Privacy Policy
THE PALACE GROUP OF COMPANIES – PRIVACY POLICY
1. INTRODUCTION
1.1 Palace Group of Companies
Palace Cinemas operate a wide variety of entertainment businesses. Through these varied operations, Palace from time to time gathers information from Customers and other parties with whom we deal for a variety of reasons including, in particular, to enable us to improve the nature of the services we provide. Palace understands individuals’ concerns regarding confidentiality and takes seriously its obligations in respect of all information it gathers. This Privacy Policy outlines how Palace deals with Personal Information.
2. WHY PALACE COLLECTS PERSONAL INFORMATION
2.1 Nature of Information
The information Palace collects in most cases relates to Customers but can relate to suppliers and other parties we deal with (for the purposes of this Privacy Policy all such people are described as “Customers”). Information is gathered for a range of purposes, including the provision of ongoing Customer support and the compiling of Customer databases to enable us to more accurately market our goods and services. The type of information we collect includes such things as contact details, buying habits, opinions, product preferences and transactional details. Palace treats all such information which is collected and identifiable as relating to an individual as Personal Information. It is this information which is described as “Personal Information” for the purposes of this Privacy Policy.
2.2 Collection of Information
Customers of Palace may deal with Palace on an anonymous basis. However, as a provider of a wide range of services, Palace frequently finds that it is necessary to collect Personal Information during the course of transactions. Personal Information may collected about Customers via the following means:
(a) competition entry forms;
(b) application forms;
(c) email;
(d) websites (including in some instances cookies);
(e) online transactions;
(f) networking functions (eg: business cards);
(g) over the phone;
(h) credit card details via credit card purchases; and
(i) information collected from third parties.
2.3 Information given to Customers
When Personal Information is collected from a Customer, they are advised at the time of collection or as soon as practical after its collection as to:
(a) the purpose of collection;
(b) the fact that the Customer can gain access to the Personal Information;
(c) the key consequences if all or some of the information cannot be collected.
2.4 ‘Sensitive Information’
Palace will not ask a Customer for 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, unless:
(a) the Customer provides their consent;
(b) the collection of that information is specifically authorised by law;
(c) the collection of the information is necessary for the establishment, exercise or defence of a legal claim.
2.5 Customer Consent
Wherever practical, Palace will obtain the express consent of Customers to the collection of Personal Information.
In some situations, Palace will interpret a Customer’s actions as indicating that a Customer consents to the collection of Personal Information. This may occur where the Customer has provided Personal Information for a particular purpose and that purpose cannot be achieved without Palace making use of the Customer’s Personal Information.
2.6 What happens if Personal Information is not provided
Where relevant, Palace will endeavour to make Customers aware that Palace may not be able to provide a proper service to them if Personal Information is not provided upon request.
3. MAINTENANCE AND MANAGEMENT OF PERSONAL INFORMATION
3.1 Who may view Personal Information
In general, only officers, employees or contractors of Palace may view Personal Information.
3.2 Storage and Security
Personal Information may be stored in either hard copy form or on computer or both. Hard copy Personal Information is wherever practical, kept under locked security. Personal Information stored on computer is wherever practical, password protected. Where possible and practical, Palace will endeavour to comply with recognised Australian and international standards relating to information security. Palace regularly deletes and de-identifies Personal Information if the information is no longer needed.
3.3 Updating Personal Information
Palace regularly monitors the quality and accuracy of Personal Information that it maintains and where practical, updates that information on a regular basis. Customers can update their Personal Information at any time by contacting Palace.
4. MINORS
Palace has adopted the position proposed by the Privacy Commissioner that a young person is able to give their consent when he or she has a sufficient understanding and maturity to understand what is being proposed.
5. COMPETITIONS
Personal information gathered during competitions run by Palace will be governed by the principles set out in this Privacy Policy unless an express statement is made in relation to privacy in the conditions of entry for the competition.
6. DIRECT MARKETING
Personal Information collected for direct marketing purposes will only be collected, used or disclosed with the consent of the relevant Customer as provided for in this Privacy Policy. In circumstances where Palace cannot practically obtain the consent of a Customer, then Palace may still engage in direct marketing to that Customer, but will:
(a) advise the Customer that he or she can be taken off the mailing list at any time; and
(b) display its contact details clearly in each direct marketing publication.
Customers may be taken off any mailing list by contacting Palace’s Privacy Officer.
7. ACCESS TO PERSONAL INFORMATION
Customers may access their Personal Information. Palace may impose a reasonable charge for access.
8. WHEN PALACE MAY WITHHOLD ACCESS TO PERSONAL INFORMATION
8.1 When access can be withheld
Access to Personal Information may be withheld in a number of circumstances. These include where:
(a) providing access would pose a serious and imminent threat to the life or health of a person;
(b) providing access would have an unreasonable impact on the privacy of others;
(c) the information is subject to confidentiality where the person who provided the information to Palace did so expressly on the condition that it remains confidential;
(d) the request is vexatious or frivolous;
(e) the information relates to current or anticipated legal proceedings between Palace and the person and the information would not be required to be discovered to a court;
(f) providing access would be unlawful or Palace is required by a law to withhold access; or
(g) providing access could prejudice the investigation or detection by Palace or by a government body of an unlawful activity or some serious or improper misconduct.
Where Palace does withhold Personal Information, Palace may instead choose to give the Customer a summary of that information.
8.2 Written reasons
If Palace does withhold Personal Information, Palace will provide written reasons.
8.3 Third party intermediary
9. CONTRACTORS
Palace may from time to time employ subcontractors to provide services to it. In these situations, Personal Information may be collected about those subcontractors. This Privacy Policy applies equally to those subcontractors.
10. SECURITY POLICY
Palace When purchasing from Palace Cinemas your financial details are passed through a secure server using the latest 128-bit SSL (secure sockets layer) encryption technology. 128-bit SSL encryption is approximated to take at least one trillion years to break, and is the industry standard. If you have any questions regarding our security policy, please contact Palace Cinemas (see 11. WHO TO CONTACT)
11. WHO TO CONTACT
Contact Palace Head Office: [email protected]
12. MODIFICATIONS TO THIS DOCUMENT
Palace may modify this Privacy Policy and the way it handles Personal Information at any time in its sole discretion.
13. FURTHER INFORMATION
Further information on privacy can be obtained from the Privacy Commissioner at www.privacy.gov.au
14. GOOGLE ANALYTICS
We use Google Analytics data to helping us improve the offerings on the Palace Cinemas website. As part of that implementation we use Google Analytics Demographics and Interest Reporting so that we know more general information about the users of our website. None of this data is personally identifiable, and we respect your need for privacy. As such, if you wish to opt-out of Google Analytics tracking, you can do so by following this link to Google Analytics’ currently available opt-outs.
