PRIVACY POLICY

This Privacy Policy describes how we collect, use, process and distribute your information, including Personal Data which includes certain identifiable information about you, like your name, email, address, telephone number, bank account details, payment information, support or contact queries, online community comments and so on.
We will not use or share your information with anyone except as described in this Privacy Policy.
Please read this Privacy Policy carefully. This Privacy Policy may be amended from time to time with changes, additions and deletions, at our sole discretion. You should check this page regularly to ensure that you are aware of any changes. Your continued use of the Website following any amendments indicates that you accept the amendments. In the event of a material change, we will let you know via email and / or a prominent notice on our Website.
By using our Website or its content, you consent to this Privacy Policy as at June 2019, whether or not you have read it.


What personal information do we collect, use and disclose?

Circular Digital, in the course of conducting its business, collects a range of personal information including, amongst other things, names, email addresses, mailing and residential addresses, business and home phone numbers.
Circular Digital only collects personal information that is reasonably necessary for one or more of Circular Digital functions or activities.
Circular Digital only collects sensitive information (a) if it is reasonably necessary for Circular Digital’s functions or activities or an exception applies under the Privacy Act and the individual to whom the information relates has given their express consent to the collection.
(a) Sensitive Information includes information about an individual’s mental health, disability, racial or ethnic origin, criminal convictions, religious affiliation and political affiliation.


How does Circular Digital collect the information?

Collection of personal information by Circular Digital is only done by lawful and fair means.
Circular Digital collects personal information about an individual directly from that individual wherever it is reasonable and practicable to do so. This may be through contact forms, letters, emails, websites, receipts, telephone conversations, consultations and attendance at events.
Circular Digital will always take reasonable steps to ensure individuals are aware of (amongst other things) the facts and circumstances of collection, the purpose of collection and information about Circular Digital’s privacy policy.


What does Circular Digital use personal information for?

Circular Digital will only use or disclose personal information for the Primary Purpose including things such as managing our relationships, performing administrative functions, informing customers and others about our products and services by direct marketing methods, market research, building and maintaining business relationships, implementing our communication model and complying with legal requirements.
Where Circular Digital uses personal information other than for the Primary Purpose, Circular Digital does so in accordance with the Privacy Act and APP 6.


Direct Marketing

Circular Digital engages in direct marketing of its products and services from time to time.
Circular Digital only uses personal information for direct marketing in circumstances where Circular Digital has collected the information directly from the individual and that individual reasonably expects to receive direct marketing material from Circular Digital (for example, where an individual has signed up to receive direct marketing material from Circular Digital).
Circular Digital offers all individuals the opportunity to unsubscribe from receiving direct marketing communications.


Access to and accuracy of personal information

Circular Digital takes all reasonable steps to ensure that the personal information it collects, uses and/or discloses is accurate, complete, up to date and relevant.
You have the right to ensure that your personal information which is held by Circular Digital is accurate. To make a request to access and/or correct your personal information, please contact Circular Digitals’ Privacy Officer using the contact details provided below.
While Circular Digital will always endeavour to give access to personal information free of charge, Circular Digital reserves the right to charge individuals for access to personal information to cover costs associated with:

• searching for, locating and retrieving personal information and deciding which information to provide to the individual;
• using an intermediary; and
• reproducing and sending the information.

Circular Digital is entitled to refuse to give access to personal information in certain circumstances. For further information, please contact Circular Digital’s Privacy Officer using the contact details provided below.


Security of personal information

Circular Digital takes all reasonable steps to ensure that information held by Circular Digital is safe and secure, and that it is protected from misuse, loss, unauthorised access, modification and disclosure.
Circular Digital stores and secures all personal information via a third party data storage provider. Circular Digital will make all reasonable endeavours to ensure the storage provider is compliant with the APP’s.
Destruction and de-identification of personal information.
Circular Digital will take reasonable steps to de-identify or destroy personal information when it is no longer needed by Circular Digital except where the information forms part of a Commonwealth record or Circular Digital is required, by law or a court/tribunal order, to retain the information.


Anonymity and pseudonymity

Individuals have the option of dealing anonymously or by pseudonym with Circular Digital unless it is impracticable to do so or Circular Digital is required, by law or a court or tribunal order, to deal with identified individuals.


Changes to privacy policy

Circular Digital reserves the right to amend this privacy policy from time to time. Changes will be posted on the Circular Digital website.


Complaints

If you believe there has been a breach of the APPs or an APP Code, please contact Circular Digital’s Privacy Officer using the details provided below.
Circular Digital takes privacy complaints very seriously. If you make a complaint, Circular Digital will respond within 5 business days to let you know who is responsible for managing your complaint. Circular Digital will try to resolve your complaint within 10 business days. When this is not possible, Circular Digital will contact you within that time to let you know how long we will take to resolve your complaint.
Circular Digital will investigate your complaint and where necessary, consult with third parties about your complaint. Circular Digital will make a decision about your complaint and write to you to explain our decision.
Individuals can also complain directly to the Office of the Australian Privacy Commissioner. Details about how to file a complaint can be found at www.oaic.gov.au or by calling 1300 363 992.


Contact Circular Digital

All queries and complaints should be directed to Circular Digital.
Contact Name: Clare McFadyen
Address: Mackay Qld 4740
Email: clare@circulardigital.com.au

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