Bullet Creative Pty Ltd (ABN 98 078 880 074) and its Related Bodies Corporate (Bullet)
- how and when we collect personal information;
- how we use and disclose personal information;
- how we keep personal information secure, accurate and up-to-date;
- how an individual can access and correct their personal information; and
- how we will facilitate or resolve a privacy complaint.
If you have any concerns or complaints about the manner in which your personal information has been collected, used or disclosed by us, we have put in place an effective mechanism and procedure for you to contact us so that we can attempt to resolve the issue or complaint. Please see Section 11 for further details.
If you have any concerns or questions, please contact us and our privacy officer at firstname.lastname@example.org or write to us at 223 Liverpool St, Darlinghurst NSW 2010 or 7703/55 Forbes St, West End, QLD 4101 and our privacy officer will then attempt to resolve the issue.
We recommend that you keep this information for future reference.
1. What is personal information?
The Privacy Act 1988 (Cth) defines “personal information” to mean any 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 or opinion is recorded in a material form or not.
2. The kinds of personal information collected, used and disclosed
We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to by you. At or around the time we collect personal information from you, we will endeavour to provide you with a notice which details how we will use and disclose that specific information. We set out some common collection, use and disclosure instances in the table below.
3. How Bullet collects and holds personal information
3.1 Collection generally
When you engage in certain activities, such as filling out a survey or sending us feedback, we may ask you to provide certain information. It is completely optional for you to engage in these activities.
Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory information or any other information we require in order for us to provide our products or services to you, we may be unable to provide our products or services to you in an effective manner, or at all.
3.2 Other collection types
We may also collect personal information about you from other sources, such as competitions and also from third parties. Some examples of these alternative collection events are:
(a) when we collect personal information about you from third parties; or
(b) when we collect personal information about you from publically available sources including but not limited to, court judgments, directorship and bankruptcy searches, Australia Post, White Pages directory, and social media platforms (such as Facebook, Twitter, Google, Instagram etc).
3.3 Notification of collection
If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply, including as described in this clause 3.3(a) to 3.3(c) below. Generally speaking, we will not tell you when we collect personal information about you in the following circumstances:
(a) where information is collected from any personal referee you have listed on any application form (including any employment application) with Bullet;
(b) where information is collected from publicly available sources including but not limited to court judgments, directorship and bankruptcy searches, social media platforms (such as Facebook, Twitter, Google, Instagram etc); or
(c) as otherwise required or authorized by law.
3.4 Unsolicited personal information
In the event we collect personal information from you, or a third party, in circumstances where we have not requested or solicited that information (known as unsolicited information), and it is determined by Bullet (in its absolute discretion) that the personal information is not required, we will destroy the information or ensure that the information is de-identified.
In the event that the unsolicited personal information collected is in relation to potential future employment with Bullet, such as your CV, resume or candidacy related information, and it is determined by Bullet (in its absolute discretion) that it may consider you for potential future employment, Bullet may keep the personal information on its human resource records.
3.5 How we hold your personal information
Once we collect your personal information, we will either hold it securely and store it on infrastructure owned or controlled by us or with a third party service provider who have taken reasonable steps to ensure they comply with the Privacy Act 1988 (Cth). We provide some more general information on our security measures in Section 9 (Data security and quality).
3.6 Cookies and IP addresses
If you use our website, we may utilise “cookies” which enable us to monitor traffic patterns, trends and to serve you more efficiently if you revisit our website. In most cases, a cookie does not identify you personally but may identify your internet service provider or computer.
We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.
You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. However, if you disable cookies, you may not be able to access certain areas of our websites or take advantage of the improved web site experience that cookies offer.
4. Uses and discloses of personal information
4.1 Use and disclose details
We provide a detailed list at Section 2 of some common uses and disclosures we make regarding the personal information we collect.
4.2 Other uses and disclosures
We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:
(a) when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose;
(b) if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
(c) if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
(d) if it is required or authorised by law.
4.3 Use and disclosure procedures
4.4 Communications opt-out
5. Sensitive information
5.1 Sensitive information generally
Sensitive information is a subset of personal information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
5.2 Collection and use of sensitive information
In general, we attempt to limit the collection of sensitive information we may collect from you, but depending on the uses you make of our products this may not always be possible and we may collect sensitive information from you in order to carry out the services provided to you. However, we do not collect sensitive information from you without your consent.
The type of sensitive information we may collect about you is dependent on the services provided to you by Bullet will be limited to the purpose(s) for which it is collected. We set out some types of sensitive information we may collect about you in the “Human resources” section of the table at Section 2 above.
We do not use sensitive information to send you Direct Marketing Communications (as set out in Section 6 below) without your express consent.
We may collect other types of sensitive information where you have consented and agree to the collection of such information. Generally speaking, we will obtain this type of consent from you at (or around) the point in time in which we collect the information.
6. Direct Marketing
6.1 Express informed consent
You give your express and informed consent to us using your personal information set out in:
(a) the “Enquiries and providing services” section of the table at Section 2 of this document above; and
(b) the “Marketing Services” section of the table at Section 2 of this document above;
to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications).
6.2 Inferred consent and reasonable expectations of direct marketing
Without limitation to paragraph 6.1, if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.
If at any time you do not wish to receive any further Direct Marketing Communications from us or others under this Section 6, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the Direct Marketing Communication or by contacting us via the details set out at the top of this document.
7. Anonymity and pseudo-anonymity
Due to the personal nature of the services that we provide, it is only practicable or reasonable for Bullet to transact and correspond with you on a named basis and your personal information may be required in order to provide you with our products and services or to resolve any issue you may have.
8. Cross Border Disclosure
8.1 Cross border disclosures
Any personal information collected and held by Bullet is not disclosed to, or held at, a destination outside of Australia. However, we use third party service providers to assist us with providing our goods and services to you. Those providers may disclose, hold or process your personal information at, a destination outside Australia, including but not limited to United States, Netherlands and the United Kingdom.
As we use service providers and platforms which can be accessed from various countries via an Internet connection, it is not always practicable to know where your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed above.
In addition we may utilise overseas IT services (including software, platforms and infrastructure), such as data storage facilities or other IT infrastructure. In such cases, we may own or control such overseas infrastructure or we may have entered into contractual arrangements with third party service providers to assist Bullet with providing our products and services to you.
8.2 Provision of informed consent
8.3 If you do not consent
If you do not agree to the disclosure of your personal information outside Australia by Bullet, you should (after being informed of the cross border disclosure) tell Bullet that you do not consent. To do this, either elect not to submit the personal information to Bullet after being reasonably informed in a collection notification or please contact us via the details set out at the top of this document.
9. Data security and quality
9.1 Bullet’s security generally
We have taken steps to help secure and protect your personal information from unauthorised access, use, disclosure, alteration, or destruction. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information, especially where human error is involved or malicious activity by a third party.
Notwithstanding the above, we will take reasonable steps to:
(a) make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
(b) protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods;
(c) store your personal information on a secure server; and
(d) destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.
The accuracy of personal information depends largely on the information you provide to us, so we recommend that you:
(a) let us know if there are any errors in your personal information; and
(b) keep us up-to-date with changes to your personal information (such as your name or address).
We provide information about how you can access and correct your information in Section 10.
10. Access to and correction of your personal information
You are entitled to have access to any personal information relating to you which we hold, except in some exceptional circumstances provided by law (including the Privacy Act 1988 (Cth)). You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.
If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out at the top of this document.
11. Resolving Privacy Complaints
11.1 Complaints generally
We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.
11.2 Contacting Bullet regarding complaints
If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information, please contact us:
Telephone: 02 9357 4888 or 07 3846 0328
Address: 223 Liverpool St, Darlinghurst NSW 2010 or 7703/55 Forbes St, West End, QLD 4101
Please mark your correspondence to the attention of the Privacy Officer.
11.3 Steps we take to resolve a complaint
In order to resolve a complaint, we:
(a) will liaise with you to identify and define the nature and cause of the complaint;
(b) may request that you provide the details of the complaint in writing;
(c) will keep you informed of the likely time within which we will respond to your complaint; and
(d) will inform you of the legislative basis (if any) of our decision in resolving such complaint.
11.4 Register of complaints
We will keep a record of the complaint and any action taken in a Register of Complaints.
12. Consent, modifications and updates
12.1 Interaction of this Policy with contracts
(a) certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not give rise to contractual obligations onto Bullet, but do create contractual obligations on the other party to the contract; and
(b) the consents provided in this policy become contractual terms provided by the other party to the contract.
12.3 Modifications and updates