Vinyl Media
Privacy Policy

“Vinyl Media” means Vinyl Group Media Operations Pty Ltd (ACN 614 595 201) and its related bodies corporate from time to time. Vinyl Media owns, operates and/or provides services in connection with a portfolio of media brands, publications, websites, applications and other digital properties, including properties operated under licence from third-party rights holders (collectively, the Properties).

This Policy applies where a Property links to or otherwise adopts this Policy.

In the course of our activities Vinyl Media (we, us, or our) will collect, store, use, transfer and disclose personal information. We are committed to the protection of your personal information and to compliance with Australian privacy laws.

This statement explains our policies and practices regarding the use, collection, storage and disclosure of your personal information.

Personal Information

“Personal Information” 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 is recorded in a material form or not.

Types of personal information we collect and hold

We collect and hold personal information about individuals for the provision of our products and services and purposes connected to those products and services. Consistent with the provision or our products and services to you, the types of personal information we may collect and hold about you include but are not limited to the following:

1. contact and account information;
2. subscription, membership and transaction information;
3. competition and event-entry information;
4. communications and enquiries;
5. employment/recruitment information;
6. IP address, device identifiers and browser/device information;
7. browsing, usage and interaction information;
8. advertising identifiers;
9. approximate location information;
10. preferences and inferred interests;
11. information obtained from social media platforms or other third parties; and
12. demographic information.‍

How and why we collect and hold personal information

We may collect personal information directly from you in the course of providing our products and services from our Properties.

We collect personal information reasonably necessary to carry out our business, to assess and manage our members' and subscribers’ and customers’ needs, and provide our services to those groups. We may also collect information to fulfill administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties and managing member and other business relationships. We also collect personal information to administer and manage relationships with our shareholders. We may allow shareholders and other visitors to our websites to sign up for alerts and otherwise communicate with us.

Our principal purpose in collecting, using and storing your personal information is to provide you with access to and use of our services and those of related entities in a personalised, safe and efficient manner. We collect, hold, use and disclose personal information for purposes reasonably necessary for our functions and activities, including;

1. to provide news and information about our services or services of companies related to us and/or special offers to users;
2. to obtain opinions or comments about services from users;
3. to send you marketing and promotional material that you have opted in to receive
4. to record statistical data for marketing analysis from users;
5. managing, planning, advertising and administering programs, events, competitions and performances;
6. managing our relationship with you if you are a data supplier, business partner or shareholder;
7. researching, developing and expanding our services and those of related entities;
8. informing you of our activities, events and services and those of related entities;
9. to enable your access to members-only features or services;
10. to conduct competitions;
11. to operate, evaluate and improve our business and the business of companies related to us, including developing new products and services; managing our communications; determining the effectiveness of, and optimizing the content you see; analyzing our products, services, website, mobile application, and any other digital assets and those of companies related to us; facilitating the functionality of our website, mobile application, and any other digital assets and those of companies related to us;
12. to investigate any complaints about or made by you;
13. for purposes of recruitment processes;
14. to investigate breaches of our terms and conditions or other unlawful behaviour;
15. for market research purposes and to innovate our delivery of services; and
16. responding to requests for information, general enquiries and complaints.

Use of Digital Technologies

Vinyl Media and its advertising/analytics partners may use cookies, pixels, tags, SDKs and similar technologies.

These technologies assist in managing customized settings of the platform and delivering content. We collect certain information such as your device type, browser type, IP address, the pages you have accessed on our website and on third-party websites.

Information collected through these technologies may not identify you directly, but in some circumstances may constitute or be combined with other information to constitute personal information.

Why we use these technologies

We use these technologies to personalize your browsing experience (for example, by remembering your preferences and recognizing you as a repeat visitor to our Property’s websites), and to track statistics about the usage of our Property’s websites. This allows us to better understand our users and improve the layout and functionality of our websites.

We use the technologies that

12. are required for the operation of our website, such as cookies that enable you to log into secure areas of our website (for example, our membership platform).
13. allow us to count the number of users and see how users move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
14. record your visit to our website, the pages you have visited and the links you have followed. We will use this information, subject to your choices and preferences, to make our website and any advertising displayed on it more relevant to your interests.

How you can manage these technologies

If you do not wish to receive any cookies (other than those which are strictly necessary) you may set your browser (such as Firefox, Google Chrome, Internet Explorer or Safari) to either prompt or refuse cookies. Please note that rejecting cookies may mean that not all the functions on our website you visit will be available to you.

Holding Personal Information

Personal information is held securely, is subject to various security protections and we retain personal information only for as long as reasonably necessary for the purposes for which it was collected, or as required or permitted by law. When personal information is no longer required, we take reasonable steps to destroy or de-identify it.

We take all reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorised access, including by means of firewalls, password access and secure servers.

You acknowledge that we are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose your personal information to in accordance with this policy or any applicable laws). The collection and use of your information by such third parties may be subject to separate privacy and security policies.

Our properties may feature proprietary measurement software, which will allow you to contribute to market research, like Digital Content Ratings.

Permitted Disclosure of your Personal Information

We may disclose personal information to third parties:

12. 1. engaged by us to perform functions or provide products and services on our behalf;
13. 2. that are our agents, business partners, joint venture entities or brand activation partners;
    
14. 3. that may include hosting/cloud providers, data analytics providers, advertising and marketing technology providers, payment processors, CRM/email distribution providers and professional advisers.
15. 4. that sponsor or promote any competition that we conduct or promote;
16. 5. that are authorised by you to receive information held by us;
17. 6. if we have reason to suspect that you have committed a breach of our terms and conditions, or have otherwise been engaged in any unlawful activity;
18. 7. as part of a sale (or proposed sale) of all or part of our business; and/or
19. 8. as required or permitted by any law (including the Privacy Act).

Addressing Your Concerns - access, correction and deletion

If you suspect any misuse or loss of, or unauthorised access to, your personal information, please contact us immediately. You may contact us at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

We will take all reasonable steps to ensure any personal data we collect, use or disclose is up to date and accurate. If you believe personal information we hold about you is not up to date or accurate, you may ask us to correct it.

You may ask us to provide you with details of the personal information we hold about you, and copies of that information. We will respond to your request and attempt to provide you with the data within 30 days of receipt of your request.

We will not charge you for making an access request. Where permitted by law, we may charge a reasonable amount for giving you access to your personal information, which will not exceed our reasonable costs of providing access.

If you want us to delete the personal information that we have collected about you, you may contact us by email at legal@vinyl.group

Please direct all request for access and correction to:

Privacy Officer

Vinyl Group Media Operations Pty Ltd

The Commons, 11 Wilson St, South Yarra, Victoria, 3141

If you consider a breach of the Australian Privacy Principles has occurred, you may direct your query to Vinyl Group Media’s Privacy Officer and we will attempt to resolve your issue.

We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week. If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking.  We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint.  If the matter is more complex or our investigation may take longer, we will let you know.

If you do not consider our response satisfactory, you may contact the Australian Privacy Commissioner at its website www.oaic.gov.au or by telephone on 1300 363 992.

If you are outside of Australia, you may wish to take your complaint up with the local data protection authority in your jurisdiction. For example, if you are based in the United Kingdom, this is the UK Information Commissioner’s Office.

Aggregated information

We may aggregate the information you and others make available to us and post it publicly or share it with third parties. Examples of the type of information we may aggregate include information about music and media preferences and demographics. We may use, sell, license, and share this aggregated information with third parties for research, business or other purposes such as to promote the music, media, leisure, lifestyle and entertainment industries or to help our partners understand more about the people who use their products and services.

International use of Personal Information

Personal information may also be shared between our related entities or affiliated companies, located in Australia and overseas. We are a global organisation and work with service providers, sponsors and commercial partners globally. It is likely that your personal information will be disclosed to overseas recipients, including service providers who may handle, process or store your personal information on our behalf. The recipients of such information may be located in jurisdictions such as Australia, the United Kingdom and the United States.

Our related entities may have operations in countries including the United Kingdom and the United States and other countries.

We generally collect personal information about you in Australia or the jurisdiction in which the related entity you are dealing with is located.

It is likely that your personal information will be transferred outside of the jurisdiction it was collected.  We only ever disclose your personal information outside the jurisdiction it was collected where we are permitted to do so under applicable privacy laws. Where personal information is disclosed overseas, we take reasonable steps as required by applicable privacy laws in relation to that disclosure.

Residents in the European Economic Area

We have described the purposes for which we may use your personal information. If the GDPR applies to you, we are permitted to process your personal information in this way, in compliance with the GDPR, by relying on one or more of the following lawful grounds:

12. you have explicitly agreed to us processing your information for a specific reason;
13. the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
14. the processing is necessary for compliance with a legal obligation we have; or
15. the processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
    
    1. to prevent fraud;
    2. to protect our business interests;
    3. to ensure that complaints are investigated;
    4. to evaluate, develop or improve our services; or
    5. to keep our members informed about relevant services, unless you have indicated at any time that you do not wish us to do so.

If the GDPR applies to you, you have the following additional and specific rights in relation to your personal information (where applicable):

12. Access: you have the right to request a copy of any personal information we hold about you. Any request for access to or a copy of your personal information must in writing, and we will endeavor to respond within a reasonable period and in any event within one month (in compliance with the GDPR).
13. Rectification: you have the right to the rectification of your personal data, if you consider that it is inaccurate.
14. Deletion: you have the right to request that we delete personal information that we process about you, except we are not obliged to do so if we need to retain such personal information in order to comply with a legal obligation or to establish, exercise or defend legal claims.
15. Portability: you have the right to ask us to transfer a copy of your personal information to you or to another service provider or third party where technically feasible.
16. Restriction: you may have the right in certain circumstances to request that we restrict the processing of your personal information.
17. Objection: you have the right to object to your personal information being processed for a particular purpose or to request that we stop using your information.
18. Complaint: If you are unhappy with our treatment of your personal information, and you have contacted us as set out below, you have the right to lodge a complaint with the local data protection authority.

Children

Some of our Properties may be accessed by people under 18. Where we collect or handle personal information relating to children or young people, we will do so in accordance with applicable privacy laws and any applicable privacy code.

Anonymity and Pseudonymity

Where practicable, you may interact with us anonymously or using a pseudonym. However, there may be circumstances where we need to know your identity in order to provide a service, process a transaction, administer a competition, respond to a request or otherwise deal with you.

Changes to this Privacy Policy.

We may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes. We also attempt to make you aware of major changes to our Privacy Policy (for example by putting a notice up on our website(s)). This Privacy Policy may be translated into languages other than English. If there is a discrepancy between the English language version and any translated version of this Privacy Policy, the English language version will prevail.