Privacy policy

This Privacy Policy has been published to provide a clear and concise outline of how and when personal information is collected, disclosed, used, stored and otherwise handled by Ember Hot Tubs (“Ember”).

Ember abides by the Privacy and Data Protection Act 2014 (Vic), in relation to disclosure, use and storage of personal information.

 

1. COLLECTION OF PERSONAL INFORMATION

Personal information is information or details provided by an individual’s identity. The nature of personal information collected by Ember generally but not exclusively comprises an individual’s name and contact details (including address, phone, fax and email). Such personal information is collected for the purposes of arranging, conducting and promoting the Ember business.

Ember also collects other types of personal information from time to time (e.g. credit card information and drivers licence details), and will inform you upon collecting such information the purpose for which it is being collected.

Ember will destroy personal information when it is no longer required or if requested to do so.

Ember will generally collect personal information from the individual directly. For example, Ember may collect personal information via telephone or letter, or when the individual attends our business location.

 

2. USE & DISCLOSURE OF PERSONAL INFORMATION

Ember will use and disclose your personal information for which the personal information was initially collected.

Ember may also use that personal information for a purpose related to the initial purpose of collection if that other purpose would be within your reasonable expectations. Related purposes might include for example consumer research, cross promotions and such, adding your name to a contact list, guest list or invitation list which may be of benefit or interest to you.

Ember will not use or disclose your personal information for any other purposes without first obtaining your express or implied consent. Ember may however be required to disclose your personal information without your consent if the disclosure is:

1. required or authorised by law;
2. required in order to investigate an unlawful activity;
3. required by an enforcement body for investigative activities; or
4. necessary to prevent a serious and imminent threat to a person’s life, health or safety, or to public health or safety.

Generally, Ember will retain your personal information within Australia and not use or disclose it overseas.

As like most business organisations, Ember relies on third party suppliers who are contracted to conduct specialised activities such as finance transactions, marketing, research, and such. While personal information may be provided to these suppliers in order to enable them to perform the agreed tasks, Ember will make every effort to ensure that the supplier handles the personal information in accordance with the Privacy and Data Protection Act 2014 and confidentiality principles. Ember will require all such suppliers to provide privacy undertakings and enter confidentiality agreements.

 

3. DIRECT MARKETING

From time to time Ember may use your personal information to identify retail offerings or special events which may be of interest to the individual available through Ember or its business partners.

If you do not wish to receive direct marketing information, please let Ember know. Ember will take immediate steps to ensure that you do not receive any direct marketing information in future.

 

4. PERSONAL INFORMATION QUALITY

Ember’s objective is to ensure that all personal information collected by Ember is accurate, complete and up-to-date. To assist Ember in achieving its objective, please contact us if any of your details change. Further, if you believe that the information Ember holds is not accurate, complete or up-to-date, please contact Ember in order to have the information corrected.

 

5. PERSONAL INFORMATION SECURITY

Ember is committed to keeping your personal information secure, and we will take all reasonable precautions to protect your personal information from unauthorised access, loss, misuse or alteration.

Your personal information may be stored in hard copy documents, or electronically on Ember’s software or systems.

Ember maintains physical security over its paper and electronic data stores, such as locks and security systems. Ember also maintains computer and network security using passwords to control and restrict access to authorised staff for approved purposes. Where information is particularly sensitive, the information is overwritten and then manually deleted.

 

6. ACCESS TO PERSONAL INFORMATION

You may request access to the personal information Ember holds about you.

The procedure for gaining access is as follows:

1. All requests for access to your personal information must be made by email
2. You must provide as much detail as possible regarding the business entity, department or person to whom you believe your personal information has been provided, and when. This will allow Ember to process your request faster.
3. Ember will acknowledge your request within 14 days, and access will usually be granted within 14 days, or if it is more complicated, 30 days. Ember will inform you if this time frame is not achievable.
4. You will be asked to verify your identity.
5. 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.
6. 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.
7. You will be given the opportunity to correct any personal information which is no longer accurate.

In some circumstances, Ember may not be in a position to provide access. Such circumstances include where:

1. access would create a serious threat to safety;
2. providing access will have an unreasonable impact upon the privacy of other individuals;
3. denying access is required or authorised by law;
4. the request is frivolous;
5. legal proceedings are underway;
6. negotiations may be prejudiced by such access;
7. or access would reveal a commercially sensitive decision making process.

If Ember denies access to your personal information, it will provide you with reasons in writing.

 

7. CHANGES TO THIS POLICY

Ember may change this Policy from time to time for any reason and will update the Policy accordingly.

 

8. COMPLAINTS

If you believe that your privacy has been infringed you are entitled to complain. All complaints should initially be in writing and directed to the Marketing Officer Ember Hot Tubs by email. Ember will respond to your complaint as soon as possible, within 14 working days, to let you know who is responsible for managing your query. Ember will try to resolve the complaint within 30 working days. When this is not possible Ember will contact you to provide an estimate of how long it will take to handle the complaint.

If you believe Ember has not adequately dealt with your complaint, you may complain to the Victorian Information Commissioner whose contact details are as follows:

Officer of the Victorian Information Commissioner
PO Box 24274
Melbourne VIC 3001
enquiries@ovic.vic.gov.au