The Huffington Post Australia Privacy Policy
This privacy policy applies to The Huffington Post Australia Pty Ltd (ACN 605 765 491) ("The Huffington Post Australia", "we", "our" and "us").
The Huffington Post Australia takes your privacy very seriously. This privacy policy sets out information regarding how we deal with personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs") that is collected from you when you visit The Huffington Post Australia sites and applications (the "Site") or when you otherwise provide personal information to us including; how personal information may be used and disclosed; how you can control the use and disclosure of personal information; how you can access and correct personal information that we hold about you; how you can make a complaint if you think we have not complied with the APPs or this privacy policy; and how personal information is protected. If you use The Huffington Post Australia mobile applications or sites, additional terms apply("Additional Terms"). If you have any questions about this privacy policy, please contact our privacy team at privacy@huffingtonpost.com.
You do not have to provide any personal information to us. However, if you do not provide us with the personal information that we request we may not be able to provide our services to you.
By using the Site, engaging our services, seeking our assistance, providing personal information to us or authorising another person to provide us with personal information, you consent to personal information (including any sensitive information) being collected, held, used and disclosed by us in accordance with this privacy policy.
1. Third-party websites and services not covered
This privacy policy does not apply to personal information collected through any other website or to the practices of companies that The Huffington Post Australia does not control. Please note that the Site may contain links to other websites. For example, if you click on an advertisement on the Site and link to another website, then this privacy policy will not apply to any personal information collected on that website. We are not responsible for the privacy practices of other websites or services, and we recommend that you read the privacy policies of each website that you visit or service you use.
2. What personal information we collect and how we collect it
We endeavor to collect personal information directly from you. However, we may also collect personal information from third parties including:
• social networking services (such as Facebook Connect or Twitter) you access through the Site;
• online marketing firms and ad targeting firms; and
• from publicly available sources.
Information you provide directly to us:
You are not required to provide personal information directly to us in order to view the Site. However, when you use certain Site functions, such as when you register for certain services, access certain content or features, or directly contact the Site or otherwise contact us, we may ask you to provide personal information, including:
• contact information, such as name, email address, postal address, phone number, and mobile number;
• username and password;
• information posted in community discussions and other interactive online features;
• search queries conducted on the Site; and
• correspondence you send to us.
Information automatically collected when you visit and interact with the Site:
When you visit and interact with the Site, certain information (which may include personal information) may be collected automatically, including:
• your computer's Internet Protocol (IP) address;
• your browser type and operating system;
• the web pages you were visiting immediately before and after you came to the Site;
• activities within community discussions;
• web pages and advertisements that you view, and links that you click on, within the Site;
• your bandwidth speed and information about the software programs that are installed on your computer;
• aggregated data about email click-through rates and user video viewing;
• standard server log information; and
• information collected through HTML cookies, Flash cookies, web beacons, and similar technologies. For more information, please see our discussion of cookies and other technologies.
Information we collect from other sources:
We may access information (which may include personal information) about you from third-party sources and platforms (such as social networking sites, databases, online marketing firms, and ad targeting firms), including:
• if you access third-party social networking services (such as Facebook Connect or Twitter) through the Site, your username and connection lists for those services;
• demographic data, such as age range, gender, and interests;
• advertisement interaction and viewing data, such as ad click-through rates and information about how many times you viewed a particular ad; and
• unique identifiers, including mobile device identification numbers, that can identify the physical location of such devices in accordance with applicable law.
Please note that the Site may combine the information that we collect (which may include personal information) with information we obtain from third-party sources (which may itself include personal information).
If you provide to us the personal information of another person you warrant that you have shown or referred this privacy policy to the person or persons to which the personal information relates and they have consented to such disclosure and to our collection, holding, use and disclosure of the personal information in accordance with this privacy policy.
3. How we use the information that we collect
We collect, hold, use and disclose personal information for the purposes for which it was provided to us, as set out in this privacy policy and as permitted or required by law ("Purposes"). The Purposes include:
Email Communications:
We may use the personal information that we collect to send you e-mail communications, such as editorial updates, information about your account or changes to the Site, and with your consent promotional messages about our own or our marketing partners' products and services. If you signed up for one of our email newsletters, we also will send you the newsletter that you requested. We note you may unsubscribe from receiving promotional information at any time.
Mobile Communications:
With your consent, we may use your mobile number to send you promotions, notifications, or other services. We note you may unsubscribe from receiving promotional information at any time.
Advertising:
In order to provide our readers with free access to our content, we display advertisements on the Site, many of which are targeted based on information about you. For example, using information (which may include personal information) collected through cookies, web beacons, and other sources, we may use demographic data or information about your online activities or interests (which may include personal information) to display targeted advertising that may be relevant to your preferences. Through this process, advertisers reach Site visitors who are most interested in their products, and you see advertising for products or services in which you may be interested. For more information on how cookies and other technologies work, please see our discussion ofcookies and other technologies.
Third-party advertisers and advertising platforms also may serve targeted ads on the Site. For more information, please see our section on third party advertising. Please remember that the information practices of third-party advertisers or platforms collecting data on our site are not covered by this privacy policy.
User Accounts:
To provide you with an open, but also civil, discussion forum, we track user involvement in our community discussions. For example, we keep track of the ratio of how many flagged comments are eventually deleted in order to award badges to our most effective comment moderators. For more information on this process, please see our FAQ section about comment moderation guidelines.
Request Fulfillment:
We may use personal information that we collect to fulfill your requests for products, services, and information. For example, we may use your contact information to respond to your customer service requests or to enable you to participate in features on the Site such as surveys, polls, sweepstakes, and message boards.
Statistical Analysis:
In order to learn more about how our Site is used, we aggregate and analyze the data that we collect. We may use this information, for example, to monitor and analyze use of the Site, to increase our Site's functionality, and to better tailor our content and design to suit our visitors' needs.
Enforcement:
We may use the information that we collect to prevent illegal activities, to enforce the Site's Terms of Service, and to otherwise protect our rights and the rights of our users.
In addition to the uses identified above, we may use the personal information that we collect for any other purposes disclosed to you at the time we collect personal information, pursuant to your consent and/or as permitted or required by law.
4. Information sharing
The Huffington Post Australia values your privacy, and discloses personal information only under certain circumstances. We will make personal information about you available to other companies, applications, or people in the circumstances listed below:
• We may disclose personal information to our related entities and corporate partners;
• We may disclose aggregated information or information that does not directly identify you with third parties to help us develop content, services, and advertising that we hope you will find of interest. Please note that we do not disclose contact information with third parties that advertise on the Site.
• We may employ third parties to perform Site-related services, including database management, maintenance services, analytics, marketing, data processing, and email and text message distribution. These third parties have access to personal information only to perform these tasks on our behalf.
• If you choose to engage in public activities on the site, such as posting comments on community message boards, any personal information you submit can be read, collected, or used by others. Please exercise caution when deciding to disclose any personal information in public activities or submissions.
• We may disclose personal information about you in the event that the Site is acquired by or merged with another company or a similar corporate transaction takes place. However, the Site will notify you by placing a prominent notice on our site or sending a notice to the primary email address specified in your account before personal information about you is transferred and becomes subject to a different privacy policy.
• We may disclose personal information about you to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety or other rights and interests of any person, violations of the Site's Terms of Service, or as otherwise permitted or required by law.
• We may disclose personal information about you to respond to subpoenas, search warrants, judicial proceedings, court orders, legal process, or other law enforcement measures, to establish or exercise our legal rights, or to defend against legal claims.
• In addition to the scenarios identified above, we may disclose personal information about you for any other purposes disclosed to you at the time we collect personal information about you or pursuant to your consent.
Please note that third parties may independently collect information about you, including your IP address and other information (which may include personal information) about the websites you visit and the links you click, through cookies, clicks on links, or other means when you visit or view ads on the Site. For more information, see our section on cookies and other technologies and third party advertising.
5. Third-party services
To customize your experience on the Site and to simplify the Site's registration process, we provide you with the opportunity to access or interact with third-party services, such as Facebook and Twitter. When you connect to the Site through these third-party services, we may disclose personal information about you with these third-party service providers and they may share data about you with us.
When you allow us to access your data through a third-party service to create a Site profile, we may use this data for several purposes, including:
• Creating relationships automatically within our system. For example, if you connect to us via a service with a public friend list, like Twitter, we may check to see if any people you follow on Twitter are also Site members. If we find a match, we will replicate your Twitter relationship with those members, setting them to be fans, followers, or friends on our Site.
• Suggesting relationships. For example, if you connect via a service that has a private contact list (like Google and Yahoo!), we check for people in your contacts who are Site members and suggest that you become a fan of these users. This process is not automatic; you must affirmatively choose to become a fan of these suggested users.
• Populating a list of potential friends to whom you can send emails. When users share content with their friends using, for example, the forward-to-a-friend feature on the Site, we may use friend lists from third-party services to create a list of contacts to whom you may choose to send the email message.
• Populating a list of potential friends to whom you can send service-specific messages. For example, we may use friend lists from a third-party service to create a list of contacts to whom you may choose to send an invitation to view an interactive slideshow.
• To enhance and personalize your experience on the Site. When you are connected via a third-party service, we may access certain account information, such as your profile picture, what stories are popular in your network, and what your friends are saying about certain articles or blog posts, in order to enhance and personalize your experience on the Site.
In addition, if you connect to a Facebook account, your experience on the Site may be personalized. For example, you may automatically see what stories are popular in your network, and what your friends are saying about particular stories.
Please note that you may disconnect third party accounts at any time. Click here for a link to your social profile, where you may set your privacy preferences or disconnect all of your third-party service accounts. You also may be able to modify your privacy settings directly with the third-party service. To modify your Facebook privacy settings, click here. To modify your Twitter privacy settings, click here.
Please remember that we do not control the privacy practices of these third-party services. We encourage you to read the privacy policies of all third-party service providers.
6. Your choices
Deactivating your account
You can deactivate your account at any time by visiting the preferences page for your profile. When you deactivate your account, your user profile will be disabled, but your public comments will remain on the site. The Site has no responsibility to take down, remove, or edit any of your public activities or any submissions that are a result of your public activities. For more information, please review our Terms of Service.
Cookies and other technologies
As discussed in the sections on cookies and other technologies and third party advertising in this privacy policy above, some information (which may include personal information) is collected about you automatically through cookies and other technologies.
• Cookies. You can change your browser settings to reject all cookies, accept only certain cookies, or notify you when a cookie is set. Please note that you may need to renew these settings if you delete your cookies after these preferences are made. These settings also may not apply if you are using a different computer or Internet browser. In addition, many third-party advertising networks are members of the Network Advertising Initiative ("NAI"). To opt out of having information collected by NAI member companies used for behavioral advertising, to obtain information about the technologies these ad networks might use, and to view information regarding their privacy policies, please visit http://www.networkadvertising.org/optout_nonppii.asp. You may also visit Your Online Choices.
• Flash Cookies. You can control how Flash cookies are used by visiting the Adobe Macromedia site, located here. Adobe enables you to allow some Flash cookies from certain websites, limit Flash cookies' storage capacity, and disallow Flash cookies altogether. In addition, if you use Mozilla Firefox for your Internet browser, you can download the BetterPrivacy add-on to automatically delete your Flash cookies every time you close your browser.
If you opt out of these technologies, you will continue to see advertising displayed on the Site, but the advertising may not be targeted to your interests.
Please remember that we do not have access to, or control over, advertisers' or service providers' cookies, and the information practices of third parties are not covered by this privacy policy. For more information on the use of cookies in online advertising, please visithttp://www.youronlinechoices.com.au.
7. Access to personal information
If you choose to share contact information with us, you may update or amend this information by contacting us at privacy@huffingtonpost.com.
You may otherwise access personal information about you that we hold subject to a small number of legal restrictions or exemptions. Where such restrictions or exemptions exist we will advise you of the reasons if we deny your request for access. If you wish to access personal information about you that we hold you should contact us at privacy@huffingtonpost.com and provide us with proof (satisfactory to us) of your identity.
While we do not charge you for a request for accessing personal information about you, please be aware that we may charge a reasonable fee (which will be notified to you once you make a request) for our time and costs in complying with your request in the following circumstances:
• if an extended amount of time is required to collate and prepare the material for you; and/or
• if you wish to have personal information about you photocopied by us.
8. Correction of personal information
We take reasonable steps to ensure that personal information is accurate, complete and up-to-date. However, we rely on you to advise us of any changes to personal information about you.
9. Confidentiality and security
We take reasonable steps to protect personal information that we hold from misuse, interference and loss and from unauthorized access, alteration and disclosure, including limiting access to personal information about you to employees or service providers who we believe reasonably need to come into contact with that personal information to provide products or services to you or in order to do their jobs. We also have adopted commercially reasonable technical, physical, and administrative procedures to help protect personal information including:
• physical security procedures for access to our business premises; and
• IT security procedures including password protection, firewalls, intrusion detection and site monitoring.
Please note that no data transmission or storage can be guaranteed to be 100% secure. We want you to feel confident using the Site, but we cannot ensure or warrant the security of any information you transmit to us.
10. Overseas recipients of personal information
Some of the entities that we disclose personal information to may be located in the United Sates.
Please be aware that the personal information we collect in accordance with this privacy policy may be subject to the privacy and data protection laws of the United States which are not equivalent to the laws of Australia and access to personal information held outside of Australia may be restricted.
By using the Site or providing us with personal information about you, you consent to the disclosure of such personal information to and holding of such personal information in the United States.
AOL Inc. adheres to the EU-US Safe Harbor Privacy Principles of Notice, Choice, Onward Transfer, Security, Data Integrity, Access and Enforcement, and is registered with the U.S. Department of Commerce's Safe Harbor Program.
11. Children
We do not knowingly collect personal information from children. If we learn that we have collected any personal information from a child without verifiable parental consent, we will delete that personal information from our database as quickly as possible. If you believe that we may have collected personal information from a child, please contact us at privacy@huffingtonpost.com.
12. Changes to the privacy policy
We may update this privacy policy at any time to reflect changes in our practices and service offerings. If we modify this privacy policy, we will update the "Effective Date" below. We will notify you of any material changes in the way we treat personal information by placing a prominent notice on our Site or sending a notice to the primary email address specified in your account.
Your continued use of the Site, requesting our assistance or your provision of further personal information to us (directly or via an authorized person) after this privacy policy has been modified constitutes your acceptance of and consent to the modified privacy policy.
13. Questions and suggestions
If you have questions about this privacy policy, please contact our privacy team atprivacy@huffingtonpost.com.
14. Complaints
If you wish to make a complaint about our handling of personal information or if you believe we have breached the APPs or this privacy policy please contact us at privacy@huffingtonpost.com. You will need to provide us with sufficient details regarding your complaint together with any supporting evidence.
We will investigate your complaint and determine the steps (if any) that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the outcome of our investigation.
If you are not satisfied with our determination, at any time you can complain to the Australian Privacy Commissioner (see www.oaic.gov.au for contact details).
Effective Date: August 17, 2015
