Privacy Policy

INTRODUCTION

Gumbuya will from time to time gather information from our Guests and other parties with whom we deal to enable us to improve the nature of the services we provide. The types of personal information Gumbuya collects about you will depend on what interactions you have with us and the types of services or products you use. Gumbuya understands our Guests’ concerns regarding confidentiality and takes seriously its obligations in respect of all information it gathers. To safeguard that information, we have implemented a policy to ensure the privacy of our Guests and other parties is protected. This Privacy Policy outlines how Gumbuya deals with Personal Information.


COLLECTION OF INFORMATION

Nature of information

The information Gumbuya collects in most cases relates to Guests but can relate to suppliers and other parties we deal with (for the purposes of this Privacy Policy all such people are described as Clients). Information is gathered for a range of purposes, including the provision of ongoing Client support and the compiling of Client databases to enable us to more accurately market our goods and services. The type of information we collect includes such things as contact details, buying habits, opinions, product preferences and transactional details. Gumbuya treats all such information which is collected and identifiable as relating to an individual as Personal Information within the context of this Privacy Policy.

How information is collected

Where practical, Clients of Gumbuya may deal with Gumbuya on an anonymous basis. However, as a provider of a wide range of services, Gumbuya frequently finds that it is necessary to collect Personal Information during the course of transactions. Personal Information may be collected about Clients via the following means:
  1. competition entry forms;
  2. application forms;
  3. email;
  4. websites (including in some instances cookies);
  5. online transactions;
  6. networking functions (such as business cards);
  7. over the phone;
  8. patron surveys;
  9. at the front gate;
  10. in contracts;
  11. incident and visitor records;
  12. CCTV footage, RFID data and photographs;
  13. credit card details via credit card purchases; and
  14. information collected from third parties.

Information given to Clients

When Personal Information is collected from a Client, they are advised at the time of collection or as soon as practical after its collection as to:
  1. Gumbuya's contact details;
  2. the purpose of collection;
  3. the fact that a Client can access the Personal Information that Gumbuya holds about them;
  4. the types of organisations to which their Personal Information may be disclosed ;
  5. any law that requires the Personal Information to be collected; and
  6. the key consequences if all or some of the information cannot be collected; and
  7. whether the Personal Information will be disclosed to overseas recipients.
Where Gumbuya collects Personal Information about a Client from a third party, and the Client has not previously consented to that third party providing the information to Gumbuya, we will, where reasonable and practical, provide the Client with the following information about that third party:
  1. the third party's contact details;
  2. the purpose of collection;
  3. the fact that the Client can gain access to the Personal Information;
  4. the types of organisations to which their Personal Information may be disclosed by that third party;
  5. any law that requires the Personal Information to be collected; and
  6. the key consequences if all or some of the information cannot be collected.

“Sensitive information”

Gumbuya will not ask a Client for information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation, unless:
  1. the collection of that information is specifically authorised by law; or
  2. the collection of the information is necessary for the establishment, exercise or defence of a legal claim.

Client consent

Wherever practical, Gumbuya will obtain the express consent of Clients to the collection of Personal Information. In some situations, Gumbuya will interpret a Client's actions as indicating that a Client consents to the collection of Personal Information. This may occur where the Client has provided Personal Information for a particular purpose and that purpose cannot be achieved without Gumbuya making use of the Client's Personal Information.

If personal information is not provided

Where relevant, Gumbuya will endeavour to make Clients aware that Gumbuya may not be able to provide a proper service to them if Personal Information is not provided upon request.

Cookies

Cookies are small pieces of data stored on the web browser on computers. Gumbuya websites may store cookies on a Client’s web browser. The main reasons cookies may be stored are to:
  1. improve Clients’ website browsing experience. For example, to remember a Client’s search criteria and to remember any site preferences for future visits to those web sites;
  2. gather statistics on site usage; for example, page views and drop off points so Gumbuya can monitor site usage and make improvements to site usability.


USE AND DISCLOSURE OF PERSONAL INFORMATION

Use of personal information

Gumbuya may use Personal Information for the purposes identified at the time of collection which may include:
  1. to provide and administer Gumbuya’s goods and services, such as verifying a Client’s identity; contacting Clients about orders and bookings; processing payments; training staff; testing its systems; and managing interaction with Gumbuya’s suppliers;
  2. to provide and operate Gumbuya’s competitions, promotions and events;
  3. to distribute Gumbuya’s newsletters and other communications by itself or with the assistance of third party services providers;
  4. for Client support, including resolving and providing assistance for orders or tickets or to respond to other enquiries or requests;
  5. to conduct marketing activities for Gumbuya’s products and services, or products and services of third parties, and to conduct market and other research to improve Gumbuya’s products, services and marketing activities;
  6. to conduct market research and analysis;
  7. to provide information technology services such as data storage, distribution services, communication networks, software and system development, maintenance and support, and information processing, analysis and reporting;
  8. to provide services in the course of investigating a complaint or a security incident;
  9. for the purposes of a confidential alternative dispute resolution process; or
  10. to maintain records and comply with Australian law.

Disclosure of personal information

In general, only officers, employees or contractors of Gumbuya may view Personal Information. Gumbuya will only grant access to parties other than Gumbuya’s officers, employees and contractors to view Personal Information where Gumbuya believes that access is necessary to achieve the purpose for which the Personal Information was collected. From time to time, Gumbuya may grant access to service partners, companies or individuals with whom it shares some common commercial interest to view Personal Information where Gumbuya believes that access is necessary to achieve the purpose for which the Personal Information was collected. To the extent that these service partners, companies or individuals are located in Australia and Gumbuya gives them access to a Client’s Personal Information, they are subject to privacy legislation which prevents the Personal Information being used for any other purposes. Gumbuya will only disclose Personal Information to parties other than Gumbuya’s officers, employees and contractors without a Client’s consent if:
  1. Gumbuya believes that the disclosure may lessen a risk of harm to the health or safety of any person;
  2. Gumbuya believes an unlawful activity is being undertaken and the Personal Information is disclosed as part of Gumbuya’s investigation into this activity;
  3. Gumbuya is required by law to disclose the Personal Information; or
  4. The disclosure is required for the enforcement of a criminal law or a law imposing a pecuniary penalty or for the protection of public revenue.

International transfers

Gumbuya may disclose Personal Information to countries outside Australia. Gumbuya will only do so in compliance with all applicable Australian data protection and privacy laws. Gumbuya will take reasonable steps to protect Personal Information no matter what country it is stored in or transferred to.

Identification

Gumbuya does not use any prohibited identifiers (such as a tax file number) to identify its Clients.

Storage and security

Personal Information may be stored in either hard copy form or on computer or both. Hard copy Personal Information is wherever practical, kept under locked security. Personal Information stored on computer is wherever practical, password protected. Where possible and practical, Gumbuya will endeavour to comply with recognised Australian and international standards relating to information security. Gumbuya regularly deletes and de-identifies Personal Information if the information is no longer needed by Gumbuya.

Updating personal information

Gumbuya regularly monitors the quality and accuracy of Personal Information that it maintains and where practical, updates that information on a regular basis. Clients can update or correct their Personal Information at any time by contacting Gumbuya’s Privacy Officer.

MINORS

Gumbuya will only collect Personal Information from, or about, minors for any booking and delivery of a specific program being purchased for use by the minor.

COMPETITIONS

Personal information gathered during competitions run by Gumbuya will be governed by the principles set out in this Privacy Policy unless an express statement is made in relation to privacy in the conditions of entry for the competition.

DIRECT MARKETING

Personal Information collected for direct marketing purposes will only be collected, used or disclosed with the consent of the relevant Client as provided for in this Privacy Policy. In circumstances where Gumbuya cannot practically obtain the consent of a Client, then Gumbuya may still engage in direct marketing to that Client, but will:
  1. include an 'unsubscribe' facility so Clients can unsubscribe from the mailing list at any time; and
  2. clearly and accurately identify the sender of the message; and
  3. include information about how Clients can contact Gumbuya if Clients wish to be removed from any mailing list or to contact Gumbuya's Privacy Officer.

ACCESS TO PERSONAL INFORMATION

Clients may access their Personal Information by contacting Gumbuya’s Privacy Officer. Any request to provide access to this information will be dealt with within a reasonable time.


WITHHOLDING ACCESS TO PERSONAL INFORMATION

When access can be withheld

Access to Personal Information may be withheld in a number of circumstances. These include where:
  1. providing access would pose a serious and imminent threat to the life or health of a person;
  2. providing access would have an unreasonable impact on the privacy of others;
  3. the information is subject to confidentiality where the person who provided the information to Gumbuya did so expressly on the condition that it remains confidential;
  4. the request is vexatious or frivolous;
  5. the information relates to current or anticipated legal proceedings between Gumbuya and the person and the information would not be required to be discovered to a court;
  6. Gumbuya is in commercial negotiations with the person and the information would reveal Gumbuya's intentions;
  7. providing access would be unlawful or Gumbuya is required by a law to withhold access; or
  8. providing access could prejudice the investigation or detection by Gumbuya or by a government body of an unlawful activity or some serious or improper misconduct.
Where Gumbuya does withhold Personal Information, Gumbuya may instead choose to give the Client a summary of that information.

Written reasons

If Gumbuya withholds access to Personal Information, Gumbuya will provide written reasons to the extent required and how the Client may protest the refusal.

Third party intermediary

If Gumbuya withholds access to Personal Information, Gumbuya will consider whether the provision of access to an independent third party will meet Gumbuya's and the relevant Client's needs.

CONTRACTORS

Gumbuya may from time to time employ subcontractors to provide services to it. In these situations, Personal Information may be collected about those subcontractors. This Privacy Policy applies equally to those subcontractors.

WHO TO CONTACT

Gumbuya is committed to working with its Clients to obtain a fair resolution of any complaint or concern about privacy. If you have a concern about your privacy or you have any query on how your Personal Information is collected or used please contact Gumbuya using the details below. We will respond to your query or complaint within a reasonable time.

Write to us

You can contact our Privacy Officer at:  

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