Website Privacy Statement

We are committed to upholding your privacy as a valued user of this website.

This website is run by the Australian Digital Advertising Alliance. Wherever possible we allow you to interact with this website anonymously. If we have to collect your personal information to allow us to provide a service to you or manage a complaint then the personal information we collect, process or use will be kept secure and in accordance with this privacy policy, described below. Whenever you give us personal information, you are consenting to its collection and use in accordance with this policy, including our use of cookies explained below.

Your data

We log your Internet Protocol (IP) address and use cookies to recognise you when you return to our site.

What is a cookie?

A cookie is a text-only string of data that is entered into the cookie file or “memory” of the browser on your computer. It will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number.

How to manage the use of cookies at our website

All browser technologies enable you to manage the cookies in the cookie folder of your browser. This means that you can either delete cookies from your cookie folder once you have finished your visit at our site or you can set your preferences with regard to the use of cookies before you begin surfing our website. Please note that deleting or rejecting cookies may affect your user experience of our website for example you may be asked to re-enter some information e.g. your name and password to use some pages.

How we use cookies

Using cookies is useful for us in optimising our site and making sure we are offering the best content to our users. We use cookies in order to give us information on the number of visitors to different parts of our website and thus to monitor which areas are most useful. We do not use them to identify you.

Links

This site contains links to other websites. We are not responsible for the content or privacy policies of any of these sites.

This privacy policy may change at any time, so you may wish to check it each time you visit our website.

Australian Digital Advertising Alliance Privacy Policy

This Privacy Policy sets out the approach which the Australian Digital Advertising Alliance (ADAA) will take in relation to the treatment of Personal Information. It includes information on how ADAA collects, uses, discloses and keeps secure, individuals’ personal information. It also covers how ADAA makes the personal information it holds available for access to and correction by the individual.

This policy has been drafted having regard to ADAA’s obligations under the Privacy Act.

This policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.

For more information about the Australian Digital Advertising Alliance click here

1. Collection

1.1 ADAA will only collect personal information where the information is necessary for ADAA to perform one or more of its functions or activities. In this context, “collect” means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.

1.2 ADAA collects Personal Information primarily to:

– receive feedback on this website and the Best Practice Guidelines

– provide further information or answer inquiries

– manage, resolve and address complaints

ADAA also collects and uses Personal Information for secondary purposes including ensuring that industry has in place an appropriate consumer safeguards and mechanisms for Online Behavioural Advertising.

1.3 ADAA will notify individuals (including, but not limited to, our customers) of the matters listed below at the time of collecting any Personal Information:

–    the main reason that we are collecting Personal Information (this reason will be the Primary Purpose)
–    other related Uses or Disclosures that we may make of the Personal Information (Secondary Purposes)
–    our identity and how individuals can contact us, if this is not obvious that individuals can access the Personal Information that ADAA holds about them
–    that individuals should contact ADAA if
           –    they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information
    –    the organisations or types of organisations to whom we usually Disclose the Personal Information
     –    where applicable, any law that requires the Personal Information to be collected the consequences (if any) for the individual if all or part of the Personal Information is not provided to ADAA

1.4 Where it is not practicable for ADAA to notify individuals of all of the Collection Information before the collection of Personal Information, ADAA will ensure that individuals are notified of the Collection Information as soon as possible after the collection. ADAA will provide “post collection notification” in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.

1.5 ADAA will not collect Sensitive Information from individuals except with express consent from the individual and only where it is necessary for ADAA to collect such information for an activity or function.

1.6 ADAA will not collect Personal Information secretly or in an underhanded way.

2. Use

2.1 ADAA will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual’s Reasonable Expectations.

2.2 ADAA Uses Personal Information primarily for the purposes listed in 1.2 above.

2.3 ADAA may use Personal Information to avoid an imminent threat to a person’s life or to public safety. It may also use Personal Information for reasons related to law enforcement.

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

2.7 ADAA will not attempt to match de-identified or anonymous data collected through surveys or such online devices as “cookies”, with information identifying an individual, without the consent of the relevant individual.

3. Disclosure

3.1 ADAA will only Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.

3.2 ADAA may Disclose Personal Information to unrelated third parties to enable outsourcing of functions where that Disclosure or Use is for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations.

3.3 ADAA 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.

3.4 In the rare event that ADAA is required to disclose Personal Information to law enforcement agencies, government agencies or external advisors ADAA will only do so in accordance with the Privacy Act or any other relevant Australian legislation.

3.5 ADAA may Disclose Personal Information to avoid an imminent threat to a person’s life or to public safety.

3.6 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, ADAA will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.5 above.

4. Information quality

4.1 ADAA will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.

4.2 ADAA will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.

5. Information security

5.1 ADAA requires employees and contractors to perform their duties in a manner that is consistent with ADAA’s legal responsibilities in relation to privacy.

5.2 ADAA 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 ADAA who have a genuine “need to know” as well as “right to know”.

5.3 ADAA will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.

6. Access and correction

6.1 ADAA will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.

6.2 ADAA will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.

6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting ADAA, as per the details at the end of this Privacy Policy.

6.4 ADAA will not charge a fee for processing an access request unless the request is complex or is resource intensive.

7. Openness

7.1 Contact with ADAA via web inquiry will be the first point of contact for inquiries about privacy issues.
Any formal privacy related complaints should be directed in writing to the ADAA Privacy Officer GPO Box 3895 Sydney NSW 2001.

7.2 ADAA will endeavour to manage any privacy related complaint efficiently and in a timely manner.

7.3 ADAA websites will contain a prominently displayed privacy statement and will include a copy of this ADAA Privacy Policy.

8. Anonymous transactions

8.1 ADAA will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. ADAA may however request visitors to provide Personal Information voluntarily to ADAA (for example, so we can keep you updated on future industry initiatives for Online Behavioural Advertising).

8.2 ADAA will allow individuals to transact with it anonymously wherever that is reasonable and practicable.

9. Transferring personal information overseas

9.1 ADAA generally does not send information overseas.

9.2 If Personal Information must be sent by ADAA overseas for sound reasons, ADAA will require the overseas organisation receiving the information to provide a binding undertaking that it will handle that information in accordance with the National Privacy Principles.

10. Glossary

Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.

Disclosure generally means the release of information outside ADAA, including under a contract to carry out an “outsourced function”.

Health Information means information or an opinion about:
–    the health or a disability (at any time) of an individual
–    an individual’s expressed wishes about the future provision of health services to him or her
–    a health service provided or to be provided to an individual that is also personal information
–    other personal information collected to provide or in providing a health service
–    other personal information about an individual collected in connection with the donation or intended donation by the individual of his or her body parts or body substances

ADAA means the Australian Digital Advertising Alliance, which includes but is not limited to, the Australian Association of National Advertisers, the Australian Direct Marketing Association, the Australian Interactive Media Industry Association, the Communications Council, Google, the Australian Interactive Advertising Bureaux, the Internet Industry Association, the Media Federation of Australia, Microsoft, News Digital, NineMSN, Sensis, Yahoo!7,
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.

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

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

Sensitive Information means:

(a) information or an opinion about an individual’s:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual preferences or practices; or
(ix) criminal record;that is also personal information or
(b) Health Information about an individual.

Use means the handling of Personal Information within ADAA.

Contacting ADAA

If you require further information regarding ADAA’s Privacy Policy, contact us.

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