In this policy, "us", "we" or "our" means Stan Entertainment Pty Ltd (ABN 94 168 856 924) and its related bodies corporate (Stan Group). Your privacy matters to us whether you are new to our service or are a long time user. Please read this policy carefully as its set out the way we handle your "personal information".

We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) ("Act").

What is personal information

When used in this policy, the term "personal information" has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, age, gender, postcode and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card information.

What personal information do we collect and hold

We may collect the following types of personal information:

• name;
• mailing or street address;
• email address;
• telephone number and other contact details;
• age or your date of birth;
• credit card information;
• details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
• any additional information relating to you that you provide to us directly through our websites or indirectly through use of our website or online presence through our representatives or otherwise, or through other websites or accounts from which you permit us to collect information;
• information you provide to us through our service centre, customer surveys or visits by our representatives from time to time;
• any other personal information which may be required in order to facilitate your dealings with us.

Cookies and beacons

We may also collect additional information about your interaction with Stan websites/services/products. For example, we use website analytics tools on our websites to retrieve information about your usage of Stan services. We also use technologies, such as cookies and web beacons (described below), to collect information about the pages you view, the links you click and other actions you take on our sites and services. Additionally, we receive certain standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times and referring website addresses. We generally use this information to report statistics, analyse trends, administer our services, diagnose problems, gather demographic and behavioural information and target and improve the quality of our products and services. To the extent this information does not constitute or is not associated with personal information because it does not identify you or anyone else, the Australian Privacy Principles do not apply and we may use this information for any purpose and by any means whatsoever.

We may also use cookies to enable us to collect data which may include personal information. When you access our website, we may send a "cookie" (which is a small summary file containing a unique ID number placed by a web server) to your device. This enables us to recognise your device each time you visit our website or use our application, without bothering you with a request to register or log-in. It also helps us keep track of and personalise products or services you view and your preferences, so that we can send you news about those products or services.

Our websites, products and services may contain electronic images known as "web beacons" - sometimes called single-pixel gifs - that may be used to assist in delivering cookies on our sites and allow us to count users who have visited. We may include web beacons on all webpages on our website/products/services in order to determine whether messages have been opened and acted upon. We may also employ web beacons from third parties in order to help us compile aggregated statistics regarding the operations of our websites. We prohibit web beacons on our websites from being used by third parties to collect or access your personal information.

Cookies must be enabled in your browser or device in order to use Stan services.

Anonymous data which we collect about your interaction with Stan services may be used by us for the purposes described in this Privacy Policy or may be sold or otherwise provided by us to third parties including our partners, clients, shareholder and service providers for purposes including (but not limited to) data-matching, analysis, selling aggregated anonymous data via advertising exchanges, conducting launch surveys, and modelling.

When you receive newsletters or promotional e-mails from us, we may use web beacons (described above), customised links or similar technologies to determine whether the e-mail has been opened and which links you click in order to provide you with more focused e-mail communications or other information.

How we collect personal information

We collect your personal information directly from you unless it is unreasonable or impractical to do so.

We do this in various ways including:

• through your access and use of our website and apps;
• during communications between you and our representatives;
• when you register your interest to access a free trial or to access Stan services;
• when you make an inquiry or a complaint;
• when you participate in a Stan survey, competition, promotion or other marketing campaign; and/or
• when you create a Stan account or use Stan services.

We may also collect personal information from third parties including:

• third party companies such as credit reporting agencies, law enforcement agencies and other government entities;
• social media accounts and services, where you consent to us collecting such information from those services, including when you sign up to Stan services or connect your third party social networking service profile to Stan services;
• advertisers;
• mailing lists;
• recruitment agencies; and/or
• contractors and business partners.

How we store personal information

We may hold your personal information in electronic or hard copy format or a combination of both. This personal information may be combined or linked with other information held about you, including information that we receive from third parties. We have taken a number of physical, electronic and procedural steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure including by means of firewalls, password access, secure servers and encryption of credit card transactions.

If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.

Why do we collect, hold, use and disclose personal information

Generally we only use personal information for the primary purpose for which we collect information about you or for another closely related secondary purposes. We collect, hold, use and disclose your personal information for the following purposes:

• to assess your application for Stan services;
• to provide products and services to you;
• to provide you with news, information or advice about our existing and new products and services;
• to provide you with more effective customer service;
• to communicate with you including by email, mail or telephone;
• to manage, operate and enhance our products and services;
• to personalise and customise your experience;
• to provide you with access to our service;
• to conduct competitions or promotions on our behalf and on behalf of selected third parties;
• to conduct business processing functions for operation of our website, our service or our business;
• for our administrative, marketing (including direct marketing), promotional, planning, product/service development, quality control and research purposes, or those of our contractors, partners or external service providers;
• for displaying content and advertising that are customised to your interests, preferences and experiences;
• to provide information (including personal information) to our shareholders (ninemsn Pty Ltd and Fairfax Entertainment Pty Ltd) and their related bodies corporate for the purpose of, for example, providing data matching and targeted advertising services;
• to verify your identity;
• to provide as part of business data to third parties if you have authorised us to do so;
• to provide your updated personal information to us, our contractors or external service providers;
• for credit verification purposes, transactions, fraud and credit worthiness;
• to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and/or
• as required or permitted by any law (including the Privacy Act).

We may state a more specific purpose at the point we collect your personal information.

You acknowledge and agree that any personal information submitted by you to us may be provided by us to our shareholders (ninemsn Pty Ltd and Fairfax Entertainment Pty Ltd) and their related bodies corporate and used by those organisations for any of the purposes disclosed in this Privacy Policy.

Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

What happens if we can't collect your personal information

If you do not provide us with the personal information described in this policy, some or all of the following may happen:

• we may not be able to provide you with the products or services you requested, either to the same standard, or at all (for example, if you do not create a Stan account, you will not be able to access Stan services); and/or
• we may not be able to provide you with information about products and services that you may want, including information about discounts, sales or special promotions.

How do we disclose your personal information

We may disclose your personal information to:

• our employees, related bodies corporate, contractors or external service providers for the operation of our websites or our business, fulfilling requests by you, and otherwise in connection with providing our products and services to you, including without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment and other transaction processors, photographic analysers, promotions agencies, customer support providers, statistical analysis providers, data entry service providers, electronic network administrators, debt collectors, and professional advisers such as accountants, solicitors, business advisors and consultants;
• our shareholders (ninemsn Pty Ltd and Fairfax Entertainment Pty Ltd) and their related bodies corporate. We may disclose your personal information to these entities for the purposes disclosed in this Privacy Policy, for example, providing data matching and targeted advertising services and enabling us and these entities to better understand and meet your interests and needs;
• our existing or potential agents, business partners or joint venture entities or partners (including for clarity as part of a corporate transaction such as a merger or sale of shares or assets);
• our sponsors, or promoters of any competition that we conduct or promote via our services;
• specific third parties authorised by you to receive information held by us;
• the police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator, for example, if we have reason to suspect that you have committed a breach of any of our terms and conditions, or have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary; and/or
• as required or permitted by any law (including the Privacy Act).

You acknowledge and agree that any personal information submitted by you on our website and applications may be provided by us to our related bodies corporate and our shareholders (ninemsn Pty Ltd and Fairfax Entertainment Pty Ltd) and their related bodies corporate and used by those organisations for any of the purposes disclosed in this Privacy Policy.

Direct marketing materials

We may send you direct marketing communications and information about products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS or email, in accordance with applicable marketing laws, such as the Spam Act 2004 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.

In addition, at any time, you may opt-out of receiving marketing communications from us by contacting us (details below) or by using the opt-out facilities provided (e.g. an unsubscribe link). We will then ensure that your name is removed from our mailing list. We do not provide your personal information to other organisations for the purposes of direct marketing unless expressly authorised by you.

If you receive communications from us that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact us using the details provided below.

Accessing and correcting your personal information

You may request access to any personal information we hold about you at any time by contacting us (details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We will not charge for simply making a request and will not charge for making any corrections to your personal information. If you make an access request, we will ask you to verify your identity. There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.

We request that you keep your information as current as possible so that we may continue to improve our service to you.

How to contact the Privacy Officer

If you have any questions or concerns about our Privacy Policy, complaints regarding how we handle your personal information or would like to make an access request, please contact us using the contact information below.

We will treat your requests or complaints confidentially. All complaints received will be assessed by our Privacy Officer and all reasonable steps (if any) will be taken to remedy the complaint. Our representative will endeavour to respond to your complaint within 30 days of receipt of the complaint by our Privacy Officer.

Please contact our Privacy Officer at:

Privacy Officer
Stan Entertainment Pty Ltd
Post: Suite 1, Level 20, 321 Kent Street, Sydney NSW 2000
Email: privacy@stan.com.au

Disclosure of personal information outside Australia

We may disclose personal information to our external service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

We may disclose your personal information to entities located outside of Australia, including the following:

• our data hosting and Cloud-based IT service providers;
• other external technology partners and service providers located in the United States; and
• other third parties operating in jurisdictions including the United States where you have authorised us to do so.

Links

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

Changes to our Privacy Policy

We may change this privacy policy from time to time and the most current version of the policy will apply. Any updated versions of this privacy policy will be posted on our website. This privacy policy was last updated in November 2014.