This Privacy Policy sets out the approach in which The Affinity Partnership Pty. Ltd. (AFFINITY) will take in relation to the treatment of Personal Information. It includes information on how AFFINITY collects, uses, discloses and keeps secure, individuals’ personal information. It also covers how AFFINITY makes the personal information it holds available for access to and correction by the individual.

1. COLLECTION

1.1 AFFINITY will only collect Personal Information where the information is necessary for AFFINITY to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.

1.2 AFFINITY collects Personal Information primarily on behalf of our customers or uses Personal Information provided by our customers, their employees, contractors and third party suppliers, for the provision of marketing products and services. AFFINITY also collects and uses Personal Information for secondary purposes, including:

• provision of products and services;
• accounting purposes;
• recruitment purposes;
• business planning and product development.

1.3 AFFINITY will notify individuals of the matters listed below at the time of collecting any Personal Information:

• the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
• other related Uses or Disclosures that we may make of the Personal Information(Secondary Purposes);
• our identity and how individuals can contact us, if this is not obvious;
• that individuals can access the Personal Information that AFFINITY holds about them;
• that individuals should contact AFFINITY if they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;
• the organisations or types of organisations to whom we usually Disclose the Personal Information;
• where applicable, any law that requires the Personal Information to be collected;
  the consequences (if any) for the individual if all or part of the Personal Information is not provided to AFFINITY.

1.4 Where it is not practicable for AFFINITY to notify individuals of all of the Collection Information before the collection of Personal Information, AFFINITY will ensure that individuals are notified of the Collection Information as soon as possible after the collection.

1.5 AFFINITY will not collect Sensitive Information from individuals except with express consent from the individual and only where it is necessary for AFFINITY to collect such information for an activity or function.

1.6 AFFINITY will not collect Personal Information secretly or in an underhanded way.

1.7 AFFINITY will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.3.

2. USE

2.1 AFFINITY will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose, which would be within the relevant individual’s Reasonable Expectations.

2.2 AFFINITY Uses Personal Information primarily for the purposes listed in 1.2 above.

2.3 If AFFINITY relies on the Direct Marketing exception to Direct Market to individuals it will ensure that: individuals are clearly notified of their right to Opt Out from further Direct Marketing; and if the individual Opts Out of all Direct Marketing the Opt Out will be respected by AFFINITY and implemented free of charge.

2.4 AFFINITY will not use Sensitive Information for Direct Marketing.

2.5 AFFINITY may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.

2.6 AFFINITY will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.

2.7 AFFINITY will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.

3. DISCLOSURE

3.1 AFFINITY may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.

3.2 AFFINITY may Disclose Personal Information to unrelated third parties to enable outsourcing of functions where that Disclosure or Use is for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations.

3.3 AFFINITY will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.

3.4 In the rare event that AFFINITY is required to disclose Personal Information to law enforcement agencies, government agencies or external advisors, AFFINITY will only do so in accordance with the Privacy Act or any other relevant Australian legislation.

3.5 AFFINITY may Disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.

3.6 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, AFFINITY will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.5 above.

3.7 AFFINITY does not generally share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved.

4. INFORMATION QUALITY

4.1 AFFINITY will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.

4.2 AFFINITY will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.

5. INFORMATION SECURITY

5.1 AFFINITY requires employees and contractors to perform their duties in a manner that is consistent with AFFINITY’s legal responsibilities in relation to privacy.

5.2 AFFINITY will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within AFFINITY who have a genuine “need to know” as well as “right to know”.

5.3 AFFINITY will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.

6. ACCESS AND CORRECTION

6.1 AFFINITY will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.

6.2 AFFINITY will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.

6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting AFFINITY.

6.4 AFFINITY may charge a fee for processing an access request.

7. OPENNESS

7.1 Contact with AFFINITY via phone or web inquiry will be the first point of contact for inquiries about privacy issues.

7.2 Any formal privacy related complaints should be directed in writing to the AFFINITY Privacy Officer, PO Box 168, Darlinghurst NSW 1300.

7.3 AFFINITY will endeavor to manage any privacy related complaints efficiently and in a timely manner.

7.4 AFFINITY websites will contain a prominently displayed privacy statement and will include a copy of this AFFINITY Privacy Policy.

8. ANONYMOUS TRANSACTIONS

8.1 AFFINITY will not make it mandatory for visitors to its websites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service.

8.2 AFFINITY will allow its customers to transact with it anonymously wherever that is reasonable and practicable.

9. TRANSFERRING PERSONAL INFORMATION OVERSEAS

9.1 AFFINITY generally does not send information overseas.

9.2 If Personal Information must be sent by AFFINITY overseas for sound business reasons, AFFINITY will require the overseas organisation receiving the information to provide a binding undertaking that it will handle that information in accordance with the National Privacy Principles, preferably as part of the services contract.

10. GLOSSARY

Collection of Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.

Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services that are marketed may be those of AFFINITY or a Related Body Corporate or those of an independent third party organisation.

Disclosure generally means the release of information outside AFFINITY, including under a contract to carry out an “outsourced function”.

Opt Out means an individual’s expressed request not to receive further Direct Marketing. Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.

Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.

Reasonable Expectation means a reasonable individual’s expectation that their personal information might be Used or Disclosed for a particular purpose.

Sensitive Information means:

1. Information or an opinion about an Individual’s:

• racial or ethnic origin; or
• membership of a political association; or
• religious beliefs or affiliations; or
• philosophical beliefs; or
• membership of a professional or trade association; or
• membership of a trade union; or
• sexual preferences or practices; or
• criminal record

2. Health Information about an individual; or information or an opinion about: the health or a disability (at any time) of an individual; or

• an individual’s expressed wish about the future provision of health services to him or her; or
• a health service provided or to be provided to an individual; that is also personal information; or
• other personal information collected to provide or in providing a health service; or other personal information about an individual collected in connection with the donation; or
• intended donation by the individual of his or her body parts or body substances

Use means the handling of Personal Information within AFFINITY.

CONTACTING AFFINITY

If you require further information regarding AFFINITY’s Privacy Policy,

Telephone: 02 8354 4400

Email: hello@affinity.ad

Visit: Level 3, 50 Stanley Street, Darlinghurst NSW 2010