1.1 Navlife means the KNUST FAMILY TRUST . ABN 93 792 046 712 (“Navlife”, “we”, “us”, “our”).
1.2 We operate the Navlife Membership Rewards Program (“Program”) which offers membership rewards with participating merchant businesses upon production of a Navlife Membership Rewards card.
1.3 In operating the Program, we may collect and handle personal information from our Members. We recognise the importance of protecting the privacy of our Members who provide their personal information to us and are committed to handling personal information in accordance with applicable privacy laws, including the Australian Privacy Principles set out in Privacy Act 1988 (Cth) (“Privacy Act”).
1.4 This policy explains how we collect your personal information, what we do with it, and how it is protected.
1.5 This policy applies to the Navlife Membership Rewards Program only.
2 KINDS OF PERSONAL INFORMATION COLLECTED AND HELD
The personal information we collect about you for the Program may include your:
2.1 name, age, date of birth and contact details (including residential or business address, delivery address, email address, telephone number);
2.2 marketing preferences, including the type of marketing materials you wish to receive and the method of delivery (email, SMS, direct mail or other); and
2.3 device identification information (see the section headed ‘Online and Digital Services’ below for further information).
3 HOW PERSONAL INFORMATION IS COLLECTED AND HELD
3.1 We may collect your personal information:
3.1.1 directly from you during conversations with our team members (by phone, in person or electronically);
3.1.2 when you complete an application for the Program (by phone, in person or electronically);
3.1.3 when you communicate with us during competitions, special events and promotions; and
3.1.4 where you access and interact with the website or social media sites (see the section headed ‘Online and Digital Services’ below for further information).
3.2 We may also collect personal information from third parties including our Merchant Businesses or through the acquisition of third party mailing lists and from organisations with whom we have an affiliation.
4 HOW WE HOLD YOUR PERSONAL INFORMATION
4.1 We may hold your personal information in hard copy (paper) or electronic form.
4.2 Information held in electronic form is generally held on servers controlled by Navlife and on servers controlled by third parties under contractual arrangement with Navlife. We use physical security, password protection and other measures to ensure that personal information stored in electronic form is protected from misuse, interference and loss and from unauthorised access, modification and disclosure.
4.3 Personal information collected in hard copy (paper) form may be converted to electronic form. Where this occurs, generally the hard copy is securely destroyed at the end of this process. Information held in paper-based form is generally securely stored at our head office. Navlife uses physical security and other measures to ensure that personal information in hard copy form is protected from misuse, interference and loss and from unauthorised access, modification and disclosure.
5 PURPOSES FOR COLLECTING, HOLDING, USING AND DISCLOSING PERSONAL INFORMATION
5.1 The main purposes for which we collect, hold and use your personal information are:
5.1.1 to properly account for membership benefits as part of the Program;
5.1.2 to communicate with you, including about products and services, competition results, special offers, and events which might interest you; and
5.1.3 to answer your questions, provide you with information or advice or consider and respond to requests or complaints made by you.
5.2 We also use and disclose your personal information:
5.2.1 to carry out administration, marketing, planning, and risk management activities;
5.2.2 for product and service development, quality control and research to improve the way Navlife provide products and services;
5.2.3 to seek your feedback in relation to Member satisfaction and our relationship with you and perform research and statistical analysis using such feedback; and
5.2.4 to comply with laws or regulations or to comply with any directions given by regulators or authorities.
5.3 The kinds of third parties to whom we may disclose personal information to include delivery services providers, manufacturers, suppliers, distributors, marketing and communications agencies, data analysts, IT service providers and our advisors including our professional advisors (including legal and financial advisors).
5.4 We may collect, hold, use and disclose personal information for other purposes explained at the time of collection.
6 DIRECT MARKETING
6.1 Navlife may send you direct marketing communications to keep you informed about products and services we provide and other products and services that may be of interest to you via email, SMS, social media, or regular mail.
6.2 If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so.
6.3 Navlife acknowledges and respects its Members’ choice to “opt-out” of direct marketing communications, including communications about the Program. You may opt out of direct marketing communications at any time by contacting us on 07 3180 3865 or by emailing [email protected].
6.4 You can also unsubscribe from emails by clicking the unsubscribe link on the footer of the email communication you have received.
7 ONLINE AND DIGITAL SERVICES
Our website or communications from Navlife in connection with the Program may also contain links to websites which are owned or operated by parties other than Navlife. You should make your own enquiries as to the privacy policies of these parties. We are not responsible for information on, or the privacy practices of, any third party websites.
8 COOKIES AND DIGITAL IDENTIFIERS
8.1 We may collect device identification information when you use a computer, mobile phone, smart phone, tablet, or other device to access or interact with us through our website or other applications. This information may include session cookies, your device IMEI number, IP address or MAC address. In some cases, these identifiers may only relate to a device or may be of an aggregated or statistical nature, and will not identify you as the user. In other cases we may associate information about your use of the website and other digital services over time with your personal information (e.g. where on any occasion you have logged in, followed a link sent to you by email or we have otherwise been able to identify you).
8.3 Navlife and third-party vendors use first-party cookies and third-party cookies together to inform, optimize, and serve ads based on an individual’s past visits to our website and third party websites.
9 ACCESSING AND SEEKING CORRECTION TO PERSONAL INFORMATION
9.1 Accessing personal information
You are entitled to access your personal information held by Navlife on request. To request access to your personal information, please contact us. In limited circumstances, access to your personal information may be declined in accordance with the Australian Privacy Principles. We may charge a reasonable fee for providing access to your personal information.
9.2 Updating personal information
Navlife will endeavour to keep your personal information accurate, up-to-date and complete. You can assist us with this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your details change.
If you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
9.3 Destruction of personal information
Navlife take reasonable steps to destroy or permanently de-identify your personal information where it is no longer required and to protect your personal information from unauthorised access, disclosure, loss, misuse and alteration.
If you wish to have your personal information removed from our records, you may request that your personal information be deleted or securely destroyed. It will not always be possible to comply with your request to delete or destroy your personal information.
10 COMPLAINTS ABOUT HANDLING OF PERSONAL INFORMATION
10.1 If you have any queries or complaints regarding privacy, you should contact us by calling 07 3180 3865 or via email at [email protected].
10.2 If your complaint requires more detailed consideration or investigation, we may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved. We will respond to your complaint as soon as reasonably practicable and, in any case, within 30 days.
10.3 If you are not satisfied with our response to a complaint, or you consider that Navlife may have breached the Australian Privacy Principles or the Privacy Act, you are entitled to make a complaint to the Office of the Australian Information Commissioner.
10.4 The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.
11 CHANGES TO THIS POLICY