Privacy Policy

CROCMEDIA PRIVACY POLICY
Privacy Policy

This privacy policy sets out how Crocmedia Pty Ltd ACN 129 637 378 (“we”) treat the privacy of our customers and consumers, of users of our various radio, broadcast and podcast services (collectively “Services”) and others with whom we interact.  
In the course of conducting our business we may handle and collect your personal information. 
We are bound by and committed to the Australian Privacy Principles set out in the Privacy Act (1988)(Cth.) (“Privacy Act”) 

In this privacy policy, the term “personal information” has the meaning in the Privacy Act. Personal information is any information or opinion about an identified or reasonably identifiable individual. It includes a subset of information that constitutes “sensitive information” as defined in the Privacy Act.
The personal information we typically collect about individuals may include

(a) Name, address, email address and phone number;
(b) Age, date of birth and gender;
(c) Credit card or other banking details; and
(d) Photographs, audio, video and audiovisual footage.

1. Collection and Storage of Personal Information  
We may collect and store your personal information in circumstances including:
(a) When providing you with goods or services; 
(b) When you sign up to become a user of our Services;
(c) When you post content revealing your identity or the identity of another person on a Service;
(d) When you send an enquiry through or makes a comment or other post through our website, through an email or via a social media platform;  
(e) When you ask or agree to be added to an email marketing or newsletter list;
(f) When you enter into a competition or trade promotion (including through partner sites such as www.icanwin.com.au);
(g) When you participate in a loyalty program that we run or administer;
(h) When you ask for and we issue tickets to events for you; 
(i) When you ask us to arrange travel/ tours/ accommodation/ entertainment for you;
(j) When you participate in research, such as surveys that we run or are associated with; 
(k) When you download an app or stream content through an app that we are associated with;
(l) When dealing with personnel from an organisation that is doing or considering doing business with us;
(m) When you enter into a transaction with us using a credit card or method other than cash; and
(n) When we evaluate job applicants and personnel which may include collection of details such as employment history and educational qualifications. This may include “sensitive information” as defined in the Privacy Act.
In some circumstances we may obtain personal information about you through a third party, for example, through a partner organisation (such as the AFL, or a broadcaster), 
where you have consented to the collection and provision of that information to us. 

2. Anonymity 
Where practicable, users of the Services and others have the right to interact with us and each other anonymously.  

3. Cookies
We may use or engage other service providers who use ‘cookies’ to collect data (typically not personal information) relating to your general usage of the Services. 
 This data may include IP-addresses, geographic location, browser versions, number of visits and similar such data relating to your navigation of our Services and linked services and online stores. Cookies help us to improve and deliver better and more tailored Services. 
You may refuse to accept cookies by activating settings on your device. However, please note that if you select such settings you may be unable to access certain parts of our Services.   

4. Use and disclosure of Personal Information
In most cases we do not disclose personal information about users of the Services to each other, instead limiting the information that is disclosed between users to de-identified and anonymous information.  

We also frequently provide aggregated information that identifies trends and other sentiments without identifying the individuals who have provided the corresponding feedback or information. 

We use the personal information collected from you for the purpose it was provided or collected, including in the following ways:
(a) For use for the purposes of collection described in (1) above;
(b) If and when that information is included in feedback from a user;
(c) To respond to enquiries received from you;
(d) To perform authorised financial transactions with you;
(e) To verify your identity and to assist you if you have forgotten any user ID, user name or password;
(f) To seek user comments and feedback on our Services;
(g) To communicate with you and provide you with information (whether by email, post or other means) about our products or the Services (including to notify you of changes to the Services), 
where you have requested or consented to receiving this from us or where this provision is otherwise permitted under the Australian Privacy Principles or other applicable law;
(h) To allow you to participate in interactive features of our Services when you choose to do so;
(i) To receive and address feedback or complaints about us or our Services from you; 
(j) To protect our legal interests and fulfill our regulatory obligations (if and to the extent necessary); 
(k) To respond to allegations of abuse of the Services; and
(l) In other circumstances, with the relevant individual’s prior consent. 
We may use personal information for the purpose of marketing to users but only where such use complies with applicable legislation. 
All users and others with whom we interact have the option to opt-out of receiving marketing communications from us. 
 If you do not wish to continue to receive electronic marketing communications from us and/or selected third parties you should opt-out by clicking on the "unsubscribe" link in any email communications that we might send you.
We may disclose your personal information to any of our related group companies. They will only use it for the same purposes that we may under this policy. We may disclose your personal information to third parties outside our group of companies: 

(a) Where we have your express permission to do so;
(b) Where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties;
(c) If Crocmedia Pty Ltd or substantially all of its assets are acquired by a third party, in which case personal information which we hold about our customers and users may be one of the transferred assets 
(subject to the same constraints on use and disclosure as under this policy); and
(d) If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions or to protect the rights, property, or safety of Crocmedia Pty Ltd, its personnel or customers . This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 
We would only use or disclose the type and amount of information necessary to carry out the relevant purpose.   
We deal with third parties that are required to meet the privacy standards required by law in handling your personal information, and use your personal information only for the purposes that we gave it to them. 

5. Disclosure and transfer of information overseas
We do not disclose or transfer personal information outside Australia, except if and in the context of arranging travel, accommodation or other services to be provided in other countries, at your request. 

6. Security of personal information
We hold personal information in our own secure databases and in secure storage facilities.
We take all reasonable steps to protect your personal information, including by internal and external security and restricting access within the organisation to personal information to those who have a need to know. 
We implement and maintain technological products to prevent unauthorised computer access and regularly review our technology to maintain security. 
We treat website and credit card security seriously and endeavour to provide a secure, safe platform through which to conduct transactions. 

7. Questions and concerns and access to/ correction or updating of your personal information
You have a right to access and if necessary correct the personal information we hold about you. To obtain a copy of the personal information we hold about you, please write to us at: 

The Privacy Officer
Crocmedia Pty Ltd
Level 5, 
111 Coventry Street, Southbank, Victoria 3006
or by email to privacy@crocmedia.com.au 
Please provide sufficient detail about the information in question to help us locate it. 
 If applicable we will then use commercially reasonable efforts to promptly determine if there is a problem and take the necessary corrective action within a reasonable time. 
We may charge a fee for giving you access to that information, which is reflective of the costs of providing the access. 

8. Changes to our privacy policy
We may modify, alter or otherwise update this privacy policy at any time. We will post revisions on our website.
We encourage you to review this policy from time to time. 
Last update: September 2017

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