THE VILLAGE ROADSHOW GROUP OF COMPANIES – PRIVACY POLICY
1. INTRODUCTION
1.1 Village Roadshow Group of Companies
Village Roadshow Ltd and its subsidiaries (collectively, “Village”, “we” and “us”) operate core businesses in cinema exhibition, theme parks, indoor games facilities, the production and distribution of films and the provision of marketing solutions.
Through these varied businesses, Village from time to time gathers information from customers and other parties with whom we deal for a variety of reasons including to enable us to provide the goods and services.
Village takes seriously its obligations in respect of the personal information it gathers. To safeguard that information, Village has implemented a program to ensure compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”).
We collect both personal information and non-personal information. This Privacy Policy outlines how Village deals with “personal information”, as defined in the Privacy Act.
2. WHY VILLAGE COLLECTS PERSONAL INFORMATION
2.1 Nature of Information
The personal information which Village collects will depend on the nature of your interactions with us. We may collect personal information about customers who enquire or purchase our goods and services, newsletter subscribers, members of loyalty programs, entrants to competitions, participants in promotions, users of our websites, suppliers, contractors, job applicants, and other parties we deal with (for the purposes of this Privacy Policy, all such people are described as “customers”).
The personal information may include:
- name, gender, date of birth, contact details;
- payment details (such as credit/ debit card number and expiry date) provided when purchasing our products and services;
- personal bank account details (including account number and BSB) to administer cash back offers and award prize money won in promotions;
- loyalty program membership number and details including buying history, date of joining, opinions and product preferences;
- information about your use of our products and services and other products and services you may be interested in; and
- employment applications.
Village (or its agent) collects certain information of shareholders for registration purposes, such as name, address, number of shares held, tax file number and bank account details. Village is required to maintain a register of shareholders under the Corporations Act 2001 (Cth).
2.2 How Village Collects Personal Information
Village may collect personal information when a customer uses our services or purchases our goods, registers to receive our newsletters or other communications, registers to be part of one of our loyalty programs, registers to be part of the Lifestyle Rewards program, enters a competition or promotion managed by us (including where a third party organisation is the promoter), visits our websites, applies for employment, completes a survey or otherwise interacts with us.
There may be occasions when Village collects personal information about a customer from a third party. These third parties may include agents and other people who sell products or services to customers for us or who interact with customers on our behalf; third parties that run competitions and other promotions for us; recruitment agencies; sharebrokers when shares in Village are purchased and social media. Village engages third parties who provide us with information about customers collected from publicly available sources or from their own databases.
In accordance with the APPs, where practical, customers may deal with Village anonymously. However, frequently it is necessary to collect personal information during the course of transactions.
2.3 What happens if Personal Information is not provided?
Village may not be able to provide a proper service to customers or undertake the activities set out at 3.1 if personal information is not provided upon request.
2.4 Cookies
Village uses “cookies” to facilitate the use of its websites. Cookies are small units of data sent to a user’s browser by a website the user visits. The main reasons Village uses cookies are:
- to improve a customer’s website browsing experience
- to better understand how its websites are used and to allow improved navigation for its customers
- to enable it to present customised messages and offerings to customers.
The cookies Village use do not store any personal data or otherwise collect personal information. However if a loyalty club member is logged into their account, the information Village collects via cookies may be linked with their personal information.
You can configure your Internet browser to erase cookies from your computer’s hard drive, block cookies or receive a warning before a cookie is stored. If a user disables the use of, or deletes, cookies on their web browser then they may not be able to gain access to all the content and facilities of Village’s websites.
2.5 Google Analytics
Village’s websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). The following is a Data Privacy Statement in relation to the use of cookies by Google Analytics:
Google Analytics is a web analysis service provided by Google. Google utilises the data collected to help Village analyse how users use the websites. The information generated by the cookie about a customer’s use of the website (including its anonymised IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating customer use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf.
Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
You can prevent Google from detecting a cookie that is generated because of and related to your usage of this website (including your IP address) as well as processing of these data by downloading and installing this browser plugin: http://tools.google.com/dlpage/gaoptout?hl=en
We may combine information collected through Google Analytics with other information we collect, to enable us to provide you with relevant marketing content.
2.6 Use of Remarketing Tools
Village may use Google remarketing, Facebook remarketing, pixel tags, web beacons, clear GIFs or other similar technologies to collect information of a customer’s visit to any one of its websites and deliver specific advertisements to that customer about products and services based on the pages visited and the way in which the customer accesses the website. These advertisements may be delivered by third party vendors when you visit our websites or other Internet websites. Where customers visit our webpages containing Warner Bros content, Village may disclose the information it collects to Warner Bros to use as a remarketing tool.
3. USE AND DISCLOSURE OF PERSONAL INFORMATION
3.1 Use of Personal Information
Village may use personal information for the following purposes:
(a) to provide and administer goods and services, such as verifying a
customer’s identity; contacting customers about orders and bookings; processing
payments;
(b) to operate competitions, promotions and events managed by Village (including where we provide this service on behalf of third party organisations);(c) to distribute Village’s newsletters and other communications itself or with the
assistance of third party services providers;
(d) to provide customer support, including assistance with ordering goods and services and responding to other enquiries or requests
(e) to conduct marketing activities for Village’s products and services, or products and
services of third parties, and to conduct market and other research to improve
Village’s products, services and marketing activities;
(f) to create aggregate data through demographic profiling and statistical analysis of the database to provide to third parties, and to allow for more efficient operation of Village’s businesses.
(g) to register any shareholding customers may have in Village and to contact them in
relation to any shareholding;
(h) to conduct market research and analysis;
(i) to facilitate participation in loyalty and rewards programs (including where we provide this service on behalf of third party organisations);
(j) to manage job applications;
(k) to establish, exercise or defend any legal claims;
and
(l) to maintain records and comply with Australian law.
3.2 Disclosure of Personal Information
In general, only officers, employees or contractors of Village may view personal information. The information we collect may be shared within Village for the purposes outlined above.
Village will only disclose to other parties where Village believes that access is necessary to achieve the purpose for which the personal information was collected.
Village may disclose personal information to a service provider (such as auditors, accountants and lawyers) and other professional services firms to comply with our legal obligations, including to various law enforcement agencies, regulatory authorities and government bodies. Village may also disclose personal information to couriers, computer security companies and hosting services or a related company or person, for example, a related body corporate or someone with whom Village shares a common commercial interest. Customers of Village may be presented with the option of having their credit card details retained (by a third party) for future purchases.
Where a third party organisation has joined our Lifestyle Rewards program, Village may disclose personal information of the participants of the Lifestyle Rewards Program to that organisation to allow it to monitor the success of the program and your use of the program.
To the extent that these third parties are located in Australia and Village discloses personal information to them, they are subject to privacy legislation which prevents the personal information being used for any other purposes.
3.3 International transfers
Village may disclose personal information to overseas service providers. Village will only do so in compliance with all applicable Australian privacy laws and will take reasonable steps to ensure the overseas service providers handle the personal information in accordance with the APPs. Village will take reasonable steps to protect personal information regardless to which country it is transferred or transferred.
Village may also disclose personal information to third parties who process data, operate customer experience surveys and send our marketing emails to subscribers. The countries in which these third parties are located include the United States, New Zealand, Singapore and South Africa.
3.4 Storage and Security
Personal information may be stored in hard copy, electronic files or both. Hard copy personal information is wherever practical, kept under locked security. Personal
information stored on computer is wherever practical, password protected. Village uses third party information system providers who may store or have access to personal information. Where possible and practical, Village will endeavour to comply with recognised Australian and international standards relating to information security. Village deletes and de-identifies personal information when the information is no longer needed by Village.
3.5 Updating Personal Information
Village monitors the quality and accuracy of personal information that it maintains
and where practical, updates that information on a regular basis. Customers can update or
correct their personal information at any time by contacting Village’s Privacy Officer.
4. MINORS
Village has adopted the position proposed by the Privacy Commissioner that a young person is able to give their consent when he or she has a sufficient understanding and maturity to understand what is being proposed. When obtaining personal information from minors, Village’s staff will make an objective determination before collecting that information as to whether the persons involved would be able to provide informed consent to the use of their personal information.
5. COMPETITIONS
Personal information gathered during competitions run by Village will be governed by the principles set out in this Privacy Policy unless an express statement is made in relation to privacy in the conditions of entry for the competition.
6. DIRECT MARKETING
Personal information collected for direct marketing purposes will only be collected, used or disclosed with the consent of the customer. However, in some circumstances where Village cannot practically obtain the consent of a customer, Village may still engage in direct marketing, but will:
(a) include an ‘unsubscribe’ facility so customers can unsubscribe from the mailing list at any time or contact the Privacy Officer to remove the customer’s details from the mailing list; and
(b) include a prominent statement to the fact that a customer may make such a request.
7. ACCESS TO PERSONAL INFORMATION
Customers wishing to request access to, or correct, personal information held by Village should contact the Privacy Officer using the contact details in the section below titled “Who to Contact”.
Village will provide access to the information held about the individual, including for the purpose of correcting or updating that information, unless there is an exception which applies under the APPs.
Any request to provide access to this information will be dealt with within a reasonable time.
If Village refuses to provide a customer with access to their personal information, Village will provide written reasons and advise the customer how they may complain about the refusal.
Loyalty program members may update their own profile information online or by contacting the Privacy Officer.
If Village withholds access to personal information, Village will consider whether the provision of access to an independent third party will meet Village’s and the relevant customer’s needs.
8. WHO TO CONTACT
Village is committed to working with its customers to obtain a fair resolution of any complaint or concern about privacy. If you have a concern about your privacy or a query on how your personal information is collected or used please contact Village using the details below. We will respond to your query or complaint within a reasonable time. If you are not satisfied with Village’s response, you may also contact the Office of the Australian Information Commissioner.
Write to us at: Privacy Officer
Village Roadshow Limited
Level 1,500 Chapel Street
South Yarra, Victoria 3141
Email: privacy@roadshow.com.au
