Startrail entity and Founder of the company (“we”) are committed to protecting your privacy. Please read this policy carefully as it describes the way in which we handle and collect your personal information. This applies to all personally identifiable information we receive, such as your name, address and telephone number. We take this stance not just to fulfill our legislative obligations under the Privacy Act but also because we value your trust and our ongoing relationship. You have no obligation to provide any personal information however if you choose to withhold your personal information we may not be able to provide the products or services that depend on the collection and use of your information.
This policy describes how we will abide by the most applicable Principles that form part of the Act.
These principles relate to:
Collection and Management of Personal Information
The type of information we collect depends upon the product or services we are providing and generally can include name, address, phone number, fax, email address, birthdate, gender, images, identity information, audio, videos, links, job title, company, bank account, debit / credit card and relevant details to enable processing of payments, IP address, as well as interests and details about your transactions. For employment we will collect additional personal information including educational and employment history and references. On occasion some of this personal information may be sensitive. We will only collect it with your consent or when required or authorized to by law.
Where possible, we collect your personal information directly from you. In some circumstances, however, we may also collect your personal information from third parties or public agencies where it is unreasonable or impracticable for us to collect the personal information directly from you.
Collection includes through:
1. registration when you purchase a membership or digital subscription;
2. registration to websites and social media accounts ;
3. entry into promotions or competitions and answers to surveys ;
4. signing up to newsletters, events , email, direct marketing and other notifications from our magazines, websites and other brands;
5. registration to attend events and functions;
6. application for employment with us;
7. communications with us such as telephone calls, sms, faxes and emails regarding products and services;
8. registration for our loyalty programs;
9. Download, share and use of our digital publications and mobile applications (“apps”).
10. Subscription to one of our memberships through a third party that is authorized to take subscriptions for us, we will collect your personal information from that third party.
We will always undertake such collection by lawful and fair means and not in an unreasonably intrusive way. If we collect personal information about you from someone else, we will take reasonable steps to ensure that it is in accordance with the provisions of the privacy act.
Use and Disclosure
We may use and disclose your personal information for the purpose for which it was initially collected, namely to arrange, conduct and promote our media activities and provide you with requested products and services (and renewals thereof), as well as all purposes necessary and incidental to the provision of goods or services by us or by anyone on behalf of us. Some of these include;
1. registration, delivery, renewal, payment for membership subscriptions;
2. registration and delivery for newsletters, events and communications;
3. offers to participate in promotions, competitions, surveys, events, functions;
4. offers that we believe will be of interest to you ;
In certain circumstances, we will use or disclose your personal information for a purpose other than the main reason it was collected (i.e. a secondary purpose). These circumstances are when:
1. the secondary purpose is related to the primary purpose of collection and you would reasonably expect us to use or disclose the information for that secondary purpose; or
2. you have consented to the use or disclosure; or
3. the information is not sensitive information and the secondary purpose is direct marketing and:
4. it is impracticable for us to seek your consent before that particular use; and
5. you have not requested that we do not send you direct marketing communications;
6. we provide you with the express opportunity to decline any further direct marketing communications at the time of first communication is sent and thereafter upon request, and at no cost to you; or
7. we reasonably believe that the use and/or disclosure is necessary to lessen or prevent a serious and imminent threat to an individual’s life or health; or
8. we have reason to suspect that unlawful activity has been, is being or may be engaged in, and we use the personal information as a necessary part of our investigation of the matter or in reporting our concerns to relevant persons or authorities; or
9. it is required or specifically authorised by law; or
10. it is reasonably necessary for the enforcement of the criminal law, a law imposing a pecuniary penalty, or for the protection of the public revenue.
We disclose your personal information offshore to our owners, joint venture partners, service providers and agents. It is not practicable to specify all countries to which we may disclose your personal information as, among other things, we are part of a global organization. We ensure that any organization which we disclose your personal information to is subject to reasonable obligations to safeguard and protect your personal information and comply with Privacy Laws.
Submission, Storage, Sharing and Transferring of Personal Data
Personal Data that you provide to us is stored internally or through a data management system. Your Personal Data will only be accessed by those who help to obtain, manage or store that information, or who have a legitimate need to know such Personal Data (i.e., our hosting provider, newsletter provider, payment processors or team members).
Websites, Apps, Cookies – non personal identifiable information
In order to properly manage our websites and digital properties we may anonymously log information on our operational systems, and identify categories of visitors by items such as domains, user’s IP address, browser version or type, device name or type, operating system, service provider, and local time. This is to ensure that our websites and digital applications present the best experience for visitors, measure your use of our products and services, show you relevant advertising. We have contracted with Google and other advertising serving technology providers to serve all advertising on our Web sites, digital executions and direct marketing programs are also used in our environment – including various analytic programs and other electronic delivery systems. Aggregated data may be collected by us so that we may better provide our services to you. Aggregated data may be provided to third parties. Aggregated data includes information that relates purely to generic statistics such as demographics and traffic flow on our website and which does not personally identify you. Cookies may be used on some areas of our websites. A cookie is generated by a software application on a website’s server, which enables it to improve your navigational experience through customization enabled by tracking your navigation through a small text file on your hard drive. If you are concerned about cookies, most browsers now recognize when a cookie is offered, and permit you to opt-out of receiving them in the Options tab of your browser.
From time to time we may use your personal information to identify products and services that may be of interest to you. We may use your personal information to send you information regarding our products and services, and those available through our business partners.
From time to time, with your consent, we may also provide your personal information to carefully selected third parties for the purpose of them providing you with information regarding products and services specific to your needs, and to help us conduct product enhancement activities.
If you do not wish to receive direct marketing information from us or third parties (as applicable) as outlined in this section, please let us know by using the unsubscribe function in the communication you receive, or alternatively by contacting us. We will take appropriate steps to ensure that you do not receive any such direct marketing information in future.
From time-to-time we may run promotions which require you to provide personal information directly to a third-party to redeem the promotional offer. In this instance, it is your responsibility to review the third-party’s terms and conditions and privacy statement relating to data use, prior to redeeming the promotional offer.
Our objective is to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date and we will take reasonable steps to ensure this.
We will take reasonable steps to protect the personal information we hold from misuse and loss and from unauthorized access, modification or disclosure. Your personal information may be stored in hard copy documents but is generally stored electronically. We store information securely – this includes onsite secure servers and trusted third party storage providers.
We will use the Personal Data you give to us in order to process your payment for the purchase of goods or services under a contract. We only use third-party payment processors that take the utmost care in securing data and comply with the GDPR (General Data Protection Regulation of the EU).
Access and Correction
You can access or correct your personal information by using your dashboard or Contact us. In certain circumstances we may refuse your request to access, or correct, your personal information.
The following are permissible exceptions under the Act:
1. providing access would pose a serious and imminent threat to the life or health of any individual; or
2. providing access would have an unreasonable impact upon the privacy of other individuals; or
3. the request for access is frivolous or vexatious; or
4. the information relates to existing or anticipated legal proceedings between us and yourself, and the information would not be accessible by the process of discovery in those proceedings; or
5. providing access would reveal our intentions in relation to negotiations with you in such a way as to prejudice those negotiations; or
6. providing access would be unlawful; or
7. denying access is required or authorized by or under law; or
8. providing access would be likely to prejudice an investigation of possible unlawful activity; or
9. the prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; or
10. the enforcement of laws relating to the confiscation of the proceeds of crime; or
11. the protection of the public revenue; or
12. the prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or
13. the preparation for, or conduct of, proceedings before any court or tribunal, or implementation of its orders; by or on behalf of an enforcement body; or
14. an enforcement body performing a lawful security function asks the organization not to provide access to the information on the basis that providing access would be likely to cause damage to the security of nation.
If we hold personal information about you and you are able to establish that the information is not accurate, complete and up to date, we will take reasonable steps to correct the information so that it is accurate, complete and up to date. Depending on the circumstances, you may be forwarded the information by mail or email, or you may be required to personally inspect your records at the appropriate place. A fee may apply to such access in the event that a request for access is onerous or time consuming. Such a fee will cover staff costs involved in locating and collating information, and reproduction costs.
Startrail, Prabhat Road, Lane 9, Pune
Maharashtra, India 411004.
Email or contact us at www.stratrail.in.
Copyright © 2018-2019 Startrail. All rights reserved.