VML Digital Pty Ltd (ABN 24 009 834 986) (VML or We/we or Our/our or Us/us) is committed to respecting the privacy of your personal information.

This Privacy Policy explains our policy for dealing with personal information that we collect through the following channels (Collection Channels):

  • our online properties (each a “Website”), including:
    • our websites, including but not limited to http://australia.vml.com/;
    • any related VML or client website, social media page, internal website, intranet and any VML or client mobile or tablet applications;
  • personal information provided to us by our clients and customers 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; and
  • any other means through which an individual provides personal information to VML and its clients, including either physically or electronically.

You may contact us with any queries you may have in respect of this Privacy Policy or your personal information by contacting VML’s privacy officer via email: webservices@vml.com.au or telephone: 02 9909 4411.

Personal information is important to VML

  1. VML takes very seriously the privacy of our Website users, clients and customers and the security of their personal information. The purpose of this privacy policy is to set out the principles governing our use of personal information that we may obtain about you. By using any Collection Channel you agree to this use. We ask you to read this privacy policy carefully. Unless given consent to do otherwise, VML will only collect and use personal information as set out below.
  2. Throughout this Privacy Policy, we refer to your 'personal information', which means information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address and workplace contact details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences.
  3. VML has developed and implemented its Privacy Policy with respect to personal information to reflect world best practice on privacy policies. These principles meet and exceed the requirements of the Privacy Act 1988 (Cth) (as amended) and the 13 Australian Privacy Principles.
  4. In order to keep up with changing legislation and best practice, we may revise this Privacy Policy at any time without notice. We will post any changes to this Privacy Policy on our Websites, so we encourage you to check this Privacy Policy from time to time.
  5. In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

Anonymity and pseudonymity

  1. Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our Collection Channels will 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.

 

Kinds of Personal Information that VML Collects and Holds

  1. Personal information that may be requested or collected by us includes:
    1. contact information such as your full name, date of birth, telephone number, mobile telephone number, current and valid email address, residential address and postcode;
    2. financial information;
    3. social media account details;
    4. employment details;
    5. enquiry and complaint details;
    6. information about your experience with our products or services or third party products or services listed on a Website. This information is requested in order to tailor our subsequent communications to you and continuously improve our products and services;
    7. the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to VML and used for the purposes set out in this policy (which may include using their details for marketing purposes);
    8. any other personal information which you directly provide to VML. Where you provide us with such unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy); and
    9. any other personal information requested or required by a Collection Channel.

Sensitive Information

  1. We will only collect sensitive information with your consent. Where you provide us with any sensitive information (including, but not limited to, information about your racial or ethnic origin, religious affiliation, political opinions, sexual orientation and/or criminal or medical history) we will only use this information for the purposes stated on the Collection Channel. We do not retain this information in our database.

How VML Collects and Holds Personal Information

  1. VML will only collect any personal information about you when it is voluntarily submitted to us through a Collection Channel, as provided in this Privacy Policy or if it is otherwise lawful to do so The only personal information collected by us is what has been provided to us in accordance with this Privacy Policy or has been provided to us lawfully by third parties, including our clients and customers.

Active Information Collection

  1. Personal information may be collected (and combined) via our Collection Channels if you:
    1. have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party, including our clients;
    2. sign-up and/or register to become a member of any Collection Channel, or provide your details to us or our clients via any Collection Channel;
    3. 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;
    4. complete and submit any forms or surveys to us or our clients, either physically or electronically;
    5. conspicuously publish or provide on request your personal information to VML;
    6. contact us or our clients 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;
    7. participate in any competitions, offers, promotions or marketing activities; 
    8. interact with a Website for a specific purpose; or
    9. interact with or browse a Website generally.
  2. 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 VML, 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 VML 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).
  3. We may also obtain your personal information from legitimate third party sources including list brokers, referral agents, our clients, social media and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so.

Children

  1. Personal information will not be collected by any person who is known by VML to be under the age of thirteen (13) without the consent of a parent or legal guardian. Persons under age thirteen (13) may only use our Websites with the involvement and consent of a parent or legal guardian.

Passive Information Collection

14.          In common with many commercial organisations, we monitor the use of our Website by collecting passive information, which is information gathered without you actively providing the information. In certain circumstances, this information may be considered anonymous information or personal information under the Privacy Act 1988 (Cth). This is dependent on the device used and the method by which an individual connects to the Internet. We may automatically collect anonymous information or personal information about you such as the type of internet browsers you use, the pages you visit or the website that directed you to our site.

Use of Cookies

  1. Cookies are small files that are sent to your web browser and stored on your computer's hard drive. Their purpose is to help analyse web traffic. You may set your web browser to notify you of cookie placement requests or to decline cookies completely. You can delete the files that contain cookies; those files are stored as part of your internet browser. However, certain features of a Website might not work without cookies and this may limit the services provided by a Website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf.

16.          VML uses third-party web beacons from Yahoo! to help analyse where visitors go and what they do while visiting our website. Yahoo! may also use anonymous information or personal information about your visits to this and other websites in order to improve its products and services and provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by Yahoo!, please  see http://info.yahoo.com/privacy/us/yahoo/opt_out/targeting/details.html

 

Purposes for which VML collects, holds, uses and discloses personal information  

  1. Personal information collected will be collected, used and/or disclosed for the following primary purposes:
    1. To comply with your request for information;
    2. For the purposes for which it was collected (as advised in this Privacy Policy).
    3. For the purposes stated in a privacy collection statement on a particular Collection Channel.
    4. To fulfil obligations in respect of any contract between you and VML or you and one of our clients.
    5. To provide you with information about your transactions (including uploading, access to, and receipt of content on a Website), content, services and products, to provide direct marketing materials, events, special offers, competitions and promotions in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email) or any other form of electronic, emerging, digital or conventional communications channel.
    6. To maintain our relationship with you.
    7. To render services related to VML.
    8. To manage your employment with VML (if applicable).
    9. To provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages.
    10. To respond to enquiries.
    11. To obtain opinions or comments about products and/or services and to conduct other research and development.
    12. To share personal information with our group companies, our promotional partners, clients and other trusted third parties and contractors.
    13. To collect, hold, use and disclose personal information as stated above, for the purpose of providing professional services to our clients and customers.
    14. To administer competitions and promotions for our clients including publication of winners, notification to gaming authorities and the delivery of prizes.
    15. To better understand your needs and how we can improve our services.
  2. For the purposes described above, personal information may be shared with our group companies, promotional partners, clients and other trusted third parties (and their directors, servants and agents) either in Australia or overseas, including, but not limited to the United States of America.
  3. Failure to provide personal information may result in VML or its clients being unable to provide you with certain content, information, upcoming promotion, event or product information and/or accept promotion entries (where applicable).
  4. In order to operate a Website or deliver a service, personal information may also be shared with our group companies, selected service providers and/or other trusted third parties or contractors either in Australia or overseas countries which may include but are not limited to the United States of America. Our group companies, selected service providers and/or other trusted third parties or contractors may be engaged to perform a variety of functions, such as data storage, conducting market research, assisting with promotions and providing technical services for our or our clients’ Websites. These companies may have access to personal information if needed to perform such functions.
  5. VML recognises the trust with which you provide personal information, and except as stated in this Privacy Policy, such information will not be used or disclosed for any other purposes without consent. However, VML reserves the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect the rights or property of VML, any member of VML group, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.

Contact by VML

  1. VML (and its directors, servants and agents), VML promotional partners or trusted third parties or contractors (and other selected service providers and other non-VML 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.
  2. VML does not send advertising or marketing information without obtaining prior consent, for example the consent contained within this Privacy Policy. If you receive communications from VML which you do not wish to receive, you may remove your name from the database either by utilising the functional unsubscribe facility (if the communication is via commercial electronic message) or by contacting VML via email:  webservices@vml.com.au or telephone: 02 9909 4411.Please allow 30 days for this request to be processed.
  3. Despite removing your name from the database from receiving future advertising and marketing information, VML may send you non-commercial “Administrative Emails”. Administrative Emails relate to a VML user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular VML user account. If you do not wish to receive such communications from VML, you may remove your name from the database by utilising the functional unsubscribe facility.

Your right of access

  1. You have the right to access and review your personal information that may be recorded on a VML database. Information may be reviewed by contacting VML’s privacy officer via email: webservices@vml.com.au or telephone: 02 9909 4411.Please allow 30 days for this request to be processed.

Ability of others to view information

  1. 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 publically 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 publically 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.

Changing and deleting the information we have about you

  1. Information contained on the database may be amended, or your preferences for contact from us changed, by using the update subscription preferences function in our email communications with you or by contacting VML’s privacy officer via email: webservices@vml.com.au or telephone: 02 9909 4411.Please allow 30 days for this request to be processed.
  2. 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 VML and its clients being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website), other content, services or product information, upcoming promotion, competition or event information, and/or provide certain content, goods or services.
  3. 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

  1. VML will endeavour to take all reasonable steps to keep secure any personal information recorded, and to keep this information accurate, up to date, complete and relevant. The information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas, including in the United Stated of America and the United Kingdom.

Disclosure of personal information to overseas recipients

  1. In some cases, VML may disclose your personal information including, but not limited to, your professional information and contact details, to overseas recipients including in the United States of America and in the United Kingdom. VML employees, data processors and other trusted third parties or contractors are obliged to respect the confidentiality of any personal information held by VML. 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. VML will not be held responsible for events arising from unauthorised access to personal information.

VML and links to other websites

  1. Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Their inclusion 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. VML is not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.

Related VML Websites

  1. All Websites operated by VML will adhere to this Privacy Policy.

Sale of the Company

  1. If VML merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy. 

Problems or queries

  1. If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled and/or disclosed your personal information, please contact our privacy officer via one of the following channels:

 

Address:           Level 14, 35 Clarence Street

                        Sydney NSW 2000

Telephone:        02 9909 4411.

Email:               webservices@vml.com.au

Please allow 30 days for this request to be processed.  If you do not receive a satisfactory response from VML 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.

 

COLLECTION STATEMENT

 

VML Digital Group Pty Ltd (ABN 24 009 834 986) (VML) collects personal information about you from http://australia.vml.com/, any related VML or client website, social media page, internal website or intranet and any VML or client mobile or tablet application (each, a Website); personal information provided to us by our clients and customers; 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, and; as provided by you by any other means, including either physically or electronically. Occasionally, we collect personal information from social media sites or from commercial data providers, referral agents, and other data providers who obtained your personal information from third party sources who hold your consent to disclose your personal information to us, or who have otherwise disclosed your personal information to us in circumstances where it is lawful to do so. Personal information will not be collected from any person who is known by VML to be under the age of thirteen (13) without the consent of a parent or legal guardian. Personal information is collected in order to respond to enquiries, to administer competitions and promotions for our clients, to provide you with newsletters and electronic newsletters, to provide professional services to our clients and customers and to provide you with certain content, products and services and, unless you opt-out or unsubscribe, contact you in the future with information on products and services and to provide you with marketing materials via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) or any other form of electronic, emerging, digital or conventional communications channel whether existing now or in the future. Our Websites may also collect and use passively collected anonymous information or personal information from various third party sources and we may combine this anonymous information or personal information with other personal information collected from you, to provide better service to Website users, customise a Website based on your preferences, compile and analyse statistics and trends, and otherwise administer and improve Websites for your use. For the purposes described above, your information may be shared with VML group companies (and their directors, servants and agents), clients, promotional partners and other trusted third parties and contractors, either in Australia or overseas including the USA and UK, who may also contact you with information about products and services and with marketing materials, including electronically. Failure to provide personal information may result in you being unable to receive newsletters and in VML being unable to provide you with certain content, products or services. Our Privacy Policy http://australia.vml.com/privacy-policycontains information about how you can access and correct your personal information, how you can lodge a complaint regarding the handling of your personal information and how any complaint will be handled by VML. You may contact our privacy officer with any queries via email: webservices@vml.com.au or mail: Level 14, 35 Clarence Street, Sydney NSW 2000 or telephone: (02) 9909 4411