This Privacy Policy applies to the collection and use of personal information (PI) by or on behalf of Head Space Entertainment Pty Ltd (ABN 86 105 743 637) trading as Broad Radio (referred to in this policy as “Broad Radio”, “We” or “us”).
Broad Radio operates a commercial online radio show, website, and other media platforms throughout Australia.
We are committed to the protection of your PI and meeting the standards set out in the Privacy Act 1988 (Cth) (the Act),the Australian Privacy Principles (APPs) and other data protection laws such as the European Union General Data Protection Regulations (GDPR).
The date of this Privacy Policy is set out above. We may change this Privacy Policy at our discretion. By continuing to access our websites or platforms, register on any of our websites, otherwise interact with us or provide your PI to us, you accept this Privacy Policy as it applies from time to time.
1. COLLECTION OF INFORMATION
1.1 What kinds of Personal Information we collect and hold
We may collect various types of PI including but not limited to your name, address, email, phone number, age, payment details, gender, interests or other information relevant to promotions and activities that BROAD RADIO runs and to your engagement with BROAD RADIO.
1.2 Why we collect Personal Information
Generally we collect your PI to provide you with services and to administer our relationship with you. We also collect PI for research and for marketing purposes and to provide you with information about events, products and services (both our own and those of other companies) that may be of interest to you, to improve the services we provide and to run various competitions
1.3 How we collect Personal Information
We primarily collect PI directly from you when you interact with us, for example when:
(a) you submit an entry into a competition or trade promotion;
(b) you participate in listener loyalty programs;
(c) you subscribe to a member database or email newsletter;
(d) you send us an email or make a post on any of our websites (including social media assets and platforms);
(f) you stream our products from a website, or via a mobile App;
(g) you call us; or
(h) you attend an event or activity that we organise, sponsor, or are otherwise affiliated with.
We may also collect anonymous information through the use of cookies on our website. Cookies are pieces of information that are stored on your computer’s hard disk. Most web-browsers are set to accept cookies but you can set your web-browser to refuse cookies. Cookies themselves do not identify users personally but they do allow the tracking of an individual’s use of a website. Cookies have become commonplace on many websites. You can configure your web browser to reject or accept cookies. If you reject cookies you may not be able to interact with us online, or you may not be able to use all of the functionality on our website.
1.5 Trade promotions (contests, promotions, competitions, sweepstakes, lotteries, and raffles)
If we conduct trade promotions (which include activities such as contests, promotions, competitions, sweepstakes, lotteries and raffles), we may collect PI for administrative purposes, and possibly to fulfil the prize for the trade promotion. We may also store the PI that you provide to us for the trade promotion on our customer information database for use for promotional, marketing and product development purposes in relation to any of our products or services, including direct marketing via any medium (including SMS and email).
On some occasions we may conduct a trade promotion that has its own specific privacy terms. In this case, notice of those terms will be provided at the time that PI is sought and those terms will apply to the PI collected as part of that trade promotion.
If we conduct a trade promotion on a social media platform (such as Facebook) we generally do not require you to share PI with us (although you may choose to do so).
We acknowledge that where we conduct a trade promotion on a social media platform:
(a) The trade promotion is not administered by the social media platform unless we expressly state that it is.
(b) Any PI provided by the you in connection with the trade promotion or activity, is provided to us and not to the social media platform.
(c) Any questions, comments or complaints regarding the trade promotion, or collection of PI in connection with the trade promotion, must be directed to us, not to the social media platform.
2. USE AND DISCLOSURE
2.1 Use
By submitting your PI to us you consent to us using your PI in the following ways and for the following purposes:
(a) to provide you with our products or services;
(b) to administer our relationship with you;
(d) to facilitate the administration of, and your participation in, a trade promotion or other activity;
(e) to facilitate the administration of, and your participation in, a listener loyalty program;
(f) to facilitate the administration of, and your participation in, a member database;
(g) to facilitate the administration of, and your participation in, an online subscription newsletter;
(j) to compile listener databases and profiles to enable us to market goods and services more accurately;
(k) for internal administrative purposes, such as procedural assessments, risk management, staff training, accounting, billing, product and service reviews;
(l) to identify and inform you about other products or services that may be of interest to you;
(m) to market, improve and add to our products and services including our websites and our radio broadcasts;
(n) where there is a serious threat to an individual’s life or to public health or safety;
(o) where there is reason to suspect unlawful activity has been engaged in;
(p) where required or authorised by law; or
(q) where required by an enforcement body.
If you do not wish to receive marketing or other communications from us, please contact us on the details below so that we can update your preferences.
If you provide us with your mobile telephone number, email address, IM address or other such personal information, you authorise us to send you promotional messages related to our products and services and the products and services that we promote. Such messages will be accompanied by a functional unsubscribe facility.
2.2 Disclosure
We may disclose PI across the Head Space Entertainment group of companies and our related bodies corporate in accordance with this Privacy Policy. We may also provide PI to third parties:
(a) engaged by us to provide functions on our behalf such as storing and managing databases, processing credit card information, mailouts, debt collection, marketing research and advertising;
(b) authorised by you to receive PI held by us;
(c) where that disclosure is reasonably required to obtain advice, prepare or conduct legal proceedings, investigate suspected improper conduct or wrongdoing or assist a lawful authority in the discharge of its duties; and
(d) where permitted or required by law.
Where we hold trade promotions in conjunction with other companies, we will offer you the opportunity to be contacted by our promotions partner(s) or sponsor(s). We will not provide your PI to the promotions partner(s) unless you have expressly consented (“opted in”).
To protect your privacy, wherever practical we impose contractual requirements of security and confidentiality on third parties as to how they handle any PI that we disclose to them. However, except to the extent that liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any misuse or unauthorised disclosure of your PI by these third parties.
When we share information with third parties as set out above, we do so in accordance with this Policy. To the extent that these third parties gain access to PI, their use is governed by their own privacy policies, the Act, GDPR and any other relevant law.
3. GOOGLE ANALYTICS
We have implemented a feature of Google Analytics referred to as Demographics and Interest Reporting on our websites.
The Google Analytics Demographics and Interest Reporting feature allows us to collect data relating to the demographics (age and gender) and interests of visitors to our websites. We collect such data to analyse how visitors engage with our websites. We do not collect or store personally identifiable information about visitors via this feature.
The data collected via the Google Analytics Demographics and Interest Reporting feature is stored on Google’s servers and is accessible by Google. By using this website, you consent to the processing of the data by Google as set out in Google’s Privacy Policy.
You can opt out of this feature by visiting the following link:https://tools.google.com/dlpage/gaoptout/
You may opt out of Google’s use of cookies by visiting the Ads Preferences Manager. Also, you can opt out of other third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page (http://www.networkadvertising.org/managing/opt_out.asp).
5. DATA SECURITY
Your PI is stored in secure Netregistry servers located at the Global Switch Sydney data centre and paper based files, and in other records. We may also engage third party service providers to assist in storing and processing certain types of personal information for us.
We have taken reasonable precautions to ensure that your PI is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
However, except to the extent that liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to your PI. Please notify us immediately if you become aware of any breach of security.
If we have reasonable grounds to believe that your PI that we hold may be subject to unauthorised access or disclosure (eligible data breach), we will investigate and assess the suspected eligible data breach to determine whether the eligible data breach is likely to result in serious harm to you (Notifiable Data Breach). If a Notifiable Data Breach occurs, then we will notify you and the Australian Information Commissioner as soon as practicable after we become aware of the Notifiable Data Breach in accordance with our obligations under the Act. We will comply in every way with our obligations under Part IIIC – “notification of eligible data breaches” of the Act.
6. Retention and Disposal of Personal Information
We will retain PI for as long as is required for us to fulfil the purposes for which the PI was collected, including to comply with legal requirements.
If we no longer require PI for any purpose, including legal purposes, or you request that we delete your PI collected by us, we will take reasonable steps to securely destroy or permanently de-identify the PI.
7. OPENNESS
If you have any questions in relation to our handling of your PI, or the kind of PI we hold about you, please contact us on the details below and we will endeavour to assist you with your request.
8. ACCESS AND CORRECTION
You have rights under the Act to access and correct the PI that we hold about you. If you wish to access, correct or update any personal information we may hold about you, please contact us as set out below.
The APPs set out some circumstances in which we are not required to provide you with such access. If you ask for your PI and any of these circumstances apply, we may, if reasonable, give you access to the PI in a way that meets our needs and yours (for example by giving you access through a mutually agreed intermediary).
We may charge a fee for giving access to PI, in which case we will inform you of the fee (which will not be excessive) in advance of providing the information.
8. ANONYMITY
Where practical, you may deal with us on an anonymous basis or by using a pseudonym. In some instances, because of the services we provide, if you do not provide us with your PI we may not be able to provide you with the requested product or service (for example, if we require your details in connection with a competition we are running, we cannot provide you with a prize should you be a prize winner and we cannot contact you).
9. OVERSEAS TRANSFERS OF INFORMATION
We do not generally disclose PI to overseas recipients in the ordinary course of our business. Where we disclose PI to recipients located outside of Australia we will do so in accordance with the requirements of the Act and in accordance with the terms of this policy.
10. SENSITIVE INFORMATION
Sensitive information includes information about your race or ethnic origins, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation. We generally do not ask for sensitive information, but may do so where it is reasonably necessary for our functions and activities and it is permitted by law. Generally we will only collect sensitive information where:
(a) you have consented to providing sensitive information (if you voluntarily submit such information to us you will be deemed to consent to us collecting that information); or
(b) the collection of the sensitive information is specifically authorised or required by law.
11. COMPLAINTS
If you have a complaint in relation to the collection and handling of your personal information, or if you believe that we have not complied with this Privacy Policy or the Act, please contact our Privacy Officer via the details provided below. We will review all complaints received and the Privacy Officer will respond to the complainant. We will take any privacy complaint seriously, and we aim to resolve all complaints in a timely and efficient manner. We request that you cooperate with us during this process and provide us with relevant information we may require.
We expect our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint to the Office of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia).
12. CONTACT US
For all privacy inquiries and complaints, please contact Broad Radio Privacy Officer by mail at PO Box 178, Elsternwick, 3185, or email hello@broadradio.com.au.
