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INTRODUCTION
We are committed to protecting and maintaining your privacy and we are bound by the Australian Privacy Principles (APPs) and Privacy Act 1988 (Cth) (Privacy Act). As part of our business operations we may collect your personal information. This Privacy Policy describes the type of personal information we may collect and how we use, hold and disclose this personal information.
Please note that due to the nature of our business activities, from time to time we will handle personal information relying on the media exemption in the Privacy Act where appropriate and this is discussed in more detail below. We may also rely on the related bodies corporate, employee records and other exemptions that are included in the Privacy Act.
This Privacy Policy is in addition to the general Terms of Use governing our digital services and should be read in conjunction with such Terms of Use.
If your personal information is being collected offline e.g. by phone or in-person, the relevant collecting entity will be made known to you as part of the collection notice given to you in connection with that activity.
Please note that if you become a member of our Future Women private Facebook Group, your activity and personal information shared via the Facebook platform will also be governed by Facebook’s Data Policy available at https://www.facebook.com/about/privacy/update
WHAT IS PERSONAL AND SENSITIVE INFORMATION
When used in this policy, the term “personal information” or “sensitive information” has the meaning given to that term in the Privacy Act. In general terms, personal information is any information that can be used to personally identify you. This may include (but is not limited to) your name, age, address and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card or direct debit information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
Sensitive information is personal information that includes information about an individual, including racial or ethnic origin, or health information.
WHAT KIND OF INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?
The type of personal or sensitive information Future Women collects will vary depending on the nature of your dealings with us. We only collect personal information that we need for our business activities, or which is volunteered to us. In general, the type of personal information we collect and hold could include (but is not limited to):
We may collect your personal information via our websites, applications, chatbots and other digital services or over the phone, when you email or write to us, when you subscribe to our services, when you attend an event or program run by us or when you participate in a survey, questionnaire, competition or other marketing campaign run by us and/or our partners.
We do not generally collect sensitive information as that term is used in the Privacy Act. We may collect sensitive information about you such as racial or ethnic origin and health information (e.g. mental health and disability). If we hold any sensitive information about you, that information will only be used and disclosed by us if you have consented to such use and disclosure. We will not collect, use or disclose your sensitive information for the purpose of marketing.
In order to access some of our services and products, you will be asked to register with us by providing us with certain information about you which we refer to in this Privacy Policy as your Future Women Account (although your account may not be branded as ‘Future Women’ and may be branded as the Future Women product for which you have subscribed e.g. “Jobs Academy”).
We also collect other information and data, such as anonymous data that we collect via your interaction with our digital services and third party digital services (where we provide digital analytics tools or deliver advertisements) using tracking technologies such as cookies and web beacons. This information and data may not be considered personal information under the Privacy Act. This information and data may be used by us internally and/or provided by us to third parties including our partners, clients and service providers for purposes that may include, without limitation, providing you with more relevant advertising, preparing audience insights, customer research, campaign analysis, conducting launch surveys and modelling.
INFORMATION WE COLLECT FROM OTHER SOURCES
We may access information, including personal and/or sensitive information, about you from third-party sources and platforms (such as social networking sites, databases, recruitment platforms such as LinkedIn and Seek, online marketing companies, agents or representatives we have engaged via our digital services, Microsoft Products, third party digital services and data supply companies) and supplement the information we collect with information obtained from those third party sources.
When you connect with us through social networking services, you will be able to see the social sharing habits of your friends and connections and participate seamlessly in our social capabilities, including commenting, live blogging, reactions, ratings, and sharing content. By connecting with us through these third-party social networking services, you are authorising us to access and use certain information from your social network profile.
If you do not provide and we do not collect your personal information in the ways we have described above, we may not be able to as effectively provide you with our products and/or services that you have requested. For example, if you do not register as a member of our website, you may not be able to access features and services that are reserved for members or we may not be able to tailor the content of our websites or applications to your preferences so your experience of our websites or applications may not be as enjoyable or useful.
HOW WILL WE USE OR DISCLOSE YOUR INFORMATION
Your personal or sensitive information collected by us will never be shared, sold or provided to third parties without your consent. We only use or disclose personal information for the primary purpose for which we have collected it, or for another related secondary purpose, unless you have provided your consent for us to use it for another purpose. We may use or disclose your personal information for one or more of the following primary purposes relevant to your relationship with Future Women:
For the purpose of providing a Future Women product or service to you, including to:
For the purpose of Future Women providing you with digital services, profile information and insights, including to:
For the purpose of Future Women undertaking general business functions, including to:
For the purpose of Future Women complying with applicable laws, including to:
We may disclose your personal data to third parties who assist and enable us to use your personal data to support delivery of our services to you, these third party service providers include:
We will not provide any personal information to an advertiser or any other third party other than in accordance with the terms of our Privacy Policy without your express consent. However, to the extent that anonymous user data does not constitute personal information, we are entitled to deal with that information in any manner we see fit.
You expressly acknowledge and agree that information including your personal information may be shared within Future Women and with the third parties referred to in this Privacy Policy for use by those third parties for the purposes disclosed in this Privacy Policy.
METADATA
In many circumstances you may use our digital services without providing any personal information to us. In these instances, we will collect metadata that results from your usage of our digital services including (but not limited to) browser type and version, operating system and interface, website from which you are visiting us (referrer URL), webpage(s) you are visiting on our digital services, date and time of accessing our digital services and internet protocol (IP) address (together, “Metadata”). We use this Metadata to improve the quality and services of our digital services by analysing the usage behaviour of our users in anonymised form and to prevent fraud, misuse of our IT systems, as well as to ensure physical, IT and network security.
We may also use the Metadata we collect for other purposes, including to personalise online advertising or other marketing that you receive from us.
WHAT MARKETING COMMUNICATIONS WILL YOU RECEIVE?
OPTING IN
In certain contexts when we collect information from you, you may be asked to “opt in” to consent to us using or disclosing your personal information. For example, you may be asked to opt-in to receive further information or communications from our advertisers and partners. We do not provide your personal information to other organisations for the purpose of direct marketing unless expressly authorised by you.
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, telephone, SMS or email, in compliance 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.
If you receive communications from us that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any applicable law, please contact us at [email protected].
OPTING OUT/UNSUBSCRIBING
You will be given the opportunity to “opt out” from receiving communications from us or from third parties that send communications to you in accordance with this Privacy Policy. For example, you will be given the option to unsubscribe from newsletters, emails, SMS communications and other marketing or promotional material sent by us. You may also opt-out of ‘interest based advertising’ (also known as ‘online behavioural advertising’) (interest based advertising) as set out in our Tracking and Targeting Policy.
If you receive communications purporting to be connected with us or our services that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any applicable law, please contact us.
SECURITY AND MANAGEMENT OF YOUR INFORMATION
We understand that the security of your personal information is important. It is our policy to ensure that all Future Women employees understand and take reasonable steps to keep your personal information secure and only use it in accordance with this Privacy Policy. Once collected, we may hold your personal information in a number of different formats, including (but not limited to) software programs (located both onsite and offsite, including in the cloud), databases, filing systems, in offsite backup storage and in other similar technology. We take all reasonable steps to protect your personal information (and your anonymous usage data) and to keep it secure from loss, unauthorised access, modification, disclosure, interference or other misuse and we have appropriate controls in place to limit who in Future Women can view, access and/or use your personal information and anonymous usage data.
We also impose strict requirements of security and confidentiality on all third parties (for example, those who provide us with technology services) as to how they store, handle and deal with the personal information and anonymous usage data that we hold.
Personal information and anonymous usage data collected by us may be stored, disclosed and processed both in Australia and/or overseas, including but not limited to the United States, New Zealand, China, India, Malaysia, the Philippines and Singapore. Our third party contractors and service providers may perform some of their services overseas and/or we may use data hosting and cloud based IP service providers whose operations are located overseas. In all instances where this occurs, we only disclose your personal information to them and authorise them to use it in accordance with the Privacy Act and this Privacy Policy.
TRACKING TECHNOLOGIES NOTICE
We also collect anonymous usage data about your browsing activity on Future Women’s network via various tracking technologies (for example, via cookies, tags, pixels). Our third party service providers may also collect anonymous usage data on the terms of their privacy policies which will be disclosed to you where relevant. This anonymous usage data may be used to identify your device on third party digital services where we have an arrangement in place to serve ads on those third party digital services. We may also collect anonymous usage data from third party digital services. One of the reasons we collect usage data is to display to you more relevant advertisements or content on the Future Women website and also on third party digital services.
Tracking technologies contain information that can later be read by a web server in the domain that issued the tracking technology to anonymously identify your device. We use the following types of tracking technologies:
We also use tracking technologies as described in Display of Advertisements below. You have the ability to accept or decline tracking technologies. If you choose to decline tracking technologies, you may not be able to sign in or use other interactive features of our digital services, and some advertising preferences may not be able to be respected. If you choose to accept tracking technologies, you also have the ability to later delete tracking technologies that you have accepted.
DISPLAY OF ADVERTISING
Many of the digital services we offer are supported by advertising. We may display advertisements on our digital services and on the digital services offered by our advertising partners. We place tracking technologies on your device when you interact with our digital websites and apps and this anonymous data may be used to group you into relevant audience segments so that we can deliver more relevant advertising to you. We may also use the tracking technologies to recognise your device each time we display an advertisement to your device. We are able to compile information over time about where you, or others who are using your device, saw and/or clicked on the advertisements we display. We may also associate this information with your visit, purchase or other activity on participating advertiser’s digital services in order to display relevant advertisements or to determine the effectiveness of the advertisements.
For example, if we inferred that you are interested in bicycles, you may see advertisements for different brands or types of bicycles whereas if we infer that someone else is interested in travel, they might see advertisements for flights and accommodation packages. It is this targeting which enables us to optimise our advertising and your user experience and to provide you with more relevant information about different products and services available to you. Advertisers may also embed their own tracking technologies in their advertisements on our digital services. Our third party service providers may also embed tracking technologies on our digital services to assist them to perform services for us. We encourage advertisers and such third party service providers to have a privacy policy that outlines their data collection activities and usage. Please refer to such third party privacy policies for more information.
YOUR ADVERTISING CHOICES
When we display interest-based advertising, we take a number of steps designed to protect your privacy. We store content consumption data (eg page views) used for ad targeting separately from your contact information or other data that directly identifies you. We use interest-based advertising to make the ads you see on our network more relevant to you. Online advertisements on our digital services are served by ad servers and exchanges and/or by our other third party service providers to whom we may from time to time outsource the procurement of advertising. These companies may offer you a way to opt in or opt-out of ad targeting based on their tracking technologies. If you would like to opt out of interest based advertising please visit the following links: https://adssettings.google.com, https://www.adobe.com/au/privacy/opt-out.html, https://platform.xandr.com/privacy-center/opt_out. You can also manage certain tracking technologies in your web browser privacy settings.
Please note that even if you opt out of interest based advertising, anonymous usage data may however continue to be collected by us and/or our third party partners for other purposes.
PRIVACY STANDARDS FOR JOURNALISTS
As we are in the media industry, the APPs do not apply to acts done or practices engaged in by us in the course of journalism as we are committed to other journalistic standards dealing with privacy. Specifically:
ACCESS TO PERSONAL INFORMATION
(a) Under the Privacy Act, you have the right to request access to the personal information which we hold about you. If you wish to exercise your right under the Privacy Act to seek access to the personal information that we hold about you, we ask that you contact us at [email protected]. If you make an access request, we will require you to verify your identity before we provide you with any access.
(b) We will endeavour to acknowledge your request for access within 7 days, and to provide you with the access to which you are legally entitled within 30 days of the date of receipt of your request. We will notify you if we consider it will take longer than 30 days to provide you with access. If you seek access to records held by us which are not current records, we may need to contact you to discuss your request and it may take a longer period of time to locate these records and we may charge you an administrative fee reflecting our cost of providing access. If we are not legally required to provide access to the personal information requested and we exercise our discretion not to provide that information, we will let you know our reasons for doing so.
CHANGES TO YOUR INFORMATION
We endeavour to ensure that the personal information we hold is accurate, complete and up-to-date. You have the right to ask us to correct information about you which is inaccurate, incomplete, out of date, not relevant or misleading. Alternatively, if you have a Future Women Account, you can access and update personal information you have entered in relation to that account by logging in and accessing or updating that information yourself.
DELETION OF YOUR PERSONAL INFORMATION
If you are a customer of one of the services provided by Future Women and no longer wish to use one of our services, you can ask us to delete the personal information you provided to that service when you registered for, or provided certain information to, the service or updated your profile such as your username, name, address, telephone number and email address.
To request the deletion of your personal information from one of our services, please contact [email protected].
We may not be able to comply with all requests, for example for legal or business reasons such as if we need to continue using the personal information for the purposes for which it was initially collected or for related business purposes, the personal information is required to comply with our legal obligations including to third parties or the courts, or for certain classes of information which cannot be deleted for technical reasons.
CHANGES TO THIS PRIVACY POLICY
We may, from time to time, review and update this Privacy Policy to take account of new laws, technologies and changes to our business and operations. All personal information held by us will be governed by our most recent Privacy Policy which will always be available on our digital services. By using our digital services, you are deemed to have agreed to the terms of our Privacy Policy (as updated from time to time) and you should therefore ensure to review our Privacy Policy regularly to keep abreast of any changes that may have been made.
PROCEDURE FOR DATA BREACHES
We do all we reasonably can do to ensure your data is collected, used and held securely in accordance with industry standards. If at any time we become aware of unauthorised access to or disclosure of personal information held by us and we consider this is likely to result in serious harm to any individual to whom the information relates we will follow the data breach notification requirements under applicable law including to notify the individual involved and the relevant regulator.
EU AND CALIFORNIAN RESIDENTS
If you are based in the European Union or California, there are specific regulations that apply in relation to the collection, processing and storing of your personal information by organisations covered by those regulations. To the extent that we are legally required to comply with those regulations in relation to any personal information and/or anonymous usage data we collect, process, disclose or store about you, we will comply with those regulations. Please note that we do not develop, target or direct our websites, products or services towards individuals (including children) situated outside Australia. Our business is targeted at individuals who are domiciled in Australia even though you are able to subscribe for our services from outside Australia. We do not knowingly collect personal information about children under 16 years of age. If you believe a child in your care has provided us with personal information or data and you would like to request us to look into removing the data from our servers, please contact us at [email protected].
CONTACT US
If you have any questions regarding this Privacy Policy, complaints regarding how we handle your personal information or our tracking and targeting policies or if you would like to make an access request, please contact us by mail at: Privacy Officer, 1 Denison Street, North Sydney, NSW, 2060 or via email at [email protected].
All complaints received will be assessed by our Privacy Officer and reasonable steps will be taken to remedy any valid complaint. We will endeavour to acknowledge your complaint within 5 business days and to respond to your complaint within 20 business days of receipt of the complaint by our Privacy Officer. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner via their enquiry line on 1300 363 992, via their online form, or send a letter to: GPO Box 5288, Sydney NSW 2001, Australia.
Last updated: 4 December 2023