Privacy Policy

Last Updated: 5 September 2018
Introduction
HSR Publishing Holdings Pty Ltd respects the privacy of all of its users and customers and is committed to protecting such privacy in accordance with this Privacy Policy and applicable Australian and International privacy laws including the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) and the General Data Protection Regulation 2016/679 (GDPR).
This policy explains HSR Publishing’s treatment of your personal information collected in connection with your activities on or related to all HSR Publishing websites referencing this policy (the “HSR Publishing Sites“) and any services made available on the HSR Publishing Sites (collectively, unless noted otherwise, the “HSR Publishing Services“).
We urge you to read this policy carefully and to check back periodically for changes, which will indicate the latest revision date. This policy does not apply to the practices of companies or websites that are not owned or controlled by HSR Publishing. Your access or use of any HSR Publishing Site indicates your understanding of, and agreement to be bound by, this policy and the HSR Publishing website Terms and Conditions.
Anonymity and use of a Pseudonym
You may request at any time that you remain anonymous, or choose a pseudonym, when dealing with us.  To the extent that it is lawful and practicable for us to enable you to do so, we will grant such a request.
What Personal Information Do We Collect?
In the course of operating any HSR Publishing Services, we may collect two types of information about our users and customers: Personal Information and Non-Personal Information.
The types of personal information we collect and hold about you will depend upon a range of circumstances, including the purpose of the collection and the product or service we are providing you.
Whilst you are not under any obligation to provide your personal information, without it we may not be able to provide you with the full extent of our services or products or we may be restricted in the way we supply those services or products.
“Personal Information” is information (or an opinion about you, whether true or not) which identifies you or from which your identity is reasonably identifiable, such as your name, address, email address / other contact details and birth date. Personal information may also include transaction details such as when you make a purchase with us and “Account Information” which is information that may be required to set up an Account or an online profile on an HSR Publishing Site (as more fully described in the Terms and Conditions).  Personal Information may also include bank account and/or credit card numbers and details as may be reasonably required for processing payments made to us. In certain circumstances, such as where you apply for employment with us, we will collect additional personal information such as your employment and educational history and employment references.
“Non-Personal Information” is information that is not linked to a specific person. This includes technical information such as your Internet Protocol Address, the domain you may have used to access an HSR Publishing Service, the type and version of browser or operating system you may be using, and the website you may have come from and visit next. Aggregate information, such as the demographic statistics of our users and customers (e.g. average age or geographical allocation of our users), number of visitors and average time spent on an HSR Publishing Service, is also considered Non-Personal Information. Non-Personal Information is collected or derived by us in the course of operating an HSR Publishing Service. For example, our web servers may automatically collect Non-Personal Information that is provided through your browser or stored on a Cookie or through a Web Beacon when you choose to visit an HSR Publishing Service.  We may also receive Non-Personal Information about you from third-party business partners and other service providers.  We may collect Non-Personal Information automatically via cookies (as set out in the “How do we use Cookies and Web Beacons” section below).  Where the cookies are not strictly necessary to provide an HSR Publishing Service, then we will only collect information about you from such cookies with your consent.
We generally do not collect sensitive information such as health details, gender orientation details or details of political affiliations but if collection of such details is required in relation to the provision of an HSR Publishing service or other benefit or offer to you we will notify you at the time of collection and obtain your consent to collect and hold such sensitive personal information.
If you provide us with sensitive information on an unsolicited basis, we will assess whether such information is reasonably necessary for our functions or activities. The unsolicited sensitive information you disclose to us may be used and disclosed for the purpose for which it was provided or, where you would reasonably expect us to, we may use the information for a directly related secondary purpose. We may also use or disclose the information for other purposes with your consent or if required by law.
Why Do We Collect Your Personal Information?
We collect your personal information for the performance of our business activities and functions.  This includes providing a range of products and services to you, including, but not limited to, those listed below.

1. Registration for Magazine Subscriptions

We collect personal information from individuals who subscribe to our magazines in order to process their payments and to confirm whether they would like to receive promotional materials in the future.
We will also seek your consent to send you promotional material and special offers. Where you have a subscription for a magazine published by us, then we will also send you renewal notices, that magazine’s regular newsletter as well as promotional material and occasionally (where notice has been given) you may also be sent special offers from third parties associated with that title.
2. Sales Promotions, Competitions, Surveys and Registration to attend our Events
We collect personal information when you respond to one of our promotions, competitions or surveys or when you register to attend an event, in order to inform you if you have won a prize, to place you on a guest-list to the event and/or to help us better understand what products and services you would like to receive information about in the future
3. Our Mobile Apps
We, or a service provider, may collect information through our apps to assist us in understanding how you use our apps, how the apps are performing across different handsets and to assist us in the selection of advertisements for groups of individuals.  By downloading the app from the respective app store, you agree to us accessing this information.
4. Registration for our Newsletters, Online Communities and/or Loyalty Clubs
We collect personal information when you sign up to register for our newsletters or join one of our online communities or loyalty clubs. By providing this personal information we are able to keep you updated on special offers and events that you may be interested in and to reward your commitment to the brands.
5. Our Online Communities
We collect personal information from you when you participate in any activity on our online communities. By providing personal information to us during such activity, we can assist in identifying ways in which we can provide you with a better service, or enhance your online experience.
6. Employment or Internship
We collect personal information from applicants who are seeking employment or an internship with us as part of the recruitment process.  In circumstances where you do not provide the mandatory personal information, we will be unable to consider you for a position with us.
7. Direct Marketing and Research
Marketing and research is important to our continued success and development, and as such we may use personal information about you for marketing and research purposes.
However, you can manage your communication preferences with us in a number of ways.  Online customers have the option to manage their own online profiles, and all customers have the option to contact our Privacy Officer. In addition, the marketing communications that we send to you will also contain information on how to unsubscribe from those communications.
You can tell us at any time if you do not want us to disclose your details to other organisations such as our related companies or third parties for marketing purposes. To do this, please contact our Privacy Officer using the details at the end of this Privacy Policy by sending an email to Privacy@hunterandcoastal.com.au
Sometimes we extract information from our collected records to produce aggregated data. This aggregated data does not identify individuals. We use the aggregated data for research purposes, product development and may share the data with third parties.
How Do We Collect Your Personal Information?
Personal Information is collected by us when you choose to provide it to us when registering for an HSR Publishing Service, such as when you choose to subscribe to an HSR Publishing Service or newsletter, or enter an HSR Publishing promotion. In addition, if you choose to contact a customer service representative of ours or provide us with feedback, we may keep a record of that correspondence so that we may fully address the subject matter. We may also receive Personal Information from our business partners and other third parties, provided that such third parties confirm to us that you have permitted them to share such information. We may also collect other information that you make publically available on-line (including but not limited to, information on social media platforms). Business contact information such as the name, title, business address, email address or telephone number of a business or professional person or an employee of an organization is not considered Personal Information.
We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may also collect personal information through some of the following means:
(a)   when you purchase a magazine or digital subscription;
(b)   when you enter into promotions or competitions;
(c)   when you provide answers to surveys;
(d)   when you sign up to newsletters and other notifications from our magazines and other brands;
(e)   when you sign up to join our online communities;
(f)    when you register to attend events;
(g)   when you provide express permission when accessing applications sitting on HSR Publishing brand social media accounts;
(h)   when you apply for an internship or employment with us;
(i)     when you communicate with us such as letters, telephone calls, text messaging and emails regarding services and products;
(j)     when you register for our loyalty clubs; and
(k)   when you download and use our digital publications and mobile applications (“apps”).
However, in some circumstances we may also collect personal information from third parties or public agencies where it is unreasonable or impracticable for us to collect the personal information directly from you, including (but not limited to):
(a)   if you subscribe to one of our magazines through a third party that is authorised to take subscriptions for us, we will collect your personal information from that third party; or
(b)   if we have difficulty in delivering a magazine to you, we may make enquiries in an effort to locate your address or correct any error in our recorded address details for you.
In some circumstances, we may provide you access to our online communities through the option of a third party platform sign on (including but not limited to, social sign-ons). In this instance we will be accessing and collecting the personal information which you have authorised the third party platform to pass on to us. Where we collect personal information from third parties, we will ensure that the collection is conducted in a fair and lawful manner and the information is reasonably necessary for our functions or activities.
How Do We Use Your Personal Information?
We may use Personal Information for the following purposes;
a) Providing you with an HSR Publishing Service (such as magazine subscriptions and in order to process payments) and information you have requested from us, including your use of an HSR Publishing Site. We may from time to time use your Personal Information to contact you about changes, enhancements or similar notices related to an HSR Publishing Service;
b) If you opted-into receiving offers or information from us or certain of our selected sponsors or advertisers, we may send you email materials and other mailings about products and services that we feel may be of interest to you. If at any time you would like to end your subscription to any such email materials, follow the directions posted at the bottom of the email or the relevant website;
c) if you participate in a survey conducted via an HSR Publishing Site we may use your personal information for the purposes of administering and verifying your participation in that survey.
d) if you register for an HSR Publishing event we may use your personal information for the purposes of administering your registration and attendance at that event.
e) If you enter a contest or other promotion offered on an HSR Publishing Site, we may, under the rules of the promotion, use your name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion;
f) We may also use Personal Information if we have reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial, foreign or other law or in order to protect or defend a legal interest; and
g) Account Information is used to manage your Account, to verify your credentials for logging-in to the HSR Publishing Site or HSR Publishing Service associated with the Account, and to communicate with you information about your Account when necessary.
We must have a legal basis to process your Personal Information.  In most cases, the legal basis will be one of the following:

• To fulfill our contractual obligations to you
• To comply with our legal obligations
• To meet our legitimate interests to run our business effectively, to understand how you use our services and to enable us to derive knowledge from that to enable us to develop new services and keep our records accurate and up to date.  When we process your personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

Disclosure of Your Personal Information
We will not sell or rent your Personal Information to any third party.
We will only disclose your Personal Information to third parties under the following circumstances:
a) Where you have specifically given us your consent to disclose your Personal Information for a designated purpose;
b) To persons acting on our behalf as our agents, suppliers or service providers, solely to enable us to more efficiently provide you with an HSR Publishing Service. Such entities act under strict contractual controls, requiring them to maintain the confidentiality of all such Personal Information, comply with all applicable Privacy Laws and to use such information solely for purposes related to the provision of the HSR Publishing Services. These organisations may include:

• newsagents for the purpose of fulfilling subscriptions to our publications;
• organisations who are sponsoring or otherwise involved with or participating in a promotion, offer, competition or survey;
• other companies or individuals we engage to perform functions on our behalf, including, but not limited to, mailing a subscription, processing credit card information, mailing information or prizes, data analysis, telemarketing, research and advertising, IT support services; and

c) As may be set out in the Terms and Conditions applicable to HSR Publishing Service to facilitate the provision of such service, such as fulfilling legal requirements;
d) As required by law, including by an order of any court, institution or body with jurisdiction or authority to compel the production of information, or in order to protect or defend a legal interest; or
e) In connection with an HSR Publishing corporate re-organization, merger, amalgamation or similar transaction with another entity, or a sale of all or a substantial portion of the assets of HSR Publishing, provided that the Personal Information disclosed continues to be used for the purposes permitted by this policy by the entity acquiring the information.
We disclose your personal information offshore to our owners, joint venture partners, service providers and agents. It is not practicable to specify all the countries to which we may disclose your personal information due to the fact that we are part of a global organisation. The major countries and regions your personal information will be disclosed to include New Zealand, Canada, the Philippines and Europe. If we disclose information to a third party, we request that the third party protect that information to the same extent that we do.
Your rights over your Personal Information
You have certain rights regarding your personal information, subject to local law. These include the following rights to:

• access your personal information;
• rectify, correct or update the information we hold about you;
• erase your personal information;
• restrict our use of your personal information;
• object to our use of your personal information;
• receive your personal information in a usable electronic format and transmit it to a third party (right to data portability);
• lodge a complaint with your local data protection authority.

If you would like to discuss or exercise such rights, please contact the Privacy Officer at the details below. We may charge you an access fee to cover our costs of providing that information to you.  We will inform you of applicable fees before they are incurred.
However, we are not obliged to correct any of your personal information if we do not agree that it requires correction and we may refuse to do so. If we refuse a correction request, we will provide you with our reasons for refusing. We take reasonable steps to make sure that the personal information we collect is accurate, complete and up-to-date including updating personal information when we are advised by you that your personal information has changed.
We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. In certain circumstances you will be able to access your own personal information via your membership sign in and correct and/or update your personal information. In certain circumstances, we may refuse your request to access, or correct, your personal information.  If that is the case, we will provide you with reasons for that decision unless it is unreasonable for us to do so.
If you wish to delete the personal information we hold about you, please let us know by contacting the Privacy Officer using the contact details set out below. We will take reasonable steps to delete the information, unless we are required to retain it for legal reasons.
Where you have provided your consent to any use of your personal information, you can withdraw this consent at any time.
We will contact you if we need additional information from you in order to honour your requests.
If you no longer wish to receive non-transactional communications from us, please click the “unsubscribe” link in any email from us, update your marketing preferences in your account, or contact us at the address below.
How Do We Use Non-Personal Information?
Non-Personal Information is collected or derived by us in the course of operating the HSR Publishing Services. In addition to our practices related to IP addresses, Cookies or Web Beacons, Non-Personal Information is used generally by us to monitor and improve the operation of our services, to perform statistical analysis of the collective characteristics and behavior of our users and customers, to measure user demographics and interests regarding specific HSR Publishing Services, to describe our services to third parties such as prospective business partners and advertisers, and to analyze how and where best to use our resources. No Personal Information will be disclosed during these activities.
We may also use Non-Personal Information to inform our sponsors and advertisers as to the performance of a particular sponsorship (such as a contest) or advertisement. In any such case, we may disclose to those third party sponsors and advertisers the overall aggregate demographics available regarding, for example, who participated in a contest or who saw and “clicked” on an advertisement. No Personal Information will be disclosed to these sponsors and advertisers as part of this process; only information in an anonymous, aggregate form will be disclosed.
How Do We Use Cookies and Web Beacons?
Information may be collected when you access our websites or apps, such as the time and specific page or app you visited.  This information is collected through “cookies”. A cookie is a small text file containing a unique identification number that is transferred (through your browser) from a web site to the hard drive of your computer. The cookie identifies your browser and will not let a web site know any personal information about you, such as your name and address. Since cookies are only text files, they cannot run on your computer, search your computer for other information, or transmit any information to anyone. Cookies are used on many major web sites. Most browsers are initially set up to accept cookies. If you prefer, you can reset your browser either to notify you when you have received a cookie, or to refuse to accept cookies. You should understand that while we do not require you to use cookies, certain of our website and app services will not function properly if you set your browser to not accept cookies.
HSR Publishing may use cookies to:
a) Monitor website usage and improve the operation and performance of our site and to make our services easier and more convenient to use. For example, cookies help us to remember who you are through your browser settings so that we can offer and provide more personalized services (e.g. language preference). Cookies also allow us to save passwords and preferences and other login information for you so that you will not have to re-enter them the next time you visit an HSR Publishing Service to sign into your Account;
b) Measure aggregate user traffic and demographic statistics related to the HSR Publishing Services and advertisements (e.g. number of users, average time spent, average age and similar statistics). This information helps us to better understand when to update, change or offer new services and provides us with details as to the performance of third party advertisements and content. This information and statistical data may be reported, in aggregate form only, to our current and prospective sponsors, advertisers and business partners for industry and other public reporting. No Personal Information will be disclosed in such reports; and
c) Displaying advertisements. HSR Publishing and third party advertising providers used by us may use cookies when serving advertisements to provide you with a more targeted advertising experience both on and off our websites or apps, allowing us to impose restrictions where appropriate and monitor how effective an advertising campaign has been.
We engage various analytic programs to analyse the performance of our websites and apps and to provide us with reports that contain aggregated, de-identified benchmark information that assists us to understand when, and how many times, you have used our websites or apps. The anonymous information assists us in the selection of advertisements for groups of individuals.
We may also use Google Analytics features (including Google Remarketing, Google Display Network Impressions Reporting, the Double Click Campaign Manager and Google Analytics Demographics and Interest Reporting) on our websites and apps.  Google Analytics uses both first party and third party cookies to record standard internet traffic information such as when, and how many times, you have visited our websites or apps.  We and some third parties also use the information to optimise advertising selection for groups of individuals based on demographic information.  The cookies allow us and other third parties to evaluate your interactions with advertising services on our websites and apps and serve targeted advertising on those websites and apps and across the Internet.  We have enabled Google Analytics for Display Advertising, which allows Google and other third parties to advertise to you on our websites and apps and across the Internet.
By using Google Ads Settings (located at https://www.google.com/settings/ads), you can opt out of these features at any time and customise your Google Display Network Ads.  Alternatively, you can opt out of a third party’s vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page (located at https://www.networkadvertising.org/choices/).
Certain HSR Publishing Services may contain electronic images known as Web Beacons – sometimes called single-pixel gifs – that allow us to count users and customers who have visited those pages and to deliver co-branded services. Web Beacons are not used to access your Personal Information; they are a technique used to compile aggregated statistics about HSR Publishing Service usage. Web Beacons collect only a limited set of information, including a cookie number, time and date of a page view, and a description of the page on which the Web Beacon resides. Certain HSR Publishing Service web pages may also contain Web Beacons placed there by our advertising partners to help us determine the effectiveness of our Internet advertising campaigns.
The following table sets out the different categories of cookies that our Services use and why we use them.

 
You have the right to choose whether or not to accept cookies.  However, they are an important part of how our Services work, so you should be aware that if you choose to refuse or remove cookies, this could affect the availability and functionality of the Services.
Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.  To do so, please follow the instructions provided by your browser which are usually located within the “Help”, “Tools” or “Edit” facility.  Some third parties also provide the ability to refuse their cookies directly by clicking on an opt-out link, and we have indicated where this is possible in the table above.
Removing or rejecting browser cookies does not necessarily affect third-party flash cookies used in connection with our Services.  To delete or disable flash cookies please visit http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html for more information.
What IP Address Information is Collected and How is It Used?
An IP address is the unique number that is assigned to every direct Internet access point. Many IP addresses can generally be associated with certain Internet service providers or large organizations. When you, through your browser, request a web page or similar Internet information from another computer on the Internet, your browser automatically provides that computer with an IP address to which it will send the requested information.
Whenever you request an HSR Publishing Service web page or certain other similar HSR Publishing content, your browser automatically provides our computers with your IP address, to which our computers will send the requested information. Each such request is logged by our computers with information including the IP address of the computer that requested the page and is stored by our computers as needed for the purposes described in this policy.
We may use your IP address to display more appropriate and relevant content and advertising, such as content and advertising based on your geographic area. Aggregate information derived from IP addresses may be reported by us to our advertisers and partners. For example, we may report to our advertisers the estimated total number of users accessing a particular HSR Publishing Site from a specific province. We may also use your IP address to facilitate the diagnoses and remedy of a technical problem reported by you or our technical team.
What Privacy Applies to the Forums on the Site?
HSR Publishing Sites may feature chat board or forums (collectively “Forums“) that enable our users to communicate with each other. HSR Publishing does not moderate and is not responsible for the content that you or any user posts on any Forum. All Personal Information you post in a Forum becomes public information and may be viewed, collected and used by any visitor to the Site, and may expose you to unsolicited messages. HSR Publishing strongly recommends that you do not post on any Forum private information about yourself or other individuals.
What Privacy Applies to User Content?
Some HSR Publishing Sites may allow for users to post or upload User Content, as more specifically outlined and defined in the Terms and Conditions. HSR Publishing may or may not edit, curate, moderate or otherwise check posted or uploaded User Content (depending on the HSR Publishing Site), and is not responsible for the User Content that you or any user posts or uploads on any HSR Publishing Site. All Personal Information you post or upload as part of your User Content becomes public information and may be viewed, collected and used by any visitor to the HSR Publishing Site on which the User Content is posted. HSR Publishing strongly recommends that you do not post or upload private information about yourself or other individuals in your User Content.
As outlined in the Terms and Conditions, your username may be attached to your User Content which HSR Publishing may distribute and display through third parties. We thus encourage you to consider limiting the amount of Personal Information revealed in your username. Furthermore, if you choose to attach your real name to your posted User Content (as may be permitted by some of the HSR Publishing Services), this will be available for all HSR Publishing Site visitors and third parties to view, and you consent to the use of your name in this manner.
What Privacy Applies to Business Partners’ and Third Party Web Sites? 
The HSR Publishing Site contains links from and to sites operated by our business partners and other independent third parties. Once you leave the Site, you may or may not see a new URL in the location bar. Please review the linked site’s and third party content provider’s privacy policies, and if you do not agree to be bound by the terms of the privacy policies and use governing that provider/site, terminate your use of that service or your visit to the site. By placing a link to a particular product, we are in no way endorsing that product. The linked sites are not under our influence or control, and we are not responsible for the privacy policies and practices or the content of the sites operated by our business partners or other third parties or the privacy policies and practices or contents of any linked site or subsequent links from that site.
How Do We Secure Your Information?
We understand that the security of your personal information is important.  As such, we take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
Any unauthorized use of the HSR Publishing Site may result in criminal and/or civil prosecution. We have policies and procedures in place to protect the privacy and confidentiality of your information that we collect and maintain, including contracts with third parties that manage the information provided by you. All Personal Information is stored on secured servers, behind a firewall onsite or at third party data storage providers with access to data strictly controlled. Only individuals specifically involved in the analysis and other functions set out herein have access to your Personal Information. These individuals have been provided the requisite training on our privacy policies and practices. Our staff are required to sign in and use a password when accessing our secure systems.
To help ensure the privacy of your Personal Information, we urge you not to share your user name and password with anyone and recommend that you change your password frequently and store it in a safe place. If you are asked to create a user name or password, please select words that do not personally identify you. We may offer “auto login” which allows users to enter member areas of our site without re-entering password information. You may want to disable auto login on your “Set Up” page if you are not the only person using your computer.
We will keep your personal information for as long as we have a relationship with you. Once our relationship with you has come to an end, we will retain your personal information for a period of time that enables us to:

• Maintain business records for analysis and/or audit purposes
• Comply with record retention requirements under the law
• Defend or bring any existing or potential legal claims
• Deal with any complaints regarding the services

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
Changes to this Privacy Policy
You may request a copy of this privacy policy from us using the contact details set out below. We may modify or update this privacy notice from time to time.
Any changes we may make to this privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to this privacy policy.
Where changes to this privacy policy will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. object to the processing).
If we elect to update or revise this policy, we will post the date on which that revision takes effect at the end of this policy. This Privacy Policy was last updated on 5 September 2018.
How Can We Be Contacted About Our Privacy Policy and Practices?
If you have any questions, comments or complaints about our privacy policy or the handling of your personal information, or if you wish to update the personal information we hold on you, please contact our Privacy Officer using the contact details set out below:
The Privacy Officer
HSR Publishing Pty Ltd
PO Box 194
Newcastle NSW 2300
or send an email to privacy@hunterandcoastal.com.au
We take all complaints seriously and will endeavour to investigate any complaint promptly and respond to written complaints within a reasonable time from the date of receipt. If you are dissatisfied with the handling of your complaint, you may contact the Australian Information (Privacy) Commissioner at GPO Box 5218, Sydney NSW 2001, on 1300 363 992 or via email at enquiries@oaic.gov.au.