We are committed to protecting and maintaining your privacy and we are bound by the Australian Privacy Principles (APPs) and Privacy Act 1988 (Cth) (Privacy Act). As part of our business operations, we may collect your personal information. This Privacy Policy describes the type of personal information we may collect and how we use, hold and disclose this personal information. This Privacy Policy is in addition to the general Guidelines governing our digital services and should be read in conjunction with such Guidelines. If your personal information is being collected via our digital services, Umbrella News will be the entity listed by the digital service as the copyright owner and operator of the service. If your personal information is being collected offline e.g. by phone or in-person, the relevant collecting entity will be made known to you as part of the collection notice given to you in connection with that activity. When used in this policy, the term ‘personal information’ has the meaning given to that term in the Privacy 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, address and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card, direct debit or PayPal account information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
The type of personal information Umbrella News collects will vary. We only collect personal information that we need for our business activities, or which is volunteered to us. In general, the type of personal information we collect and hold could include (but is not limited to) your name, address (postal and email), contact details, geographic location (including your suburb or post code), gender, date of birth, activity, photograph, payment details, drivers licence (where necessary to verify your identity) and transaction details relating to your use, enquiry or purchase of our products and services and any preferences you tell us about. We may collect your personal information via our websites, applications, chatbots and other digital services or over the phone, when you email or write to us, when you subscribe to our services or when you attend an event. In order to access some of our services and products, you will be asked to register with us by providing us with certain information about you which we refer to in this Privacy Policy as your subscription.
We may access information, including personal information, about you from third-party sources and platforms (such as social networking sites, databases, recruitment platforms such as LinkedIn and Seek, online marketing companies, agents or representatives we have engaged via our digital services, Microsoft Products, third party digital services and data supply companies) and supplement the information we collect with information obtained from those third party sources. When you connect with us through social networking services, you will be able to see the social sharing habits of your friends and connections and participate seamlessly in our social capabilities, including commenting, live blogging, reactions, ratings, gaming mechanics and sharing content. You can connect us to your third party social networking service by downloading an application and signing into the application. By connecting with us through these third-party social networking services, you are authorising us to access and use certain information from your social network profile.
We only use or disclose personal information for the primary purpose for which we have collected it, or for another related secondary purpose, unless you have provided your consent for us to use it for another purpose. We may use or disclose your personal information for the following primary purposes:
We also collect other information and data, such as anonymous data that we collect via your interaction with our digital services and third party digital services (where we provide digital analytics tools or deliver advertisements) using tracking technologies such as cookies and web beacons (this is described in further detail below). This information and data may not be considered personal information under the Privacy Act. This information and data may be used by us internally and/or provided by us to third parties including our partners, clients and service providers for purposes that may include, without limitation, providing you with more relevant advertising, preparing audience insights, customer research, campaign analysis, conducting launch surveys and modelling. We will not provide any personal information to an advertiser or any other third party other than in accordance with the terms of our Privacy Policy without your express consent. However, to the extent that anonymous user data does not constitute personal information, we are entitled to deal with that information in any manner we see fit. You expressly acknowledge and agree that information including your personal information may be shared within Umbrella News and with the third parties referred to in this Privacy Policy for use by those third parties for the purposes disclosed in this Privacy Policy. What about sensitive information? We do not generally collect sensitive information as that term is used in the Privacy Act. This term applies to information such as your racial or ethnic origin, membership of political bodies, religion or trade unions, sexual preferences or activities, state of health or medical history and criminal record. However, in some instances, sensitive information might be disclosed during the course of your interaction with us or during the course of interaction of others acting on your behalf with us or others acting on our behalf with you. If we hold any sensitive information about you, that information will only be used and disclosed by us if you have consented to such use and disclosure (your provision of that information will be taken to be consent but will only be used and disclosed for the purpose that it was provided by you).
In certain contexts when we collect information from you, you may be asked to ‘subscribe’ to consent to us using or disclosing your personal information. We do not provide your personal information to other organisations for the purpose of direct marketing unless expressly authorised by you. 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, telephone, SMS or email, in compliance with applicable marketing laws, such as the Spam Act 2004 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
You will be given the opportunity to ‘unsubscribe’ from receiving communications from us or from third parties that send communications to you in accordance with this Privacy Policy. If you receive communications purporting to be connected with us or our services that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any applicable law, please contact us.
We understand that the security of your personal information is important. It is our policy to ensure that all of our employees understand and take reasonable steps to keep your personal information secure and only use it in accordance with this Privacy Policy. Once collected, we may hold your personal information in a number of different formats, including (but not limited to) software programs (located both onsite and offsite, including in the cloud), databases, filing systems, in offsite backup storage and in other similar technology. We take all reasonable steps to protect your personal information (and your anonymous usage data) and to keep it secure from loss, unauthorised access, modification, disclosure, interference or other misuse and we have appropriate controls in place to limit who can view, access and/or use your personal information and anonymous usage data.
We collect anonymous usage data about your browsing activity on Umbrella News via various tracking technologies (for example, via cookies, tags, pixels). Our third party service providers may also collect anonymous usage data on the terms of their privacy policies which will be disclosed to you where relevant. This anonymous usage data may be used to identify your device on third party digital services where we have an arrangement in place to serve ads on those third party digital services. We may also collect anonymous usage data from third party digital services. One of the reasons we collect usage data is to display to you more relevant advertisements or content at Umbrella News. Tracking technologies contain information that can later be read by a web server in the domain that issued the tracking technology to anonymously identify your device. You have the ability to accept or decline tracking technologies.
Many of the digital services we offer are supported by advertising. We may display advertisements on our digital services and on the digital services offered by our advertising partners. We place tracking technologies on your device when you interact with our digital websites and apps and this anonymous data may be used to group you into relevant audience segments so that we can deliver more relevant advertising to you. We may also use the tracking technologies to recognise your device each time we display an advertisement to your device. We are able to compile information over time about where you, or others who are using your device, saw and/or clicked on the advertisements we display. We may also associate this information with your visit, purchase or other activity on participating advertiser’s digital services in order to display relevant advertisements or to determine the effectiveness of the advertisements. Advertisers may also embed their own tracking technologies in their advertisements on our digital services. Our third party service providers may also embed tracking technologies on our digital services to assist them to perform services for us. We encourage advertisers and such third party service providers to have a privacy policy that outlines their data collection activities and usage. Please refer to such third party privacy policies for more information.
When we display interest-based advertising, we take a number of steps designed to protect your privacy. We store content consumption data (eg page views) used for ad targeting separately from your contact information or other data that directly identifies you. We use interest-based advertising to make the ads you see on our network more relevant to you. Online advertisements on our digital services are served by ad servers and exchanges and/or by our other third party service providers to whom we may from time to time outsource the procurement of advertising. These companies may offer you a way to opt in or opt-out of ad targeting based on their tracking technologies.You can also manage certain tracking technologies in your web browser privacy settings. What about my privacy as a journalist? As we are in the media industry, the APPs do not apply to acts done or practices engaged in by us in the course of journalism as we are committed to other journalistic standards dealing with privacy. Specifically:
(a) Under the Privacy Act, you have the right to request access to the personal information which we hold about you. If you wish to exercise your right under the Privacy Act to seek access to the personal information that we hold about you, we ask that you contact us. If you make an access request, we will require you to verify your identity before we provide you with any access. (b) We will endeavour to acknowledge your request for access within 7 days, and to provide you with the access to which you are legally entitled within 30 days of the date of receipt of your request. We will notify you if we consider it will take longer than 30 days to provide you with access. If you seek access to records held by us which are not current records, we may need to contact you to discuss your request and it may take a longer period of time to locate these records. If we are not legally required to provide access to the personal information requested and we exercise our discretion not to provide that information, we will let you know our reasons for doing so.
We endeavour to ensure that the personal information we hold is accurate, complete and up-to-date. You have the right to ask us to correct information about you which is inaccurate, incomplete, out of date, not relevant or misleading.
We may, from time to time, review and update this Privacy Policy to take account of new laws, technologies and changes to our business and operations. All personal information held by us will be governed by our most recent Privacy Policy which will always be available on our digital services. By using our digital services, you are deemed to have agreed to the terms of our Privacy Policy and you should therefore ensure to review our Privacy Policy regularly to keep abreast of any changes that may have been made.
We do all we reasonably can do to ensure your data is collected, used and held securely in accordance with industry standards. If at any time we become aware of unauthorised access to or disclosure of personal information held by us and we consider this is likely to result in serious harm to any individual to whom the information relates we will follow the data breach notification requirements under applicable law including to notify the individual involved and the relevant regulator.
If you are based in the European Union or California, there are specific regulations that apply in relation to the collection, processing and storing of your personal information by organisations covered by those regulations. To the extent that we are legally required to comply with those regulations in relation to any personal information and/or anonymous usage data we collect, process, disclose or store about you, we will comply with those regulations.
If you have any questions regarding this Privacy Policy, complaints regarding how we handle your personal information or our tracking and targeting policies or if you would like to make an access request, please contact us.
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