Privacy

Introduction

This privacy policy (Policy) is issued by Direct Group Pty Ltd ACN: 065 432 199 and its Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth)) (DG, we, us or our), which together are the owners of Our Brands.

Our Policy applies to the personal information we collect, store, maintain, and use about you as our customers, visitors to our website, social media pages and other digital services, readers of our magazines and catalogues, and members of the public. Our Privacy Policy applies to all of the brands owned by us from time to time, including but not limited to, Over Sixty and WYZA.

This policy is for individuals whose personal information we hold (you or your) and sets out the way we manage your personal information, including:

  • the kinds of personal information that we collect and hold;
  • how we collect and hold personal information;
  • the purposes for which we hold, use and disclose personal information;
  • how you can access personal information we hold about you and seek correction of such information;
  • how you can complain if we breach the applicable Privacy Principles (or any related code of practice that binds us) and how we will handle such a complaint; and
  • the circumstances under which we may disclose your personal information to overseas recipients

The Policy also details how we may collect and use non-personally identifiable information about your browsing and or use of our website/s and app/s.

This Policy is made available without charge at (AUS) www.oversixty.com.au>or (NZ) www.oversixty.co.nz but you may request a copy in another form by writing to us:

Applicable Law

In relation to the personal information of Australian residents, OverSixty is committed to protecting your privacy and respects and upholds your rights under the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth), applicable related regulations as amended, applicable related codes of practice as amended and successors to any of those (Australian Law). For convenience, ‘(AUS)’ indicates provisions of this Policy applying exclusively to Australian residents.

In relation to the personal information of New Zealand residents, this Policy is issued subject to the Privacy Act 2020 (NZ) as amended, applicable related regulations as amended, applicable related codes of practice as amended and successors to any of those (New Zealand Law). For convenience, ‘(NZ)’ indicates provisions of this Policy applying exclusively to New Zealand residents.

 

Collection of Personal Information

What kinds of personal information do we collect?

The basic personal information we collect about you is your name, your address, date of birth and your contact information (e.g. email, phone, mobile, fax, etc.).

If you make payment to us or receive payment from us, we may also collect one or more of credit card information, debit card information, EFT information, bank account and similar financial information.

To the extent it would be impracticable to obtain it directly from you, we also collect other personal information about you from time to time from third party sources where it is relevant to the conduct of our business functions and activities (such as credit scoring information and consumer preference information).

Sometimes, you may voluntarily disclose other information to us in the course of your dealings with us or with our representatives. If this information comprises or contains one or both of unsolicited personal information or sensitive personal information, such information will be further dealt with as set out below.

In addition to personal information (i.e. information that identifies you individually), we may also collect information that relates to you but which has been anonymised or otherwise de-identified; this information is statistical in nature.

Please note that as we expand and extend the apps and other software tools we make available to you, we may collect device-specific information (e.g. information relating to a specific phone or tablet), log information, GPS/WiFi location information and other tracking information; such information may also constitute personal information if it identifies you. Your express consent will be sought prior to disclosing this type of information to any third parties such as Google or other advertising affiliates.

We may also collect additional personal information which you provide to us in the course of your OverSixty member relationship with us, including when you communicate with us in chat areas.

We also use social media channels such as Facebook (“social media”) to distribute news announcements, promotions, blogs and to address enquiries. If you submit or post comments, images, recordings or other personal content for public display on social media or on our website, that information may be available for anyone in the world to read/view/comment on. We are not responsible to you for the information handling practices of social media.

If you access or log into our services via social media or connect our services to social media the personal information we collect may also include your user ID and/or user name associated with the social media, any information or content you have elected to share on the social media with us, such as your name, age, date of birth, gender, profile picture, email address, followers or friends lists and any other information that you have disclosed or posted in connection with that social media. We do not collect any passwords except in relation to our Services. When you access our services through social media or when you connect our services to social media, you are authorising us to collect, store and use that information and content in accordance with this privacy policy.

Who do we collect the personal information from?

Generally, we collect your personal information directly either from you (when you provide your contact details to us in letters, emails, faxes, phone calls, social media postings and other online postings) or from third parties as described above. We also collect information about you indirectly through browser tracking cookies, mobile app reporting and webpage pixel tags when you use our website and apps.

Please note that most of the information we collect indirectly is not personal information (since it cannot identify you individually) but some may be (especially when held or used in combination with other information we hold about you).

Why do we collect the personal information? The purposes of collection

We collect, hold and use your personal information:

  • to supply our services;
  • to measure and improve our services and our platforms. That includes improving your experience with our online and offline services by delivering content to you that we believe you are likely to find relevant and interesting;
  • communicating with you in connection with your OverSixty membership, member service issues, newsletters, Advertiser account information and Advertiser service issues;
  • marketing and promotional purposes in connection with our services. That includes advertising and marketing messages, (which may include the display of personalised content and advertising) and to participate in competitions and surveys

We also collect, hold and use your personal information to share social media information. If you log in with or connect a social media account with our services, we may share your user name, pictures, likes and preferences, as well as any other of your activities and comments, with other users of our Services, and your friends who are linked to your social media account and with the social media provider. If you do not want your personal information shared in this way, you should not connect your social media account with our services and you should not participate in social media sharing of your personal information.

Please note: To the extent that we engage in direct marketing, both that activity and the corresponding purpose(s) of collection of your personal information are described in the section of this Policy headed ‘Direct Marketing’.

Collection of non-personally identifiable information

OverSixty may, at any time, utilise advertising and marketing analytics collection services to collect information about user habits and use of our website/s and app/s. This information does not and will not contain, or be used to identify personal information about any individual who browses or utilises any website/app or function of a website/app maintained by OverSixty.

Information that may be collected and stored in the cookie may include your IP address, Internet Service Provider information and usage statistics. If at any stage OverSixty implements features which would collect precise geographical location (i.e. through mobile specific websites), OverSixty will seek your individual consent to such services.

The information or data collected through the use of cookies, a small file saved onto user’s computers to store website preferences and other information, may allow OverSixty to identify patterns or other analytical information from that data. Those patterns may be used by OverSixty or third party advertisers on any of OverSixty websites to tailor advertising and marketing.

OverSixty may utilise remarketing facilities whereby your visit to one of OverSixty websites or apps may result in advertising for OverSixty goods or services may be included in advertising from other online affiliates in the remarketing network. In the cookie saved to your computer by OverSixty website/app, information relating to your usage will be stored and may be accessed by other websites also utilising Google Analytics.

OverSixty is part of the Google Display Network. Advertising displayed on OverSixty websites or apps may include advertising from other Google Display Network affiliates if cookies from those other affiliates’ websites are found on the same computer.

You may opt-out from the use of cookies at any time by visiting Google’s Ads Settings, or by changing the security settings on your browser. Note that disabling or otherwise blocking the use of cookies may inhibit your use of certain websites and features operated by OverSixty. OverSixty will not collect phone numbers, email addresses, credit card or other financial information or any other sensitive or personally identifiable information through these means. Any personal information collected by OverSixty under other areas of this Policy will not be used for remarketing purposes in connection with non-personally identifiable information without your express consent.

Direct Marketing

We are an organisation that engages in direct marketing and so you may reasonably expect us to use your personal information for that purpose.

After we collect your personal information from you, we may continue to use or disclose that personal information for the purpose of direct marketing to you for so long as we have not received an ‘opt out’ request from you.

If we collect your personal information from a third party, we may continue to use or disclose that personal information for the purpose of direct marketing to you, subject to your consent to do so unless it is impracticable to obtain such consent, for so long as we have not received an ‘opt out’ request from you.

You may also request that we (a) not use or disclose your personal information for the purpose of facilitating direct marketing by third parties and (b) identify the source of the personal information we hold about you. If you wish to request:

  • to ‘opt out’ from receiving direct marketing communications from us;
  • that we do not provide your personal information to third parties for the purpose of facilitating direct marketing; or
  • that we tell you where we sourced your personal information,
  • then advise us of your request:
  • by email to contact@oversixty.com.au  or contact@oversixty.co.nz
  • by post to
      • OverSixty
      431 Warringah Road
      FRENCHS FOREST NSW 2086

If we receive a request from you about (a) and (b) above, we will action your request within a reasonable period. If we receive a request from you about (c) above, we will notify you of the source within a reasonable period unless it is impracticable or unreasonable to so.

Use or Disclosure

Limited use or disclosure

Unless we obtain your further recorded consent, we will:

  1. only use or disclose your personal information for the purposes permitted or required by applicable law and otherwise in accordance with this Privacy Policy, and
  2. not allow third parties to hold, use or disclose personal information we collect from you except for purposes permitted or required by applicable law and otherwise in accordance with this Privacy Policy.

 Exceptions to this are:

  • where from time to time, we may facilitate email or mail order offers from reputable companies that have interesting products and services.  These companies are not permitted to retain any customer information unless you have specifically expressed interest in their products or services
  • where we are required by law to disclose certain information
  • if you have a product from us that requires personalisation, or delivery to you by an external company
  • disclosure of personal information with other DG companies, including Our Brands, to carry out our business and marketing activities and functions.

We will only ever use your email address so that we can:

  • Contact you or answer a query or
  • Send newsletters and membership updates
  • Send you special offers from time to time, if you have opted to receive such information. Your email address is private and we will never sell it to third parties.

 Non-Personally Identifiable Information that may be collected and stored in cookies may be disclosed or distributed to our advertising and marketing affiliates including Google, however this information will never include personal information collected from you via other means.

Our representatives

We utilise a number of individuals to carry out business functions and activities on our behalf including not only employees but also contractors, sub-contractors, agents and commercial representatives expressly affiliated to us (all collectively being representatives).

Our technical service providers are obliged to respect your privacy and confidentiality.

You consent to our disclosure of your personal information to our representatives other than our employees, and to the use and disclosure of your personal information by such representatives when it becomes necessary to enable them to carry out business functions and activities on our behalf.

 

Third-party service providers

Sometimes we use third-party platforms and services for numerous purposes including, but not limited to, processing sales, analysing data and information, providing web support, sending marketing messages, delivering products or information or to otherwise achieve the purpose for which the information was collected. These services are hosted and managed by organizations other than ourselves, and some of these services are hosted overseas.

To the extent that our third-party service providers hold, use or disclose your personal information in connection with providing their services to us, you consent to such use and disclosure and our disclosure to them of your personal information.

We take all reasonable steps to ensure that these third-party overseas companies are compliant with the APP’s. However we will not be liable for any conduct that is inconsistent with the APP’s on the part of these third parties.

 

Business affiliates

In addition to our representatives and service providers, we have commercial arrangements with a number of industry partners and other reputable business affiliates in AUS and NZ.

Our business affiliates are obliged to respect your privacy and confidentiality.

We will not disclose your personal information to our business affiliates except where:

1.the information in question has been anonymised or otherwise de-identified (such that it is no longer personal information); or

2.the nature of your dealings with OverSixty is such that you may reasonably expect us to disclose your personal information to our business affiliates;

3.you consent to our disclosure of your personal information to our business affiliates.

 Only to the extent of the limited exceptions set out above, you consent to the disclosure by us of your personal information to our business affiliates and to their holding, using or disclosing your personal information.

 

Overseas use or disclosure

A number of our service providers and business affiliates are located overseas including the United States, the United Kingdom, the Philippines, New Zealand (in so far as Australian residents are concerned) and Australia (in so far as New Zealand residents are concerned).

To the extent that applicable law requires your consent to our transfer of your personal information to our service providers and business affiliates overseas, you consent to such transfer and to subsequent use and disclosure of your personal information by our overseas service providers and overseas business affiliates when necessary for them to provide their services and honour their commercial arrangements with us respectively.

(NZ) In addition to the business operations of our service providers and business affiliates being overseas, we ourselves are principally located overseas, being based in Australia.

To the extent that applicable law requires your consent to overseas transfer of your personal information to us, you consent to such transfer and subsequent use or disclosure by us consistent with this Policy and with applicable law. We may disclose your personal information to other external providers located in Australia, New Zealand and other countries, including our data hosting and Cloud based IT service providers for some of the purposes listed above. We take all reasonable and prudent steps to ensure that these service providers are fully compliant with the Australian Privacy Principles (AUS) and Information Principles (NZ).

 

Required or authorised collection, use or disclosure

If collection, use or disclosure of your personal information is required or authorised by law or by order of a court or tribunal, we will inform you of that requirement or permission with details (unless the law or order requires otherwise).

Quality and Security of Personal Information

We will take all reasonable measures to make sure that any personal information about you that we collect, hold, use or disclose is accurate, up-to-date and complete. If you are (or become) aware of any personal information that we hold about you that is not accurate, up-to-date and complete, please let us know as soon as possible:

We will take all reasonable measures (including application of industry standards and industry best practice where possible) to protect your personal information from misuse, interference and loss, unauthorised access, unauthorised modification and unauthorised disclosure. To the extent we disclose your personal information to our representatives, other DG companies, our service providers and our business affiliates, they are subject to obligations in relation to privacy and confidentiality.

 

Access to your Personal Information

If you request access to your personal information, we will respond within a reasonable period and provide you with the information in the manner you request if it is reasonable and practicable to do so.

Please note that we are not obliged to give you access as requested in some circumstances, including where the request is frivolous or vexatious, the request would have an unreasonable impact on the privacy of others or the request is denied in compliance with applicable law (or under a court or tribunal order).

We will not charge you for making a request for access to your personal information.

If the estimated cost to us to provide you with the information exceeds $10 (AUD for Australian residents, NZD for NZ residents), we reserve the right to charge you on a cost recovery basis for providing access to your personal information.

If we refuse to provide access to your personal information, we will issue a written notice that sets out the reasons for our refusal, the mechanisms to complain about our refusal and any other matters prescribed by applicable law. In relevant circumstances, we will consider providing an alternative means of access to your personal information to the refused means of access.

If you wish to seek access to your personal information, please contact us:

Correction of Personal Information

We will take reasonable steps to correct your personal information to ensure that, having regard to the purpose(s) for which it is held, such information is accurate, up-to-date, complete, relevant and not misleading if we are satisfied that that the information does not meet those thresholds.

We may also correct your personal information upon request from you. If you wish to request a correction of your personal information, please advise us of your request:

If you make such a request, we will respond within a reasonable period.

If we correct your personal information and you request us to notify third parties to whom we have disclosed such information, we will take reasonable steps (if any) to give that notification unless it is impracticable or unlawful to do so.

We may refuse your request to correct your personal information if it is not reasonable in the circumstances (e.g. the correction you request us to make is inaccurate).

If we refuse your request to correct your personal information, we will issue a written notice that sets out the reasons for our refusal, the mechanisms to complain about our refusal and any other matters prescribed by applicable law.

If, we refuse your request to correct your personal information and you request us to associate with your personal information a statement that the information is inaccurate, incomplete, irrelevant or misleading, we will take reasonable steps to associate the statement apparent to users of the information. If you make such a request, we will respond within a reasonable period.

We will not charge you for making a request for correction to your personal information, for correcting your personal information or associating a statement with your personal information that it is inaccurate, irrelevant or misleading.

 

Removing, Deleting or Destroying Personal Information

We normally seek to remove, delete or destroy personal information from our records as soon it is no longer required. However, there may be circumstances where such removal, deletion or destruction is either delayed or not possible, including, in the case of our electronic record systems, in relation to backup, archival and general record-keeping processes. If, for technical or other reasons, it is not possible to remove, delete or destroy personal information, we will put such information beyond use (e.g. in the case of our electronic record system, by marking an account inactive, by locking a record or by similar technical means) and we will not access it again unless either we are subsequently requested to do so by you or we are required or permitted to access it by applicable law.

 

Miscellaneous

Your dealings with us

If and where dealing with us anonymously or pseudonymously is practicable in respect of particular matters (e.g. posting to our other online forums), we will make that option available.

 

Unsolicited personal information

If in the course of communications with us or our representatives, you provide unsolicited personal information, we will review that information. If, upon review, that unsolicited information is relevant to our business functions or activities, we may hold, use or disclose that personal information consistently with your reason for disclosing it.

 

Sensitive personal information

(AUS) Please note that we do not seek to collect from you health information or other sensitive information as defined by Australian Law. However, if unsolicited personal information provided by you also includes health information or other sensitive information as defined by Australian Law, you consent to us holding, using or disclosing such health information or other sensitive personal information consistently with your reason for disclosing it.

(NZ) We will apply the same principles as above to the same kinds of personal information of New Zealand residents.

 

Recruitment Policy

A copy of our Recruitment Privacy Policy can be found at //directgroup.com.au/careers.aspx

Partial identification in commercial communications

Sometimes in the course of our commercial communications (e.g. communication of written testimonials, product conversations, product-related tweets or similar), we may partially identify an individual by reference to part of that individual’s name and an area (e.g. suburb, region or state). To the extent that such information might identify you as an individual, you nevertheless consent to us holding, using or disclosing your personal information in that way.

 

 

Making a Complaint

If you wish to make a complaint with regard to a possible breach of this Policy or the Australian Privacy Principles (AUS), or Information Privacy Principles (NZ), or in respect of any other request or enquiry in relation to this policy, please contact:

Privacy Officer

    OverSixty
    431 Warringah Road
    FRENCHS FOREST NSW 2086

What happens to my complaint?

  • When we receive your complaint we will contact you when reasonably practicable to let you know that we have received it.
  • We will use reasonable endeavours to investigate your complaint and aim to resolve it. We may contact you for further information.
  • We will write to you and let you know the outcome. We will use reasonable endeavours to resolve your complaint within 30 days however some complaints are more complex and take longer. We will keep you informed if this is the case.
  • If for some reason we cannot resolve your complaint (for example, the issue is outside our responsibilities), we will write to you and let you know

If we are unable to resolve your complaint, you may contact the Office of the Australian Information Commissioner (OAIC) or Office of the New Zealand Information Commissioner (NZIC).

  • OAIC website: https://www.oaic.gov.au
  • OAIC telephone: 1300 363 992
  • OAIC postal addresses: GPO Box 2999, Canberra, ACT 2601 or GPO Box 5218, Sydney NSW 2001

Or

  • NZIC website: https://www.privacy.org.nz
  • NZIC telephone: 0800 803 909
  • NZIC postal addresses: PO Box 10 094, The Terrace, Wellington 6143 NEW ZEALAND

Reminder – Helping Us to Help You

While we will do what we can to make sure that your personal information is accurate, up-to-date and complete, we do need your help. If your personal information changes (e.g. because of a change of name, address or credit card provider), please contact us to let us know what those changes are.

Policy Changes

Please note that this Policy may change from time to time to take into account new laws and technology, changes to our operations and practices, and the changing business environment.

We will make available the current version of our Policy, with a date and version notice, via our website(s) and, upon request, in other forms.

Updated December 2020

© Copyright 2024 OverSixty.All Rights Reserved.