1 Collection of your personal information
2 Purposes for which personal information is collected, held, used and disclosed
We will use and disclose your personal information for the purposes for which we collected it, and for other related purposes that you would reasonably expect. Generally, these purposes include responding to your enquiries, marketing and promotion, providing you with our products and services (including developing new products and services) that you have requested from us, obtaining your feedback, running promotions and for our general business operations (for example, maintenance of our business records, compliance with our legal and insurance obligations and statistical and analysis purposes). By providing us with your personal information, you consent to us using your personal information for these purposes. You agree that we may send you such information by post or by electronic means (including e-mail and SMS). You can opt-out of marketing and promotional communications at any time using an opt-out mechanism in one of our communications, or by contacting SEM Phoenix via the details shown below. We may disclose your personal information to our licensees, agents, contractors, professional advisors, insurers, promotion partners and/or relevant sporting bodies or programs in Australia for the purposes set out above except for direct marketing; we do not provide your information to third parties for them to use to market their products and services to you. Apart from the above instances, we may also use and disclose your personal information with your consent, to lessen or prevent a threat to an individual or public health and safety and as otherwise required or permitted by law or any enforcement body.
3 Sensitive information
4 Navigational Data
SEM Phoenix may use your navigational information by combining it with the navigational information that we have collected about other users. We cannot identify you from that information; instead it gives us aggregated results about the usage of the Website and App. We use the information collected to make the Website and the App more user-friendly and to improve the services that we provide.
5 Storage and security of your personal information
We may hold your personal information in electronic formats or in hard copy. We take reasonable steps to securely store your personal information to ensure it is protected from unauthorised access, modification and disclosure, and from other types of misuse, interference and loss. We will take reasonable steps to destroy or permanently de-identify your personal information when we no longer require it for any purpose for which it was collected. We may retain your personal information for as long as necessary to comply with any applicable law, for insurance and corporate governance purposes, for the prevention of fraud and to resolve disputes. Your personal information may also be retained in our IT system back-up records. The transfer of data over the Internet is inherently insecure. We cannot guarantee the security, during transmission, of any personal information provided to us via our Website or App; please bear this in mind when transmitting information by this means to us.
6 Access and correction of your personal information
You may lodge a request to correct personal information that we hold about you if you believe it is inaccurate, incomplete, out-of-date, irrelevant or misleading. Please contact us via the contact details shown below and we will endeavour to update the information as soon as possible. You may request that we provide you with access to the personal information we hold about you. Generally, we will provide you with access, except in limited circumstances where the APPs permit us to deny access. Any such requests must be made in writing to SEM Phoenix via the details shown below. Under the APPs we are permitted to charge you a reasonable fee for providing access to your personal information. Please note that no fee will be incurred for requesting access, and if your request for access is accepted we will inform you of the fee (if any) that will be payable for providing access if you proceed with your request.
7 SEM Phoenix Website and App
When you use a mobile device to access our Website or App, we may access, collect, monitor, store on your device, and/or remotely store on or more “device identifiers”. Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by SEM Phoenix. A device identifier may deliver information to us or to a third party partner about how your browse and use our service and may help us or others provide reports or personalized content. Some features of our App (and Website) may not function properly if use or availability of device identifiers is impaired or disabled.
8 Location information
Through your use of the App (and Website), we collect and receive information about your location which helps us offer features such as sending personalised push notifications based on your location. We may use information from GPS and Bluetooth signals, device sensor data, Wi-Fi access points and cell towers or an IP address received from your browser or device to determine your approximate location. The type of information we receive from you about your location will vary depending on your device and account settings. For example, if you wish to change what location data we can access and disable any location features such as background location data, you can do so at any time by adjusting your device settings.
9 Overseas disclosure of your personal information
SEM Phoenix may disclose some of your personal information to persons or organisations that are outside Australia if it is necessary to conduct our business, to provide the services to you or if it is required by law. For example, database and webhosting services provided to SEM Phoenix may involve personal information being transferred to IT service providers that may be based in India, Philippines, Singapore, New Zealand, the United Kingdom, Canada and the United States of America. We will not transfer your information outside your country for any other reason without your express consent. Where we are allowed or where you consent to the disclosure of your personal information to an overseas recipient you understand and agree that SEM Phoenix may not take steps to ensure that the overseas recipient handles your personal information in accordance with the Privacy Act and APPs. You further acknowledge that the overseas recipient may not be required to comply with the Privacy Act and APPs, and may not be subject to comparable laws in their jurisdiction. SEM Phoenix is not responsible for, or otherwise liable for the way in which the overseas recipient handles your personal information.
10 Children’s privacy
SEM Phoenix does not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to register for the service. The services and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under the age of 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us via the contact details below.
You may lodge a complaint with us if you believe we have handled your personal information other than in accordance with the APPs or breached your privacy rights in any other way. To do so please contact us via the contact details below.
13 Contact us
If you would like further information about the way we manage your personal information or if you have a complaint, please contact SEM Phoenix by telephone on +61 1800 746 364, by mail at South East Melbourne Phoenix, Level 1, 5 Lakeview Drive, Scoresby VIC 3179, or by email at email@example.com. We will confirm receipt of your correspondence, and in the case of a complaint, will set out the time frame we require to investigate your complaint and provide you with a response as quickly as possible, which generally will be within 14 days of receiving your complaint. If we do not answer your concerns to your satisfaction you have the right to make a complaint to the Office of the Australian Information Commissioner, at www.oaic.gov.au or on 1300 363 992.
SEM Phoenix's Privacy Collection Statement