1 Overview

This privacy policy (Privacy Policy) sets out how Marilyn Moloney trading as Options – Ageing Solutions ABN 97 613 298 014 of PO Box 4281, Frankston Heights 3199 (‘The Supplier’, ‘Us’ ‘We’) collects, stores, uses, protects and shares your personal information. It applies to our website and all related websites, applications, services and tools (together the Website). By visiting or using the Website you agree to the collection, storage, usage and disclosure of your personal information by Us in the manner described in this Privacy Policy.

Unless we obtain your written consent, we will not sell, disclose, licence or rent your personal information to a third party for that third party’s marketing purposes.

We reserve the right to amend this Privacy Policy at any time by posting the amended terms on the Website. If we make material changes to this policy, we will notify you by means of a notice on our Website so that you can access and review the changes. If you object to any changes, you may close your account with Us. By continuing to use the Website after notice of changes has been published on the Website, you are deemed to have consented to the changes.

2 Definitions

“Personal Information” means information that can be associated with a specific person and can be used to identify that person. Information that has been made anonymous or aggregated so that it cannot be used, whether in combination with other information or otherwise, to identify a specific user is not personal information.

3 Collection

We collect Personal Information in a number of ways, including:

(a)         when you provide information directly to Us in person, by phone or in writing (whether electronic, via our communication tools or otherwise);

(b)         when you visit and/or use the Website, in which case, We record information sent to us by your computer, mobile device or other access device; and

(c)          from third parties such as Our related entities, service providers to Us, credit reporting agencies, operators of linked websites, applications and advertising on the Website.

3.1 What we collect

We collect the following types of Personal Information in order to provide you with our services, use of the Website and for the purposes provided for in this Privacy Policy:

(a)         your name, phone number, mobile telephone number, email address, physical address and other contact information;

(b)         financial information such as credit card or bank account numbers;

(c)          records and content of communications with Us or any other person including when using Website communication tools;

(d)         personal information based on your activities on the Website;

(e)         personal information you provide to us through any discussions boards, correspondence, member information pages, disputes, or shared by you from other social applications, services or websites;

(f)           to the extent permitted by law, other personal information provided by or obtained from third parties (such as a credit bureau) including navigation and demographic data and credit check information;

(g)         additional personal information we ask you to provide to verify your identity or when we suspect that you are in breach of our Terms & Conditions, this Privacy Policy or other Website policies (including your personal ID and your answers to any questions we pose to you); and

(h)         personal information from your interaction with the Website and its content and advertising, including device identifiers, device type, geo-location information, connection information, statistics on page views, traffic to and from the Website, mobile network information, time, date, referring URL, the type of operating system and browser, ad data, IP address and standard web log data.

4 How personal information is used

Our principal purpose in collecting, using and storing your personal information is to provide you with the goods and/or services requested by you and use of the Website in a personalised, safe and efficient manner. You consent to us collecting, using, storing and sharing your personal information to:

(a)         provide the goods and services requested by you;

(b)         research, develop and improve Our goods and services;

(c)          to conduct surveys to determine use and satisfaction with Our goods and services;

(d)         to generate statistics in relation to the Website;

(e)         detect, investigate and prevent potentially unlawful acts or omissions or acts or omissions with the potential to breach our Terms & Conditions, this Privacy Policy or other policies;

(f)           enforce our Terms & Conditions, this Privacy Policy or other policies;

(g)         verify information for accuracy or completeness (including by way of verification with third parties);

(h)         combine or aggregate your personal information with information we collect from third parties and use it for the purposes set out this Privacy Policy;

(i)           contact you at your contact details we have collected, by way of voice call, post, text message or email;

(j)           aggregate and/or make anonymous your personal information, so that it cannot be used, whether in combination with other information or otherwise, to identify you;

(k)          collect fees, resolve disputes and to identify, test and resolve problems;

(l)           notify you about the Website and updates to the Website from time to time;

(m)         investigate and determine whether to approve the opening of a credit account on your behalf;

(n)         supply you with generalised, targeted or personalised marketing, advertising and promotional notices, offers and communications based on your preferences, and measure and improve our marketing, advertising and promotions based on your ad customisation preferences.

4.1 Opting out

You may withdraw your consent to us collecting, storing, using and disclosing your personal information in accordance with this Privacy Policy, but as a result you may not be permitted to continue to use the Website or some of our goods and services.

You may opt out of receiving our marketing, advertising and promotional notices, offers and communications by communicating this to us in writing at the email address below.

4.2 Disclosure to third parties

Notwithstanding section 4.1 above, you agree that we may disclose your personal information to:

(a)         enforce our Terms & Conditions, this Privacy Policy and other policies;

(b)         comply with any applicable law, request by a governmental agency or regulatory authority or legally binding court order;

(c)          respond to or resolve claims that a member has violated the rights of others;

(d)         protect a person’s rights, property or safety;

(e)         Our directors, staff, contractors, professional advisers and related entities;

(f)           outsourced service providers who assist Us to provide its services such as information technology providers and marketing advisers (including in relation to fee collection, fraud investigations and Website operations);

(g)         third parties to whom you expressly ask us to send, or consent to us sending, your personal information;

(h)         credit agencies (including regarding missed and late payments or other defaults or breaches on your account); or

(i)           such entities that we propose to merge with or be acquired by and in such case, we will require that the new entity following the merger or acquisition to adhere to this Privacy Policy.

5 Use of Cookies

(a)         We (or a third party providing services to Us) may use cookies, pixel tags, “flash cookies”, or other local storage provided by your browser or associated applications (each a Cookie and together Cookies). A Cookie is a small file that stays on your computer or device until, depending on whether it is a sessional or persistent cookie, you turn your computer or device off or it expires (typically between 7 and 30 days depending on user settings).

(b)         Cookies may be used to provide you with our range of services including identifying you as a user of the Website, remember your preferences, customise and measure the effectiveness of the Website and our promotions, advertising and marketing, analyse your usage of the Website, and for security purposes.

(c)          Cookies may collect and store your personal information. This Privacy Policy applies to personal information collected via Cookies. You may adjust your internet browser to disable Cookies. If Cookies are disabled, We may not be able to provide you with the full range of Our services.

(d)         You also may encounter Cookies used by third parties and placed on certain pages of the Website that we do not control and have not authorised (such as webpages created by another user). We are neither responsible nor liable for the use of such Cookies.

(e)         The Website may also include links to third party websites (including links created by users or members) and applications and advertising delivered to the Website by third parties (Linked Sites). Organisations that operate Linked Sites may collect personal information including through the use of Cookies. We are neither responsible nor liable for Linked Sites and recommend that you read the privacy policies of such Linked Sites before disclosing your personal information.

6 No Spam, Spyware or Spoofing

(a)         You are prohibited from engaging in spam, spyware or spoofing type activities, regardless of whether directed towards Us or other users of our Website.

(b)         You must not use the Website or any of its communication tools to send, upload or distribute spam, viruses or malicious, illegal or prohibited content to the Website or otherwise send content that would breach our Terms & Conditions or this Privacy Policy.

(c)          We may (or we may engage a third party service provider to) take steps to scan and filter messages to check for spam, viruses, phishing attacks and other malicious activity or unlawful or content prohibited by this Privacy Policy and our Terms & Conditions.

(d)         To report spam, spyware or spoof activities to Us, email us at oasservices@mail.com.

7 Accessing and amending your personal information

(a)         You can access and amend much of your Personal Information by contacting Us in accordance with Clause 11 of this Privacy Policy. It is your responsibility to ensure that your information is accurate and up to date. You may need to confirm your identity with Us in order to amend your Personal Information. We will not amend your Personal Information if we cannot confirm your identity.

8 Storage and security

(a)         We store and process your Personal Information on our local computer hard drive in password protected files and in paper based files stored in in Australia.

9 Account Closure

(a)         If you request us to do so, we will as soon as reasonably practicable close your account, file or matter with Us.

(b)         We may also close, terminate or deactivate inactive accounts, files or matters that have been used in breach of our Terms & Conditions, Privacy Policy or other policies from time to time.

(c)          To the extent permitted by law, we reserve the right under certain situations to retain and store your Personal Information for such period as is deemed necessary by Us, notwithstanding closure, termination of your account, file or matter. Such situations include where we are required to comply with laws or regulations, the collection of fees owing to Us, the resolution of disputes, the prevention of fraud, unlawful activity or activity prohibited by this Privacy Policy or our Terms & Conditions, or the enforcement of our Terms & Conditions or this Privacy Policy.

10 Information Sharing with Social Media

We may offer services that allow you to share public aspects of the Website with third party websites such as Google Plus, Twitter, LinkedIn, Facebook and other social media websites.

11 Contact Us

If you have a question regarding this Privacy Policy or you would like to make a complaint, please contact the Privacy Manager at:

Email:               oasservices@mail.com
Address:            PO Box 4281, Frankston Heights 3199
Contact:             Marilyn Moloney

Prepared for Options Ageing Solutions by

City Pacific Lawyers

765D Hawthorn Road
Brighton East, VIC, 3187
P: (03) 9592 3356
F: (03) 9592 3357
Email: emichael@citypacific.com.au

Ref: EAM:RP:170028