Privacy Policy

This Privacy Policy applies to personal information we handle about subscribers to our publications (subscribers) visitors to our websites and digital publications, recipients of our other electronic communications, users of other services we may provide, and members of the public. It provides information about the personal information that we collect, and the ways in which we use that personal information.

Controller

The Prime Creative Media Group (Group) is made up of different companies, details of which can be found here: https://www.primecreative.com.au/prime-creative-media-group/. This privacy policy is issued on behalf of the Group so when we mention “Prime Creative Media”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Group responsible for processing your data. Prime Creative Media Pty Ltd is the controller and responsible for this website.

Collection of personal and other information

Prime Creative Media collects both personal information and anonymous information.

Types of personal data we collect about you

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses.
• Usage Data includes information about how you interact with and use our website, products and services. Including engagement on the site to provide relevant news, products & services.
• Marketing and Communications Data includes data related to preferences for direct marketing, newsletters, or promotional content as well as: Consent Datain Salesforce, being details on how and when consent was given to process the data, including records of withdrawal; Location Datain DocuSign, including geolocation data (GPS coordinates, IP-based location tracking); Third-Party Data being data received from third parties (advertising platforms, social media integrations); Retention Data, being data held for suppression purposes if you do not want to receive direct marketing from us; and Security Data, being information related to account security: login details, password hashes, and multi-factor authentication details.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

How is your personal data collected?

We collect personal information about you when you provide us with your personal information directly yourself or through an authorised third party. Generally, we try to collect personal information directly from you, however sometimes we may collect personal information from publicly available records, information brokers and third parties. We use different methods to collect data from and about you including through:

Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• create an account on our website or digital publications;
• subscribe to our service or publications;
• request marketing to be sent to you;
• purchase advertising from us; or
• give us feedback or contact us.

Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our cookie policy https://primeglobalpublishing.com/privacy-policy/#cookies

Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

Salesforce Account Engagement

We use Account Engagement (a marketing automation platform) to gather information about visitors on our website. If a visitor completes a form on our website, for example registering for an event, then their personal information is stored in Account Engagement/Salesforce. The visitor cookie includes the name “visitor_id” plus the unique identifier. This cookie is set by our tracking code.

You can review how Account Engagement tracks activities:https://help.salesforce.com/articleView?id=pardot_basics_cookies.htm&type=5#what-are-the-names-of-the-cookies-and-what-are-they-for-

Account Engagement’s privacy policy can be viewed here:https://www.salesforce.com/company/privacy/.

Google Analytics

We use Google Analytics to analyse the use of this website. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users’ computers. The information generated relating to our website is used to create reports about the use of the website. Google will store this information. Google’s privacy policy is available at:https://www.google.com/privacypolicy.html.

Our advertisers/payment services providers may also send you cookies.

Google Ad Manager

Google Ad Manager is an advertising service provided by Google LLC that allows us to run advertising campaigns in conjunction with external advertising networks that the we, unless otherwise specified in this document, have no direct relationship with. In order to understand Google’s use of data, consult Google’s privacy policy is available at:

https://www.google.com/privacypolicy.html..

Optinmonster (Lead collection Plugin)

We use Optinmonster campaigns to collect leads for offering a newsletter sign up or freebies on our website. Optinmonster does not collect any personal data. You can read more information about the privacy policy of Optinmonster onhttps://optinmonster.com/privacy/

Facebook Pixel

We use Facebook Pixel to measure, optimize and build audiences for advertising campaigns served on Facebook. In particular it enables us to see how our users move between devices when accessing our website and Facebook, to ensure that our Facebook advertising is seen by our users most likely to be interested in such advertising by analysing which content a user has viewed and interacted with on our web site. To opt-out please seehttps://www.facebook.com/ads/preferences.

Survey Monkey

We use Survey monkey to collect and collate survey results from our users. Survey Monkey collects and passed to us the details of your response. You can read more information about the privacy policy of Survey Monkey onhttps://www.surveymonkey.com/mp/legal/privacy/

LinkedIn

We use information that you chose to make public on LinkedIn to build our audiences for marketing campaigns and offers.

If we are not provided with the personal information that we request, we may not be able to fully provide our services to you.

How we use your personal data

The table below describes all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Additionally, if your data is collected at an event organised by Prime Creative Media, you hereby grant the use of your data across relevant publications. This may include, but is not limited to, event-related materials, reports, promotional materials, and other relevant publications. We will ensure that your data is used in a manner consistent with the purpose of the event and in compliance with applicable data protection laws and regulations.

From time to time, Prime Creative Media may invite you to participate in surveys or offer additional products or services related to those that you may already access. Your participation in any surveys will be anonymous to us and your answers will not be linked to you in any way, except where you consent to provide relevant contact information for purposes specifically stated within the survey, such as the offer of a prize or free product/service trial. If you express interest in any offer presented to you by Prime Creative Media and its associated entities, relevant contact information will be used solely for the purpose of fulfilling that offer. Subsequent use of any such personal information will be subject to the terms and conditions of such offer.

Anonymous information

We may use anonymous information collected from you for internal purposes including improving our products and services.

Some anonymous demographic information, including but not restricted to, age, location, gender, occupation and total net worth and assets may be provided to advertisers for the sole purpose of their designing advertisements for the website. All information disclosed in these circumstances will be de-identified and stripped of personal information. Your personal information will not be disclosed.

Third-Party Ads

We may, on behalf of our advertisers, occasionally send you third-party advertising campaigns. When you sign up you indicate your acceptance of this arrangement, acknowledging that we may send you promotional content and communications from our affiliated partners. You can opt out of receiving such communications at any time by following the unsubscribe instructions provided in our messages.

Opt-out

You can ask to stop sending you marketing communications at any time. All our communications will contain suitable links to enable you to opt out of further communications, or you can email Prime Creative Media atsubscriptions@primeglobalpublishing.com. If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example relating to order confirmations, updates to our Terms and Conditions or checking that your contact details are correct.

Disclosures of your personal data

We may also share your personal data where necessary with the parties set out below for the purposes set out in the above table showing the purposes for which we will use your personal data.

Group Companies:

PCM is part of the Prime Creative group of companies. We may share your information with other members of that group:

• Perform analytics and analysis of how you interact with the group’s products and services, to facilitate business efficiencies and develop products and services that would be relevant to you; and
• Deliver more relevant advertising from across our network.

Legal basis: Performance of a contract, legitimate interest.

Mailhouses:

In order to deliver a print magazine, we will disclose your personal and contact details with our mailhouses so they can mail you the magazine. Details of the mailhouse privacy policies can be found here; https://cliffe-enterprise.com/privacy-policy/.

Legal basis: Performance of a contract, legitimate interest.

Email verification companies:

In order to verify your email we will share said email with third party companies to ensure its validity. We do this to protect PCM as sending out too many emails to invalid addresses will flag our accounts as spammers. Details of these platforms’ privacy policies can be found here; Never bounce,.

Legal basis: Performance of a contract, legitimate interest.

Marketing platforms:

We share your information with marketing platforms to send you relevant marketing communications and make personalised suggestions and recommendations to you about goods or services that may be of interest to you. Also to enable you to partake in a prize draw, competition or complete a survey. Details of these platforms’ privacy policies can be found here; https://www.surveymonkey.com/mp/legal/privacy/.

Legal basis: Performance of a contract, legitimate interest, consent.

Customer relationship management tools:

We use a CRM to store information regarding people with whom we have a relationship within order to track and subsequently fulfil a contract or otherwise manage and maintain said relationship. Details of these platforms’ privacy policies can be found here; https://www.salesforce.com/company/legal/privacy/,https://www.docusign.com/privacy.

Legal basis: Performance of a contract, legitimate interest.

Billing:

We share your billing information with our payment processing partners in order to charge you where necessary. Details of the platforms’ privacy policy can be found here https://sec.windcave.com/pxmi3/privacy-policy.

Legal basis: Performance of a contract, legitimate interest.

Automating systems:

We use some third parties to exchange data between our various systems, for the purposes of maintaining and administering your data and our relationship.

Details of these platforms’ privacy policies can be found here; https://gearset.com/legal/privacy/.

Legal basis: Performance of a contract, legitimate interest.

AI Tools:

We use some AI tools to analyse data analytics that we collect about you to for the purposes of identifying and segmenting our audience into market segments. The output of which is then used to engage you through marketing, surveys and promotional material. Details of these platforms’ privacy policies can be found here; https://privacy.clay.com/policies?name=privacy-policy

Legal basis: Performance of a contract, legitimate interest.

We may also disclose your data to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

Legal basis: Performance of a contract, legitimate interest.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Prime Creative Media’s use of “cookies”

Prime Creative Media’s websites use cookies to manage user access and subscriptions. A cookie is a small text file that a server places on your hard drive to identify that subsequent requests to a site have come from the same user. Prime Creative Media uses cookies to ‘remember’ your browser between page visits.

The cookie records only your member identification number. After your initial log in to a website, Prime Creative Media recognises you as a member and, if your subscription is current, facilitates direct access to news stories. If the ‘cookie’ is not present, members will be asked to provide their login credentials (email address and password) on subsequent visits to subscriber-protected sections of websites. Most browsers allow you to reject all cookies, whilst some browsers allow you to reject just third-party cookies. For example, in Internet Explorer you can refuse all cookies by clicking “Tools”, “Internet Options”, “Privacy”, and selecting “Block all cookies” using the sliding selector. Blocking all cookies will, however, have a negative impact upon the usability of many websites, including this one.

Members who choose not to accept ‘cookies’ from any of Prime Creative Media’s websites can use the service by entering their email address and password at the beginning of each visit.

To view a sample of the content of Prime Creative Media’s cookies please contact us onsubscriptions@primeglobalpublishing.com.

Storage and security of your details

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have also adopted procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Prime Creative Media encourages you to play an important role in keeping your personal information secure, by maintaining the confidentiality of any passwords and account details used on websites. It is your sole responsibility to maintain such confidentiality and Prime Creative Media will not be liable for any damage, loss or expense suffered due to disclosure caused by your failure to do so.

Direct Marketing

You may receive marketing communications from us if you have requested information from us or purchased subscriptions or other services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

You can opt out at any time by using the unsubscribe function on each of our emails.

Other websites

Prime Creative Media’s websites may contain links to third-party websites, plug-ins and application. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites. Prime Creative Media is not responsible for the privacy policies or practices of any such third parties. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Your Right to Access and Amend Information about you

Under the Australian Privacy Principles (APPs) contained in the Privacy Act 1988(Cth), you may be able to obtain a copy of the personal information that we hold about you. The APPs provide some exceptions to your rights in this regard. If you wish to seek access to or to request correction of any personal information we hold about you, please email us atsubscriptions@primeglobalpublishing.com. We request that you provide us with as much detail as possible about the particular information sought in order to help us retrieve it. In certain circumstances, we may not be required by law to provide access to or to correct personal information. If that is the case, we will give you our reasons for that decision.

We take reasonable steps to make sure that the personal information we collect, use and disclose is accurate, complete and up-to-date.

Acts in the course of journalism

To the extent that Prime Creative Media carries on activities in the course of journalism (including investigating, preparing and publishing news, articles, reviews and current events), then its acts may be exempt from the requirements of the Privacy Act. However Prime Creative Media will deal with personal information in accordance with the privacy standards as set out by theAustralian Press Council.

Rights of individuals located in the European Union (EU) and United Kingdom (UK)

Your rights

In addition to the other terms of this policy, this section applies to personal information of individuals located in the EU and the UK. It is in addition to the

In addition to the Privacy Act, individuals located in the EU also have rights under EU based rules known as the General Data Protection Regulation (GDPR). Individuals located in the UK have similar rights under the version of the GDPR that the UK retained after Brexit, along with the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (together the UK Data Privacy Laws).

Our legal basis for processing your personal data

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

Performance of a contract with you, where we need to perform the contract we have entered with you or to take steps at prior to entering into a contract.

Legitimate interest, where we use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example: to maintain our relationship and so that we are able to provide you with excellent customer services. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Legal obligation, where we may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

Consent, we rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

Your rights under the GDPR and the UK Data Privacy Laws

These include the right to:

• Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the “Purposes” table above for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • If you want us to establish the data’s accuracy;
  • Where our use of the data is unlawful but you do not want us to erase it;
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 6 years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see “Your rights under the GDPR and the UK Data Privacy Laws” above for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

International transfers

We share your personal data within the Prime Creative Media Group. This will involve transferring your data outside the UK to our overseas offices in Australia.

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the The International Data Transfer Addendum to the European Commission’s standard contractual clauses for international data transfers. To obtain a copy of these contractual safeguards, please contact us at online@primeglobalpublishing.com.

Complaints

You have the right to make a complaint at any time to your data protection regulator. PGM is regulated by the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.