Edwards Promotions Pty Ltd ACN 074 862 089 trading as Handiskins ("Handiskins", "we", "us" or "our") is committed to complying fully with its obligations under the National Privacy Principles ("NPPs"), which are contained in the Privacy Act 1988 (Cth) ("Privacy Act").
This Policy outlines the types of personal information Handiskins collects and explains how it collects, uses, discloses and holds that information. The Policy also explains how you can gain access to personal information that Handiskins holds about you and provides contact details for Handiskins.
- What personal information does Handiskins collect?
If you access the Handiskins website, hold or participate in a golf competition using the Handiskins rules, or ask Handiskins to provide you with goods or services (including choosing to receive promotional information), we may ask you to provide information that is personal in nature and includes things such as your name, postal address, email address and mobile number. We may also ask you for additional anonymous demographic information, which is not unique to you, such as your post code, age, gender, preferences, interests and any of your preferences in respect of offers and promotions run by Handiskins and other organisations such as Handiskins business partners and sponsors.
When we conduct market research and profiling, we may also ask you for your opinions about goods and services related to those that we provide, your website use and your general activities and participation in the sport of golf.
We also collect information about visitors to our website using cookies and code embedded in this website, as described in the "Site Statistics" and "Online collection of personal and non-personal information" sections of this Policy.
Generally, if we do ask you for personal information, we will endeavour to say which information we require and which information is optional. You can refuse to provide Handiskins with the personal information that it requests from you. However, if you do not provide such information, we may not be able to provide you with our goods or services.
Handiskins does not collect information that is unrelated to its goods and services or that it does not need. For example, Handiskins does not collect sensitive information (such as information about your health or political beliefs) because it does not need it in order to provide you with our goods or services.
If you do not wish to be notified about goods, services or promotions offered by Handiskins, or if you do not wish to receive any further communications from Handiskins, you can opt-out of any, or all, Handiskins communications by directly contacting Handiskins at any time.
- How is Personal Information Used?
The primary purpose for which Handiskins collects personal information is so that we can provide you with goods and services, administer your use of those goods and services, and provide you with information in relation to them. We will also use it for purposes related to the supply of our good and services and the supply of the good and services of our business partners and sponsors including, but not limited to, golf related goods and services, product research and development, and marketing, promotions and special offers.
Handiskins also uses your personal information for purposes incidental to these purposes including, without limitation, for the purpose of managing its relationship with you, communicating with you effectively and updating you on our latest products, news and special offers whether from us or third parties (unless you tell us not to - which you can do at any time at our unsubscribe page).
- Communication & Marketing
If you have held or participated in a Handiskins competition we may occasionally update you on our latest products, news and special offers and those of selected third parties via email.
- Site Statistics
We may collect and disclose aggregate, anonymised statistics about the number of visitors to our websites or number of purchases made. We gather data regarding the visitors to our websites using cookies and code which is embedded in the site (and we may also use third party measurement and research services to assist us with such date gathering). Both the cookies and the embedded code provide statistical information about visits to pages on the site, the duration of individual page view, paths taken by visitors through the site, data on visitors' screen settings and other general information. Handiskins uses and stores this type of information, as with that obtained from other cookies used on the site, to help it improve the services to its members and users. Further information regarding the way in which this information is obtained and used can be obtained by contacting us at Contact Us.
- Will Personal Information be given to anyone else?
If we disclose your personal information to any of our group companies, they may use it for the same purposes that we may (including so that they can update you on their latest products, news and special offers via e-mail, post & telephone). We may also provide your personal information to our business partners and sponsors in order to provide you with offers and promotions.
Handiskins may disclose personal information to third parties to whom it contracts out specialised functions. These third parties usually help us in providing goods and services to you, and include:
- Vendors promoting goods and services related to Handiskins or related to golf generally;
- Distribution agencies (with whom we arrange to deliver certain communications to you on our behalf);
- Outsourced service providers (eg: market research agencies).
If Handiskins does disclose personal information to third party contractors under outsourcing or contracting arrangements, Handiskins will take steps to ensure that those contractors:
- Handle your personal information consistently with the National Privacy Principles (NPPs);
- Only use your personal information in order to provide the specific services or to perform the specific functions required by Handiskins; and
- Store your personal information securely, and only for as long as is necessary to provide the required services or perform the required functions.
- Disclosures required or permitted by law
Handiskins may also disclose personal information to individuals, corporations, organisations or governmental authorities without your consent if it is required to do so by law, or if the disclosure is permitted under the Privacy Act. Handiskins reserves the right to give information to law enforcement agencies should any content passing through our Website or systems raise suspicion of an illegal act.
- Transfer of personal information overseas
Generally, your personal information will be processed in Australia. However, from time to time Handiskins will transfer personal information to overseas companies. For example, this may occur in the course of providing members with support services, product offerings, or when we outsource certain functions (eg: when we store personal information about members on servers that are hosted by an external offshore company).
If Handiskins does transfer your personal information overseas, we will take steps to ensure your personal information is given the same privacy protection in the destination country as it receives in Australia.
- Personal information that you communicate or publish via Handiskins websites
Handiskins recommends that you do not publish or communicate personal information accessible to the public via our websites (eg: in our online community and in our forums) unless you want that information to be seen by others.
Should you choose to publish or communicate personal information, or select features on our websites that allow you to display, publish or communicate personal information about yourself to the public via our websites, you acknowledge that Handiskins cannot control the use of such personal information by others.
We may also disclose your personal information to third parties outside our group of companies:
In connection with a sale or purchase by Handiskins of any business or assets (or prospective sale or purchase); or
If Handiskins or some or all of its assets are acquired (or proposed to be acquired) by a third party, in which case personal data which we hold about our customers may be one of the transferred assets.
- Access and Correction of Personal Information
Under the Privacy Act, you generally have a right to seek access to the personal information that Handiskins holds about you and the purpose/s for which it is being held. However the NPPs provide that there are some circumstances in which it is permitted or required to withhold access to some or all of that personal information. If Handiskins denies you access based on any of the exceptions set out in the NPPs it will endeavour, where appropriate, to inform you of the exception under which the denial falls.
You also have the right to ask Handiskins to correct personal information about you that you think is inaccurate, incomplete or out of date. We encourage you to help us keep the personal information we hold about you accurate and up-to-date by updating your details immediately if you change them.
If you wish to access personal information that Handiskins holds about you, Handiskins asks that you make a request in writing to its Privacy Officer (contact details are set out below). Your request should state whether you are seeking access to all the personal information Handiskins holds about you or to particular personal information (in which case you should specify that in your request). You should also provide some form of identification (eg: a photocopy of your driver's licence or passport) so Handiskins can verify that you are the person to whom the personal information relates. You should also include details of how Handiskins can contact you in case it needs to discuss your request. If you need more information before making a formal request for access, please contact Handiskins's Privacy Officer, who can explain how Handiskins will handle your access request and assist you in making that request.
Depending upon your access request, we may impose a charge to recover our reasonable costs in providing you with details of this service. We will notify you of any such charge upon receiving your request and will confirm whether you wish to proceed and pay such charge. We will generally respond to a request of this type within 30 days of receiving it.
If you think that any of the personal information Handiskins holds about you is not accurate, complete or up to date, please provide Handiskins Privacy Officer with your request for correction. It is Handiskins policy to consider and respond to any requests for correction within 30 days of receiving it.
If Handiskins agrees that your personal information is not accurate, complete and up to date, it will correct such information for you. If it does not agree with your view, Handiskins will provide you with reasons for its view, and will provide you with an opportunity to make a statement of your view and have it included with the information.
- Storage and Security of Personal Information
Handiskins takes reasonable steps to protect the personal information it holds and controls from such risks as loss, misuse, unauthorised access, destruction or disclosure. The means of protection Handiskins uses includes, but is not limited to firewalls, password access, secure servers and encryption of credit card transactions. At Handiskins, other than as provided for under this Policy, we only allow authorised personnel to access personal information, and it is a condition of employment with Handiskins that its employees maintain the confidentiality of personal information.
- Destruction and de-identification of personal information
Unless a legal requirement provides otherwise:
Handiskins will keep your personal information for as long as it requires such information (in accordance with the scope of the consent to use and purposes set out in sections 1 and 2);
if you request in writing for Handiskins to destroy or de-identify your personal information that it has collected from you, Handiskins will take steps to destroy or permanently de-identify your personal information.
- Online Privacy Issues
- Online collection of personal and non-personal information
Generally, Handiskins collects personal information from you when you register to participate in a Handiskins competition or event, or when you otherwise visit or participate at our websites. If you have been a participant in a Handiskins competition you have already consented to receiving emails from Handiskins and/or its business partners presenting you with advertisements and promotional materials on or through the Website, at competitions or via email. This consent was included in the registration sheet.
Handiskins websites may also collect other information that may or may not be personal information. Each time you visit a Handiskins website, its server automatically recognises and stores your cookie ID and internet protocol address, the type of internet browser you are using, the address of the site that "referred" you to Handiskins websites and clickstream data.
Where we sell Edwards Partners Pty Ltd, the Handiskins business or any of related assets, or we change ownership or our corporate structure, you consent to us transferring data we hold (including your personal information) to any third party as part of any such process.
- Links to other websites
- How to Contact Handiskins
If you have any questions or comments about this Policy, if you wish to access any personal information Handiskins holds about you (for which you agree that we may elect to charge you reasonable fees for the time we have identifying and providing access to such information), if you do not wish to receive promotional emails, or if you wish to make a complaint about how Handiskins has handled personal information about you, please contact Handiskins Privacy Officer at: firstname.lastname@example.org
This Policy may change from time to time.