What is personal information?
“Personal information” means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether that information or opinion is true or not or recorded in a material form or not.
What personal information do we collect?
We collect and hold personal information that is necessary for, or related to, one or more of our services or activities; or because it is required under a relevant law or regulation.
The types of personal information that we may collect from you will depend on the nature of your interaction with us but will ordinarily include:
• contact information, such as your first and surname, your email address and phone number;
• unique identifiers such as user name, account number and password;
• preference information, such as marketing preferences; and
If you are interested in working with us, we may collect your full name, contact details (including address, phone number and email address), job title, passport details, employment history and education details, we well as names and contact details of referees.
From time to time, you may be able to visit our Website or App or deal with us anonymously or by pseudonym. However, please be aware that, if you do not provide us with certain information that we request, we may not be able to provide you with the services you require.
How do we collect personal information?
We may collect personal information from you in variety of ways, including when you:
• sign-up for an account on our Website or via the App;
• register your name and contact details to obtain full access to news articles on our Website;
• register your name and contact details on our Website to obtain a free report from our related company, Kalkine Pty Ltd;
• register your name and contact details on our Website to receive a call about Kalkine Pty Ltd’s stock recommendation services from our related company, Kalkine Solutions Private Limited (Kalkine Solutions);
• update your account;
• contact our Customer Support desk;
• register to attend online events we hold;
•engage with us via our official social media pages, such as our Facebook, Twitter or LinkedIn pages;
• contact us by phone, email, post or via our Website or App enquiry forms;
• subscribe to receive (by email and phone) our promotional offers and marketing materials and/or push notifications;
• provide your personal information in response to a banner advertising campaign; and
• sign-up to participate in surveys and competitions.
We may also collect certain non-personal information when you visit or use our Website or App and use our services, for example, your IP address and details of your operating system or internet browser.
Do we collect personal information from third parties?
We may also collect your personal information from third parties when permitted or required by law. We may collect personal information from:
• our related companies located in Australia, New Zealand, India, the United Kingdom and Canada;
• someone duly authorised to act on your behalf;
• law enforcement agencies and other government entities;
• third party suppliers and contractors who assist us to operate our business, such as our call centre operator; and
• if you are a job applicant, recruiters or your referees.
Your personal information will only be collected from third parties if it unreasonable or impractical to collect that personal information from you directly. If and when we do collect personal information from third parties, we will take reasonable steps, in the circumstances, to inform you of this collection.
Why do we collect your personal information and how do we use it?
Kalkine Media may collect and use your personal information for the purposes of providing you with our services and for our internal business purposes. These purposes include (but are not limited to):
• registering, setting up and managing accounts;
• providing our services, articles, reports and newsletters;
• sending you notifications about our services;
• sending you push notifications about, for example, trending topics and news;
• responding to your questions, comments and requests and to otherwise provide customer services;
• assessing applications for employment;
• to display content based on your interests;
• marketing our products and services (and those of our related companies) and providing you with information and updates such as newsletters or offers of promotional events or opportunities (such as competitions or surveys) that you may be interested in;
• the prevention of fraud and/or identifying and investigating any suspicious use of our Website or App or services;
• for our internal business and management processes, for example, to conduct research and analysis, improve our services and for accounting or auditing purposes;
• for any other purpose to allow us to comply with our obligations under law; and
• for any other purposes that would reasonably be expected by you.
Our App has a push notification function. We may process information that you provide to us for the purpose of subscribing you to our push notifications. If you are a registered user of the App, you may receive notifications in the “notifications” section within the App and on your device, such as: notifications of trending topics and news. With your consent, we may send push notifications or alerts to your mobile device. If you have logged-in using Facebook or Google, you can manage your push notification preferences or deactivate these notifications at any time by turning off the notification settings in the App. If you choose to use the SKIP feature, then you will not receive In-App notifications or push notifications on your device.
Kalkine Media and its related companies, such as Kalkine Pty Ltd and Kalkine Solutions, may use your personal information for the purposes of marketing our services or to inform you of new services, promotions or events that we believe you may be interested in. Kalkine Solutions (an Indian subsidiary of Kalkine Pty Ltd) is an authorised representative of Kalkine Pty Ltd and is an Australian Registered Body (ARBN 622 210 075). When you provide us with your personal information via our Website or App, over a phone call or through an email, you agree to receive marketing materials or information on our services, promotions or events. Please note that Kalkine Solutions provides telemarketing services on our behalf and on behalf of Kalkine Pty Ltd, for example, calls in respect of Kalkine Pty Ltd’s stock recommendation services are made by Kalkine Solutions. We will continue to process your personal information for this purpose indefinitely until you unsubscribe or request that we cease to do so. If you would like to stop receiving any of these marketing communications, you can opt out by writing to us at the contact details listed below (“Contact Details”) and informing us that you no longer wish to receive these materials. If at any time you would like to stop receiving future electronic marketing messages (such as emails or SMS), you can click the “unsubscribe” link in the electronic marketing messages we send.
Recording of phone calls
We may record telephone calls for training and quality purposes. We will let you know at the beginning of the call if the call is being recorded. If you do not want the call to be recorded, then you can let us know or terminate the call.
Will your personal information be disclosed to third parties?
From time to time, Kalkine Media may disclose your personal information to third parties for the purposes of providing our services and conducting our business. These third parties may include:
• our related companies, which are located in Australia, New Zealand, India, the United Kingdom and Canada, for operational and business administration functions as well as for direct marketing purposes;
• our related company in India, Kalkine Solutions, which provides our call centre services;
• third party service and content providers, dealers and agents, contractors, advisors and suppliers who assist us in managing our business or operating our Website or App, for example, business support service providers, web-hosting service providers, cloud storage providers, mailing houses and information technology providers;
• our professional advisors including lawyers, accountants, tax advisors and auditors;
• if you are applying for employment with us, recruiters we have engaged and/or your referees;
• law enforcement bodies to assist in their functions, courts of law or as otherwise required or authorised by law; and
• regulatory or government bodies for the purposes of resolving customer complaints or investigations.
If we sell or purchase any business or assets, your personal information may be disclosed to the prospective buyer/seller. If our business (or substantially all of our assets) is acquired by a third party, your personal information held by Kalkine Media may be an asset which is transferred to the buyer.
How do we secure and protect your personal information?
We take such steps as are reasonable in the circumstances to maintain the integrity of your personal information and to store your personal information securely to protect it from interference, misuse and loss and from unauthorised use, access, modification or disclosure.
Any personal information you submit to us through an online order form is transferred to us via a Secure Sockets Layer, an encryption protocol and is kept in databases that cannot be accessed from outside our firewall. Our firewall is a mechanism that prevents access to our servers by anyone outside Kalkine Media.
Data is stored on servers through cloud infrastructure in Australia.
Kalkine Media takes reasonable steps to destroy or permanently de-identify your personal information if it is no longer needed for a purpose which it may be used or disclosed under the Australian Privacy Principles and we are not required by law or a court/tribunal order to retain the information.
Check the “Help” menu of your browser for more information on how to change your cookie preferences. You may disable cookies or set your browser to alert you when cookies are being sent. If you do disable cookies, we may be unable to optimise your visit to our Website or App and you may experience some errors. Refer to your browser instructions or help screens to learn about these functions.
When we send you emails, we may include a web beacon to allow us to determine the number of people who open our emails. When you click on a link in an email, we may record this individual response to allow us to customise our offerings to you. Web beacons collect only limited information, such as a cookie identifier, time and date of a page being viewed, and a description of the page on which the Web beacon resides (the URL).
Web beacons can be refused when delivered via email. If you do not wish to receive Web Beacons via email, you will need to disable HTML images or refuse HTML (select Text only) emails via your email software.
Third Party Links
Accuracy and requests for access and correction of personal information
We will take reasonable steps to ensure that the information we hold about you is relevant, accurate, up-to-date and complete.
You can request that we provide you with access to information we hold about you or ask us to correct any personal information we hold about you that is out-of-date, incorrect, incomplete or misleading. You can update your contact details by logging in to your account. You can also contact us by submitting a request in writing to the address set out below. If we are able to, we will action your request within a reasonable time frame (usually no more than 30 days) following receipt of your request.
We may decline a request for access to, or correction of, personal information in circumstances prescribed by the Privacy Act. If complying with your request for access requires considerable time and expense on our part, we may charge you a reasonable fee for providing you with information.
If we do refuse your access or correction request, we will provide you with written reasons for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
You may make a complaint about privacy to our Privacy Officer using the contact details set out below.
Our Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint.
Your complaint will then be investigated. 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 a reasonable time, usually 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 are not satisfied with our response to your complaint, or you consider that we may have breached the Australian Privacy Principles or the Privacy Act, you may make a complaint to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.
Individual Rights Under the EU GDPR
If you are located in the EU, you have the following additional rights:
• The right to information – you can request confirmation about the following: whether your personal information is being processed by us; the purpose of processing; the categories of personal information which are processed; the recipients (or types of recipients) who may receive the personal information; the anticipated retention period of the personal information; and your rights to rectification, erasure, to restrict (or object) to processing and to lodge a complaint with a data protection supervisory authority in the EU.
• The right to object to our processing of your personal information for (i) direct marketing purposes; (ii) for scientific, historical research or statistical purposes; or (iii) where our processing is based on legitimate interest grounds or because it is in the public’s interest. We will respond to your objection request within a month. However, there may be some circumstances where we are not required to stop processing your personal information. If this is the case, we will provide you with a written explanation.
• The right to restrict processing – in some circumstances, you can request us to restrict our use of your personal information in which case we will not use or disclose your personal information while it is restricted. We will respond to your restriction request within a month.
• The right to erasure – you can request us to erase your personal information where it is no longer required for a purpose for which it was collected or where, for example, you have exercised successfully your right to object to processing. We will respond to your erasure request within a month. However, where there are legal or other reasons for us to retain your personal information, we will provide you with a written explanation.
• The right to data portability you can request us to provide you with a copy of the personal information you have provided to us. We are required to provide it to you in an electronic format that can be reused easily. You can also request us to transfer your personal information in an electronic format to another entity.
You can exercise any of these rights by contacting us using the contact details below.
You also have the right to:
• access your personal information and request the correction of your personal information (see “Accuracy and requests for access and correction of personal information” above); and
• lodge a complaint with a data protection authority if you are unhappy with the outcome of a privacy complaint. The “Complaints” section above explains our complaints handling process. A list of EU data protection authorities is available at https://ec.europa.eu/.
The Privacy Officer
Kalkine Media Pty Limited
Suite 202, 234 George Street
Sydney NSW 2000
Email: [email protected]
Tel: +61 (02) 9042 2308