Western Manchester Privacy Policy
1. Your privacy
Western Manchester Pty Ltd (ABN 62 619 330 915) (Western Manchester) is committed to protecting your personal information in accordance with the Australian Privacy Principles (APPs) in the Privacy Act as well as other applicable legislation, such as the Spam Act, the Do Not Call Register Act, and health privacy legislation.
This Privacy Policy is available on the Western Manchester website at www.WesternManchester.com.au, or you can request a copy by contacting our Customer Service Centre. Western Manchester one members are covered by a separate Western Manchester one Privacy Policy, which includes the Western Manchester one App.
2. What we collect and how we collect it
The personal information we collect about you depends on the dealings you have with us. Personal Information includes information about an individual who is reasonably identifiable.
For example, if you:
o make an in-store purchase, we may collect your credit card, identity and transaction details in person and, if you use our delivery service, your name, contact details and delivery address. Certain departments such as intimate apparel or cosmetics etc may collect certain sensitive information about you in order to provide the goods or services
o pre-order goods or services, put goods on hold, use our lay-by service, leave goods for repair or purchase certain electronic devices from us, we may collect your name and contact details
o provide details to join special mailing lists or databases if you’d like to receive information about, for example, certain brands, products or designers, we may collect your name, contact details, date of birth and information about your shopping or product preferences
o attend a store, we may capture images and/or sound recordings of you through CCTV cameras
o make a purchase online or using an electronic device such as an iPad when in-store or when you otherwise set up an online account, we will collect your name, contact details, order details, credit card details, delivery address or store pick up details and we may also ask you to provide your date of birth and gender
o provide information via social media pages or download any Western Manchester Apps such as providing your name or contact details via the Western Manchester Facebook pages, or our Twitter or Instagram accounts or other social media sites or Apps
o attend a Western Manchester function or event, we will collect your name, contact details and any dietary or accessibility requirements
o create a gift registry with us, we will collect your name, contact and event details
o enter a competition or complete a survey, in online or printed format, we may collect your name and contact details along with your merchandise or services preferences and feedback
o send us an enquiry or provide us with feedback through our online form or via our Customer Service Centre, we will collect your name, contact
details, details of your enquiry or feedback and information about our response
o submit a sponsorship application, we will collect the information you include in your proposal
o apply for a job at Western Manchester, we will collect the information you include in your job application, including your and your referee’s contact details
o engage with or purchase products from third parties who deal with Western Manchester, such as Western Manchester one Affiliates, the Western Manchester Market, or through third parties such as those offering Western Manchester-branded insurance or credit card facilities
o purchase shares in Western Manchester Holdings Limited, we, or our share registry operator will collect your name, contact details and other information required to manage the share registry.
You can transact with Western Manchester (eg by paying cash in-store for purchases) and make general enquiries or provide certain feedback anonymously, however in some cases if you don't identify yourself, we may not be able to respond to you or provide you with the product or service you are seeking: eg, you must identify yourself to purchase products online, place items on lay-by or arrange for products to be delivered to you.
xv. Collection of personal information through websites and Apps
Information is automatically collected through your use of the Western Manchester, The Western Manchester Market and Western Manchester one websites, Affiliates’ websites and Apps, through cookies. Cookies are small text files that websites or apps may place on your computer or device. Most often, cookies are used to recognise repeat users of websites and remember user preferences. We may collect this information both anonymously and in relation to user accounts. Cookies are also used to allow the website to track usage behaviour and aggregate data to allow Western Manchester to customise a user's experience on their websites. For example, when you visit the Western Manchester website or use a Western Manchester App, we may use cookies to record information including 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. The information is used and disclosed by Western Manchester for purposes including statistical analysis and to assist Western Manchester to improve the functionality and usability of the website and our Apps. Similarly, when you use Apps from Western Manchester, we may periodically collect and use technical data and related information (including technical information about your mobile device and system preferences), to facilitate the provision of software updates, software support and other services related to the Apps.
xvi. Sensitive information
Western Manchester only collects sensitive information (eg health information) where it is reasonably necessary for our functions or activities and either you have consented, or we are required or authorised by law to do so.
xvii. Collection of personal information by third parties in Western Manchester stores
A number of third parties (eg cosmetics companies), operate within Western Manchester stores and they may collect your personal information (eg when you join their mailing list, or recording your product preferences). Western Manchester is not responsible for the privacy practices of these third parties and this Policy does not apply to them. These businesses should have their own privacy policies, which we encourage you to read before providing your personal information to them. Certain third parties conducting health related services (eg breast screening, weight loss services, or optometry services) may collect sensitive information.
3. Why we collect personal information
. Main purposes
The main purposes for which we collect, hold, use and disclose personal information are:
• processing transactions, in-store and online, and delivering products and services
• to provide any associated loyalty program
• promoting Western Manchester and its products and services, including through direct marketing, events and competitions, public relations and social media
• performing research and statistical analysis, including for customer satisfaction and product and service improvement purposes. This may include matching information we collect against other information held by third parties. (We may also use and disclose de-identified data for these purposes)
• helping us tailor existing or develop new products, services or offers, and to help us selectively target promotional offers and opportunities
• developing or seeking to deliver new ranges of products or services
• protecting the security of our stores, staff, customers, suppliers and merchandise (including theft and fraud prevention)
• answering queries, resolving complaints and responding to social media
• recruiting staff and contractors
• general planning and administration
We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or which are required or authorised by or under law, and for which you have provided consent.
i. Direct marketing and opting out
By providing your address, email address and telephone numbers to Western Manchester, you consent to Western Manchester contacting you for the purposes set out above. We may send this information in a variety of ways, including by mail, email, social media, SMS, MMS, telephone and if you download them any Western Manchester Apps. You can opt out of being contacted by:
• contacting our Privacy Officer by email at privacy@WesternManchester.com.au, by speaking to our Customer Service Centre by phone on 02 9896 4196 or by writing to the Privacy Officer, Western Manchester, 703, 57 Hill Road, Wentworth Point, NSW 2127;
• advising us if you receive a marketing call that you no longer wish to receive these calls; or
• using the unsubscribe facility that we include in our electronic messages (eg email, SMS or MMS) to opt out of receiving those messages.
You can opt out of receiving notifications via any Western Manchester Apps if you turn off Push Notifications in the settings.
ii. Email and mobile communication
If you provide us with an email address or phone number, you consent to electronic communication such as notices or reminders being sent to you via that address or number. You may prefer to provide to us with your personal email address or phone number rather than, for example, an email address accessible by your work colleagues.
4. Who we may share your personal information with
We may share your personal information with third parties where appropriate for the purposes set out above, including:
o Third party sellers in order to fulfil an order placed on The Western Manchester Market
o financial institutions for payment processing
o referees whose details are provided to us by job applicants
o Western Manchester's contracted service providers or partners, including: overseas and local agents, delivery and shipping providers, information technology service providers, venues and event organisers, marketing and communications agencies, research and statistical analysis providers, call centres, hard copy and electronic mail houses, manufacturers and suppliers, external business advisers (such as recruitment advisors, auditors and lawyers), and those third parties who offer Western Manchester-branded products, such as insurance or credit card facilities
o regulatory, investigative or government bodies to comply with laws
We may ask one of these third parties to contact you directly for a specific purpose, and provide us with information collected from you in the course of providing the relevant products or services.
5. Cross border disclosure
We may disclose personal information to overseas recipients, who are located in places such as Japan, Singapore, India, Hong Kong, the Philippines, the United States of America and other countries or jurisdictions depending on the nature of the services those recipients provide to Western Manchester (for example storing data via a cloud service, or where Western Manchester’s customer relationship management system is hosted on servers located overseas, or where delivery address information for online orders is managed via a third party located overseas).
6. Data quality and security
. General
We hold personal information in a number of ways, including in printed documents, electronic databases and email contact lists. Printed documents may be held at Western Manchester’s head office, or archived in boxes and stored in secure offsite facilities. We take reasonable steps to:
• ensure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
• protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and
• destroy or permanently de-identify personal information that is no longer needed for purposes permitted by the APPs.
You can help us keep your information up to date, by letting us know about changes to your details.
i. Security
The steps we take to secure personal information include website protection measures, security restrictions on access to Western Manchester's computer systems, controlled access to Western Manchester's corporate premises, policies on document storage and security, personnel security and training and workplace policies. While we endeavour to protect the personal information of users of our website, we cannot guarantee the security of information you disclose online: you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact Western Manchester as set out in section 8. You can also help protect your personal information by keeping your account details confidential. If you become aware of any security breach, please let us know as soon as possible.
ii. Third party sites
Links to third party sites that are not operated or controlled by Western Manchester are provided for your convenience. Western Manchester is not responsible for the privacy or security practices of those sites, which are not covered by this Privacy Policy. Third party websites should have their own privacy and security policies, which we encourage you to read before supplying any personal information to them.
7. Access and correction
. General
Please contact our Privacy Officer if you would like to access or correct the personal information that we hold about you. We may ask you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.
i. Access
We will generally provide you with access to your personal information within 30 days, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (eg by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.
ii. Correction
If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. If we correct personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, we will take reasonable steps to do so, unless this would be impracticable or unlawful.
8. Complaints or Questions
If you would like further information about how we manage your personal information, or if you have any queries relating to our Privacy Policy, or wish to lodge a complaint in relation to an alleged breach of the Privacy Act, please contact our Privacy Officer by:
Mail: Privacy Officer, Western Manchester, 703, 57 Hill Road, Wentworth Point, NSW 2127
Email: privacy@WesternManchester.com.au
All complaints received by the Privacy Officer will be dealt with fairly and in a timely manner considering all the circumstances of the complaint. In most cases, we expect that complaints will be investigated and a response provided within 30 days of receipt of the complaint. If the matter is more complex and our investigation may take longer, we will contact you and tell you when we expect to provide our response.
9. Changes to this Policy
Western Manchester may amend this Privacy Policy from time to time. The current version will be posted on our website and a copy may be obtained by contacting our Customer Service Centre on 02 9896 4196.