1. Our Commitment
Your privacy is important to us. This document explains how Creative Surrounds (ABN 50 238 178 297) (“we” or “us”) collects, handles, uses and discloses your personal information collected through your use of any of our Services or Websites. We review regularly our information handling practices to ensure we comply with our legal obligations including the Privacy Act 1988.

2. Why we collect personal information
We own all information collected by or through use of or access to any of the Services and any Website. We will not sell, share, or rent this information to others in ways different from what is disclosed in this document. We collect information at different times, and for different reasons during the use of or access to Services or a Website and in several different ways. We will only use fair and lawful ways to collect personal information. Sometimes we may need to collect information from third parties. However, we will collect personal information directly from you if it is reasonable and practicable to do so.

3. How we collect personal information – direct input by you
In order to use Services you may be required to provide certain personal information. If you do not provide certain information, you will not be able to use or obtain the full benefit of the Services. This information is clearly identified at the point of collection.

Other personal information that is requested is optional (but encouraged, so that your experience is more personal).

4. How we collect personal information – submission by or collection from 3rd parties
We may request third parties to provide or allow access to and collection of information, including personal information that the third parties hold and are authorised or entitled to disclose, directly to us, verbally and in hard copy and electronic records or documents, whether stored in or provided by way of digital storage media, electronic communications, including through a computer, communications interface or API available over a SSL protocol.

5. How we collect personal information – cookies
Cookies are small text files that are placed on your computer by websites that you visit, or certain emails you open (including the Websites or emails we send in connection with Services). Cookies are used by us and third parties that provide services to us in relation to our Websites, payment, inventory management and other information systems and social media and other forms of marketing to make our websites and electronic communications work, or work more efficiently, as well as to provide business and marketing information to us. Use of a cookie is in no way linked to any personal information. Most web browsers allow some control of most cookies through the browser settings.

6. How we collect personal information – publicly available information
We may source information, including personal information, from publicly available information sources.

7. How we collect personal information – financial information
If you establish a facility to pay for Services or place an order for Services using an App, we request certain personal information from you, including your name, email, and postal address and financial information including credit or debit card number, CCV number and credit or debit card expiration date (financial information). We use this financial information to invoice and charge you for Services, as well as to verify your contact information. When financial information is collected, it passes through our bank (and for transactions outside Australia, correspondent banks that may be used by our bank in respect of foreign currency transactions) for processing. We never permanently store a complete record of the financial information but may retain and use some parts of that financial information (but never a credit or debit card number) as part of maintaining a record of transaction history and for account and Service verification, fraud prevention and management, audit, complaints handling and dispute resolution purposes. All data is stored and processed on third party secure servers certified to comply with international and financial industry standards for managing risks to security of information.

8. How we use your personal information
We may use and disclose your personal information (in whole or in part, and in identifiable and de-identifiable formats) in order to provide any Services, confirmation of personal information held and the fact that a Service has been provided or requested, or in relation to any service that is ancillary or necessary to those Services, including administration, management, account management, verification and auditing of Services and our business, complaints handling, dispute resolution, product and services improvement and development and service support and for marketing (including by third parties, in respect of our Services and other services or products including third party products and services), developmental, research, statistical, analytical, validation and archival purposes (purpose).

For any statistical or other analysis or similar research we will only use de-identified information.

We may retain and use all data that is collected during or as a result of any of Services (other than data from a cookie as a result of a visit to or use of a Website) in order to maintain and improve the Services and to validate the integrity, accuracy and consistency of actions, measures, principles, expectations and outcomes underpinning our Services and service standards. This requirement is continuous and ongoing and means that this data is always retained and able to be used by us.

9. How we use your personal information – disclosure to third parties
We will only disclose your personal information to third parties for a purpose and with whom we have entered into an agreement that gives you (or that the law requires to give you) at least the same level of protection to your personal information as we do.

We may enter into agreements with third parties to whom disclosures may be made who are located outside Australia. If this occurs, and it is practicable to do so, we will update this document to provide information, as required by law, about the location of actual or likely recipients of any personal information held and disclosed.

10. How we use your personal information – direct marketing
You consent to use or disclosure by us of your personal information for direct marketing (including direct marketing by third parties), unless you have requested to opt-out of any direct marketing communications.

Any direct marketing campaign by us or on our behalf will provide a method for you to opt-out (if you have not already done so). If you wish to opt-out or you wish to no longer receive direct marketing communications please contact our privacy officer by email.

11. Information access
On written request (and subject to verification of your identity), we will give you access to the personal information we hold about you. If any personal information we hold about you is out of date or inaccurate, we encourage you to let us know, and ask us to correct it. If we cannot accommodate your request, you will receive our reasons in writing.

We will make available to you a copy of this document free of charge and in the most appropriate form. If you require a copy of any amended version of this document other than as provided on the Websites, please contact our privacy officer by email. We will use reasonable efforts to provide you with a copy of this document in the form or manner you request.

12. Links
Services that are offered online may contain links to other sites. We are not responsible for the privacy or data handling practices of any sites other than the Websites.

13. Information Security
We will take reasonable steps to ensure the personal information that we collect, hold, use or disclose is accurate, complete and up-to-date. We recommend you notify us if you change your address or contact details as soon as possible. This will help us to maintain your privacy by ensuring that any communications are sent to the correct postal address, email address, or telephone number. This can be done online or by contacting our privacy officer by email.

We will take reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification or disclosure. We will also take reasonable steps to destroy or permanently de-identify personal information if we no longer need it for any purpose.

If you enter financial information on or using a Website, that information is encrypted using SSL technology. All online payment transactions performed through a Website using this technology are secured payments. When financial information is collected, it passes through to our bank (and for transactions outside Australia, correspondent banks that may be used by our bank in respect of foreign currency transactions) for processing. We never permanently store complete financial information.

14. Changing our approach
We may amend or replace this document at any time in accordance with the law and our commercial interests. We will give notice on the homepage of each Website and will post the amended or replaced document on each Website.

If we want to use personal information in a manner different from that when it was collected, we will notify you by email (or as otherwise reasonably requested by you). You decide whether we can use that information in this different manner. Subject to that decision, we will only use information in accordance with the version of this document under which the information was collected.

If you wish to be notified other than by email please provide in writing your preferred contact details and we will endeavour to accommodate any reasonable request.

Please visit our Websites regularly to check for updates or amendments to or replacement of this document.

15. If you are not happy
If you feel we are not complying with this document or our obligations in relation to your personal information, please contact our privacy officer by email or through any of the means identified below.

We will do our best to resolve as quickly as possible any issue or complaint that you notify us of in writing. If you are not satisfied with our response, you can refer the matter to the Office of the Australian Information Commissioner. Information about the Office of the Australian Information Commissioner, the complaints process and how to lodge a complaint is available here.

16. Office of the Australian Information Commissioner
t: 1300 363 992
m: GPO Box 5218 Sydney NSW 2001
e: enquiries@oaic.gov.au
w: oaic.gov.au/about-us/contact-us-page

17. Definitions
“App” means any online or other smart phone, tablet (or similar device) enabled application or user interface offered by or branded as Creative Surrounds.

“we” or “us” means Creative Surrounds, ABN 50 238 178 297.

“Services” means the services we offer from time to time, including but not limited to provision of legal advice, intellectual property management and protection advice, audits, training and programs, compliance, risk management and corporate governance advice, audits, training and programs, policy analysis and development, program evaluation and reviews, training, services that are ancillary to those services or the operation and management of our business and feedback or other interaction between an individual and us in connection with any of those services and includes services integrated with or offered as part of goods or services of a third party.

“Website” means each of the websites located at www.creativesurrounds.com.au the mobile versions of each website, any App and any other domains we advise from time to time.