iNC Network Australia Pty Ltd trading as iNC Digital Media and Catalogue Central Pty Limited and their related businesses (iNC, our, us, we) respect your right to privacy.
We encourage you to check this policy regularly as this policy may change from time to time. If you have any suggestions or concerns that are not addressed in this policy, please contact us. Please take some time to read through this policy and understand our position on privacy before you provide us with any personal information.
Our Commitment to privacy
Aside from the contents of this policy, the conduct of iNC is governed by the Privacy Act 1988 (Cth) and in particular the APPs.
Personal information we may collect
We maintain physical, electronic and procedural safeguards that protect your personal information. Only authorised Catalogue Central staff have access to your personal information. Information is only accessible when required in the normal course of business from Catalogue Central.
This policy applies to:
- End users who are served advertisements through our advertising technologies and services (Ad Network);
- Website publishers and/or advertisers who use our Ad Network; and
Individuals who visit websites under our control, including:
iNC will only collect personal information about you if it is reasonably necessary for our functions and activities. When submitting information to us, or using our Ad Network we may collect details such as your name, gender, email, phone number, the company for which you work, and in some instances, your financial information (including credit card information) which may personally identify you. Some of this information is essential for us to be able to identify accurately who is using our services so that we may be able to respond to your requests and, as such, is indicated by mandatory fields. Mandatory information requirements are clearly identified and are denoted by an asterisk (*). When submitting a form, you will also be prompted if any mandatory data has not been completed. Other types of information are collected to help us provide better services. Information of this type is optional – you need only fill it in if you wish to do so.
You may be asked to provide iNC with personal information when you:
- Register with one of our Sites, use one of our Sites or our Ad Network;
- Create an account with us;
- Send us your comments, suggestions or other information;
- Report a technical problem;
- Request sales and advertising information;
- Subscribe to a newsletter or catalogue; or
- Enter a competition, promotion or event.
We also collect personal information in the normal course of business through meetings, phone calls, letters, faxes and emails, as well as via third party credit agencies, mailing lists, advertisers, commercial agreements, documents and dealings. All this information is subject to the APPs.
In addition, we may also collect information about you if you:
- post comments or submit content which is publicly available which contains information about you – this may include information such as your name, user name, likes, tweets, status, profile information and pictures; and
- log-in to or access one of our Sites, services or activities through a third party social media service or connect one of our Sites, services or activities to a third party social media service - this may include information such as your user ID, user name, information you have disclosed via the social media service and information or content you have permitted the social media service to share with us (for example your profile picture, email address, followers or friends lists).
When you engage in the activities described above, you are authorising us to collect, store, use and disclose such information and content in accordance with this policy.
iNC will not collect sensitive information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation. However if we do collect sensitive information we will do so in compliance with the APPs.
You have the option of not identifying yourself or dealing with us using a pseudonym in relation to particular matters. We will endeavour to make it clear where you may withhold your name or use a pseudonym.
Non-personal information we may collect
We may combine your personal information with non-personal information about you that we collect so as to provide you with the services listed below.
How we use your information
If we hold personal information about you that was collected for a particular purpose, we will not use or disclose it for another purpose unless: (a) you consent; (b) you would reasonably expect us to use or disclose it for that other purpose; or (c) it is required or authorised by law or a court/tribunal order.
iNC generally uses personal information, and you consent to us using your personal information, to:
- provide you with catalogues, products or services you have requested;
- provide you with relevant advertising and promotional material;
- conduct promotions or competitions, including Joint Activities;
- help iNC manage and enhance its services, Sites and Ad Network;
- communicate with you; or
- use our Ad Network to send you ongoing information and promotional material about opportunities, services and products (relating to our business or a third party business) in which iNC believes you may be interested, including via email, SMS or mail.
We may also share your personal information with our Related Companies, Partners and others, as referred to below.
The information and feedback you provide through our Sites and Ad Network may be used to identify ways of improving the Sites and Ad Network and how we can make them more effective for your use.
Opting in or out and unsubscribing
At the time we collect information from you, you may be asked to "opt in" to consent to us using or disclosing your personal information, other than in accordance with this policy or any applicable law. For example, you may be asked to “opt-in” to receive further information or communications from us, our Related Companies or our Partners, as referred to below.
You will be given the opportunity to "opt out" or unsubscribe from receiving communications from us, our Related Companies or our Partners in accordance with this policy. Alternatively, you may contact us at the address below to “opt out” of, or unsubscribe from, any future communications.
iNC will use reasonable endeavours to comply as quickly as possible with that request, and in any event, within five business days.
If you receive communications purporting to be connected with us or our services that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact us.
Disclosure of your personal information
You consent to iNC disclosing your personal information to the authorised personnel of iNC and to:
- our Related Companies;
- our Partners;
- third parties which we engage with in Joint Activities;
- credit reporting agencies; or
- parties involved in a business sale or restructure,
- as referred to further below.
You acknowledge and agree that we may collect and share personal information about you with related bodies corporate, joint venture partners and affiliated companies and businesses (Related Companies) so we can provide you with the products and services you request and bring you information about products and services we offer. We will inform our Related Companies that information shared with them must be collected, used, disclosed and stored in accordance with this policy.
In some cases, we contract with other companies or individuals to work with us or provide goods or services for us (Partners) including business partners, distributors, suppliers and advertisers. Examples of the goods and services our Partners may provide are electronic communications, data storage, deliveries, direct marketing services, market research, prizes, advertising, public relations, debt collection, legal advice, accounting and audits. We provide our Partners only with such information about you as they need to provide their goods or perform their services and we impose strict requirements of security and confidentiality on them in how they handle your personal information. We make it clear that our Partners are not permitted to use your personal information other than as permitted under this policy.
Related Companies and Partners may be located in Australia and/or overseas countries, including New Zealand, Hong Kong, Ireland, Singapore and the United States of America. You hereby consent to the disclosure of your personal information to such Related Companies and Partners overseas (as referred to above) and you acknowledge that as a result of your consent to such disclosure, clause 8.1 of the APPs does not apply.
Credit information about you may be obtained from and provided to credit reporting agencies in accordance with applicable legislation.
Sale of business
If we sell all or part of our business, merge with another company or business, or restructure our business, we may transfer or disclose your personal information to the parties involved in the transaction.
Access and correction
iNC will take reasonable steps to ensure your personal information is accurate, up to date and complete. If you have an account on one of our Sites, you are encouraged to correct your personal information through the relevant settings in that account.
Where iNC holds personal information about you, we will provide you with access to the information on request within a reasonable time. There are some exceptions to this where we may refuse to give you access and these are set out in clause 12.3 of the APPs. In that case, where required, we will give you written notice setting out the reasons for our refusal and the mechanisms available if you wish to complain about our refusal.
We will also give you access to the information in the particular manner you request if it is reasonable and practicable to do so. If we do not give you access in the manner requested, we will take reasonable steps to give you access in a way which meets both your needs and ours. We may also impose a reasonable charge for giving you access to your personal information.
If iNC is satisfied that your personal information is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct your personal information. In addition, if you request us to correct your personal information, we will take reasonable steps to do so within a reasonable time. If you request it, we will also take reasonable steps to notify any other Related Companies or Partners of the changes if we have previously provided your personal information to that entity. There is no fee for correcting your personal information. We may require you to provide particulars of your identity before providing you with access to, or making changes to, your personal information.
iNC will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access and modification or disclosure. Any personal information that we receive is securely stored and access is restricted to authorised personnel of iNC, its Related Companies and Partners, as described above. Please contact us immediately at the address listed below if you become aware of any unauthorised use of your personal information.
Third party websites
You may follow links on our Sites to other third party websites (Other Sites). We encourage you to always read the privacy policies on those Other Sites as they may also collect your personal information. iNC is not responsible for the information on, and the contents of, those Other Sites or their practices or policies.
If you: (a) have any questions or comments on this policy; (b) would like to access or correct your personal information; (c) would like a hard copy of this policy; (d) would like to know how we received your personal information; or (d) would like to make a complaint about a breach of the APPs or the use or disclosure of your personal information, then please contact iNC’s Privacy Officer at:
iNC Digital Media
Level 2, 31 Coventry Street
South Melbourne VIC 3205
Phone: (03) 9016 7943