Privacy Policy

Privacy Policy

Last Updated: 8th March 2016

Focal Attractions Pty Ltd (ABN 86 121 918 090) (Focal Attractions or We/we or Our/our or Us/us) is committed to respecting the privacy of your personal information.

This Privacy Policy explains our policy for dealing with personal information that we collect through the following channels (here and after, the Collection Channels):

You may contact us with any queries you may have in respect of this Privacy Policy or your personal information by contacting Focal Attractions’ privacy officer via email: martin@focalattractions.com.au or telephone: (02) 8296 0200

Personal information is important to Focal Attractions

Focal Attractions is committed to safeguarding personal privacy. It recognises that you have a right to control how your personal information is collected and used. Providing personal information is an act of trust and it is taken seriously. Unless given consent to do otherwise, Focal Attractions will only collect and use personal information as set out below.

Throughout this Privacy Policy, we refer to your ‘personal information’, which means information which identifies you as an individual or which renders you reasonably identifiable. Your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address and workplace contact details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences.

Focal Attractions has developed and implemented its Privacy Policy with respect to personal information to reflect world best practice on privacy policies. These principles meet and exceed the requirements of the Privacy Act 1988 (Cth) (as amended) and the 13 Australian Privacy Principles.

In order to keep up with changing legislation and best practice, we may revise this Privacy Policy at any time without notice. We will post any changes to this Privacy Policy on our Websites, so we encourage you to check this Privacy Policy from time to time.

In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

Anonymity and pseudonymity

Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our Collection Channels will seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the information identified below.

Kinds of Personal Information that Focal Attractions Collects and Holds

Personal information that may be requested or collected by us includes:

  1. contact information such as your full name, date of birth, telephone number, mobile telephone number, current and valid email address, residential address and postcode;
  2. more detailed contact preferences;
  3. information regarding your personal and professional interests and your networks;
  4. information about your employment history and future plans, and documents relating to your employment;
  5. information about your education and qualifications;
  6. information about your experience with our products or services or third party products or services listed on a Website. This information is requested in order to tailor our subsequent communications to you and continuously improve our products and services;
  7. your credit card details (where you purchase any products or services from us);
  8. the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to Focal Attractions and used for the purposes set out in this policy (which may include using their details for marketing purposes);
  9. any other personal information which you directly provide to Focal Attractions. Where you provide us with such unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy); and
  10. any other personal information requested or required by a Collection Channel.

Sensitive Information

We will only collect sensitive information with your consent. Where you provide us with any sensitive information (including, but not limited to, information about your racial or ethnic origin, religious affiliation, political opinions, sexual orientation and/or medical history) we will only use this information for the purposes stated on the Collection Channel.

How Focal Attractions Collects and Holds Personal Information

Focal Attractions will only collect or monitor any personal information about you with your consent including as provided in this Privacy Policy or if it is otherwise lawful to do so. The only personal information collected by us is what has been collected by or provided to us in accordance with this Privacy Policy or has been provided to us lawfully by third parties, including our clients and customers.

Active Information Collection

Personal information may be collected (and combined) via our Collection Channels if you:

  1. have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party;
  2. sign-up and/or register to become a member of any Collection Channel, or provide your details to us via any Collection Channel;
  3. purchase a product or make a booking via a Collection Channel;
  4. subscribe to any newsletters, updates, alerts or news and media releases, or request launch or event information or information about our products or services or other information services as well as third party products or services;
  5. complete and submit any forms or surveys to us, either physically or electronically;
  6. conspicuously publish or provide on request your personal information to Focal Attractions;
  7. contact us directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
  8. participate in any competitions, offers, promotions or marketing activities; 
  9. interact with a Website for a specific purpose; or
  10. interact with or browse a Website generally.

Personal information is requested in order to facilitate or provide you with certain content, products or services, and information about such content, products or services (including the uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), marketing materials, newsletters, electronic newsletters (e-newsletters), news and media releases / launch information, and also to advise you of other Focal Attractions or third party products, services, offers, competitions or events which may be of interest. No one is obligated to provide personal information. However, failure to do so may result in Focal Attractions being unable to facilitate or provide you with certain content, products or services, products or services information, upcoming promotion, competition, offer or event information or accept competition entries (where applicable).

We may also obtain your personal information from legitimate third party sources including social media sites, list brokers, referral agents and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so.

Children

Personal information will not be collected by any person who is known by Focal Attractions to be under the age of fifteen (15) without the consent of a parent or legal guardian. Persons under age fifteen (15) may only use our Websites with the involvement and consent of a parent or legal guardian.

Passive Information Collection

As with many commercial websites, Focal Attractions may also collect information which tells us about visitors to our Websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a Website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally, you consent to the collection of such information where it is personal information.

As you navigate through our Websites, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as Unique Device Identifiers (UDI), cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). In certain circumstances, this information may be considered anonymous information or personal information under the Privacy Act 1988 (Cth). This is dependent on the device used and the method by which an individual connects to the Internet. Your Internet browser automatically transmits to the Website you are browsing some of this anonymous information or personal information, such as the URL of the website you just came from, the Internet Protocol (IP) address, the UDI (if applicable) and the browser version your device is currently using. Our Websites may also collect anonymous information or personal information from your device through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of a Website might not work without cookies and this may limit the services provided by a Website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf.

Our Websites may use and combine such passively collected anonymous information or personal information from various third party sources, including as described in paragraph 15, to provide better service to Website visitors and users, customise a Website based on your preferences, compile and analyse statistics and trends, and otherwise administer and improve a Website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website, you consent to information about you being collected, compiled and used in this way.

For more information about cookies and how you can opt out, you can visit http://www.youronlinechoices.com.au/.

Purposes for which Focal Attractions collects, holds, uses and discloses personal information

Personal information collected will be collected, used and/or disclosed for the following primary purposes:

  1. For the purposes for which it was collected (as advised in this Privacy Policy).
  2. For the purposes stated in a privacy collection statement on a particular Collection Channel.
  3. To maintain the functionality of a Website, including the provision of information to you relating to the content available on the Website and e-commerce transactions conducted via the Website.
  4. To fulfil obligations in respect of any upload terms of use, sale and purchase contract and/or any other contract between you and Focal Attractions.
  5. To send you any technical, administrative or legal notices important to our Websites and services generally.
  6. To provide you with information about your transactions (including uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), content, services and products, to provide direct marketing materials, events, special offers, competitions and promotions in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email) or any other form of electronic, emerging, digital or conventional communications channel.
  7. To maintain our relationship with you.
  8. To render services related to Focal Attractions (including after sales services and enquiries).
  9. To undertake recruitment for Focal Attractions.
  10. To manage your employment with Focal Attractions (if applicable).
  11. To provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages.
  12. To respond to customer enquiries.
  13. To improve Website and system administration.
  14. To obtain opinions or comments about products and/or services and to conduct other research and development.
  15. To record statistical data for marketing analysis and to conduct market research.
  16. To share personal information with Focal Attractions group companies, our promotional partners and other trusted third parties in the manner described below.
  17. To compile personal information into commercial databases and to share it (including via a database downloading function) with subscribers.
  18. To disclose personal information including your name and IP address.

For the purposes described above, personal information may be shared with Focal Attractions group companies, Focal Attractions promotional partners, Focal Attractions clients, customers and subscribers to commercial databases made available by Focal Attractions (including, but not limited to, The Source) and other trusted third parties (and their directors, servants and agents) either in Australia or Asia. Failure to provide personal information may result in Focal Attractions being unable to provide you with certain content, information, upcoming promotion, event or product information and/or accept promotion entries (where applicable).In order to operate a Website or deliver a service (including, for example, processing of credit card payments), personal information may also be shared with Focal Attractions group companies, selected service providers and/or other trusted third parties either in Australia or Asia. Focal Attractions group companies, selected service providers and/or other trusted third parties may be engaged by Focal Attractions to perform a variety of functions, such as data storage, processing credit card payments, fulfilling orders, payroll management, conducting market research, assisting with promotions and surveys, and providing technical services for our Websites. These companies may have access to personal information if needed to perform such functions. Your credit card details are only used to facilitate your booking and/or purchase. They are not used for any other purpose and will never be supplied to a third party.

Focal Attractions recognises the trust with which you provide personal information, and except as stated in this Privacy Policy, such information will not be used or disclosed for any other purposes without consent. However, Focal Attractions reserves the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect the rights or property of Focal Attractions, any member of Focal Attractions group, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.

Contact by Focal Attractions

Focal Attractions group companies (and their directors, servants and agents), Focal Attractions promotional partners or trusted third parties (and other selected service providers and other non-Focal Attractions companies or professionals) either in Australia or overseas, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the primary purposes for collection of personal information as stated above.

Focal Attractions does not send advertising or marketing information without obtaining prior consent, for example the consent contained within this Privacy Policy, or unless otherwise lawful to do so. If you receive communications from Focal Attractions which you do not wish to receive, you may remove your name from the database either by utilising the functional unsubscribe facility (if the communication is via commercial electronic message) or by contacting Focal Attractions via email: martin@focalattractions.com.au or telephone: (02) 8296 0200. Please allow 30 days for this request to be processed.

Despite removing your name from the database from receiving future advertising and marketing information, Focal Attractions may send you non-commercial “Administrative Emails”. Administrative Emails relate to a Focal Attractions user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular Focal Attractions user account. If you do not wish to receive such communications from Focal Attractions, you may remove your name from the database by utilising the functional unsubscribe facility.

Ability of others to view information

Focal Attractions may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, contribute comments, communicate with other users, provide reviews for content, products and/or services or interact with or vote on particular content. This information may be shared with others and may be publically posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publically available and may be read, collected and used by others outside of our Websites. Focal Attractions is not responsible for the conduct of others who may read, collect and use this information.

Our system automatically captures the IP address of those who post comments on a Website. We reserve the right in circumstances such as attempts to mislead other users about a comment poster’s identity through statement or omission, to disclose that information.

Your right of access

You have the right to access and review your personal information that may be recorded on a Focal Attractions database. Information may be reviewed by contacting Focal Attractions’ privacy officer via email: martin@focalattractions.com.au or telephone: (02) 8296 0200. Please allow 30 days for this request to be processed.

Changing and deleting the information we have about you

Information contained on the database may be amended, or your preferences for contact from us changed, by contacting Focal Attractions’ privacy officer via email: martin@focalattractions.com.au or telephone: (02) 8296 0200. Please allow 30 days for this request to be processed.

In the same way, a request may be made to delete personal information, and all reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in Focal Attractions being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), other content, services or product information, upcoming promotion, competition or event information, and/or provide certain content, goods or services.

We are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this policy.

Storage and security of personal information

Focal Attractions will endeavour to take all reasonable steps to keep secure any personal information recorded (including your credit card details), and to keep this information accurate, up to date, complete and relevant. The information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas.  Online credit card payments are processed using a third party payment gateway run by Web Active Corporation Pty Ltd (eWay). eWay provides a PCI-DSS (Payment Card Industry Data Security Standard) compliant payment gateway that is used to process payments. For more information, you can read eWay’s Privacy Policy.

Disclosure of personal information to overseas recipients

In some cases, Focal Attractions may disclose your personal information to overseas recipients. Focal Attractions employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by Focal Attractions. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. Focal Attractions will not be held responsible for events arising from unauthorised access to personal information.

Focal Attractions and links to other websites

Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. Focal Attractions is not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.

We may use third party advertisements on our Websites. All third party advertising, if paid for, is paid for by the relevant third party advertisers and are not recommendations or endorsements by Focal Attractions or any of its affiliates. Focal Attractions is not responsible for the content (including representations) of any third party advertisement on a Website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties.

Related Focal Attractions Websites

All Websites operated by Focal Attractions will adhere to this Privacy Policy. The policies on the Websites of some members of Focal Attractions group may vary, however, because of local customs, practices or laws.

Sale of the Company

If Focal Attractions merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy. 

Problems or queries

If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled and/or disclosed your personal information, please contact our privacy officer via one of the following channels:

Address: 46-48 Balfour Street

Chippendale, NSW, 2008

Telephone: (02) 8296 0200

Email: martin@focalattractions.com.au

Please allow 30 days for this request to be processed.  If you do not receive a satisfactory response from Focal Attractions to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at http://www.oaic.gov.au/about-us/contact-us-page.

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