Privacy Policy

This Privacy Policy sets out the approach which PhoneCycle will take in relation to the treatment of Personal Information. It includes information on how PhoneCycle collects, uses, discloses and keeps secure, individuals' Personal Information. It also covers how PhoneCycle makes the Personal Information it holds available for access to and correction by the individual.

 

This Policy outlines our approach to the ethical management of personal information in line with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

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COLLECTION

1. PhoneCycle will, from time to time, receive and store personal information you enter onto our website, provided to us directly or given to us in other forms. You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your product or service order. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.

2. Additionally, we may also collect any other information you provide while interacting with us.

3. PhoneCycle collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website or store and when we provide our services to you. We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.

4. PhoneCycle also collects and uses Personal Information for secondary purposes including:

   • billing and account management

   • business planning and product development

   • to provide individuals with information about promotions

   • to enhance the online shopping experience by displaying products and/or services that match the personal preferences of individuals based on their previous website browsing history and/or buying activity.

 

USE

1. We use Personal Information primarily for the purposes listed above.

2. Direct Market to individuals it will ensure that:

   • the individual is clearly notified of their right to Opt Out from further Direct Marketing;

   • the individual is given an Opt Out in all further instances of Direct Marketing if they have not previously chosen to Opt Out; and

   • if the individual Opts Out of all Direct Marketing the Opt Out will be respected

3. We will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.

4. We may Disclose Personal Information to unrelated third parties to enable outsourcing of functions (such as billing, customer relations management and order fulfilment), where that is Disclosure or Use for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual's Reasonable Expectations.

5. We will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.

6. We may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.

7. We may Disclose Personal Information to avoid an imminent threat to a person's life or to public safety.

8. If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, we will not Disclose Personal Information otherwise than in accordance with the exceptions set out above.

 

INFORMATION SECURITY

1. We take all reasonable steps to make sure your personal information is held securely and protected from loss, interference, unauthorised access or misuse. We generally store personal information in electronic databases. Some of these databases may be held on our behalf by third party data storage providers.

2. We require employees and contractors to perform their duties in a manner that is consistent with our legal responsibilities in relation to privacy.

3. We will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within who have a genuine "need to know" as well as "right to know".

4. We only keep information for as long as we need it and destroy, return or de-identify when it is no longer required. We do this according to the terms of our funding contracts and our data retention and disposal procedures.

 

ACCESS AND CORRECTION

1. We will allow our records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.

2. We will correct our records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.

3. Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting us, as per the details on the website.

 

ANONYMOUS TRANSACTIONS

We will not make it mandatory for visitors to our web site to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. We may however request visitors to provide Personal Information voluntarily (for example, as part of a competition or questionnaire).

 

GLOSSARY

1. Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means.

2. Opt Out means an individual's expressed request not to receive further Direct Marketing.

3. Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.

4. Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.

5. Reasonable Expectation means a reasonable individual's expectation that their personal information might be Used or Disclosed for the particular purpose.

6. Sensitive Information means information or an opinion about an individual's:

   • racial or ethnic origin; or

   • political opinions; or

   • membership of a political association; or

   • religious beliefs or affiliations; or

   • philosophical beliefs; or

   • membership of a professional or trade association; or

   • membership of a trade union; or

   • sexual preferences or practices; or

   • criminal record; that is also personal information or

   • Health Information about an individual.