BFJ MEDIA (TRADING AS BFJ DIGITAL) PTY LTD ABN 22 616 127 185 PRIVACY POLICY

Protecting personal information and privacy has always been important to us at BFJ MEDIA Pty Ltd ABN 22 616 127 185 (‘BFJ MEDIA TRADING AS BFJ DIGITAL’). Amendments to Australia’s Privacy Act 1988 (Cth) (“Privacy Act”) introduced Australian Privacy Principles (APP) to replace the National Privacy Principles in March 2014. These Privacy Principles are to ensure that your personal information is handled in an open and transparent way.

This is a summary of the policy of BFJ Digital on the management, integrity, security, collection, disclosure of and access to the personal information of clients. We recommend that you take the time to read this policy and retain a copy for future reference.

Personal Information collected and disclosed by BFJ MEDIA

Information
Purpose of collection and disclosure of personal information and how we protect that personal information

• Contact details including name, address, occupation, email, phone number and professional contact
• Copies of identification documents
• Date of birth
• Financial information
• Court proceeding information
• Publicly available information
• Information provided by on or behalf of prospective employees

Personal information is collected for:
• identification;
• communication with you;
• to provide the services that you request;
• to do all things necessary to administer those services;
• to develop, manage and improve those services;
• investigate, prevent and deal with breaches of our agreement with you;
• conduct client surveys and inform you of any improvements that we have made to our services;
• deal with credit reporting bodies (CRBs) as to your information;
• providing ongoing information and marketing about products and services to you that we believe may be of interest to you and where you have signed up for such information and marketing.

This information is collected either directly from you, as authorised by you, as is required for our reasonable business purposes, or in accordance with the law. Where it is unreasonable or impractical to collect the information directly from you, we may collect that information from other persons that we deal with. When your personal information is provided to us by other people including family, colleagues, clients or agents, and where it is reasonable to assume you would not already know or expect us to have the information, we will take reasonable steps to inform you that we have received your personal information.

We may disclose your personal information to third parties including:
• employees of BFJ MEDIA;
• organisations and contractors that may be used to provide you with requested services;
• your company or organisation if you use our services under a corporate account;
• banks;
• credit reporting and fraud checking agencies;
• debt collection agencies, if you default in payment of monies owed to us;
• government, regulatory and law enforcement agencies where the disclosure is required or authorised by law.

You may choose not to provide some of your personal details however this may limit us providing our services to you.

Unsolicited or sensitive information
We may sometimes collect sensitive information. Sensitive information is only collected if the information is reasonably necessary for the purpose of performing our functions and activities. When we collect sensitive information we will collect it directly from you or with your consent unless we are otherwise entitled to do so. We will destroy unsolicited information, whether sensitive or otherwise, unless it is necessary for the reasonable purposes of our business.

Overseas Disclosure of information
We generally do not disclose personal information overseas. However, if for any reason BFJ MEDIA needs to disclose your personal information overseas, we will comply with the requirements of the Privacy Act that relates to trans-border data flow.

Government related identifiers
Unless you otherwise authorise us, we will not collect and/or disclose government related identifiers with the exception of your driver’s licence information which is collected in order to accurately identify you.

Marketing

You acknowledge and agree that you consent to the receipt of direct marketing material from BFJ MEDIA. The marketing material may be information about BFJ MEDIA, information about services, products, events, Related Projects and/or other communications.

We will only use your personal information for this purpose if we have collected such information direct from you, and if it is marketing material of a type which you would reasonably expect to receive from us. We do not use sensitive personal information in direct marketing activity. Our direct marketing material will include an option by which you can request not to receive further communications of this nature. Alternatively, you may opt out of these communications at any time by contacting the following email [email protected].

Security and Access of your Private Information

BFJ Digital endeavours to make sure the information we collect is accurate, complete and up to date. We shall take reasonable steps to protect personal information from misuse and loss and from unauthorised access, modification or disclosure.

Collection of Personal Information

If BFJ Digital collects, holds, uses or discloses Personal Information in the course of or relating to this agreement, BFJ MEDIA will:

(a) handle all Personal Information in accordance with this privacy policy and in accordance with applicable privacy laws; and

(b) only use Personal Information for the purpose of performing its obligations under this agreement.

Privacy Warranties

BFJ MEDIA warrants that it complies with and will continue to comply with the Privacy Act and all other applicable privacy laws.

You warrant that you comply with and will continue to comply with the Privacy Act and all other applicable privacy laws.

You warrant that you will not provide any sensitive information to BFJ MEDIA unless that information is necessary for BFJ MEDIA to perform its obligations under any agreement with you and then only with BFJ MEDIA specific (and the individuals whose Personal Information is being disclosed) written consent.

Breach of Privacy

If BFJ MEDIA becomes aware, or there are reasonable grounds to suspect, that a data incident has occurred, BFJ MEDIA will:

(a) take reasonable steps to contain the data incident and prevent any further serious harm to affected individuals;

(b) notify you in writing stating the:

a. nature and details of the data incident;

b. specific Personal Information affected (where possible); and

c. actions taken by BFJ MEDIA.

(c) identify whether the data incident is an eligible data breach by conducting a thorough investigation of the data incident within 20 Business Days of becoming aware of the data incident (Data Breach Investigation);

(d) provide a copy of the report of the Data Breach Investigation to you on completion;

(e) engage in discussions with you regarding:

a. the conduct and outcomes of the Data Breach Investigation; and

b. in the case of an eligible data breach, whether you and BFJ MEDIA will make the relevant notifications under the Privacy Act; and

c. where it is agreed by the parties that BFJ MEDIA is making the relevant notifications, you must approve the notifications before they are made (such approval to be given promptly and not to be unreasonably withheld).

You acknowledge that BFJ MEDIA is reliant on you for direction as to the extent to which BFJ Digital is entitled to use personal information disclosed to it in the course of and for the purpose of your dealings

You indemnify BFJ MEDIA for any claim brought by any third party in connection with any act or omission by BFJ MEDIA in relation to a third party’s Personal Information to the extent that such act or omission resulted directly from your instructions, warranties, or your breach of this agreement.

Destruction of Information

BFJ MEDIA will destroy personal information upon your request (by telephone and/or by e-mail) or when the personal information is no longer required. The exception to this is if the personal information is required in order to fulfil the purpose of this organisation or is required to be maintained and/or stored in accordance with the law.

Your access

You may request access to your personal information we hold about you at any time.

External access to information

Any authorised representative including accountants and financial planners must be authorised to receive your personal information, security checked and verified and it be recorded on our database except if it’s required in accordance with the law such as a Federal Act.

The following measures are in place in order to deal with any enquiries that would result in the divulgence of personal information:

Telephone Enquiry
Administration staff will advise the third party of privacy requirements, and seek authorisation in writing from you to divulge personal information before providing said information.

Written Enquiry
Response is provided to the address on the written enquiry but only if it is the same as in BFJ MEDIA records.

Authorised Representatives
Any authorised representative including accountants, solicitors and spouses must have been authorised by you, security checked and verified and it be recorded on BFJ MEDIA database except if it’s required in accordance with the law such as a Federal Act.

Contact for Further Information or Complaints

If you have any questions about how we handle your personal information or if you believe that we have handled your personal information inappropriately, you can contact BFJ MEDIA by telephone on 07 3106 3777 or e-mail [email protected]. BFJ MEDIA will respond to any complaint within 14 days of receipt and will take all reasonable steps to make a decision as to the complaint within 30 days of the receipt of the complaint.

If you are not satisfied with the way in which we handle your enquiry, you can call the Office of the Australian Information Commissioner on 1300 363 992 or make a complaint to the Information Commissioner on the OAIC website at https://www.oaic.gov.au/.

Consent

You hereby agree and consent to the contents of the collection, use and disclosure of your personal information. In the event that you do not wish to agree or consent to any of the above use, collection and disclosure of your personal information by BFJ Digital, BFJ Digital warrants that any request by you to withdraw your consent or agreement shall be deemed as confirmation by you to cease any and/or all collection use and disclosure of your personal information. Request (by telephone and/or by e-mail) can be made by you to BFJ MEDIA in that regard.

Changes to this Policy

This is our current privacy policy outlining our personal information management practices. It replaces any previously published privacy policy. From time to time, we may need to vary this policy. If we do so, we will provide you with an updated version, which shall apply to all the information held by us at the time.