Effective Date: 19 February 2021
Tracks Media Pty Limited and its affiliated companies and websites (“Tracks Media”, “our”, “we”, ”us”) are committed to protecting your privacy. Please read this policy carefully as it describes the way in which we handle and collect your personal information. This applies to all personally identifiable information we receive, such as your name, address and telephone number.
We take this stance not just to fulfil our legislative obligations under the Privacy Act 1988 (“the Act”), but also because we value your trust and our ongoing relationship. You have no obligation to provide any personal information however if you choose to withhold your personal information we may not be able to provide the products or services that depend on the collection and use of your information.
This policy describes how we will abide by the Australian Privacy Principles (“APPs”) that form part of the Act.
1. What Personal Information Do We Gather About You?
When you use Tracks Media Services by, among other actions, ordering a subscription or other product, providing registration details, setting newsletter preferences, browsing our sites, completing a survey, entering a contest or otherwise interacting with Tracks Media Services, we gather personal information. Personal information is information that identifies you as an individual or relates to an identifiable individual. Several different types of personal information can be gathered when you interact with Tracks Media Services, depending on the type of product or service being used. Collection of personal information is necessary to delivering you the Tracks Media Services or to enhance your customer experience.
We and our service providers collect personal information in a variety of ways, including:
A) Through Tracks Media Services
i. Registration: When you register for a Tracks Media Service, we collect personal information. See below “From Other Sources” for more information about linking your Facebook or Google Accounts. Registration to an event, conference or digital resources requires that you complete a form that will include, at a minimum, your name and email address. Registration when you purchase a magazine or digital subscription.
ii. Billing: To subscribe to a Tracks Media Service or enable payment via the Tracks Media Services, we collect and use your name, address, telephone number, email address, credit or debit card information and other billing information.
iii. User-Generated Content and Public Activities (Including Comments and Reader Reviews): We offer you opportunities to engage in public activities on our websites and other Tracks Media Services. “Public activities” are any actions you take on Tracks Media Services that are designed to be visible to other users, including comments, recommendations, reader reviews, ratings or any other items that you submit. If you choose to engage in public activities, you should be aware that any personal information you submit can be read, collected and used by other users of these services. We are not responsible for the personal information you choose to submit in the course of your public activities and we have no responsibility to publish, take down, remove or edit any of your public activities or submissions (except as required by applicable laws). For more information, read the “Use of the Tracks Media sites and the Community Areas” section of the Terms & Conditions.
iv. Competitions, Promotions and Special Offers: We collect personal information, such as your name, address, age and email, from you when you participate in competitions, promotions or special offers.
v. Reader Surveys and Market Research: We and our service providers collect personal information from you through voluntary surveys or feedback programs conducted via the Tracks Media Services, through our service providers’ platforms, by phone, by mail or during in-person interviews or events. We will ask you for your consent to the processing of information at the point of collection. We also conduct similar research for advertisers.
vi. Loyalty Programs: When you interact with our loyalty programs and answer questionnaires, we collect personal information about you.
vii. Contact With Our Call Centres. We collect personal information from you in non-digital contexts, including, for example, when you place an order over the phone or contact customer service.
viii. Application for Employment and Internship. We collect personal information from you such as your name, date of birth, address, and email.
B) From Other Sources
i. Publicly available databases, including privately-held marketing and data analytics resources. For example, we may receive demographic information (age, sex, household income, job industry and job title) from these sources.
ii. Joint marketing and third-parties, when they share the information with us.
2. What Do We Do With The Personal Information We Collect About You?
We collect, use or otherwise process personal information as allowed under applicable law, including where based on one or more of the following:
- The consent you provide to us at the point of collection of your personal information;
- The performance of the contract we have with you;
- The compliance of a legal obligation to which we are subject; or
- The legitimate interests of Tracks Media, a third-party or yourself. It means that there are good reasons for the processing of your personal information and measures are taken to minimise the impact on your privacy rights and interests. Legitimate interest also references our use of your data in ways you would reasonably expect and that have a minimal privacy impact. We have a legitimate interest in collecting and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within Tracks Media; and (3) to prevent fraud.
A) Provide the Tracks Media Services You Request.
We use the information we gather about you to enable your use of Tracks Media Services and fulfil your requests for certain products and services, such as providing the Tracks Media Services’ functionality to you, arranging access to your registered account, providing you with customer service, responding to your inquiries, requests, questions, suggestions, compliments or complaints, completing your transactions, sending you administrative information (such as change of our terms, conditions, or policies) and enabling you to participate in and renew paid services, polls, promotions, surveys, research, events, digital resources and message boards (forums). We will engage in these activities to manage our contractual relationship with you or comply with a legal obligation.
B) Analysis and Development of New Products and Services.
We perform statistical, demographic and marketing analyses of users of the Tracks Media Services, and their subscribing, purchasing, browsing and reading patterns, so we can analyse or predict our users’ preferences for product and services development purposes, to determine our promotional campaign effectiveness so we can adapt our campaign to the needs and interests of our users, and to generally inform advertisers about the nature of our subscriber base. We use this information for analytical purposes, including analysis to improve customer relationships, to support strategic business decisions and our marketing tactics and to measure and track our brand health. We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or because we have a legitimate interest in doing so.
C) Customising Your Experience.
We use the information that we have to better understand you and customise certain features of Tracks Media Services to provide you with an enhanced experience including to show you offerings, promotions or products that may be of interest to you, based on the demographic information, type of device you are using to access the Tracks Media Services, your usage of the Tracks Media Services and your browsing and reading history. We will provide personalised services because we have a legitimate interest.
D) Email Newsletters and Other Marketing Activities as well as Facilitating Social Sharing.
E) Administrative Purposes.
We and our service providers use the information we have about you for the following legitimate business purposes:
- For auditing purposes, to verify that our internal processes function as intended and comply with legal, regulatory and contractual requirements;
- For fraud and security monitoring purposes, including, for example, to detect and prevent cyberattacks; and
- To understand and assess satisfaction with our Services or our customer care team.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or because we have a legitimate interest.
F) Allowing you to participate in Competitions, Promotions and Special Offers.
Some of these promotions have additional rules containing information about how we will use and disclose your personal information. We use this information to manage our contractual relationship with you.
G) Aggregating and/or Anonymising Personal Information.
We aggregate and/or anonymise personal information so that it will no longer be considered personally identifying. We do so periodically to generate other data for our use, which we may use and disclose for any purpose.
H) User Generated Content and Public Activities.
3. With Whom Do We Share The Personal Information We Gather?
A) Sharing Within Tracks Media.
B) Sharing With Service Providers.
We contract with other companies, agents or contractors (“service providers”) to provide services on our behalf. These services are, for example, credit-card, payment and billing processing, fulfillment of subscriptions, orders and prizes, information technology and related infrastructure provision, customer service, ad serving, shipping, email distribution, lead generation, list processing and analytics, research surveys, interviews, event management and analysis, or promotions management. In the course of performing these services, our service providers have access to your information including your personal information.
C) Sharing With Other Third-Parties.
i. We may share personal information, such as name, email, company and title, about attendees to our live events and conferences with sponsors; if we do, we will notify you when you provide us the information.
ii. We may also share personal information to third-party sponsors of competitions, promotions and special offers and will let you know at the point of collection of your information if we do.
iv. We share in aggregate results from research surveys or events with advertisers and clients.
v. We have a legitimate interest in disclosing or transferring your personal information to a third-party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third-parties may include, for example, an acquiring entity and its advisors.
D) Compliance With Legal Process.
We may access, preserve and disclose personal information if we are required to do so by law or we have a good faith belief that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend our rights and property; (3) protect against misuse or unauthorised use of Tracks Media Services; (4) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions); and (5) cooperate with public and government authorities (which may be outside your country of residence).
E) By Using Tracks Media Services, You May Elect to Disclose Personal Information.
i. Public Activities: see above for more details on such activities. Public activities may be included in our RSS feeds, APIs and other distribution formats. As a result, your public activities may appear on other websites, blogs, or feeds.
4. Other Information Collected Using Technology
Other information does not specifically identify you and are collected through technology. It includes tracking information collected by us as well as third-parties.
We use various internet technologies to manage, and track the use of, the Tracks Media Services. We use and disclose this information for any purpose, except where we are required to do otherwise under applicable law. Information that we collect using these technologies is combined with personal information about you. If we combine information with personal information, we will treat the combined information as personal information.
A) Device Information.
We collect information about the computer, mobile device or other device you use to access the Tracks Media Services, such as Internet protocol (IP) addresses (the region or general location where your computer or device is accessing the Internet), geolocation information, unique device identifiers, browser type, browser language and other transactional information.
B) Cookies, Beacons, Local Storage and Other Similar Technologies.
We use “cookies,” Web beacons, tags and scripts, and other similar technologies including local storage objects such as HTML5. These technologies allow us to manage access to and use of the Tracks Media Services, recognise you and provide personalisation, and help us understand how people use the Tracks Media Services. You will not be able to access certain areas of our websites, if your computer does not accept cookies from us. Because there is no accepted standard on how to respond to “do not track” browser-based signals, we do not respond to such signals.
We transmit website usage information to third-parties in order to show you advertising for Tracks Media and affiliated brands when you visit other sites.
C) Analytics, Log Files and Reading History.
We gather certain information automatically and store it in log files. This information includes IP address, browser type, operating system and other usage information about the use of Tracks Media Services, including a history of the pages you view.
We automatically combine this collected log-information with other information we collect about you. We do this to improve services we offer you, including customised recommendations, advertising to improve marketing, and to track access and use of Tracks Media Services across the devices that you use to access us.
One of the analytics service providers we use is Google Analytics. To learn more about how Google use data, visit https://policies.google.com/privacy/partners.
For opt-out options specific to Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.
5. Third-Party Advertising
Some of the services and advertisements included in Tracks Media Services, are delivered or served by third-party companies, which may collect information about your use of Tracks Media Services.
These companies place or recognise cookies, pixel tags, web beacons or other technology to track certain information about Tracks Media Services website users. For example, in the course of serving certain advertisements, an advertiser may place or recognise a unique cookie on your browser in order to collect certain information about your use of Tracks Media Services. For another example, an advertiser or ad server may also be able to collect your device’s unique identifier in the course of serving an ad. In many cases, this information could be used to show you ads on other websites based on your interests.
Your access to our websites should not be affected if you do not accept cookies served by third-parties.
6. How Do I Opt Out From Receiving Emails and Promotions?
You can choose not to receive commercial email messages in the future by either (1) following the “unsubscribe” instructions located near the bottom of each email, or (2) you can email us at hello@Tracksmedia.com.au. It is important to note that this request does not prohibit us from sending you important administrative disclosures for non-marketing purposes.
A) Email Newsletters.
Tracks Media and its affiliated websites offers email newsletters. If you no longer wish to receive a specific newsletter, follow the “unsubscribe” instructions located near the bottom of each newsletter. If you experience difficulty with the “unsubscribe” process, please contact us at hello@Tracksmedia.com.au and provide your email address along with the name of the newsletter from which you would like to unsubscribe.
B) Mail or Telephone Promotions.
If, at any time, you prefer not to receive mail or telephone solicitations originated by Tracks Media Services or if you prefer that we do not share this information with third-parties for marketing purposes, please email us at hello@Tracksmedia.com.au or write to us at The Privacy Officer, Tracks Media Pty Ltd, SE1005 L10 97-99 Bathurst St SYDNEY NSW 2000. Please include your name and phone number in the body of your email or letter, and put “Opt-out” in the subject line.
7. How Do I Access, Change or Update My Personal Information?
If you would like to request to review, correct, restrict or delete personal information that you have previously provided to us, object to the processing of personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us hello@Tracksmedia.com.au.
In your request, please state what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
We will respond to your request consistent with applicable law. A fee may apply to such access in the event that a request for access is excessive.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion).
Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. Australian privacy complaints are available here.
Manage Your Magazine Delivery Account in the Account Area. You may update your magazine delivery for print subscribers via firstname.lastname@example.org. If you have subscribed to our digital publications via another third-party platform, please direct your query to the appropriate third-party vendor.
8. Card holder data and Sensitive Personal Information
The security of your personal information is important to us. When you enter sensitive information (such as credit card numbers) on our website, we encrypt that information using secure socket layer technology (SSL). When Credit Card details are collected, we simply pass them on in order to be processed as required. We never permanently store complete Credit Card details.
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we received it
Unless specifically requested (for example, in connection with a particular survey), we ask that you not send us, and you not disclose, any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or membership of a professional or trade association or union) on or through Tracks Media Services or otherwise to us. Any requested information that includes sensitive information about health, political opinions, ethnicity, race, religion, sex life or sexual orientation can be left unanswered.
9. Data Retention
We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you, provide Tracks Media Services to you and to support strategic business decisions for Tracks Media Services;
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (for example, in light of applicable statutes of limitations, litigation or regulatory investigations).
10. Is My Information Protected?
We seek to protect personal information with reasonable organisational, technological and physical safeguards commensurate to the sensitivity of the personal information. Although we take appropriate measures to safeguard your information, we cannot guarantee its absolute security. To further protect your data, we recommend that you use complex passwords for your accounts with us and for accounts with third-parties that you link to any of your accounts with us. Please do not use the same passwords you use for Tracks Media Services for other services or share your password with unauthorised people. If you have reason to believe that your interaction with us is no longer secure, please immediately notify at hello@Tracksmedia.com.au.
11. Children’s Guidelines
We do not knowingly collect or store any personal information from children except as permitted by applicable law or unless otherwise stated (for example, as per the specific competition entry terms and conditions).