Introduction

(“Poppy Renegade,” “we,” “us,” “our”) respects your privacy. We have developed this Policy to inform you of how we protect the Personal Information that we Collect, Use, Disclose and keep secure. It also covers how Poppy Renegade makes the Personal Information it holds available for access to and correction by you.

This Policy has been drafted having regard to our obligations under the Act 1988 (Cth), the Amendment (Enhancing Protection) Act 2012 which includes the Australian Principles (collectively, the Act) and the Spam Act 2003 Cth (Spam Act). This Policy is a public document and has been prepared in light of Australian Principle 1 – Open and Transparent Management of Personal Information.

Please take a few minutes to review this Policy. By using the Site, you are consenting to the Collection, Use and Disclosure of your Personal Information as set forth in this Policy.

Collection of Personal Information

Poppy Renegade Collects Personal Information about Website users which is reasonably necessary for, or directly related to, one or more its functions or activities. We Collect your Personal Information in several ways, including but not limited to:

the registration process on the Site; and

other instances in which you provide Personal Information via the Site.

The Personal Information that we Collect includes (but is not necessarily limited to): your first name, your last name, your email address, your physical address and your social handles (usernames on Facebook, Twitter, Instagram etc.).

At or before the time, or, if that is not practicable, as soon as practicable after, we Collect your Personal Information, we will notify you of the matters required pursuant to Australian Principal 5 – Notification of the Collection of Personal Information, by providing you with this Policy, or by notifying you of how you may access this Policy.

Poppy Renegade will not Collect Personal Information secretly and will not sell your Personal Information to any third party.

How We Use Your Information and When We May Disclose It

Poppy Renegade holds Personal Information which it has Collected to Use and/or Disclose for its Primary Purposes, including but not limited to:

sending you materials relating to Poppy Renegade and products and services that may be of interest to you;

answering your inquiry; and

providing you with effective customer service.

Poppy Renegade also holds Personal Information which it Uses and/or Discloses for purposes other than its Primary Purposes (Secondary Purposes). You provide your consent to us Using and/or Disclosing your Personal Information for the following Secondary Purposes:

business planning and product development;

enabling us to better understand your needs and interests;

improving the content, functionality and usability of the Site;

improving our marketing and promotional efforts;

billing and account management;

displaying personalised advertising when you visit the Site;

for any other purpose identified in any other agreement between Poppy Renegade and you;

issues, news or other information relevant to your dealings with Poppy Renegade, or about Poppy Renegade generally; and

as otherwise described in this Policy.

Poppy Renegade may Use and/or Disclose your Personal Information for any Secondary Purposes not included in this Policy if:

the Secondary Purpose is related to a Primary Purpose; and

you would have a Reasonable Expectation that we would Use the information for that Secondary Purpose.

From time to time we may Disclose your Personal Information to organisations outside of Poppy Renegade in order to deliver the services you require. Your Personal Information is Disclosed to these organisations only in relation to us providing our services to you. These organisations carry out, amongst other services, our:

customer inquiries;

information technology services;

marketing services (including market research);

billing and debt- recovery functions; and

website usage analysis

to support or facilitate any of those activities described above.

We will take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your Personal Information.

The Site may use social plugins (hereinafter “Plugins”) of the social network Facebook, which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA (hereinafter “Facebook”). The plugins are marked by a Facebook logo or the words “Social Plug-in by Facebook” or “Facebook Social Plugin”. Find an overview of the Facebook plugins and their appearance on http://developers.facebook.com/plugins. If you request a page of the Site which contains a plugin, your browser will build up a direct connection to the servers of Facebook. Facebook directly transmits the content of the plugin to your browser and from there it is incorporated in the Site. By integrating the plugin, Facebook receives the information that your browser has accessed the page of the Site, even if you do not have a Facebook account or if you are not logged into Facebook at the time. This information (including your IP address) will be sent directly from your browser to a Facebook server in the U.S. and stored there. If you are logged into Facebook, Facebook can assign your visit to the Site directly to your Facebook account. If you interact with the plugins, for example, by pressing the “Like” button or by leaving a comment, the corresponding information is also transmitted directly to a Facebook server and is stored there. The information is also posted on Facebook and can be seen by your Facebook friends. Facebook may use this information for purposes of advertising, market research and personalised design of Facebook pages. For this purpose, Facebook creates profiles regarding usage, interests and relationships, e.g. to evaluate your use of the Site with regard to the advertisements displayed to you on Facebook, to inform other Facebook users about your activities on the Site and to provide further related services with the use of Facebook. If you do not want Facebook to allocate the collected data via the Site to your Facebook account, you must log out of Facebook before you visit the Site. To find out more about the purpose and extent to which Facebook collects, processes and uses these data, your rights and the settings available to protect your privacy, please read the Facebook privacy policy.

Direct Marketing

You consent to Poppy Renegade Using and/or Disclosing any Personal Information Collected from you for Direct Marketing purposes, whether Collected via telephone, the Site, or otherwise, but subject to the terms of this Policy.

Unless otherwise provided in this Policy and in accordance with the Act and the Spam Act, Poppy Renegade retains the right to Use and Disclose your Personal Information for Direct Marketing purposes:

that has been Collected from you in circumstances where:

you have provided consent to do so; or

it is within your Reasonable Expectations; or

where it is impracticable to obtain your consent;

that has been Collected from any third party in circumstances where:

you have provided consent to do so; or

it is impracticable to obtain your consent.

In each Direct Marketing communication, we will include a:

prominent statement appearing on the relevant piece of marketing material notifying you of your right to Opt Out from further Direct Marketing; and

simple means for you to Opt Out of receiving further Direct Marketing communications of that kind.

Should you Opt Out, we will stop Using and/or Disclosing your Personal Information for Direct Marketing purposes.

Poppy Renegade will not Use your Sensitive Information for Direct Marketing purposes.

Ensuring Information Is Accurate and Up-To-Date

We take reasonable precautions to ensure that the Personal Information we Collect, Use and Disclose is complete, relevant and up-to-date.

However, the accuracy of that information depends to a large extent on the information you provide. That’s why we recommend that you:

let us know if there are any errors in your Personal Information; and

keep us up-to-date with changes to your Personal Information such as your name or email address. You may change your personal details by using the relevant facility on the Site or by contacting Poppy Renegade.

How We Protect Your Information

Poppy Renegade will take reasonable steps to protect the Personal Information from misuse, interference, loss and unauthorised access or disclosure. This may include taking reasonable steps to destroy or permanently de-identify Personal Information once it is no longer needed for any purpose for which it may be Used or Disclosed in accordance with Australian Principal 11.2, subject to the exceptions contained therein.

Poppy Renegade 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.

Poppy Renegade requires employees and contractors to perform their duties in a manner that is consistent with Poppy Renegade’s legal responsibilities in relation to privacy, including those in this Policy.

Poppy Renegade will take reasonable steps to ensure that Personal Information is only accessible by people who have a genuine “need to know” as well as “right to know.”

How You Can Access or Correct Your Information

Poppy Renegade will permit its records containing your Personal Information to be accessed by you when required by the Act. We may, however, refuse to provide you with access to your Personal Information if one or more of those matters contained in Australian Principle 12.3 – Access to Personal Information – applies, including but not limited to instances in which:

we reasonably believe that giving you access to your Personal Information would pose a serious threat to the life or to the health and safety of any individual (including you);

giving access to the information would have an unreasonable impact on the privacy of any other individual;

your request for access is frivolous or vexatious or giving such access will be unlawful

If Poppy Renegade is satisfied that:

having regard to the purpose for which the information is held, the information is inaccurate, out of date, incomplete or irrelevant or misleading; or

you (as the person to whom the Personal Information relates) request that we correct the information;

we will take reasonable steps to correct our records containing your Personal Information as soon as practically possible in accordance with the Act.

If we have refused to grant you access to your Personal Information in accordance with the point above, we will still take all reasonable steps to provide you with access to your Personal Information in a way that meets both your needs and our needs.

If you:

wish to lodge a request to access and/or correct your Personal Information; or

have been refused access to your Personal Information by us for any reason described in this Policy and you wish to challenge that refusal;

you may do so by contacting Poppy Renegade.

Poppy Renegade will not normally charge a fee for processing an access request unless the request is complex or is resource intensive. Poppy Renegade does, however, reserve the right to charge an administration fee if an individual requests access to their Personal Information more than once in a three month period.

Where Poppy Renegade offers online account management facilities, customers can use this capability to control aspects of their account, including amending or updating certain Personal Information.

Staying Anonymous

Poppy Renegade will not make it mandatory for visitors to the Site to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. Poppy Renegade may however request visitors to provide Personal Information voluntarily to Poppy Renegade (for example, as part of a competition or questionnaire).

Poppy Renegade will allow its customers to transact with it anonymously or by using a pseudonym wherever that is reasonable and practicable.

Transferring Information Overseas

If we send Personal Information overseas, Poppy Renegade will take steps which are both reasonable and practicable to ensure that the overseas recipient handles such information in accordance with the Act.

Poppy Renegade may disclose Personal Information to an overseas recipient without complying with the point above if:

you are Expressly Informed of the intended disclosure of your Personal Information to the overseas recipient, and you provide consent accordingly; or

we reasonably believe that the overseas recipient is subject to a law or a binding scheme that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the Act seeks to protect same and you can access mechanisms to enforce the protection of your Personal Information under that law or that scheme; or

the Disclosure is required or authorised by an Australian court or tribunal or under Australian law.

Changes to the Policy

Poppy Renegade may, in its sole discretion, update this Policy at any time and from time to time. Any changes will be effective when posted on the Site. Your continued use of the Site will indicate your acceptance of any changes to the Policy. All Personal Information, Collected both before and after any changes take effect, will be subject to the terms of the revised policy (for which you will be taken to have provided consent) unless you indicate otherwise by contacting Poppy Renegade. We urge you to refer back to this page regularly and especially prior to providing us with any Personal Information.

Glossary

“Collect” means gather, acquire or obtain by a lawful and fair means, information in circumstances where the individual is identifiable or identified.

“Direct Marketing” involves the Use and/ or Disclosure of Personal Information to communicate directly with an individual to promote goods or services through written, verbal or electronic means of communication. The goods or services which are marketed may be those of Poppy Renegade or a Related Body Corporate or those of an independent third party organisation.

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

“Express Consent Consequences” includes the fact that that we will not be accountable under the Act and you will not be able to seek redress under the Act in the event that you provide consent to the disclosure of your Personal Information by us to an overseas recipient and the overseas recipient handles your Personal information in breach of the Act.

“Expressly Informed” means the circumstance where we have provided you with a clear statement (either verbal or in writing) of the Express Consent Consequences.

“Opt Out” means an individual’s expressed request not to receive further Direct Marketing communications.

“Personal Information” means information that is not Sensitive Information, including information or an opinion (whether 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. This includes, but is not limited to, an individual’s name, address, telephone number and email address.

“Primary Purpose” is the main reason for the Collection of any Personal Information.

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

“Related Body Corporate” is given its meaning in the Corporations Act 2001 (Cth).

“Secondary Purpose” means a purpose of Use or Disclosure other than a Primary Purpose.

“Sensitive Information” is given its meaning in section 6(1) of the Act 1988 (Cth).

“Site” means the Site of Poppy Renegade and related webpages.

“Use” means the handling of Personal Information within Poppy Renegade.

Contacting Poppy Renegade

If you have any questions about this privacy policy, any privacy related dealings with us or a possible breach of your privacy or would like further information about our information management practices, our contact details can be found at http://www.poppyrenegade.com/contact-us/.

Last modified: 11 November 2015

 

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