Your Privacy Matters

PRIVACY POLICY: DIRECT HOSPITALITY

 

  1. INTRODUCTION

Direct Hospitality Pty Ltd (ACN 600 668 602) ("Direct Hospitality") manages personal

information in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian

Privacy Principles as set out in Schedule 1 of the Privacy Act ("APP").

 

This Privacy Policy ("Policy") relates to any personal information that Direct Hospitality

collects, holds, discloses and/or uses via https://www.directhospitality.com.au and any

related Direct Hospitality website, social media page, internal website or intranet

("Websites") or applications ("Applications").

 

We may change this Policy from time to time. You should check this webpage regularly to

ensure that you are at all times aware of the current policy. This Policy is effective from

01 September 2018.

 

Personal Information

Throughout this Policy we refer to "Personal Information" which is information or an opinion

about an identified individual, or an individual who is reasonably identifiable, whether the

information or opinion is true or not and whether the information or opinion is recorded in a

material form or not.

 

Sensitive Information

"Sensitive Information" is a subset of Personal Information, and includes information or an

opinion about a person’s racial or ethnic origin, political opinions, membership of a political

association, religious beliefs or affiliations, philosophical beliefs, membership of a professional

or trade association, membership of a trade union, sexual orientation or practices, criminal

record, or health, genetic or biometric information.

 

  1. WHAT KINDS OF PERSONAL INFORMATION IS COLLECTED AND HELD?

Personal Information

Examples of Personal Information that may be collected and held by Direct Hospitality includes

but is not limited to:

• Your first and last name

• Date of birth

• Gender

• Company name and details

• Delivery Address

• Contact phone number

• Mobile phone number

• Email address

• Individual preferences

• Payment details

 

Sensitive Information

Direct Hospitality will not collect Sensitive Information unless the person to whom it relates

consents to the collection of that information, and the information is reasonably necessary for

one or more of Direct Hospitality's functions or activities, except where the collection is

required or authorised by law, is necessary to prevent or lessen a serious and imminent threat

to the person’s (or another person’s) life or health, or is necessary in relation to legal

proceedings (current, anticipated or potential), or another permitted exception in the Privacy

Act applies.

 

  1. HOW DO WE COLLECT AND HOLD PERSONAL INFORMATION?

 

Directly

• Directly from customers when you provide Personal Information. For example when

purchasing goods from Direct Hospitality.

• When you interact and/or browse the Website or any Application associated with it

application generally or for a specific purpose.

• Directly from customers when you provide Personal Information to create an account

with Direct Hospitality.

 

Indirectly

Third party providers

Data is collected, processed and stored using third party analytics software that is to the best

of our knowledge secure and confidential. Analytical data is used to gain an understanding of

user behaviour, perform system critical operations, and in extraordinary circumstances, for

legal reasons. Anonymous user data is shared between third party services in order to gain

insight as to aggregate user behaviour.

Analytic data insights are also used to target users through remarketing, demographics,

interests and website behaviour. Third party vendors, including but not limited to Google and

Facebook may show our ads on sites across the internet. We and third party vendors, including

but not limited to Google, make use of third party cookies together in order to inform,

optimise and serve ads based on past visits to a website. We make use of demographic data

(such as age, gender and interests) obtained through third party tools in order to, but not

limited to: influence marketing spend and communicate internally and externally the

aggregate behaviour.

 

Combining/linking Personal Information

Other than as referred to elsewhere in this policy, we will not facilitate the merging of

personally identifiable information with non-personally identifiable information without prior

user consent to that merger to optimise our Website and Website marketing. For example,

we may collate Personal Information data and aggregate data for the purpose of comparing

marketing costs with revenue on a transactional basis.

 

Passive collection of information – Direct Marketing and Behavioural Advertising

As you navigate through our Websites and access our Applications, certain information can be

passively collected (that is, gathered without your actively providing the information) using

various technologies, such as cookies, Internet tags or web beacons, and navigational data

collection (log files, server logs, and clickstream data).

 

For example, we may collect information about matters including but not limited to the date,

time and duration of visits and which pages of a Website or Application are most commonly

accessed. This information is generally not linked to the identity of visitors, except where a

Website or Application is accessed via links in an email or another electronic message we have

sent or where we are able to uniquely identify the device or user accessing a Website or

Application, such as when you are logged into an account.

We may share hashed portions of your information with certain strategic partners to make

our business more responsive to your interests and/or those of like-minded consumers. For

example, we may aggregate your email address together with the email addresses of others

who place Enquiries on our Site, locally hash such data, and transmit the resulting hashed data

to third parties including but not limited to Facebook/LinkedIn/Google for the purpose of

creating “Custom Audiences” (where targeted ads are sent to people on Facebook who have

already been on our Site), and “Lookalike Audiences” (where targeted ads are sent to people

on Facebook/LinkedIn/Google who have similar characteristics to people on our Custom

Audience list).

Where we use Personal Information for promotional or direct marketing purposes, a person

may at any time request Direct Hospitality to not use their Personal Information for sending

direct marketing material to that person including if you wish to opt-out of the use of certain

hashed portions of your Personal Information. Such a request can be made by contacting

Direct Hospitality either in writing, by email or by telephone at the contact details below.

There is no fee for making such a request.

Direct marketing can include for example: Displaying an advertisement on a social media site

that an individual is logged into, using Personal Information, including data collected by

cookies relating to websites the individual has viewed. 1

1 https://www.oaic.gov.au/resources/agencies-and-organisations/appguidelines/

APP_guidelines_complete_version_2_March_2018.pdf

 

Cookies & Web Beacons

We use cookies on our Websites. Cookies are text files placed in your computer's browser to

store your preferences. Cookies, by themselves, do not tell us your e-mail address or other

personally identifiable information. However, once you choose to furnish the Websites with

personally identifiable information, this information may be linked to the data stored in the

cookie.

We may use web beacons on the Websites from time to time. Web beacons or clear .gifs are

small pieces of code placed on a web page to monitor the behaviour and collect data about

the visitors viewing a web page. For example, web beacons can be used to count the users

who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

 

Security

We have systems in place to ensure that information is accessible by our staff on a need-to-know

basis.

 

  1. THE PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL

INFORMATION

Direct Hospitality collects this Personal Information in various ways in the course of

conducting its business, including for the purposes of:

• Contacting customers

• Providing goods and services to customers

• Providing newsletters and discounts to customers via e-mail

• Responding to customer queries in relation to our products and services

• Interaction with customers who utilise our Website

• To better understand your needs, enabling us to improve our products and services

• To customise our Websites according to your interests

• To make improvements to the Websites to enhance the user experience

• Direct Marketing and Behavioural Advertising

• Promotional and marketing activities

• Monitor the effectiveness of our advertising

 

  1. HOW CAN YOU CONTROL YOUR PERSONAL INFORMATION?

Accessibility

A person may request to access Personal Information about them held by Direct Hospitality.

Such a request must be made in writing via our contact details below.

Direct Hospitality will take reasonable steps to ensure the accuracy and completeness of the

Personal Information we hold. However, if a person believes that any Personal Information

that we hold about them is inaccurate or out of date, then they should contact Direct

Hospitality in writing via our contact details below.

Direct Hospitality will grant a person access to their Personal Information as soon as possible,

subject to the circumstances of the request.

Verification of identity is required with a request to access (or update) Personal Information

so that we can ensure your Personal Information is disclosed only to you.

 

Complaints

An individual can contact Direct Hospitality in relation to lodging a complaint about a breach

of the APP or a binding registered APP code, via our contact details below.

Direct Hospitality will make an assessment of the complaint and will respond to you within a

reasonable timeframe. Any further action following this initial response will vary depending

on the nature of the complaint. If necessary, the complaint may be taken to the Office of the

Australian Information Commissioner or to another review body if an external review is

required.

 

Opt outs

The opportunity to opt out of behavioural based digital advertising is available by visiting

http://www.youronlinechoices.com.au/opt-out.

 

If you wish to install an advertisement blocking program, an example is provided at:

https://chrome.google.com/webstore/detail/adblock/gighmmpiobklfepjocnamgkkbiglidom?

hl=en.

You may also opt out of our direct marketing emails by clicking on the link contained in any

such emails or by writing to Direct Hospitality at info@directhospitality.com.au.

 

Freedom of Information Act 1982 (Cth)

An individual also has the right under the Freedom of Information Act 1982 (Cth) to request

access to documents that we hold and ask for information that we hold about that person to

be changed or annotated if it is incomplete, incorrect, out-of-date or misleading.

 

  1. DISCLOSURE OF PERSONAL INFORMATION

Personal Information will not be disclosed unless otherwise stated in this policy.

 

  1. DIRECT HOSPITALITY CONTACT DETAILS

Contact Person: Doug Shemilt

Email: info@directhospitality.com.au

Postal Address: Direct Hospitality

PO Box 1113

SHEPPARTON VIC 3630

Phone: 1800 999 905