1. BACKGROUND
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| 1.1 |
This Privacy Policy summarises how LA Inc. handles your personal information in the performance of its business activities. LA Inc. means the incorporated association Legacy Australia Inc. consisting of the 50 legacy clubs (49 in Australia and 1 in London).
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| 1.2 |
LA Inc. recognises the importance of respecting your personal information and your privacy. LA Inc. complies with the Privacy Act 1988 (Cth) when collecting, using, disclosing and managing your personal informatio.
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| 1.3 |
In this policy, personal informationhas the meaning given to it in the Privacy Act. Generally, it includes information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information is true or not, or whether the information is recorded in a material form or not.
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2. TYPES OF INFORMATION
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| 2.1 |
| Where relevant to our current business operations, LA Inc. collects personal information such as: |
| a) |
contact information (both home and work) such as full name (first and last), e-mail address, current postal address and phone numbers; |
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| b) |
date of birth; |
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| c) |
your membership history and details; |
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| d) |
if you are an employee or a job applicant, your employment details including your job title, training and skills and the information provided in your resumé and by your referees, former employers and educational institutions; |
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| e) |
financial details, including insurance policies, if applicable; |
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| f) |
if you apply to LA Inc. for financial support, details relating to your financial situation and your health and family; |
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| g) |
opinions via surveys and questionnaires, if applicable; |
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| h) |
details relating to the goods or services LA Inc. has supplied to you and the events and activities in which you have participated; |
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| i) |
details relating to donations or bequests that you have made or would like to make; |
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| j) |
any relevant payment or billing information (including bank account details, credit card details, billing address and invoice details); |
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| k) |
usernames and passwords for access to the members-only area of the LA Inc.website; and |
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| l) |
health information and other relevant sensitive information. |
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| i. |
collection of health records (examples, but not limited to, physical disability or Mental Health) may assist in the processing of claims with the Department of Veterans’ Affairs (DVA), Veterans’ Review Board (VRB) or for seeking financial assistance through LA Inc.; and |
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| ii. |
LA Inc. promotes thorough screening of all Legacy Representatives. This may include collecting, storing and disclosing of criminal records where consent has been provided for Criminal History Checks, Working With Children Checks or Working With Vulnerable People Checks. |
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| 2.2 |
If you make an online donation, we will collect your personal details for the purpose of providing a tax receipt. LA Inc. will not give your details to any other organisation and will only use your details with your consent. You may choose to receive regular communications from LA Inc., as well as information about future opportunities to assist LA Inc. with its work.
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| 2.3 |
LA Inc. uses a secure encryption page for online credit card donations. Your credit card details are only used to process your donation and are securely stored by the provider of our electronic payment service. The details are not used for any other purpose. All personal information collected from you will be securely stored by LA Inc. and protected from unauthorised use or access.
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| 2.4 |
In some cases LA Inc. may also collect personal information through the use of “cookies”. When you access our website, LA Inc. may send a small electronic file containing a unique ID number to your computer – a cookie. The cookies used by LA Inc. do not identify you but only identify your computer. This enables LA Inc. to keep track of products or services you view and to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. If you do not wish your computer to receive cookies, you can set your browser so that your computer does not accept them.
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| 2.5 |
Data is collected for use in Google Analytics software to help improve website performance, and may also be used for remarketing, Google Analytics demographics, and Interest Reporting. The LA Inc. website may make use of pixel tracking, which also gathers data on visitor behaviour. These features use first party and third party Cookies to inform and optimise content based on past visits to our website. Site visitors can opt out of customised Google Display Network services and Google Analytics for Display Advertising using Ad Settings. A Google Analytics Opt out Browser Add-on is also available to prevent tracking in Google Analytics if desired.
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| 2.6 |
This website contains links to other websites. Please be aware that LA Inc. is not responsible for the privacy practices of other websites and you may wish to review the privacy policies on those websites if you visit them.
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3. HOW LA INC. COLLECTS AND HOLDS PERSONAL INFORMATION
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| 3.1 |
LA Inc. will collect your personal information directly from you where practicable to do so.
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| 3.2 |
| LA Inc. may collect personal information in a number of ways, including: |
| a) |
through application forms; |
| b) |
by email or other written mechanisms; |
| c) |
over a telephone call; |
| d) |
in person; |
| e) |
through transactions e.g. donations; |
| f) |
through our website; and |
| g) |
by technology that is used to support communications between us; |
| h) |
through publically available information sources (which may include telephone directories, the internet and social media sites); and |
| i) |
information providers such as direct marketing database providers and government entities. |
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| i |
Note:LA Inc. has a responsibility to ensure direct marketing database providers are compliant with the Privacy Act 1988, Spam Act 2003 and this policy. |
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4. PURPOSES FOR WHICH LA INC. COLLECTS, HOLDS, USES AND DISCLOSES PERSONAL INFORMATION
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| 4.1 |
LA Inc. will collect personal information if it is reasonably necessary for one or more of its business functions or activities. Disclosure will usually be to related entities. Click here for a list of related entities or ask the Privacy Officer for a copy (see contact details below). |
| 4.2 |
| The main purposes for which LA Inc. may collect, hold, use or disclose personal information include: |
| a) |
providing products and services to you and responding to your requests for information; |
| b) |
answering enquiries and providing information or advice about existing and new products or services; |
| c) |
providing you with access to protected areas of our website; |
| d) |
assessing the performance of our website and improving its operation; |
| e) |
conducting business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties; |
| f) |
administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of LA Inc., its related bodies corporate, including by disclosing personal information to LA Inc.’s contractors or service providers so that they can provide services for and behalf of LA Inc.; |
| g) |
maintaining employee records; |
| h) |
coordinating and managing individuals who wish to volunteer with LA Inc.; |
| i) |
managing donations and bequests left to LA Inc.; |
| j) |
reviewing applications for financial support and, where applicable, providing financial support; |
| k) |
stakeholder management; |
| l) |
providing your updated personal information to our related bodies corporate, contractors or service providers; |
| m) |
updating our records and keeping your contact details up to date; |
| n) |
processing and responding to any complaint made by you; and |
| o) |
complying with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country. |
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| 4.3 |
LA Inc. may also collect, hold, use and disclose personal information if you consent, or if LA Inc. is so required or authorised under law. |
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5. DIRECT MARKETING
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| 5.1 |
LA Inc. may use or disclose personal information about you for the purpose of direct marketing and you consent to your personal information being used in that way. Our direct marketing activities may include advising you of new goods or services being offered by LA Inc. or contacting you about making further charitable donations, or telling you about the activities of LA Inc. |
| 5.2 |
You can opt out of receiving direct marketing communications from the LA Inc. by contacting the Privacy Officer in writing or, if applicable, by using the unsubscribe link in an email or by accessing LA Inc.’s website and unsubscribing appropriately. |
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| 6.1 |
If LA Inc. holds personal information about you, you may request access to that information by putting the request in writing and sending it to the Privacy Officer (please see the contact below). LA Inc. will respond to any request within a reasonable period, and a charge may apply to cover our administrative and other reasonable costs in providing access to the personal information. |
| 6.2 |
| There are certain circumstances in which LA Inc. may refuse to grant you access to the personal information (e.g. if it resulted in a breach of confidentiality). In such situations LA Inc. will give you written notice that sets out: |
| a) |
the reasons for the refusal; and |
| b) |
the mechanisms available to you to make a complaint. |
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7. CORRECTION OF PERSONAL INFORMATION
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| 7.1 |
If your personal details change (for example, you change your address or telephone number), please contact us so that we can update our records. If LA Inc. holds personal information that is inaccurate, out-of-date, incomplete, irrelevant or misleading, you can ask us to correct the information. |
| 7.2 |
If LA Inc. holds personal information and you make a request in writing addressed to the Privacy Officer to correct the information, LA Inc. will take reasonable steps to correct the information. LA Inc. will respond to any request within a reasonable period. |
| 7.3 |
| There are certain circumstances in which LA Inc. may refuse to correct the personal information. In such situations LA Inc. will give you written notice that sets out: |
| a) |
the reasons for the refusal; and |
| b) |
the mechanisms available to you to make a complaint. |
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8. CROSS BORDER DISCLOSURE
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| 8.1 |
LA Inc. does not use data hosting facilities or enter into contractual arrangements with overseas third party service providers which involve the disclosure of your information to overseas recipients. |
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9. INTEGRITY AND SECURITY OF PERSONAL INFORMATION
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| 9.1 |
| LA Inc. takes reasonable steps to help ensure the security of your personal information, including by: |
| a) |
making sure that personal information is accurate, complete and up to date; |
| b) |
protecting personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and |
| c) |
destroying or permanently de-identifying personal information if it is no longer needed for any authorised purpose, e.g. destroying credit card details of donors following a successful electronic transfer within a reasonably practicable period. |
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| 9.2 |
LA Inc. does not store donor’s credit card details. Instead, they are processed and stored as encrypted files by our electronic payment service provider. |
| 9.3 |
LA Inc. encourages users of our website to exercise normal safety precautions when providing personal information. LA Inc. has taken reasonable steps to ensure the security of your personal information, however it cannot guarantee protection from a targeted criminal attack by individuals and/or group(s). |
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10. ANONYMITY AND PSEUDONYMITY
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| 10.1 |
| Where practicable, you may be given the opportunity to engage with LA Inc. on an anonymous basis or using a pseudonym. This does not apply where: |
| a) |
LA Inc. is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves; or |
| b) |
it is impracticable for LA Inc. to deal with individuals who have not identified themselves or who have used a pseudonym. |
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| 10.2 |
However, in some cases if you do not provide LA Inc. with your personal information when requested (whether pseudonymously or otherwise), LA Inc. may not be able to respond to your request or provide you with the support or services that you are requesting. |
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11. COMPLAINTS
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| 11.1 |
If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below. If you wish to make a complaint, LA Inc. usually requests that you make the complaint in writing so that the details of the complaint are clear and can be investigated properly. |
| 11.2 |
LA Inc. will treat your requests or complaints confidentially. Our representative will investigate your request or complaint and will contact you within a reasonable time after receipt of your request or complaint to discuss your concerns and outline options regarding how they may be resolved. LA Inc. will aim to ensure that your request or complaint is resolved in timely and appropriate manner. |
| 11.3 |
Please contact our Privacy Officer at:
Privacy Officer Legacy Australia Incorporated Post: P.O. Box 231, DARLINGHURST, NSW, 1300 Tel: (02) 8333 0600 Fax: (02) 8333 0699 Email: privacy@legacy.com.au |
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12. CHANGES TO OUR PRIVACY POLICY
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| 12.1 |
We may change this privacy policy from time to time. |
| 12.2 |
Any updated versions of this privacy policy will be posted on our website. Please review it regularly. |
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This privacy policy was last updated 24/06/2016
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