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Privacy Policy

Privacy Policy for

Instagami Australia Pty Ltd

(“instagami”)

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1.  OVERVIEW

 

[This Privacy Policy will become effective upon instagami launching its business or completing its 'Market validating' program.]

 

At instagami, the privacy of the Personal Information of our customers and visitors to our website is always kept on top of our priority list.   To ensure we comply with the Privacy laws in your country, we must also provide you with this Privacy Policy in our website.  We have wherever possible kept the legal jargon to a minimum.

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“Personal Information” means information which identifies you as an individual from which you can be reasonably identified.   Of course, at instagami we must identify you and collect your information otherwise we are unable to do business with you and provide you with the goods/services you require.

 

This Privacy Policy document contains types of information that might be collected and recorded by instagami and how we use it.   If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us.

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2.  GENERAL DATA PROTECTION REGULATION (GDPR)

 

For the purpose of the information you provide to us, and according to the requirements imposed by the GDPR regulations, we are a ‘Data Controller’ of your information, and a member of our staff is selected and appointed as the person responsible for keeping the privacy of your information.

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instagami’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and in the specific context in which we collect the information:

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  • instagami needs to perform a contract with you;

  • you have given instagami permission to do so;

  • Processing your personal information is in yours and instagami's legitimate interests; and

  • instagami needs to comply with the law.

 

instagami will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy.   We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.   Our Privacy Policy was generated from information including GDPR Privacy Policy Generator and the Privacy Policy Generator.

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If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.

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In certain circumstances, you have the following data protection rights:

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  • The right to access, update or to delete the information we have on you.

  • The right of rectification.

  • The right to object.

  • The right of restriction.

  • The right to data portability

  • The right to withdraw consent

 

3.  LOG FILES

 

instagami follows a standard procedure of using log files in instagami.com.   These files log visitors when they visit instagami.com.   All hosting companies do this and a part of hosting services' analytics.   The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks.   These are not linked to any information that is personally identifiable.   The purpose of the information is for analysing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

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4.  COOKIES AND WEB BEACONS

 

Like any other website, 'cookies' are used in instagami.com.   instagami provides and/or will provide information and services through a range of digital and online services including websites (e.g. instagami.com), apps, email, online advertisements, IPTV, and social media profiles, which are/will be collectively known as ‘In-house Digitised Services’ (“IDS”).   These services may be operated by instagami and/or by outside marketing organisations scrutinised and contracted by it.

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IDS may use “cookies”.   A cookie is a piece of information that allows the server to identify and interact more effectively with PC and mobile devices.   The cookie assists us in maintaining the continuity of your browsing session (e.g. to maintain a shopping cart) and remembering your details and preferences when you return.   Other technologies that may be used with IDS include web beacons (which may operate in conjunction with cookies), Flash local stored objects, and JavaScript.   A web beacon is a clear picture file used to keep track of your navigation through a single website or a series of websites.   You can configure your web browser to reject and delete cookies and block JavaScript but you may find some parts of our website providing limited or inferior functionality.    You can control your preferences regarding Flash local stored objects at

http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html

 

Our systems record a variety of information in relation to interactions with our online services.   This can include information about software versions used, device identifiers (like IP address), location data (where available and not disabled by the user), dates, times, file metadata, referring website, data entered, and user activity such as links clicked.   In some cases, third parties may use cookies and other technologies such as those described above as part of IDS.   These technologies may be used in connection with activities like surveys, online behavioural advertising, website analytics, and email campaign management.  The services we may use from time to time include those offered by Google (including AdSense and DoubleClick), Yahoo, Adobe (including Campaign Manager and Analytics), and Microsoft.  You can find more details in the privacy policies for those services, including information on how to opt-out of certain conduct.  Bear in mind, you may need to opt-out separately from each service. The website www.youronlinechoices.com.au also allows you to opt-out of some online behavioural advertising and provides further information about how online behavioural advertising works.  You can contact us to request further details of the services we use.   Many of these services operate without collecting or using any Personal Information.

 

Some information we collect in relation to IDS is not related to an individual.   In many cases the information only relates to a device or is of an aggregated or statistical nature, and we will have no way of knowing the identity of the user.   In other cases we may associate information about your use of the IDS over time with your Personal Information, e.g. where on any occasion you have logged in, followed a link sent to you by email or we have otherwise been able to identify you.

 

We are constantly developing and enhancing our use of online technologies, and make reasonable efforts to ensure we keep this Privacy Policy and related documents up to date in this regard.   Please check back when you return to use our online services to ensure you are familiar with our current practices.

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Our online services may contain links to other sites.   We are not responsible for the privacy practices or policies of those sites and recommend that you review their privacy policies.

 

More information on “Cookies” and “Web Beacons” is widely available in the internet.

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5.  THIRD PARTY PRIVACY POLICIES

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instagami's Privacy Policy does not apply to other advertisers or websites.   Thus, we are advising you to consult the respective Privacy Policies of these third-party ad servers for more detailed information.   As noted earlier, the Privacy Policies may also include their practices and instructions about how to opt-out of certain options.

 

You can choose to disable cookies through your individual browser options.   To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites or it can be researched on the internet under the heading ”What Are Cookies?”

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6.  CHILDREN'S INFORMATION

 

Another part of our priority is adding protection for children while using the internet.   We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

instagami does not knowingly collect in instagami.com any Personal Identifiable Information from children under the age of 13.   If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

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7.  TYPES OF PERSONAL INFORMATION COLLECTED

 

The types of Personal Information we collect includes:

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  • Name;

  • Contact details (e.g. email address, telephone number(s), residential and delivery addresses);

  • Information to identify you (e.g. date of birth);

  • Household details (e.g. number of people living at a household and their ages);

  • Payment and transaction details/history (including information about payment cards linked to your purchases);

  • Details regarding participation in competitions and customer loyalty incentive programs organised from time to time;

  • Records of your communications and interactions with us; and

  • Details/history of purchases, preferences, interests and choices relating to transactions, products, services and activity with our digital services.

 

We may not be able to provide our products or services, or make offers to you without your Personal Information.    For example, we may not be able to deliver items ordered online to your home address if you do not provide us with your residential and delivery addresses.   As another example, we may not be able to award you/deliver to you any prizes that you may win in competitions where you have not provided your Personal Information, which includes your credit/debit card number.

 

Where you provide us with Personal Information about someone else you must have their consent to provide their Personal Information to us based on this Privacy Policy.

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8.  HOW PERSONAL INFORMATION IS COLLECTED AND STORED

 

instagami may collect your Personal Information in relation to your interactions and transactions with us, which will include when you:

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  • Use your payment cards;

  • Make a purchase in any of our vending machines or place an order online;

  • Participate in our customer incentive loyalty programs organised from time to time;

  • Participate in a promotion, competition, or survey;

  • Request customer service or contact us;

  • Post a review or comment on one of our websites or social media pages, or post a rating or review or other user generated content on one of our websites or apps; or

  • Otherwise use our related apps, social media and other digital services.

 

We may monitor and record your communications with us (including email and telephone) for security, dispute resolution, and training purposes.

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9.  PURPOSES FOR HANDLING PERSONAL INFORMATIONn

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instagami handles your Personal Information in connection with providing, administering, improving, and personalising our products to best suit you, as well as to support our business functions.   This can include:

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  • To manage your requests for products and services, including delivery, processing payments, providing refunds and discounts;

  • To register and service your account, including keeping your information up-to-date, and verifying your identity;

  • To communicate with you about our products, services, and promotions (including direct marketing);

  • To help us improve our products and services, including conducting product and market research;

  • To improve our operational processes to enhance your customer experience;

  • To respond to your feedback, queries, or concerns;

  • Working with our service providers, including shippers of our products to you;

  • Investigative, fraud, and loss prevention activities;

  • Interacting with Regulators and relevant government entities;

  • As otherwise required or permitted by law.

 

We may also handle your Personal Information to lawfully protect our interests. 

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We may provide our marketing and communications agencies with targeted product offers of interest to you by telephone, electronic messages (e.g. email), our digital services, and other means unless you opt out by writing to us at dataprotectionofficer@instagami.com.   These communications may only relate to the products and services which may be of interest to you.

 

Where you provide us with Personal Information about someone else, you must have their consent to provide their Personal Information to us based on this Privacy Policy.

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10.  SHARING OF PERSONAL INFORMATION

 

We do not sell or deal in Personal Data or any information of our customers.

 

We work with a number of suppliers that carry out specific functions on our behalf to facilitate our delivery of goods/services to you.   These include companies that assist us with:

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  • Logistics organisations providing us with shipping/delivery of products to you;

  • Technology services including application, development, technical support, processing, storing, hosting and analysing data;

  • Processing payments;

  • Communicating our offers and promotions to you;

  • Product development and market research;

  • Business advisory services, such as our lawyers, accountants, or other professional service providers to extent reasonably required; and

  • Administrative services, including mailing services, printing, archival, and contact management service.

 

Some of our service providers including technology or data storage providers may be located in countries outside Australia.   While it is not reasonably practicable to list all of the countries to which your Personal Information may be disclosed from time to time, it is likely that such countries may include New Zealand, Germany, India, Ireland, Japan, Hong Kong, Malaysia, the Philippines, Singapore, Brazil, South Africa, the United Kingdom, and the United States.

 

When we disclose your information overseas, we take steps to ensure that our service providers are obliged to protect the privacy and security of your Personal Information in accordance with the standards that apply in Australia including that they only use Personal Information for the purpose for which it is disclosed.

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11.  PROCEDURE FOR ACCESS, CORRECTION AND FEEDBACK

 

If you wish to access or correct any Personal Information we hold about you, please contact us as set out below.

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When making an access request, please provide as much detail as you can about the particular information you seek, in order to help us retrieve it.   Under the Privacy Act and other relevant laws, we are required to provide a written response outlining our reasons if we refuse your request.   Where we decide not to make a requested correction and you disagree, you may ask us to add a note of your requested correction to the information that explains your correction request.

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12.  COMPLAINTS AND CONCERNS

 

If you have any complaints or concerns about this Private Policy, or our handling of your Personal Information, you can contact us as set out below.

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Once a complaint has been lodged, we will let you know who will be handling your matter and when you can expect a full response within 30 days.   If you are not satisfied with our response, please let us know and we will investigate further and respond to you.

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If you are still not satisfied, you can contact the Office of the Australian Information Commissioner, whose contact details are set out below.

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13.  CONTACT DETAILS

 

Queries regarding privacy should be directed to instagami at the below address:

 

By email: dataprotectionofficer@instagami.com

 

By post:  The Data Protection Officer,

                Instagami Australia Pty Ltd

                PO Box 5, YORKEYS KNOB   QLD   4878 Australia

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If you query is not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner:

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By post:  Office of the Australian Information Commissioner

               GPO Box 5218 Sydney NSW 2001

 

By telephone:  1300 363 992

 

By email: enquiries@oaic.gov.au

 

Website: www.oaic.gov.au

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14.  CONSENT

By using our website, you hereby consent to our Privacy Policy and agree to its terms.

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