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1 October, 2020
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    Privacy Policy

    Last Updated on 11th October 2019

    The Eacham Times (“ET,” “we” or “our”) cares about your privacy and the security of your information. We want you to be familiar with how we collect, use and disclose information, including personal information. This Privacy Policy describes our practices in conjunction with your access to our digital services. These services include our website www.eachamtimes.com.au email newsletters, social media pages, mobile and other applications owned and operated by us, and to any other services that display this notice (collectively referred to as the “ET Services”). This Privacy Policy does not apply to certain of our services that display a different privacy policy.

    The ET Services contain links to other websites for your convenience and information. We are not responsible for the privacy practices or the content of those sites.

    Contact Us

    If you have any questions, email us at editor@eachamtimes.com.au

    For information on how this Privacy Policy applies to your use of ET Services, please visit the relevant section below.

    1. What Personal Information Do We Gather About You?
    2. What Do We Do With The Personal Information We Collect About You?
    3. With Whom Do We Share The Personal Information We Gather?
    4. Other Information Collected Using Technology
    5. Third-Party Advertising
    6. How Do I Opt Out From Receiving Emails?
    7. How Do I Access, Change or Update My Personal Information?
    8. Sensitive Personal Information
    9. Data Retention 
    10. Is My Information Protected?
    11. Children’s Guidelines
    12. International Transfers
    13. Changes to This Privacy Policy

    1. What Personal Information Do We Gather About You?

    When you use the ET Services by, among other actions, browsing our site, completing a survey, entering a contest or otherwise interacting with our ET Services, we gather personal information. Personal information is information that identifies you as an individual or relates to an identifiable individual. Several different types of personal information can be gathered when you interact with the ET Services, depending on the type of service being used. Collection of personal information is necessary to delivering you the ET Services or to enhance your customer experience.

    If you disclose any personal information relating to other people to us or to our service providers in connection with the ET Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

    We and our service providers collect personal information in a variety of ways, including:

    A) Through the ET Services.

    i) Registration: When you register for an ET Service, we collect personal information. For example, registration to an event or conference requires that you complete a form that will include, at a minimum, your name and email address. 

    ii) Billing: To subscribe to an ET Service or enable payment and donations via the ET Services, we collect and use your name, address, telephone number, email address, credit or debit card information and other billing information. Note that ET Services at www.eachamtimes.com.au are not on a paid subscription at this time.

    iii) User-Generated Content and Public Activities (Including Comments and Reader Reviews): We offer you opportunities to engage in public activities on www.eachamtimes.com.au and other ET Services. “Public activities” are any actions you take on ET Services that are designed to be visible to other users, including comments, recommendations, reader reviews, ratings or any other items that you submit. If you choose to engage in public activities, you should be aware that any personal information you submit can be read, collected and used by other users of these services. We are not responsible for the personal information you choose to submit in the course of your public activities and we have no responsibility to publish, take down, remove or edit any of your public activities or submissions (except as required by applicable laws).

    iv) Contests, Sweepstakes and Special Offers: The ET collects personal information, such as your name and email, from you when you participate in, contests or special offers.

    v) Reader Surveys, Reader Panels and Market Research: We and our service providers collect personal information from you through voluntary surveys or feedback programs conducted via the ET Services, through our service providers’ platforms, by phone, by mail or during in-person interviews or focus groups. We will ask you for your consent to the processing of information at the point of collection. We also conduct similar research for advertisers.

    vi. Reader Experience Programs: When you interact with our interactive programs and answer questionnaires, we collect personal information about you.

    B) From Other Sources.

    i. Publicly available databases, including privately-held marketing and data analytics resources. For example, we may receive demographic information (age, sex, household income, job industry and job title) from these sources.

    ii. Joint marketing third party, when they share the information with us.

    iii. Social-media platforms or other third-party services. If you choose to link your social-media account or account relating to other third-party services to the ET Services, you may be asking third parties to send us certain information from those social media accounts or services accounts, and you are authorising us to collect, store, and use what they send us in accordance with this Privacy Policy.

    2. What Do We Do With The Personal Information We Collect About You?

    We collect, use or otherwise process personal information as allowed under applicable law, including where based on one or more of the following:

          • The consent you provide to us at the point of collection of your personal information;
          • The performance of the contract we have with you; 
          • The compliance of a legal obligation to which we are subject; or
          • The legitimate interests of the ET, a third party or yourself. “Legitimate interest” is a technical term under the regulation. It means that there are good reasons for the processing of your personal information and measures are taken to minimize the impact on your privacy rights and interests. “Legitimate interest” also references our use of your data in ways you would reasonably expect and that have a minimal privacy impact. We have a legitimate interest in collecting and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within the Eacham Times; and (3) to prevent fraud.

    A) Provide the ET Services You Request. We use the information we gather about you to enable your use of the ET Services and fulfill your requests for certain services, such as providing the ET Services’ functionality to you, providing you with customer service, responding to your inquiries, requests, questions, suggestions, compliments or complaints, sending you administrative information, and enabling you to participate in, polls, promotions, surveys, panels or research, and message boards.

    B) Analysis and Development of New Products and Services. We perform statistical, demographic and marketing analyses of users of the ET Services, so we can analyze or predict our users’ preferences for product and services development purposes, to determine our promotional campaign effectiveness so we can adapt our campaign to the needs and interests of our users, and to generally inform advertisers about the nature of our reader base. We use this information for analytical purposes, including analysis to improve customer relationships, to support strategic business decisions and our marketing tactics and to measure and track our brand health. We will engage in these activities to manage our Services, to comply with a legal obligation, or because we have a legitimate interest in doing so. 

    C) Customizing Your Experience. We use the information that we have to better understand our readers and customize certain features of the ET Services to provide our readers with an enhanced experience including to show our readers offerings, promotions or products that may be of interest to all readers, based on the demographic information, type of device readers are using to access the ET Services, our readers usage of the ET Services and readers reading history. We will provide personalized services because we have a legitimate interest when you write to us with any concern, comment, complaint or compliment. 

    D) Administrative Purposes. We and our service providers use the information we have about our readers for the following legitimate business purposes:

        • For auditing purposes, to verify that our internal processes function as intended and comply with legal, regulatory and contractual requirements;
        • For fraud and security monitoring purposes, including, for example, to detect and prevent cyberattacks; and
        • To understand and assess satisfaction with our ET Services.

    We engage in these activities to manage our relationship with readers, to comply with a legal obligation, or because we have a legitimate interest.

    E) Allowing You to Participate in Contests or Other Promotions. We may offer readers the opportunity to participate in contests or other promotions. Some of these promotions have additional rules containing information about how we will use and disclose your personal information. We use this information to manage our contractual relationship with you.

    F) Aggregating and/or Anonymising Personal Information. We aggregate and/or anonymize personal information so that it will no longer be considered personally identifying. We do so to generate other data for our use, which we may use and disclose for any purpose.

    G) User Generated Content and Public Activities. When you share or recommend links to content on a social-media platform (such as Facebook, Google+ and Twitter), that action and any information you share will be covered by that platform’s privacy policy. Any information you disclose in your public activities, along with your screen name or ID, or any image or photo, becomes public.

    3. With Whom Do We Share The Personal Information We Gather?

    A) Sharing With Service Providers. We contract with other companies, agents or contractors (“service providers”) to provide services on our behalf. These services are, for example, information technology and related infrastructure provision, customer service, ad serving, email distribution, list processing and analytics, research surveys/interviews/focus group management and analysis, or promotions management. In the course of performing these services, our service providers have access to your information including your personal information.

    B) Sharing With Other Third Parties. We will not sell, rent, swap or authorize any third party (except our service providers) to use your email address without your permission. Nothing in this Privacy Policy is intended to restrict our use or sharing of aggregated or de-identified information in any way.

    i) We may share personal information, such as name, company and title, about attendees to our live events and conferences with sponsors; if we do, we will notify you when you provide us the information.

    ii) We may also share personal information to third-party sponsors of contests, and similar promotions and will let you know at the point of collection of your information if we do.

    iii) We share in aggregate results from research surveys or panels with advertisers.

    D) Compliance With Legal Process. We may access, preserve and disclose personal information if we are required to do so by law or we have a good faith belief that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend our rights and property; (3) protect against misuse or unauthorized use of the ET Services; (4) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions); and (5) cooperate with public and government authorities (which may be outside your country of residence).

    E) By Using the ET Services, You May Elect to Disclose Personal Information.

    i) Public Activities: see above for more details on such activities. Public activities may be included in our RSS feeds, APIs and other distribution formats. As a result, your public activities may appear on other websites, blogs, or feeds. 

    ii) Through Your Social Sharing Activity: When you connect your ET Services with your social media account, you will share information with your friends associated with your social media account, with other users, and with your social media account provider. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by the social media provider’s privacy policy.

    4. Other Information Collected Using Technology

    Other information does not specifically identify you and are collected through technology. It includes tracking information collected by us as well as third parties.

    We use various internet technologies to manage, and track the use of, the ET Services. We use and disclose this information for any purpose, except where we are required to do otherwise under applicable law. Information that we collect using these technologies is combined with personal information about you. If we combine information with personal information, we will treat the combined information as personal information.

    A) Device Information. We collect information about the computer, mobile device or other device you use to access the ET Services, such as Internet protocol (IP) addresses (the region or general location where your computer or device is accessing the Internet), geolocation information, unique device identifiers, browser type, browser language and other transactional information.

    B) Cookies, Beacons, Local Storage and Other Similar Technologies. We use “cookies,” Web beacons, tags and scripts, and other similar technologies including local storage objects such as HTML5. These technologies allow us to manage access to and use of the ET Services, recognize you and provide personalization, and help us understand how people use the ET Services. You will not be able to access certain areas of our websites, including www.eachamtimes.com.au, if your computer does not accept cookies from us. Because there is no accepted standard on how to respond to “do not track” browser-based signals, we do not respond to such signals. We transmit website usage information to third parties in order to show you advertising for the Eacham Times when you visit other sites.

    C) Analytics, Log Files and Reading History. As is true of most web sites, we gather certain information automatically and store it in log files. This information includes IP address , browser type, operating system and other usage information about the use of the ET Services, including a history of the pages you view.

    One of the analytics service providers we use is Google Analytics. To learn more about how Google use data, visit https://policies.google.com/privacy/partners. For opt-out options specific to Google Analytics, please visit https://tools.google.com/dlpage/gaoptout. 

    5. Third-Party Advertising

    Some of the services and advertisements included in the ET Services, including on www.eachamtimes.com.au are delivered or served by third-party companies, which may collect information about your use of the ET Services.

    These companies place or recognize cookies, pixel tags, web beacons or other technology to track certain information about our ET Services website users. For example, in the course of serving certain advertisements, an advertiser may place or recognize a unique cookie on your browser in order to collect certain information about your use of the ET Services. For another example, an advertiser or ad server may also be able to collect your device’s unique identifier in the course of serving an ad. In many cases, this information could be used to show you ads on other websites based on your interests.

    We do not have access to, nor control over, these third parties’ use of cookies or other tracking technologies or how they may be used.

    For example, we use Google to serve advertisements on the ET Services, which use the Google Doubleclick cookie, and in some cases, a unique device identifier, to show you ads based on your visit to www.eachamtimes.com.au and other sites on the Internet. You may opt out of the use of the Google Doubleclick cookie by visiting the Google ad and content network privacy policy. Your access to www.eachamtimes.com.au should not be affected if you do not accept cookies served by third parties

    6. Sensitive Personal Information

    Unless specifically requested (for example, in connection with a particular survey), we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the ET Services or otherwise to us. Any requested information that includes sensitive information about health, political opinions, ethnicity, race, religion, sex life or sexual orientation can be left unanswered.

    7. Data Retention 

    We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

        • Whether retention is advisable in light of our legal position (for example, in light of applicable statutes of limitations, litigation or regulatory investigations).  

    8.  Is My Information Protected?

    We seek to protect personal information with reasonable organizational, technological and physical safeguards commensurate to the sensitivity of the personal information.   Although we take appropriate measures to safeguard your information, we cannot guarantee its absolute security.

    9. Children’s Guidelines

    We do not knowingly collect or store any personal information from children except as permitted by applicable law.

    10. International Transfers

    The Eacham Times is headquartered in Queensland, Australia. The information you provide to us or that we obtain as a result of your use of the ET Services is collected in your country and subsequently transferred to Australia.

    In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.

    11. Changes to This Privacy Policy

    We evaluate this privacy policy periodically in light of changing business practices, technology and legal requirements. As a result, it is updated from time to time. Any such changes will be posted on this page.