Thursday 21, November 2024
The following policy outlines:
- Personal information definition
- Types of personal information collected and held
- Methods used to collect, hold, use or disclose personal information
- Purposes for collecting, holding, using and disclosing personal information
- Consequences if personal information cannot be collected
- Process for seeking access to and correcting personal information
- Disclosure of personal information outside Tonga
- Contact information, including complaint process
What is Personal Information
In this policy, “personal information” refers to the definition provided by the Act, which broadly encompasses any data that can be utilized to identify an individual. Such information may include (but not limited to) your name, age, gender, postal code, and contact details (such as email addresses and phone numbers), as well as financial data such as credit card, direct debit or PayPal account information. If the information collected enables your identification, or if you can be reasonably identified using it, it will be deemed personal information.What Personal Information Do We Collect and Hold
- Your name
- Mailing or street address
- Email address
- Telephone number
- Age or date of birth
- Profession, occupation, or job title
- Details of any products or services you have acquired or inquired about from us, along with any supplementary information necessary to deliver said products/services and respond to your inquiries
- Any additional information about you that you provide to us either directly through our websites or indirectly through our representatives or other online presence
- Information you give us via our customer service center, surveys, or visits by our representatives from time to timeAny other information that is reasonably required for us to fulfill our functions and activities.
Cookies
At times, we may collect your personal information using cookies and other tracking devices. When you visit our website, we may send a “cookie,” which is a small file that contains a unique ID number, to your computer. This allows us to recognize your computer and welcome you each time you visit our website without requiring you to register or log in. It also helps us track the products or services you view so that we can send you news about those products or services. Moreover, we use cookies to track traffic patterns, identify which areas of our website have been visited, and measure transaction patterns collectively. We use this information to study our users’ behaviors, so that we can improve our online products and services. If you do not wish to receive cookies, you may configure your browser to reject them. We may also log IP addresses, which are the electronic addresses of computers connected to the internet, to analyze trends, administer the website, track user movements, and gather broad demographic information. We may also collect anonymous data that is not personal information about your website activity (including IP addresses) through cookies, or we may collect information from you in response to a survey. We typically use this information to report statistics, analyze trends, administer our services, diagnose issues, and target and enhance the quality of our products and services. The Tonga Privacy Principles do not apply to this information to the extent that it does not identify you or anyone else, and we may use it for any purpose and by any means.LiveRamp
ACM utilizes LiveRamp’s Authenticated Traffic Solution (ATS) in addition to other tracking devices such as cookies, to support targeted advertising including by third-party entities. The ATS works by generating a pseudonymized digital fingerprint (known as a LiveRamp ID) for a user when they input their email address or username on an ACM website. This information is then transferred to LiveRamp without disclosing any personal information to enable targeted advertising through the LiveRamp ecosystem. The ATS solution promotes privacy-centric and transparent people-based advertising, enabling publishers to match user data with a LiveRamp ID in real-time, thus supporting people-based advertising on authenticated and cookieless inventory across the internet.How We Collect Personal Information
- Personal information is collected directly from the individual, except when it is unreasonable or impractical to do so.
- Personal information is collected through access and use of the website, apps, or sending SMS/MMS to the company.
- Personal information is collected from someone else who has provided the company with the individual’s information (e.g. a gift subscription).
- Personal information is collected during conversations between the individual and the company’s representatives.
- Personal information is collected when the individual completes an application or purchase order.
- Personal information may also be collected from third parties, such as credit reporting agencies, law enforcement agencies, government entities, advertisers, mailing lists, recruitment agencies, contractors, and business partners.
- Personal information published on social and other media may also be collected.
- To offer you products and services
- To provide you with information and updates about our current and new products and services, including newsletters, surveys, and special offers
- To communicate with you via email, mail, SMS, or phone
- To manage and improve our websites, products, and services
- To personalize and tailor your experience;
- To grant you access to secure areas of our websites;
- To run competitions or promotions on behalf of us or third parties we select;
- To verify your identity;
- To provide your personal information as part of business data to third parties if you have given us your authorization.
- to conduct business processing functions for the operation of our websites or our business;
- for our administrative, marketing, promotional, planning, product/service development, quality control, and research purposes, or those of our contractors or external service providers;
- to provide your updated personal information to us, our contractors, or external service providers;
- to investigate any complaints made by or about you or if we have reason to suspect that you are in breach of our terms and conditions or have been engaged in unlawful activity; and/or
- as required or permitted by law, including the Privacy Act.
What Happens if We can’t Collect Your Personal Information
Failure to provide us with the personal information as described in this policy may result in the following:- We may be unable to provide the products or services you requested, or we may not be able to provide them to the same level of quality or at all. For example, if you do not register as a user of our website, you will not have access to features or services that are exclusive to registered users.
- We may not be able to provide you with information about our products and services that you may be interested in, including information about discounts, sales, or special promotions.
- We may not be able to customize the content of our websites to your preferences, and your experience of our websites may not be as enjoyable or helpful.
How Do We Disclose Your Personal Information
We may share your personal information with the following parties:- Our employees, related bodies corporate, partnerships, joint venture entities, contractors or external service providers, for the purpose of operating our websites or business, fulfilling your requests, and providing products and services to you. This may include web hosting providers, IT systems administrators, mailing houses, newsagents, couriers, payment processors, photographic analysers, data entry service providers, electronic network administrators, debt collectors, and professional advisers such as accountants, solicitors, business advisors, and consultants.
- Our current or potential agents and business partners.
- Sponsors or promoters of any competition that we conduct or promote through our services.
- Our employees, related bodies corporate, partnerships, joint venture entities, contractors, or external service providers for the purpose of operating our websites or our business, fulfilling your requests, and providing you with products and services. This may include web hosting providers, IT systems administrators, mailing houses, newsagents, couriers, payment processors, photographic analyzers, data entry service providers, electronic network administrators, debt collectors, and professional advisers such as accountants, solicitors, business advisors, and consultants.
- Third parties authorized by you to receive information held by us.
- The police, any relevant authority or enforcement body, or your Internet Service Provider or network administrator, if we have reason to suspect that you have breached any of our terms and conditions, engaged in unlawful activity, or if we are required to do so by law (including the Privacy Act).
Direct marketing and targeted advertising
We may engage in direct marketing to inform you about products and services that we think may be of interest to you. The methods we use to conduct direct marketing include email, SMS, and mail, and we will comply with all relevant marketing laws such as the Spam Act 2003 (Cth). If you have a preferred method of receiving direct marketing, we will try to accommodate that method when possible. If you wish to opt-out of receiving direct marketing from us, you can contact us directly using the details below, or make use of the opt-out options provided, such as an unsubscribe link or by updating your information on our “MyAccount” webpage. We will promptly remove your name from our mailing list. Your personal information will not be provided to other organizations for their direct marketing, unless you expressly allow us to do so. If you receive any communications that do not align with this policy or that violate any laws, please let us know using the contact details provided below. In addition, you may receive targeted advertising. For more information about the LiveRamp service (including how to opt-out), please refer to the LiveRamp section above.Sensitive information
If we happen to gather sensitive information about you, such as information related to your racial or ethnic background, political affiliations, religious beliefs, sexual preferences, criminal history, state of health, or medical history, we will use and share such information only for the purpose for which it was provided by you, or as required by the Privacy Act.Accessing and Correcting Your Personal Information
You have the right to request access to your personal information that we hold at any time. To do so, please contact us using the details provided below. We will make reasonable efforts to provide you with a suitable means of accessing the information (such as mailing or emailing it to you) at no cost to you. If you request access, we may need to verify your identity first. In some cases, we may not be able to grant you access to your personal information due to privacy or confidentiality concerns. If this occurs, we will provide you with written reasons for the refusal and advise you on how to make a complaint. If you believe that any of your personal information held by us is incorrect, incomplete or inaccurate, you may request that we amend it. We will assess whether the information requires amendment and, if we agree, we will update it accordingly. If we do not agree, we will make a note on the record to indicate that you disagree with it. Users who are registered on our websites can generally access and update their registration details online. We request that you keep your information up to date to help us provide you with the best possible service.How You can Complain about a Breach of Privacy
If you have any questions, concerns, or believe that your privacy has been breached, please do not hesitate to contact our Privacy Officer using the following details. Please provide as much information as possible about the incident so that we can investigate it thoroughly. We have a formal process for investigating and handling privacy breaches. Upon receiving a complaint, the Privacy Officer will initiate an investigation with the relevant business unit to determine the nature and cause of the breach. We may contact you during the process to seek further clarification if needed. If a breach is identified, the Privacy Officer will escalate the matter to management to prevent any further breaches from occurring. We will keep you informed about the outcome of the investigation and aim to resolve all investigations in a timely manner. All requests and complaints will be handled with confidentiality. Our representatives will contact you within a reasonable time after receiving your complaint to discuss your concerns and provide options for resolving the issue. To contact our Privacy Officer, please use the following details:- Company Name:
- Address:
- Email:
Disclosure of Personal Information Outside Australia
For some of the purposes listed above, we may need to disclose your personal information to our related bodies corporate, partnerships, joint venture entities, and external service providers located overseas. We take reasonable measures to ensure that these overseas recipients uphold their privacy obligations with respect to your personal information. We may need to disclose your personal information to entities located outside of Tonga, including but not limited to:- Our data hosting and cloud-based IT service providers
- Other external service providers in the Philippines and the United States
- Other third parties operating in China, India, Indonesia, New Zealand, Hong Kong, and the United States, where you have given us permission to do so.
