This policy was last updated 2nd April 2019.
The website www.crikey.com.au and Crikey emails and newsletters are published by Private Media Pty Ltd. In this policy, “us” “we” or “our” means Crikey and Private Media.
Private Media takes its obligations under the Australian Privacy Principles as contained in the Act very seriously, and has implemented practices, procedures and systems to ensure we comply with those laws.
The scope of this Policy applies to new visitors and current visitors and subscribers of crikey.com.au website.
2 Collection of your personal information
2.1 Types of information collected
2.1.1 Identifiable information:
In the process of running the crikey.com.au website, we collect a range of personal information about our current and prospective subscribers. This information includes:
- Full name
- Full mailing or street address
- E-mail address
- Telephone number
- Credit card or direct debit account details
From time to time and as part of ad-hoc surveys to get feedback about Crikey service we might also collect from you
- Age or date of birth
- Profession, occupation or job title
2.1.2 De-identified information:
The purpose of De-identified information we collect from you is for website general analytics and statistics on our daily visitors. This data is collected via browser cookies that our website will drop on your browser so it can track how readers use our site. Our de-identifiable analytics data collection is done by Google Analytics.
These cookies track data such as:
- Time on a page
- If the visitor is new or has been to crikey.com.au website before
- Pages visited
- If a visitor read one or more pages on crikey.com.au
- Website from which a user arrived to crikey.com.au, such as social media, google search results or a newsletter.
2.2 Why we collect this information from you
In order to provide our services to you as a paid subscriber or as a reader trialing a subscription with crikey.com.au website, we need this information so that we can:
- Create a user account in our website platform so you can have access to read the content in it
- Email you our newsletters that are part of our subscription with crikey.com.au
- Email you transactional emails from our system to remind you of your subscription expiring, advise you of subscription payment being declined or successful subscription payment.
- Send you physical correspondence to your mailing address from time to time.
- Some web cookies are necessary for the successful function of the website’s platform so we can display the right content to you, for example, crikey website needs cookies to know if the user has an active subscription or not. If not then crikey.com.au will display the paywall as opposed to the content on that webpage.
2.3 How this information is collected
2.3.1 Identifiable Information
All identifiable information described above is collected via webforms on crikey.com.au, via a phone call in the case you subscribe via a phone call to our subscription team or through correspondence (whether by letter, fax or email).
2.3.2 Non-identifiable information
All non-identifiable information is collected automatically when you visit crikey.com.au website.
2.3.3 Unsolicited personal information
If we receive your personal information from a third party without having asked you for it, then within a reasonable time, we will determine whether we could have collected it in the ways outlined above. If we determine that it could not have been collected in one of those ways and it is legal and reasonable to do so, then as soon as practicable we will:
- destroy the information; or
- ensure that it is de-identified before storing in our systems
2.4 How this data is stored
Crikey website is published, hosted and managed in Australia by Private Media with web servers in Sydney. Our marketing automation tool, Pardot, is hosted in the Cloud and managed and provided by Salesforce.com Inc in the United States, also hosted in the United States. Payment transactions are done via Braintree and its data sits in the United States, with some temporary access tokens stored short term via AWS in Australia and the United States. Your subscription data is managed and hosted by Chargify, LLC in the United States.
We use strict computer and user access mechanisms to protect this data you provide in a secure way. For the purpose of protecting your data we use:
- Secure Socket Layer (ssl) on crikey.com.au that will encrypt your data being transmitted between the web form on the site and our servers.
- Firewalls protects crikey.com.au and other systems storing data 24/7
- 2 factor authentication (2FA) is used for systems storing your data so that only authorised employees have access to this.
- All credit card details are encrypted and stored under PCI DSS level 1
- Daily backups that are securely stored in the Cloud are taken daily to protect any data loss as part of a system failure.
2.5 How long we keep your data for
Personal information required as part of your subscription or free trial with Crikey is stored for as long as the subscription or the trial is active, but also:
- after your subscription expires, we will retain your financial transactions details and email/password for 7 years in case you wish to renew during this period or obtain copies of the invoices for your subscription. After this period, all the data you have provided to us will be deleted from our live systems, backups and archives as needed, unless you resubscribe with us and become active again.
- Information you provide to us as part of a free trial will be stored for 36 months after your last trial expires. During this period of time you will be able to use your trial login details (account) to upgrade to a paid subscription if you wish to do so.
2.6 How this data is used
In addition to the purpose of a subscription or a free trial with Crikey, we also use your information for direct marketing. Direct Marketing is the promotion of goods and services directly to you through emails.
Crikey will use your personal information for the purposes of direct marketing only if we have collected your personal information directly from you
2.6.1 Circumstances where we need your consent for direct marketing
Unless it would be impracticable or unreasonable, we need your consent when:
- collecting your personal information from a third party for the purpose of direct marketing; or
- you would not reasonably expect to receive the direct marketing.
If at any time you want to know who provided us with your personal information, then please contact us using the contact details below at the end of this policy.
2.6.2 Opting-out of direct marketing
We will always provide a simple means for you to “opt-out” from receiving direct marketing, which typically involves an “opt-out” link on emails, or an option to do so inside your crikey user portal.
If at any time in the future you do not want us to send you direct marketing material, then you can simply inform our Privacy Officer using the contact details below at the end of this policy.
3 Sharing your information
We will only hold your personal information for the particular purpose for which we collected it and we will not use or disclose your personal information for the purposes of direct marketing material if you have previously told us not to.
We will not use or disclose your personal information for another purpose unless:
- we first obtain your consent; or
- we are required to by law,
- we reasonably believe it is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body. In this circumstance we will make a note of such disclosure.
4 Your Rights
All current and expired free trials and subscribers of crikey.com.au have the rights to:
- Request access to personal information that Crikey holds about you
- Only the person that provided the data via the means stated in point 2.3 above can request access to their own data. Access to data of others will be denied unless it is required by law enforcement.
- Request personal data to be corrected, for example you have changed jobs and which all communication to be sent to your new work email address.
When writing to us requesting a copy of your personal information we need the following details:
- Your full name
- Your email address
- Your phone number
5 Privacy Complaints
If you have a concern or complaint relating to our handling of your personal information or any breaches of the Australian Privacy Principles, please send a written note outlining the nature of the complaint to the Privacy Officer using the contact details below at the end of this policy.
We will endeavour to respond to your complaint within 10 business days of receipt. If unresolved, the complaint may be referred to an external complaints resolution entity and finally, if necessary, taken to the Office of the Australian Information Commissioner.
6 Contact Crikey Privacy Officer
Privacy Officer, Crikey
Level 6, 22 William Street
MELBOURNE VIC 3000
Email: [email protected]