At GiroWebMedia, we take your privacy seriously. We are committed to providing you with a great service, but in an environment where your privacy is protected.

We are well aware that privacy, confidentiality and security are major concerns for many Web and e-mail users. Through our privacy policy, you will be able to see the circumstances in which we collect, use and disclose your personal information.

You may wish to check back to this site from time to time, as we will update our policy in response to emerging privacy issues. If you have any suggestions or concerns that are not addressed in this statement, please contact us at: privacy@girowebmedia.com

WHAT IS PERSONAL INFORMATION?
According to Section 6 of the Privacy Act 1988, “personal information”: “means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion”.

Thus, the kind of personal information which may be held by GiroWebMedia may include your:

• name,
  
• date of birth,
  
• address/es,
  
• phone numbers,
  
• e-mail address,
  
• bank account/credit card details
  
• GiroWebMedia password.

HOW AND WHEN IS MY PERSONAL INFORMATION COLLECTED?
Collection
GiroWebMedia will only collect personal information when it is necessary for the conduct of our business, including the provision of services and products to you.

We will not solicit or collect information by unlawful, unfair or unreasonably intrusive means, and will not solicit or collect any information that is unnecessary or unrelated to our business.

GiroWebMedia may collect your personal information in a number of ways, including:

• directly from you, when you provide information by phone, e-mail or in documents such as an on-line application form;
  
• from third parties such your representatives;
  
• from publicly available sources of information;
  
• from our contractors and/or other communications carriers to enable the provision of our services; and
  when legally required to do so.
  
• The most likely way we will collect your information is because you have given it to us. Indeed, we would prefer to collect your personal information, only from you.

When we collect information about you from another source, we will take reasonable steps to ensure you are informed as to why we are collecting the information, the purpose for its collection, that you can access the information and the consequences for you if the information is not provided.
Our site does not have the functionality of allowing third parties to perform ‘reverse searches’ to identify individuals from e-mail addresses.

When You Browse Our Web site
When you look at our Web site, our logging systems will record that your computer has visited our site and will automatically log the following information:

• your server address
  
• your top level domain name (for example .com, .gov, .au, .uk etc)
  
• the date and time of your visit to the site
  
• the pages you accessed and documents downloaded
  
• the previous site you visited
  
• the type of browser you are using.
  
• Importantly, this kind of information does not actually identify who you are.

We will not attempt to identify users or their browsing activities. However, in the unlikely event of an investigation, a law enforcement agency or other government agency may exercise its legal authority to inspect our logs.

Cookies
Cookies can be either "persistent" or "session" based. Persistent cookies are stored on your computer, contain an expiration date, and may be used to track your browsing behaviour upon return to the issuing Web site. Conversely, session cookies are short-lived, are used only during a browsing session, and expire when you quit your browser

This Web site mainly uses session cookies and only during a search query of the Web site. Upon closing your browser the session cookie set by this Web site is destroyed and no personal information is maintained which may identify you should you visit our Web site at a later date.

The only time we will set a persistent cookie, is with your explicit consent – and even then, only for your convenience by helping you remember information such as your own access code or password. In such cases, you will be asked “do wish to save your password for future use?” If you say “no”, a persistent cookie will not be stored on your computer – a persistent cookie cannot be stored on your computer by GiroWebMedia without agreeing to it. If you say “yes” such a cookie will be stored on your computer, but only for the purpose for which you consented – we will not use it in any other way.

On-line forms
Our on-line forms provide you with an easy way to contact us and order our products/services. However, the forms require you to submit certain personal information so that we can provide you with the service/product requested or contact you to answer your query.

Should you use our Web forms to contact us, you will be advised before submitting the form of:

• The purpose for which the information is being collected;
  
• The circumstances under which we will disclose that information to another body (basically when compelled by law);
  
• The risks of transmitting information across the interest, notwithstanding that we provide facilities for secure transmission; and
  
• The option to contact us by telephone if you wish to avoid the risks, all be they minimal, of transmitting data via the Net.

Anonymity
Wherever it is lawful and practicable, individuals will have the option of not identifying themselves when entering transactions with a GiroWebMedia. However, we will not be able to supply you with services or products unless you disclose certain personal information such as your name and billing details.

WHEN WOULD YOU USE OR DISCLOSE MY INFORMATION, AND TO WHOM?
Use and Disclosure
GiroWebMedia will only use your information for the purposes it was provided. This would include:

• providing the services or products you have requested;
  
• for purposes related to providing you with the service or product you have requested;
  
• for charging, billing and collecting debts in relation to the services or products you have requested;
  
• informing you of ways the services provided to you could be improved; and
  
• maintaining and developing our business systems and infrastructure, including testing and upgrading of these systems;

We will only use and disclose your information for other purposes where:

• you consent to the use or disclosure;
  
• your representatives (eg your authorised representatives or legal advisers) direct or authorise us to do so;
  
• it is necessary to lessen or prevent a threat to life, health or safety;
  
• we have been directed to do so by law enforcement agencies; and
  
• it is required or authorised by or under law.

Importantly, your contact details will not be added to a mailing list or used for any other purpose without your consent.

Disclose to whom?
The range of entities to which we could disclose your information includes:

• out sourced service providers who manage the services we provide to you including communications carriers, billing and debt recovery functions;
  
• our professional advisers, including our accountants, auditors and lawyers;
  
• government and regulatory authorities and other organisations, as required or authorised by law;
  
• organisations involved in:
  
• a transfer/sale of all or part of our assets or business (including accounts and trade receivables) - if at some time in the future we sell all or part of our business;
  
• managing our corporate risk and funding functions;
  
• other telecommunication and information service providers.

Disclosure overseas - Transborder data flows
It is highly unlikely that GiroWebMedia would be required to transfer personal data outside Australia. The only such cases would be where we were required to do so by Law.

WHAT ABOUT THE ACCURACY OF MY RECORDS?
GiroWebMedia will take reasonable steps to ensure that your personal information we collect is accurate, complete and up-to-date.

As our most likely source of your personal information is you, it is important that you check for any mistakes or typographical errors when you send us any records/correspondence containing your personal information. Similarly, it would be wise if you checked your details in our company communications to you such as account invoices.

It is also your responsibility to ensure that your personal information is up to date by notifying us of any changes to the details we hold about you.

CAN I ACCESS MY OWN RECORDS? WHAT ABOUT CORRECTIONS?
Access
GiroWebMedia welcomes any client to request access to their own records and we will provide access in a form suitable to the individual's reasonable needs. However, we are not obliged to give a person access where:

• It would pose a serious and imminent threat to the life or health of any individual;
• It would have an unreasonable impact upon the privacy of other individuals;
• the request is frivolous or vexatious;
• the information relates to an existing legal dispute between GiroWebMedia and the individual, and the information would not be accessible by the process of discovery;
• it would reveal the intentions of GiroWebMedia in relation to negotiations with the individual in such a way as to prejudice those negotiations;
• it would be unlawful;
• denying access is specifically authorised by law;
• it would be likely to prejudice an investigation of possible unlawful activity;
• it would be likely to prejudice law enforcement processes or legal proceedings; and
• we are directed not to provide access by a body such as ASIO or ASIS.
  If you wish to request access to your personal information, please contact us at privacy@girowebmedia.com

Correction
If an individual is able to establish that the information held by GiroWebMedia is not accurate, complete and up-to-date, GiroWebMedia will take reasonable steps to correct the information.

However, if the individual and GiroWebMedia disagree about whether the information is accurate, complete and up-to-date, the individual may ask GiroWebMedia to include a notation on the relevant record that the individual believes that the information is not accurate, complete or up-to-date.

WILL YOU USE AN IDENTIFIER I HAVE BEEN ASSIGNED?
In short, no. It is most unlikely that we would even have cause to see a person's identifier.
An identifier includes a number assigned by an organisation to an individual to identify uniquely the individual for the purposes of the organisation's operations - for example, a Medicare number. However, an individual's name or ABN (as defined in the A New Tax System (Australian Business Number) Act 1999) is not an identifier.

GiroWebMedia will not adopt an identifier that has been assigned by a government agency to an individual.

Further, we will not use or disclose an identifier assigned to an individual by a government agency except where it is required by law or necessary to protect the person. Again, it would be most unlikely that we would even be privy to a person's identifier.

WILL YOU COLLECT SENSITIVE INFORMATION SUCH AS MY RACE OR ETHNICITY?
It is most unlikely that GiroWebMedia would be in a position to even see sensitive information about an individual, let alone collect it. If we did so, it would most probably be because you supplied it to us.

Sensitive information includes information or an opinion about an individual's: racial or ethnic origin; political opinions; membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual preferences or practices; criminal record; or, health information.

It is difficult to conceive of circumstances where this kind of information would be disclosed to GiroWebMedia. Thus, we would only collect this kind of information if:

• You disclose it to us;
• You consent;
• It is required or specifically authorised by law;
• It is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual; and
• It is necessary for the establishment, exercise or defence of a legal claim.
  

THIRD PARTY SITES
It will be common for Web users to click-through from our site to third party sites. We are unable to comment on or attest to the privacy commitment of any third-parties. Further, we do not assume any responsibility for the information and content of third party sites.
Instead, you should look at the privacy statement of each site you visit.

This privacy policy only applies to the Web sites of GiroWebMedia.

WHAT ABOUT PRIVACY AND MY CHILDREN?
Ultimately, the only person who can police a child's Web browsing is the adult who is in the vicinity at the time. If you are concerned about stopping your child's access to certain kinds of sites, then we recommended you use an application such as "Net Nanny" or "Net Bobby". We do not endorse these products, rather, we simply list them as examples of the kind of net protectors publicly available.
Separately, we ask that children under the age of 18 have a parent or guardian verify their registration on Web sites and the submission of on-line forms. Whilst we will make every reasonable effort to ensure that children's privacy and other rights are not compromised, it is ultimately the responsibility of parents or guardians to monitor their children's Internet usage.

We would also recommend that children always ask a parent/guardian for permission before sending any transmission over the Internet.

WHAT ELSE CAN I DO TO ENHANCE MY PRIVACY WHEN USING THE INTERNET?
Always close your browser when you have finished your session, so others cannot access your personal information and correspondence.

Be careful whenever you voluntarily disclose personal information over the Internet (for example: in discussion forums, via e-mail or in chat sites), as this information can be collected and used by others. Consequently, if you post personal information online in publicly accessible areas, you may receive unsolicited messages from other parties in return.

Ultimately, you are solely responsible for maintaining the secrecy of your username and passwords and/or any account information.
Please be careful and responsible whenever you are using the Internet.

COMPLAINTS
If you consider that we have breached your privacy, please contact us at privacy@girowebmedia.com
If you consider that we have not resolved the issue, you may refer the matter to the Commonwealth Privacy Commissioner's Office.

HOW SECURE IS MY INFORMATION?
Overview
Your personal information will be stored electronically and/or in hardcopy format.
GiroWebMedia takes all reasonable steps to protect your information against unauthorised access, alteration, destruction, use or disclosure and against accidental loss.

Electronic storage
Our internal networks and databases are sufficiently protected from unauthorised access from any Web site or Internet connection by firewalls and encryption. Even so, you are still warned that a sophisticated hacker may still be able to break into even the most secure of sites.

On-line transmission
Should you use our Web forms to contact us, you will be advised before submitting the form of:

• The purpose for which the information is being collected;
• The circumstances under which we will disclose that information to another body (basically when compelled by law;
• The risks of transmitting information across the Internet, notwithstanding our secure transmission facilities; and
• The option to contact us by telephone if you wish to avoid the risks, albeit they minimal, of transmitting data via the net.

Hard copy records
Any information stored in hard copy format is kept in a secure facility, which can only be accessed by relevant GiroWebMedia staff.

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