Buchanan Group Privacy Policy

EXHIBIT B
Website Privacy Policy
http://www.brandpower.com/privacy.asp

Buchanan Group Privacy Policy

Buchanan Advertising (Australia) Pty. Ltd.ACN 155 718 942 and the other companies and organizations which make up Buchanan Group are committed to protecting the privacy of your personal information.  This Privacy Policy explains how Buchanan Group manages the personal information that we collect, use and disclose and how to contact us if you have any further queries about our management of your personal information.  This Privacy Policy does not cover personal information collected or held by Buchanan Group about its employees.

Buchanan Group knows that users’ personal information is important to them; Buchanan Group respects that importance and treats that information responsibly. Buchanan Group has created the below policy to explain the types of information it collects from users, how it uses this information, with whom and for what purposes it shares the information, and how users can interact with Buchanan Group in connection with the information collection and use.

What is personal information?
Personal information is information or an opinion, in any form and whether true or not, about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion.  Examples include an individual's name, address, contact number and email address.   
Special provisions apply to the collection of personal information which is sensitive information.   This includes health information and information about a persons' race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual preferences and criminal history.    

Collection of personal information by Buchanan Group

  • Buchanan Group will not collect personal information about you unless that information is necessary for one or more of our functions or activities. 
  • Buchanan Group will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner.
  • When Buchanan Group collects personal information directly from you, we will take reasonable steps at or before the time of collection to ensure that you are aware of certain key matters, such as the purposes for which we are collecting the information, the organizations (or types of organizations) to which we would normally disclose information of that kind, the fact that you are able to access the information and how to contact us (for example, where personal information is collected on a form, we will generally include a written privacy statement on the form which sets out these details).
  • Buchanan Group will collect your personal information directly from you where it is reasonable and practicable to do so.  Where Buchanan Group collects information about you from a third party, we will still take reasonable steps to ensure that you are made aware of the details set out above.

Use and disclosure of personal information by Buchanan Group
If Buchanan Group uses or discloses your personal information for a purpose (secondary purpose) other the main reason for which it was originally collected (primary purpose), to the extent required by the law, we will ensure that:

  • The secondary purpose is related to the primary purpose of collection (and directly related in the case of sensitive information), and you would reasonably expect that Buchanan Group would use or disclose your information in that way;
  • You have consented to the use or disclosure of your personal information for the secondary purpose;
  • The use or disclosure is required or authorized by or under law; or
  • The use or disclosure is otherwise permitted by the Law (for example, as a necessary part of an investigation of suspected unlawful activity).

How might we contact you?
We may contact you in a variety of ways, including by post, email, SMS, telephone call or facsimile.

Email Marketing
We will not send you any commercial electronic messages such as SMSs or emails unless this is permitted by law (for example, if we have your express consent to do so).  Any commercial electronic message that we send will identify Buchanan Group as the sender and will include our contact details.  The message will also provide an unsubscribe facility.  If you do not wish to receive commercial electronic messages from us, please let us know (our contact details are provided at the end of this policy). 

Do Not Call Register
We will not call you on a number listed on the Do Not Call Register unless this is permitted under the Do Not Call Register Act and related instruments (for example, if we have your express consent to do so).  If you do not wish us to call you on a particular number, please let us know (our contact details are provided at the end of this policy).

Data quality and security
To the extent required by the Law, Buchanan Group will take reasonable steps to:

  • Make sure that the personal information that we collect, use and disclose is accurate, complete and up to date;
  • Protect the personal information that we hold from misuse and loss and from unauthorized access, modification or disclosure; and
  • Destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the Law.

Anonymity
Buchanan Group will generally provide individuals with the option of not identifying themselves when entering into transactions when it is lawful and practicable to do so. 

Use of government identifiers
Buchanan Group will not use government identifiers (Identifiers) (such as Medicare numbers) as its own identifier of individuals.  We will only use or disclose Identifiers in the circumstances permitted by the Law.

Transfer of personal information overseas
If Buchanan Group transfers your personal information outside Australia, we will comply with requirements of the Law that relate to transborder data flows.

Access and correction of your personal information
Please contact Buchanan Group if you would like to access or correct the personal information that we hold about you.  Buchanan Group will generally provide you with access to your personal information (although a fee may be imposed), and will take reasonable steps to amend any personal information that is incorrect.  In some circumstances, Buchanan Group may not permit access to your personal information, or may refuse to correct your personal information, in which case we will provide you with reasons for this decision.

Further information
Please contact us if you have any queries about the personal information that Buchanan Group holds about you or the way we handle that personal information.  Our contact details for privacy queries are set out below.

Privacy Officer
Buchanan Advertising (Australia) Pty Ltd
210 Lorimer Street
Port Melbourne VIC 3207
Australia
Email: privacy@buchanangroup.com
Phone: +61 3 9644 0000
Fax: + 61 3 9644 0011

Complaints
Please contact the Buchanan Group Privacy Officer using the above details if you have any concerns or complaints about the manner in which your personal information has been collected or handled by Buchanan Group.

Chidlren
Buchanan Group does not knowingly collect or retain information in connection with the Site from children under the age of 13. Buchanan Group does not ask children under age 13 for personal information.

 

Updated January 2012.


buchanangroup.com Website Privacy Statement

Buchanan Advertising (Australia) Pty. Ltd. ACN 155 718 942 (“BG”) is committed to protecting your privacy. This Privacy Statement explains BG's policies and practices in relation to the handling of personal information that may be collected through this website (buchanangroup.com).

This Privacy Statement does not apply to personal information collected by BG elsewhere.  For information about how BG manages personal information generally, see the <Buchanan Group Privacy Policy> above.

The terms of this Privacy Statement are subject to any specific provisions dealing with privacy that may be contained in the terms and conditions for particular offers, products and services made available through this website. 

1. What personal information does BG collect?
The following types of Information about a user are among those that may be collected by BG in connection with the Site:

  • Name
  • Postal address
  • E-mail address
  • Telephone number
  • Date of birth
  • IP Address
  • Referring site
  • Other technical information collected by the Site’s servers

The type of personal information we collect about you will depend on how you use this website.  For example, personal information is collected when you:

  • register on this website to become a member of the BG community (Member);
  • post a comment in one of our forums;
  • submit an article, video or product review to be uploaded to this website;
  • send a message to another Member using the direct messaging function;
  • respond to one of our product surveys;
  • enter a competition or participate in a promotion; or
  • register or subscribe for, or contribute content to, any other services available through this website from time to time.

We may also keep records of any other interactions you have with us (for example, emails or other correspondence you send via this website), together with any other information that you choose to provide to us.

In some circumstances, we may collect sensitive information about you (for example, if you post a comment in a forum about your health).  We will not do this unless you have consented to the collection, or if we are otherwise required or authorized to do so by or under law. Sensitive information includes (for example) health information and information about a person's racial or ethnic origin, political opinions, religious beliefs, professional or trade association membership, sexual preferences and criminal record.

If you do not provide us with the personal information that we request, we may not be able to provide you with some of our products and services (except in cases where we have indicated that the provision of that information is optional). For example, if you do not register as a Member, you will not be able to access pages of this website or other services that are reserved for Members only.

Providing us with personal information about others
If, at any time, you provide personal information about another person, you warrant that you have made that person aware of this Privacy Statement and the Terms of Use and that you have obtained that person’s consent to provide their personal information to us for the purpose specified.

2. How do we collect personal information?
We will generally collect personal information directly from you, through this website.  We may also collect personal information:

  • from you over the telephone, or through written correspondence (such as letters and emails);
  • through the maintenance and analysis of Web server logs; and
  • about you from other Members (in which case, in accordance with the <Terms of Use> and this Privacy Statement, the other Member must first obtain your consent).

Collection of information other than personal information
Some of the information that is collected about your visit to this website is not personal information, because it does not reveal your identity.  For example, we may record your server address, the date and time of your visit, the pages you viewed, any documents you downloaded and the type of browser and operating system you used.

If collected, this information will be used and disclosed by BG in anonymous, aggregated form only, for purposes including statistical analysis and web site development. You are not individually identified, however BG reserves its right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorized by law to do so.

Cookies
A cookie is a small string of information that a website transfers to your browser for identification purposes. BG may use cookies to gather information about your visits to our website and enhance your experience.  The cookies used by BG do not identify individual users, although they do identify the user's internet browser.  We may use cookies to maintain session information about you when you log into our website and that information helps us to understand your preferences and improve your website experience.

We may also allow third parties that publish advertisements on our website to place and access cookies on your computer and use the information from those cookies to tailor the advertisements that you see while browsing online with your interests.

Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used.  There are also software products available that can manage cookies for you.  If you disable cookies, we may be not be able to optimize your visit to this website and certain features may not be available.

The cookies may be used to track site trends and enhance the user experience, and may be shared with third parties. BG may share information to respond to subpoenas, court order, or legal process, or to establish or exercise it legal rights or defend against legal claims. We will transfer Information about you if BG is acquired by or merged with another company.

To the extent third parties may place advertising or other content on the Site, such third parties may utilize cookies or other technological means within the advertising to collect and utilize non-personally identifiable information. BG is not responsible for information collected by third parties in this manner, nor for the collection or use of Information by other sites to which the Site is linked.

3. Why does BG collect personal information?
BG uses the personal information it collects through this website for the purposes for which it was provided and for any other purposes explained at the time of collection or in any additional terms and conditions applicable to the particular feature of the website, including:

    • to operate this website, including through the publication of forums, articles, videos and reviews;
    • to conduct competitions and promotions;
    • to provide customer support for Members;
    • to respond to questions and requests;
    • to tailor the advertising that is presented to you on this website and the product and service information that we may send you (see below), for example, by providing you with product information relevant to the preferences or opinions that you
    • have expressed in your responses to our surveys;
    • to conduct research and development;
    • to investigate any complaints made by or about you, or if we have reason to suspect that you are in breach of our <Terms of Use> or have been engaged in any unlawful activity; and
    • for other purposes required or authorized by or under law, including purposes for which you have provided your express or implied consent.

Public Material posted by Members
Some of the services offered through this website allow Members to submit, upload, post or transmit content or material such as text, photos, images, audio and video (including links to content or material) that may be accessed and viewed by the general public on the internet (Public Material). Members acknowledge that anything they post onto this website may appear elsewhere on the internet and may remain on the internet after their membership has ended, and accept that BG cannot guarantee that the Public Material will not appear elsewhere, be copied, downloaded or used otherwise. If Members have any concerns about their personal information being published in this way, they are advised to remove any personal information from the Public Material they post, or not to use these services.

As indicated in the < Terms of Use >, we may use Public Material for any promotional purposes of BG and its clients. This may include using Public Material which may include personal information (for example, reproducing in promotional materials testimonials which include either your personal information or a user name which identifies you), unless you opt out of this in your member profile page.

Product and service offers
If you are a Member, we may (unless you opt out of receiving any or all of these communications in your member profile page) use your personal information to:

    • send you news, product information and promotional offers from BG and selected third party businesses whose products or services we think may be of interest to you (Promotional Partners);
    • invite you to participate in product surveys and promotions; and
    • send you product samples and ask for your feedback.

We may send this information to you in a number of ways, including by post, email, SMS and MMS.  You can let us know at any time if you no longer wish to receive these communications by updating the relevant details in your member profile page. When sending product and service offers to you, we will also let you know how you may opt out of receiving such communications in future.  Your consent to receiving these communications will remain current until you advise us otherwise.

We will not send you any commercial electronic messages such as SMSes or emails unless this is permitted by the Spam Act.  Similarly, we will not call you on a number listed on the Do Not Call Register unless this is permitted under the Do Not Call Register Act and related instruments. 

At any time, a user may opt out from receiving future offers from BG by following the instructions contained within each marketing communication or by sending an e-mail message to members@brandpower.com. Such opting out will not apply to any communications from third parties to whom BG may have provided Information regarding the user. Third parties’ use of the information is subject to such parties’ own privacy policies, for which BG shall not be responsible.

4. When do we disclose personal information to third parties?
We may disclose your personal information:

    • for the purpose for which that personal information was collected; and
    • for the purposes set out under heading 3 above.

Personal information may be disclosed (and may be transferred overseas) for these purposes to:

    • the general public (both in Australia and overseas), by publication of this website on the internet;
    • companies and organizations within BG's group of companies;
    • to our Promotional Partners (for example, to enable them to send product samples or material requested by Members on this website directly to those Members);
    • BG's contracted service providers, which may include:
      • website development, information technology and security providers;
      • database management and data processing analysts;
      • creative, promotional and market research agencies;
      • mailing houses, freight and courier service providers; and
      • external business advisors (such as accountants, auditors, recruiters and lawyers).

The third parties identified above may provide us with personal information they have collected from you, for the purposes set out in this Privacy Statement. Any personal information collected from third parties will be used and disclosed in accordance with this Privacy Statement.

Disclosure of information other than personal information
Some of the information that we disclose to third parties is not personal information, although it may have been compiled (in part) from information that you have provided to us.  For example:

    • if you have participated in one of our product surveys, we may disclose the results of that survey to our Promotional Partners, but only in aggregated, anonymised form, which does not reveal the identity of particular respondents; 

5. Links to third party websites
Links to other websites are provided for your convenience. We are not responsible for the privacy practices of those sites, and you should review their privacy policies before supplying any personal information to them.

6. Quality and security of personal information
We rely on the personal information we hold in conducting our business. We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete and up to date.  You can help us, by letting us know about any changes to your personal information, such as email address or phone number.  Our contact details are provided under heading 8 below.

Website security
With the exception of personal information contained in Public Material, BG strives to protect the personal information and privacy of website users.  However, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact BG by telephone or post (our details are provided under heading 8 below). 

You can also help to protect the privacy of your personal information by keeping passwords secret and by ensuring that you log out of the site when you have finished using it.  In addition, if you suspect any security breach, please let us know immediately. If you register to become a member of the Site, you are responsible for maintaining the confidentiality of your member identification and password information, and for restricting access to your computer. You agree to accept responsibility for all activities that occur under your member identification and password

8. Access and correction
Please contact us if you would like to access or correct the personal information that we hold about you. We will generally provide access or make corrections, subject to some exceptions permitted by law.

9. Questions and Suggestions
If you have any questions about your privacy, or if you would like to access or correct the personal information that we hold about you, please call us on + 61 3 9644 0000.  Alternatively, you can email us at privacy@buchanangroup.com or contact us by post at the following address:

Privacy Officer
Buchanan Advertising (Australia) Pty Ltd
210 Lorimer Street
Port Melbourne VIC 3207
Australia

10. Your California Privacy Rights
Beginning on January 1, 2005, California Civil Code Section 1798.83 permits customers of Buchanan Group who are California residents to request certain information regarding Buchanan Group’s disclosure of personal information to third parties for such third parties’ direct marketing purposes. To make such a request, please write to privacy@buchanangroup.com.

11. Changes to this Privacy Statement
Buchanan Group reserves the right to revise and update this Privacy Policy at any time. Any such revisions will be effective on the date of posting to the Site, and will apply to all information collected by Buchanan Group both prior to and following the effective date. Your use of the Site following any such revisions will be deemed your acceptance of such revisions. Users should periodically visit this page to review the current policies with regard to Information

Updated September 2013.

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