SA Chess privacy policy

Posted by SA Chess  at April 8th, 2013

This Privacy Policy sets out the approach which Sachess.com will take in relation to the treatment of Personal Information. It includes information on how Sachess.com collects, uses, discloses and keeps secure, individuals' Personal Information. It also covers how Sachess.com makes the Personal Information it holds available for access to and correction by the individual.

This policy has been drafted having regard to Sachess.com' obligations under the Telecommunications Act 1997 and the Privacy Act 1988 (including the National Privacy Principles) (the Privacy Act). Nothing in this Policy changes Sachess.com' existing obligations under the credit reporting requirements of the Privacy Act.

This Policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.

1. Collection

1.1 Sachess.com will only collect Personal Information where the information is necessary for Sachess.com to perform one or more of its functions or activities. In this context, "collect" means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.

1.2 Sachess.com collects Personal Information primarily to supply customers with the products and services ordered from it and its related companies. Sachess.com also collects and uses Personal Information for secondary purposes including:

(i) billing and account management;
(ii) business planning and product development; and
(iii) to provide individuals with relevant advertisements and relevant information about promotions, as well as the products and services of Sachess.com and other organisations.

1.3 Sachess.com will notify individuals (including, but not limited to, our customers) of the matters listed below before collecting any Personal Information:

i) the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
ii) other related Uses or Disclosures that we may make of the Personal Information (Secondary Purposes);
iii) our identity and how individuals can contact us, if this is not obvious;
iv) that individuals can access the Personal Information that Sachess.com holds about them;
v) that individuals should contact our customer service department (even if they are not a customer) if wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;
vi) where applicable, any law that requires the Personal Information to be collected;

1.4 Where it is not practicable for Sachess.com to notify individuals of all of the Collection Information before the collection of Personal Information, Sachess.com will ensure that individuals are notified of the Collection Information as soon as possible after the collection. Sachess.com will provide "post collection notification" in those circumstances where it is not practicable to notify individuals about the collection of their personal information before it is collected.

1.5 Sachess.com will not collect Sensitive Information from individuals except with consent and only where it is necessary for Sachess.com to collect such information for an activity or function.

1.6 Sachess.com will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.3.

2. Use

2.1 Sachess.com will obtain an individual's consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual's Reasonable Expectations.

2.2 Sachess.com Uses Personal Information primarily for the purposes listed in 1.2 above.

2.3 Sachess.com will not use Sensitive Information for Direct Marketing.

2.4 Sachess.com may use Personal Information to avoid an imminent threat to a person's life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.

2.5 Sachess.com will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.

2.6 Sachess.com will not attempt to match de-identified or anonymous data collected through surveys or such online devices as "cookies", with information identifying an individual, without the consent of the relevant individual.

3. Disclosure

3.1 Sachess.com may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual. This will include obtaining the individual's consent for Disclosures made under the credit reporting requirements of the Privacy Act.

3.2 Sachess.com will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.

3.3 Sachess.com may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.

3.4 Sachess.com may Disclose Personal Information to avoid an imminent threat to a person's life or to public safety.

3.8 Sachess.com does not generally sell or share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved. If the consent provided is conditional, Sachess.com will take steps to ensure (by contract) that the use of its customer list by third parties does not exceed the scope of the consent.

4. Information quality

4.1 Sachess.com will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.

4.2 Sachess.com will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.

5. Information security

5.1 Sachess.com will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within Sachess.com who have a genuine "need to know" as well as "right to know".

5.3 Sachess.com will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.

10. Glossary

Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.

Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of Sachess.com or a Related Body Corporate or those of an independent third party organisation.

Disclosure generally means the release of information outside Sachess.com, including under a contract to carry out an "outsourced function".

Sensitive Information means:

(a) information or an opinion about an individual's:

(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual preferences or practices; or
(ix) criminal record; that is also personal information or

(b) Health Information or genetic information about an individual.

Use means the handling of Personal Information within Sachess.com.

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