Privacy Policy
1. General
1.1 Specialist Media is committed to protecting your privacy and complying with its obligations under the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs) and other privacy laws that may apply in respect of collecting Personal Information.
1.2 This Privacy Policy sets out how your Personal Information is collected, used, stored and disclosed by each of our entities, including:
(a) Specialist Media Pty Ltd ACN 666 958 783;
(b) Pharmacy Daily Pty. Limited ACN 124 094 604;
(c) Business Events News Pty Ltd ACN 153 775 449;
(d) TDaily Pty Limited ACN 108 508 765;
(e) Cruise Weekly Pty. Limited ACN 123 041 485;
(f) Business Publishing Group Pty Ltd ACN 112 661 613;
(g) Signature Publishing Pty Ltd ACN 001 544 538;
(h) LATTE Luxury News Media Pty Ltd ACN 687 107 777; and
(i) our Related Body Corporates (as defined in the Corporations Act 2001 (Cth),
(together, Specialist Media, we, us and our).
1.3 In this Privacy Policy, a reference to goods and services means any goods and services provided by Specialist Media and a reference to Website means any of the below websites:
(a) Pharmacy Daily
(c) Travel Daily
(d) Cruise Weekly
(e) Travel Bulletin
(g) Signature Media
(i) Latte Luxury
1.4 This Privacy Policy is subject to change at our discretion, and we will update it from time to time. The current version will always be available on the Websites. If we change this Privacy Policy in any material way, we will post a notice on our Websites (as relevant) along with the updated Privacy Policy.
1.5 In this Privacy Policy, we use the terms:
(a) ‘customers’ to refer to individuals who engage us to provide goods and services, and individuals at businesses who engage us to provide goods and services;
(b) ‘partners’ to refer to individuals who partner or collaborate with us for business projects, and individuals at businesses who partner or collaborate with us for business projects;
(c) ‘suppliers’ to refer to individuals or individuals at businesses who provide us with goods or services, and individuals at businesses who provide us with goods or services;
(d) ‘creative contributors’ to refer to individuals who submit written, photographic or artistic works in any of our publications;
(e) ’visitors’ to refer to individuals who engage with us on our website, or who enquire about our functions or activities via electronic means;
(f) ‘applicants’ to refer to individuals who apply for employment or other engagement with us; and
(g) ‘entrants’ to refer to individuals who enter our promotions and competitions for our publications.
1.6 In some circumstances, you may belong to more than one of these groups, and multiple sections of this Privacy Policy will then apply to you.
2. What Personal Information do we collect?
2.1 Personal Information is any information or opinion about you which personally identifies you or may reasonably be used to personally identify you, even if the information is not true, and whether or not it is in physical form.
2.2 The kinds of Personal Information we collect about you depends on our relationship with you, and we limit the information we collect to what is reasonably necessary for one or more of our functions or activities. Generally, we will collect:
(a) contact information about you such as your name, email address, phone number and address;
(b) records of our correspondence with you, if you contact us;
(c) commentary or opinions about you;
(d) other information relevant to providing you with the information, goods and services (as applicable) you are seeking or that someone is seeking on your behalf; and
(e) details of your visits to the Websites, including the resources and pages you access, and how you engage with our Websites.
2.3 If you are a customer, we will also collect your contact details, business name and ABN (for sole traders and partnerships), address, employment details and position, marketing and communications preferences, details of transactions you carry out through the Websites and of fulfilment of your orders, personal information you may disclose when tagging our social media handle or accounts or otherwise interacting with us on our social media platforms and information related to your interactions with us. In some cases, where you are a health practitioner subscribing to the Pharmacy Daily publication, we may also collect information about your membership with the Australian Health Practitioner Regulation Agency (AHPRA).
2.4 If you are a supplier or a partner, we will also collect your contact details, ABN (for sole traders and partnerships), business name, bank account details (if required for payment of your invoices), and information about your role including your name, position and contact details.
2.5 If you are a creative contributor, we will also collect personal information contained within any creative works you submit to us, including sensitive information that you may disclose about your travel experiences.
2.6 If you are a visitor, we may also collect the following information about you:
(a) information you provide by filling out forms on the Websites, including information provided to subscribe to our goods and services, post materials or request further services, and to report a problem or issue with the Websites;
(b) information about your device, including numbers that identify your device, IP address, geographic location of your IP address and device where that information is relevant to the services and information we are providing, cookie information, behaviour data that may reveal information about you and user preferences;
(c) information about your use of our Websites that is collected by using a cookie file. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve the Websites and to deliver a better and more personalised service, by enabling us to:
(i) estimate our audience size and usage pattern;
(ii) store information about your preferences, allowing us to customise Websites according to your individual interests;
(iii) speed up your searches; and
(iv) recognise you when you return to the Websites.
You may choose to enable or disable information you share with us via the Websites in your browser or device settings. Disabling the sharing of some information may affect your ability to use certain features of the website, and your visitor experience generally.
2.7 If you are an applicant, depending on your potential or actual position with us, we will also generally collect your Personal Information contained within an application and CV/resume, employment history, personal information derived from a reference, personal information derived from an interview, personal information derived through testing (including psychometric or aptitude testing, as applicable), licences and other certificates and qualifications, and information included in a passport, birth certificate, visa or other documentation demonstrating your right to work in Australia.
2.8 If you are an entrant, we will collect Personal Information necessary to facilitate your entry into the relevant promotions or competitions for our publications, or Personal Information you may disclose in an entry or social media campaign linked to the promotion or competition. This may include your contact details, social media account details, Personal Information you include in an entry form or interaction with us on our social media accounts and any other forms of Personal Information we clearly identify to you at the time of entry.
2.9 We support your ability to make decisions about the Personal Information you provide to us, however if you choose not to provide us with the information requested, or it’s incomplete or inaccurate, we may not be able to provide you with the information, goods, and services you are seeking. If you are an applicant, refusal to provide Personal Information may mean we are unable to process your application. If you are an entrant, refusal to provide your Personal Information in an entry form may void your entry into the relevant promotion or competition.
3. How we collect your Personal Information
3.1 We will generally collect Personal Information directly from you when you interact with us, such as in person, by email, by phone, by submitting creative works, by enquiry or feedback form, or via our website, social media channels, interviews (via any method), any of our standard forms (including application forms), contract negotiation, our employment and engagement application process, our surveys (where applicable), or any other means when you provide us with your Personal Information.
3.2 We may also need to collect Personal Information about you from third parties from time to time where it is necessary for us to do so and it is unreasonable or impractical to collect directly from you, where you have consented to us doing so, or where we are otherwise required to or authorised to by law. Those third parties include:
(a) if you are a customer: any person that engages with us to purchase goods or services on your behalf;
(b) if you are a supplier or partner: publicly available records such as the Australian Securities Investment Commission, Australian Business Register, and from the relevant business with whom you are engaged (as applicable);
(c) if you are a creative contributor: any person who submits your works to us on your behalf;
(d) if you are a visitor: technology service providers and social media platforms;
(e) if you are an applicant: referees when they provide references, academic institutions or training and certification providers, providers of licence and background-checking services, recruiters and other service providers who assist in the engagement process, and other publicly available sources such as social media platforms; and
(f) if you are an entrant: from any person authorised by you to submit an entry into the relevant promotion or competition for our publications on your behalf.
3.3 Except as otherwise permitted by law, we only collect Sensitive Information about you if you consent to the collection of the information and if it is reasonably necessary for the performance of our functions and activities. Consent may be implied by the circumstances existing at the time of collection. There may also be circumstances under which we may collect Sensitive Information without your consent, as required or authorised by law.
3.4 If you provide us with Personal Information about someone else, you must ensure that you are authorised to disclose that information to us and that, without us taking any further steps required by applicable privacy laws, we may collect, store, use and disclose such information for the purposes described in this Privacy Policy. Where we request you to do so, you must assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.
4. Why do we collect, hold, use and disclose your Personal Information?
4.1 We will generally collect, hold, use, and disclose your Personal Information if it is reasonably necessary for or directly related to the performance of our functions and activities and:
(a) to facilitate our internal business operations, including:
(i) establishing our relationship with you;
(ii) maintaining and managing our relationship with you, and communicating with you in the ordinary course of that relationship;
(iii) supplying you with information, goods and services, including processing transactions with you for the same;
(iv) updating your Personal Information, including destroying or de-identifying it when it is no longer relevant (to the extent applicable);
(v) fulfilling our legal and regulatory requirements, both at law and under our contractual arrangements with you;
(vi) analysing our goods and services, and customer and supplier needs with a view to developing new or improved goods, services, and business operations;
(vii) conducting market research and monitoring use of our goods and services;
(viii) contacting you to ask for your feedback or a testimonial;
(ix) if you are a supplier:
(A) purchasing goods or services from you and enquiring about your products and services; and
(B) as applicable, considering any creative contributions you submit in relation to a work brief, and requesting further information or amendments;
(x) if you are a supplier, creative contributor or partner: to carry out our obligations arising from any contracts entered into between you and us;
(xi) if you are a visitor or customer: streamlining and personalising your experience with our online platforms, and tailoring our information, goods and services for you;
(xii) if you are an applicant, considering your application with us; and
(xiii) if you are an entrant, to facilitate the relevant promotion or competition you enter for our publications, including to contact you if you have won.
(b) to provide you with information about other goods and services that we or our related entities and other affiliated organisations offer that may be of interest to you. You may unsubscribe from our mailing/marketing lists at any time by using the unsubscribe feature on any emails we send, or otherwise by contacting us in writing. We do not use your Sensitive Information for direct marketing purposes;
(c) to de-identify and aggregate Personal Information about you and your use of our goods and services to improve the quality of our goods and services, and for research purposes. After we delete Personal Information, we may retain de-identified and anonymised information (that can no longer be associated with you) and may continue to use this de-identified data indefinitely without further notice to you;
(d) to display targeted advertisements, including personalised marketing advertisements, to you from us and from third parties; and
(e) for any other purpose identified at the time of collection.
4.2 We may use or disclose Personal Information for secondary purposes where it would be reasonable to expect us to do so, and that secondary purpose is related (or directly related in the case of Sensitive Information) to the primary purpose set out above.
5. Who we disclose Personal Information to
5.1 We generally disclose your Personal Information for the purposes for which it was collected (set out above). We may disclose Personal Information about you to:
(a) our related entities;
(b) our employees, contractors, consultants, partners and other parties who require the information to assist us with the purposes for which it was collected, and with establishing, maintaining or terminating our relationship with you;
(c) government departments, enforcement bodies, regulatory bodies and agencies where required by law;
(d) third party service providers who assist us in operating and promoting our business and providing information, resources, goods and services to you or someone else on your behalf (including insurers, IT and technology service providers, recruitment providers, and professional advisers such as lawyers, accountants, and auditors), including but not limited to WPForms, WordPress, SurveyMonkey, Mailchimp, Postmark, Salesforce, and Xero;
(e) third parties to whom you have agreed we may disclose your information and where the information was collected from you (or from a third party on your behalf) for the purposes of passing it on to the third party (including without limitation, third party payment service providers), for example, Stripe; and
(f) if you are a participant, organisations involved in the promotion or competition for our publications, such as sponsors, partners, prize providers, technology service providers, and government regulators.
5.2 If you are accessing the Signature Media or Signature Luxury Travel Websites, we may disclose your Personal Information to third party providers operating as affiliates, such as Booking.com and Amazon, for advertising and promoting our goods and services.
5.3 We may expand or reduce our business, and this may involve the sale and/or transfer of control of all or part of our business. Personal Information, where it is relevant to any part of the business for sale and/or transfer, may be disclosed to a proposed new owner or newly controlling entity (or in some cases their professional advisors) for their due diligence purposes, and upon completion of a sale or transfer, will be transferred to the new owner or newly controlling party to be used for the purposes for which it was provided.
6. Third party content
6.1 From time to time, we may include third party content on our Websites and social media accounts, including third party links to websites, applications or resources, as well as, embedded media such as videos, images and articles.
6.2 We take reasonable measures to ensure we only include content from third parties who handle your Personal Information in a manner that meets or exceeds the standards required by the Privacy Act. However, if you access third party content, you acknowledge that you do so at your own risk, and we cannot make representations or warranties regarding third parties’ privacy practices. We encourage you to read the privacy policies and privacy collection notices of any third party resource you access via our Websites.
7. Use of cookies, and tracking devices
7.1 Our website uses cookies. A “cookie” is a small data file placed on your machine or device which lets our digital service store information. The main purpose of cookies is to identify users to create a personal record of when a customer visits our website and to prepare customised web pages for them so that we may serve customers more effectively. We may also use cookies to monitor the use of our website and digital services, like the numbers and frequency of visitors to our website, to help us improve our services by learning what our customers use and don’t use. The information can also help us identify if there are any problems with our services that need fixing.
7.2 Our Websites also use a number of third party services that also utilise cookies, including Google Analytics. You can opt out of Google Analytics by installing Google’s opt-out browser add-on. For more information on data processing by Google, you can visit https://policies.google.com/privacy?hl=en. Third parties use your personal information in accordance with their own privacy policies. Please visit the relevant third party’s website for details on how they use your Personal Information that is collected from cookies.
7.3 You may refuse to accept cookies by selecting the appropriate setting on your internet browser. However, please note that if you do this, you may not be able to use the full functionality of our Websites.
7.4 We use tracking pixels and tags to analyse Website traffic and use, improve your browsing experience on our Websites, and to display personalised ads to you when you are visiting other websites, using Google and Meta products or otherwise engaging with online campaigns run by our third party media providers, Avid Collective Pty Ltd (Avid Collective). The information collected by tracking pixels and tags includes information about how you use our Websites, links you click (both from our Websites to elsewhere, and from elsewhere to our Websites), your device information (e.g. browser type and operating system), IP address and approximate location. The data collected through the pixels and tags and provided to us is aggregated and remains anonymous, meaning that we cannot see the personal information of individual users. However, the collected data may also be saved and processed by Google, Meta and Avid Collective and used in accordance with their data use policies. We may also share information about your use of our Websites and your interactions with our advertisements with our trusted social media, advertising and web analytics partners, including Google. You can opt out of tracking pixels and tags by adjusting your browser settings, and by using the opt-out tools provided by the relevant third parties . You can also use other methods to obscure your use of our Websites (such as using browsers with enhanced tracking protection, using VPNs to mask your IP address and location, and using safe and reputable browser extensions to reduce or block tracking). However, please note that disabling tracking pixels and tags may result in a less personalised browsing experience.
8. Direct marketing
8.1 We will only send you direct marketing communications and information about our goods and services via mail or email with your consent (which may be implied in some circumstances).
8.2 If you do not provide your consent to receive direct marketing communications, you may opt-out of receiving marketing communications from us by contacting us at the details below or by using the opt-out facilities provided in our communications.
8.3 We do not provide your Personal Information to other organisations for the purposes of their direct marketing and will not sell, rent, or lease our customer lists to third parties. Our practices in regard to our emails are designed to be compliant with anti-spam laws, including Australia’s Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth). If you believe you have received mail in violation of these laws or any other anti-spam law, please contact us using the contact information in this Privacy Policy
9. Overseas disclosure
9.1 We are assisted by a variety of external service providers to operate our business and to provide you or someone else on your behalf with the information and services sought. Some of these service providers may be located overseas, and while there are too many to name, Stripe is hosted in the US and Ireland, and the website host for Signature Media and Signature Luxury Travel, SiteGround, is based in the US.
9.2 We take reasonable steps to ensure these service providers have appropriate security for your Personal Information and use it only for the purposes for which it was collected.
10. How we store and protect Personal Information
10.1 We store your Personal Information in different ways, including in paper and electronic form. We take all reasonable measures to ensure your Personal Information is stored on secure servers (which may be based in Australia or overseas) in a manner that reasonably protects it from interference, misuse and loss and from unauthorised access, modification or disclosure, including a range of electronic and physical security measures to:
(a) limit access to the Personal Information we collect about you;
(b) only provide access to Personal Information once proper identification has been given; and
(c) require third party providers to have acceptable security measures to keep Personal Information secure.
10.2 When we no longer need your Personal Information for the purpose for which we collected it, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored and kept by us for a minimum of seven years (unless legislation requires us to destroy or permanently de-identify it sooner).
10.3 Despite the reasonable steps we take to secure your Personal Information, if you provide any Personal Information to us via our Platforms (including email) or if we provide Personal Information to you by such means, the privacy, security and integrity of your Personal Information cannot be guaranteed during its transmission unless we have indicated beforehand that a particular transaction or transmission of information will be protected (for example, by encryption).
11. Accessing or correcting your Personal Information
11.1 You may access the Personal Information we hold about you, subject to certain exceptions. If you wish to access your Personal Information, please contact us via the below details (as applicable):
Address: | Attention: Privacy Compliance Officer
Level 2 Suite 1, 64 Talavera Rd, Macquarie Park |
Emails: | (a) For all enquiries, except LATTE Luxury: info@traveldaily.com.au
(b) LATTE Luxury: enquiries@latteluxurynews.com |
11.2 There are no charges for requesting access to or the correction of your Personal Information, however we reserve our rights to charge you any reasonable administration fees associated with your request. We will notify you in advance of any applicable fees.
11.3 We endeavour to respond to those requests within 30 days but will otherwise respond within a reasonable period. We may decline a request for access to Personal Information in circumstances prescribed by the Privacy Act. If we decline a request for access, where reasonable, we will provide you our reasons and information about your ability to complain about such refusal.
11.4 In order to protect the confidentiality of your Personal Information, details of your information will only ever be passed on to you where we are satisfied that the information relates to you. Accordingly, we may request documentation from you which confirms your identity before passing on any Personal Information which relates to you.
11.5 If you believe the information we hold about you is incomplete, not up to date, or is inaccurate, please advise us as soon as practicable. We will take reasonable steps to correct the information if we agree that it is incomplete, out of date, or inaccurate. We will strive to process any request within 30 days.
12. Making a complaint
12.1 Complaints about our Privacy Policy or the way we handle your Personal Information should first be directed to us at the details set out above.
12.2 We will investigate and attempt to resolve your complaint in accordance with the Privacy Act. If you are not satisfied with the outcome of this process, then you may contact the Office of the Information Commissioner, Australia. To lodge a complaint, visit the ‘Complaints’ section of the Information Commissioner’s website, located at http://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the Information Commissioner’s office.
13. Further information
13.1 If you require any further information or have any queries regarding our Privacy Policy, please contact our Privacy Officer at the details set out above.
13.2 Should you wish to read more information on the Privacy Act, we recommend that you visit the website of the OAIC at www.oaic.gov.au.