provide better service to Website visitors and users, customise a Website based on your preferences, compile and analyse statistics and trends, and otherwise administer and improve a Website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website, you consent to information about you being collected, compiled and used in this way.
- For more information about cookies and how you can opt out, you can visit http://www.youronlinechoices.com.au/.
Purposes for which IM Advertising collects, holds, uses and discloses personal information
- Personal information collected will be collected, used and/or disclosed for the following primary purposes:
Providing services to IM Advertising’s clients
- to fulfil obligations in respect of any contract between you and IM Advertising, or you and our clients, or IM Advertising and our clients;
- to render services related to IM Advertising or our clients, including providing our professional services to our clients;
- to provide services to personal information data providers with whom IM Advertising has a contractual relationship, including providing IM Advertising’s list brokerage services;
- to provide services to IM Advertising’s clients and customers, including providing IM Advertising’s list brokerage services; and
- to enable IM Advertising’s clients and customers to provide goods, services, information, upcoming opportunity, promotion, event, product information or other content to individuals whose personal information is collected.
- to carry out any purchases you make and otherwise manage our or our clients’ (or list providers) commercial and trading relationship with you including identifying you in our system and contacting you, invoicing you correctly, sending you our products and/or lists and to address your expectations of us in respect of how we conduct our business;
- to ensure that your personal information remains up-to-date and complete;
- to provide you with information about your accounts, transactions, content, services and products involving IM Advertising or IM Advertising’s clients;
- to facilitate payments from you;
- to contact you, including sending you any technical, administrative or legal notices relevant to IM Advertising, our clients or a Website;
- to otherwise maintain our relationship with you or the relationship between you and our clients, including providing after sales services and responding to enquiries;
Special offers, marketing and advertising
- to provide you with early access to new releases, exclusive events, special offers, newsletters, events, promotions and activations of IM Advertising, its clients or its trusted partners;
- to otherwise market to you (with direct marketing materials), via any medium including mail, telephone, commercial electronic messages (such as SMS, MMS, instant messaging, email, social media, mobile applications), or any other form of electronic, emerging, digital or conventional communications channel;
- to provide you with relevant and targeted advertising, including when you browse third party websites;
IM Advertising’ Website
- to maintain the functionality of a Website, including customising the Website based on your preferences; providing information to you relating to the content available on a Website; to improve the Website and system administration;
Improving offerings to you and research
- to better understand and meet your needs and interests, to enable us to improve the nature of the goods and services we or our clients provide, to more accurately market our or our clients’ goods and services, and to research our or our clients’ customers;
- to obtain opinions or comments about products and/or services and to conduct other research and development;
- to record and analyse statistical and de-identified data for analysis including marketing analysis;
- to conduct market research including identifying likeminded individuals including through third party vendors such as Facebook or other social media websites;
- for any further purposes stated in a particular Collection Channel;
- to undertake recruitment for IM Advertising (if applicable);
- for any other purpose as may be deemed reasonably necessary by IM Advertising in the circumstances;
- as needed to satisfy any law, regulation or legal request; to protect the rights or property of IM Advertising, IM Advertising’s clients’, or any member of the public; to protect the integrity of Websites; to fulfil your requests; or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.
- For the purposes described above, personal information may be shared with the entities below including their directors, servants and agents and related bodies corporate:
- IM Advertising group companies,
- IM Advertising promotional partners,
- IM Advertising clients,
- contractors and service providers engaged by IM Advertising:
- technical service providers, such as mail carriers, personal information data providers, hosting providers, IT companies and communications agencies; and
- IM Advertising sponsors and other trusted service providers, promotional partners and third parties (and their directors, servants and agents).
- Failure to provide personal information may result in us being unable to respond to your enquiry, consider your employment application or render services to you, or in IM Advertising, its clients or its sponsors being unable to provide you with certain content, information, upcoming promotion, event or product information and/or accept promotion entries (where applicable).
- In order to operate a Website or deliver a service, or for the purposes described above, personal information may also be shared with our group companies, our clients, our sponsors, selected service providers and/or other trusted third parties either in Australia or overseas countries which may include but is not limited to the United States.
- IM Advertising employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by IM Advertising. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. IM Advertising will not be held responsible for events arising from unauthorised access to personal information except to the extent required by the relevant privacy laws.
- Our group companies, selected technical service providers and/or other trusted third parties may be engaged to perform a variety of functions, such as legal and accounting services, data storage, fulfilling orders, conducting market research, processing credit card payments, assisting with promotions and providing technical services for ours or our clients’ Websites. These companies may have access to personal information if needed to perform such functions. Where you are a client or customer of IM Advertising, your credit card details are only used to facilitate your purchases. They are not used for any other purpose and will never be supplied to a third party other than IM Advertising, IM Advertising’s client from whom you are purchasing products or services or our relevant service provider. If you are a business we trade with, we may disclose your information to debt recovery agents or credit reporting bodies if necessary.
- For individuals in the EU, please note that the recipients of your personal information may be located in countries in which the privacy or data protection laws differ from those of the European Union, and which are not the subject of an adequacy decision by the European Commission. For recipients of your personal information in Australia, appropriate or suitable safeguards over your personal data will be put in place, including through the standard data protection contract clauses approved by the European Commission. Please contact our Privacy Officer for more information.
Contact by IM Advertising
- IM Advertising (and their directors, servants and agents), our promotional partners, our clients, our sponsors or trusted third parties (and other selected service providers and other non-I.M Advertising Pty Limited companies or professionals) either in Australia or overseas, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the primary purposes for collection of personal information as stated above.
- Despite removing your name from the database from receiving future advertising and marketing information, we may send you non-commercial “Administrative Emails”. Administrative Emails relate to a user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular user account. If you do not wish to receive such communications, you may remove your name from the database by utilising the functional unsubscribe facility.
Automated decision making
- IM Advertising does not rely solely on automated decision making (including profiling) for any decisions that will have a significant effect on you.
Ability of others to view information
- We may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users, provide reviews for content, products and/or services or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others outside of our Websites. We are not responsible for the conduct of others who may read, collect and use this information.
Your right of access
- You have a number of rights under the Australian Privacy Law and the GDPR. These include:
- (access) to request access to your personal information from us, in a commonly used electronic format. On a case by case basis, IM Advertising may determine that it is not legally required to give an individual access to personal information, in which case IM Advertising will provide you with a written notice of its refusal to provide access;
- (correction) to request that we correct your personal information;
- (withdrawing consent) to withdraw your consent for us to use your personal information. Please note that you can also opt-out of online marketing communications at any time by using the unsubscribe feature in each electronic commercial message; and
- (complaint) to complain about a breach of the Australian Privacy Principles.
- If you are an individual in the EU, you have additional rights under the GDPR that you can exercise against the “controller” of your data. Where we are the controller of your data, your rights include:
- (access) to request that we transfer your personal information to another service provider of your choosing;
- (erasure) to request that we erase your personal data. All reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in us being unable to facilitate or provide you with information about certain services (including the uploading, access to, and receipt of content on a website or the IM Advertising Application, and purchase transactions undertaken on a website);
- (objection and restriction) in some circumstances, to object to the use of your personal data by us and request that we restrict our use of your personal information; and
- (complaint) to lodge a complaint in relation to our processing of your personal data with a data protection supervisory authority under the GDPR.
Changing and deleting the information we have about you
- In the same way, a request may be made to delete personal information, and all reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in us being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), other content, services or product information, upcoming promotion, competition or event information, and/or provide certain content, goods or services.
- We are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this policy.
- Storage and security of personal information IM Advertising takes appropriate security measures to keep personal information secure and to prevent unauthorised access, disclosure, modification, misuse, interference or loss of personal information. IM Advertising, its employees and its subcontractors are obliged to respect the confidentiality of any personal information held by IM Advertising.
Disclosure of personal information to overseas recipients
- In some cases, we may disclose your personal information to overseas recipients, including, but not limited to, your professional information and contact details. Our employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by us. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. We will not be held responsible for events arising from unauthorised access to personal information.
Links to other websites
- Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Inclusion of such links cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. We are not responsible, nor do we accept any liability, for the conduct of companies linked to our Websites.
- We may use third party advertisements on our Websites. All third party advertisements are not recommendations or endorsements by us or any of our affiliates. We are not responsible for the content (including representations) of any third party advertisement on a Website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties.
- IM Advertising may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users, provide reviews for content, products and/or services or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others outside of our Websites. IM Advertising is not responsible for the conduct of others who may read, collect and use this information.
Sale of the Company
Problems or queries
- For individuals in Australia:
Mail: Privacy Officer
Address: I.M Advertising Pty Limited
PO Box 1 Macarthur Square LPO,
Campbelltown, NSW 2560, Australia
Telephone: (02) 4627 8011
- Please allow 30 days for this request to be processed. On receipt of your query, problem or complaint a review will be conducted, and findings will be communicated to you where required. If you do not receive a satisfactory response to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at http://www.oaic.gov.au/about-us/contact-us-page, or, for individuals in the EU, to the data protection supervisory authority in your country.
Last updated 19 June 2019