Vinyl Group Media Australia Pty Ltd

Vinyl Group Media Privacy Policy

Vinyl Group Media Australia Pty Ltd (ACN: 614 562 800) (Vinyl Group Media) is the publisher of a number of digital and physical media properties including, but not limited to: Tone Deaf, Rolling Stone (Australia & New Zealand), The Music Network, Variety Australia, thebrag.com, Refinery 29, and Mediaweek. Each of these titles, whether in digital or physical form are all brands, apps and/or publications used by Vinyl Group Media and collectively as known as “our Platforms”. Vinyl Media Group includes any subsidiaries of Vinyl Group Media, whether wholly or partly owned, and these entities are expressly included in the rights and responsibilities provided by this Privacy Policy.

In the course of our activities Vinyl Group Media (we, us, or our) will collect, store, use, transfer and disclose personal information. We are committed to the protection of your personal information and to compliance with Australian privacy laws.

This statement explains our policies and practices regarding the use, collection, storage and disclosure of your personal information.

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Personal Information

“Personal Information” is information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information is recorded in a material form or not.

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Types of personal information we collect and hold

We collect and hold personal information about individuals for the provision of our products and services and purposes connected to those products and services. Consistent with the provision or our products and services to you, the types of personal information we may collect and hold about you include but are not limited to the following:

  1. Account, Profile, Activity, and Use information While using our Platforms, you may voluntarily provide us with personally identifiable information, such as your name, email address, phone number, or other contact details. This may occur when you subscribe to our newsletter, register for an account, or submit inquiries.
  2. Location information: We may collect and process location information when you engage with our platforms or with physical events conducted by us. We do not track your device location otherwise. If you would like to stop the device location tracking, you may do so at any time by adjusting your device settings.
  3. Content you share: We gather information from the photos, posts, comments, ratings, reviews, and other content you share via our Platforms, including when you attend our or our partner(s) events or participate in partner promotions.

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How and why we collect and hold personal information

We may collect personal information directly from you in the course of providing our products and services from our Platforms.

We collect personal information reasonably necessary to carry out our business, to assess and manage our members' and subscribers’ and customers’ needs, and provide our services to those groups. We may also collect information to fulfill administrative functions associated with these services, for example billing, entering into contracts with you and/or third parties and managing member and other business relationships. We also collect personal information to administer and manage relationships with our shareholders. We may allow shareholders and other visitors to our websites to sign up for alerts and otherwise communicate with us.

Our principal purpose in collecting, using and storing your personal information is to provide you with access to and use of our services and those of related entities in a personalised, safe and efficient manner. You consent to us collecting, using, storing and sharing your personal information to enable us and related entities to provide services to you and fulfil obligations under a membership or subscription agreement and/or any other contract you may have with us or a related entity;

  • to provide news and information about our services or services of companies related to us and/or special offers to users;
  • to obtain opinions or comments about services from users;
  • to send you marketing and promotional material that you have opted in to receive
  • to record statistical data for marketing analysis from users;
  • managing, planning, advertising and administering programs, events, competitions and performances;
  • managing our relationship with you if you are a data supplier, business partner or shareholder;
  • researching, developing and expanding our services and those of related entities;
  • informing you of our activities, events and services and those of related entities;
  • to enable your access to members-only features or services;
  • to conduct competitions;
  • to operate, evaluate and improve our business and the business of companies related to us, including developing new products and services; managing our communications; determining the effectiveness of, and optimizing the content you see; analyzing our products, services, website, mobile application, and any other digital assets and those of companies related to us; facilitating the functionality of our website, mobile application, and any other digital assets and those of companies related to us;
  • to investigate any complaints about or made by you;
  • for purposes of recruitment processes;
  • to investigate breaches of our terms and conditions or other unlawful behaviour;
  • for market research purposes and to innovate our delivery of services; and
  • responding to requests for information, general enquiries and complaints.

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Use of Cookies

Our Platforms use cookies.

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What is a cookie?

A 'cookie' is a small file stored on your devices browser, which assists in managing customized settings of the platform and delivering content. We collect certain information such as your device type, browser type, IP address, the pages you have accessed on our website and on third-party websites.

While the cookie may identify your computer, it should not identify you unless you are registered with our website or product database (for example, because you are a member and subscribe to our website or product) or logged in using your social media profile. In that case, the cookie will be linked to your profile so that we can identify you and provide more relevant content.

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Why we use cookies

We use cookies to personalize your browsing experience (for example, by remembering your preferences and recognizing you as a repeat visitor to our website), and to track statistics about the usage of our websites. This allows us to better understand our users and improve the layout and functionality of our websites.

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The types of cookies we use

Specifically, we use the following cookies:

  • Strictly necessary cookies: are required for the operation of our website, such as cookies that enable you to log into secure areas of our website (for example, our membership platform).
  • Analytical/performance cookies: allow us to count the number of users and see how users move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Targeting cookies: these cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information, subject to your choices and preferences, to make our website and any advertising displayed on it more relevant to your interests.
  • Third party/sharing cookies: are cookies that are set by a domain other than the one being visited by you. If you visit our website and a separate company sets a cookie through that website this is a third-party cookie. To try to bring you offers and advertisements that are of interest to you, we have relationships with third party companies including Google, Adobe Analytics, Facebook, LinkedIn (Third Party Providers) that allow them to place cookies on our websites.

These Third-Party Providers may:

  • use Third Party Cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the internet;
  • compare de-identified information from us with information collected elsewhere on the internet; and
  • use that information to provide measurement services and target ads to you.

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How long cookies will be stored on your device

Session cookies are temporary. They allow website operators to link the actions of a user during a browser session, the time period between a user opening a browser window and closing it. Once closed, the cookies are deleted. Persistent cookies remain on a user’s device for the period of time specified in the cookie.

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How you can manage your cookies

If you do not wish to receive any cookies (other than those which are strictly necessary) you may set your browser (such as Firefox, Google Chrome, Internet Explorer or Safari) to either prompt or refuse cookies. Please note that rejecting cookies may mean that not all the functions on our website you visit will be available to you.

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Holding Personal Information

Personal information is held securely, is subject to various security protections and is held only for as long as the information remains relevant to the purpose for which it was collected.

We take all reasonable steps to protect the personal information that we hold from misuse, loss, or unauthorised access, including by means of firewalls, password access and secure servers.

However, you acknowledge that the information you provide to us is at your own risk. We cannot accept responsibility for misuse or loss of, or unauthorised access to, your personal information where the security of information is not within our control.

You acknowledge that we are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose your personal information to in accordance with this policy or any applicable laws). The collection and use of your information by such third parties may be subject to separate privacy and security policies.

Our properties may feature IPSOS proprietary measurement software, which will allow you to contribute to market research, like Digital Content Ratings. To learn more about the information that IPSOS software may collect and your choices with regard to it, please see the IPSOS Privacy Policy at https://www.ipsos.com/en-au/privacy-aus

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Purposes for which we hold and use Personal Information

The purposes for which we hold, use and disclose information include:

  1. to communicate with you and provide you with the services you have requested;
  2. to enable your access to members-only features or services;
  3. to send marketing and promotional material that you have opted in to receive;
  4. to provide you with news and information about our products and services;
  5. to personalise and customise your experience;
  6. to conduct competitions;
  7. to verify your identity;
  8. to investigate any complaints about or made by you;
  9. to investigate breaches of our terms and conditions or other unlawful behaviour;
  10. other purposes as specified at the time of you supplying information to us;
  11. as required or permitted by any law (including the Privacy Act).

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Permitted Disclosure of your Personal Information

We may disclose personal information, and you consent to us disclosing your personal information, to third parties:

  1. engaged by us to perform functions or provide products and services on our behalf;
  2. that are our agents, business partners, joint venture entities or brand activation partners;
  3. that sponsor or promote any competition that we conduct or promote;
  4. that are authorised by you to receive information held by us;
  5. if we have reason to suspect that you have committed a breach of our terms and conditions, or have otherwise been engaged in any unlawful activity;
  6. as part of a sale (or proposed sale) of all or part of our business; and/or
  7. as required or permitted by any law (including the Privacy Act).

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Addressing Your Concerns - access, correction and deletion

If you suspect any misuse or loss of, or unauthorised access to, your personal information, please contact us immediately. You may contact us at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

We will take all reasonable steps to ensure any personal data we collect, use or disclose is up to date and accurate. If you believe personal information we hold about you is not up to date or accurate, you may ask us to correct it.

You may ask us to provide you with details of the personal information we hold about you, and copies of that information. We will respond to your request and attempt to provide you with the data within 30 days of receipt of your request.

If we provide you with copies of the information you have requested, we may charge you a reasonable fee to cover the administrative costs of providing you with that information.

If you want us to delete the personal information that we have collected about you, you may contact us by email at privacy@vinyl.group

Please direct all request for access and correction to:

Privacy Officer
Vinyl Group Media Australia Pty Ltd
The Commons,

388 George St, Sydney NSW 2000

If you consider a breach of the Australian Privacy Principles has occurred, you may direct your query to Vinyl Group Media’s Privacy Officer and we will attempt to resolve your issue.

We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week. If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking.  We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint.  If the matter is more complex or our investigation may take longer, we will let you know.

If you do not consider our response satisfactory, you may contact the Australian Privacy Commissioner at its website www.oaic.gov.au or by telephone on 1300 363 992.

If you are outside of Australia, you may wish to take your complaint up with the local data protection authority in your jurisdiction. For example, if you are based in the United Kingdom, this is the UK Information Commissioner’s Office.

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Aggregated information

We may aggregate the information you and others make available to us and post it publicly or share it with third parties. Examples of the type of information we may aggregate include information about music and media preferences and demographics. We may use, sell, license, and share this aggregated information with third parties for research, business or other purposes such as to promote the music, media, leisure, lifestyle and entertainment industries or to help our partners understand more about the people who use their products and services.

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International use of Personal Information

Personal information may also be shared between our related entities or affiliated companies, located in Australia and overseas. We are a global organization and works with members, service providers, sponsors and commercial interests globally. It is likely that your personal information will be disclosed to overseas recipients, including service providers who may handle, process or store your personal information on our behalf. The recipients of such information may be located in jurisdictions such as Australia, the United Kingdom and the United States.

Our related entities may have operations in countries including the United Kingdom and the United States and other countries.

We generally collect personal information about you in Australia or the jurisdiction in which the related entity you are dealing with is located.

It is likely that your personal information will be transferred outside of the jurisdiction it was collected.  We only ever disclose your personal information outside the jurisdiction it was collected where we are permitted to do so under applicable privacy laws. Generally, this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with applicable privacy laws, including, where relevant, by entering into EU standard contractual clauses (or equivalent measures) with the party outside the European Economic Area.

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Residents in the European Economic Area

We have described the purposes for which we may use your personal information. If the GDPR applies to you, we are permitted to process your personal information in this way, in compliance with the GDPR, by relying on one or more of the following lawful grounds:

  • you have explicitly agreed to us processing your information for a specific reason;
  • the processing is necessary to perform the agreement we have with you or to take steps to enter into an agreement with you;
  • the processing is necessary for compliance with a legal obligation we have; or
  • the processing is necessary for the purposes of a legitimate interest pursued by us, which might be:
    • to prevent fraud;
    • to protect our business interests;
    • to ensure that complaints are investigated;
    • to evaluate, develop or improve our services; or
    • to keep our members informed about relevant services, unless you have indicated at any time that you do not wish us to do so.

If the GDPR applies to you, you have the following additional and specific rights in relation to your personal information (where applicable):

  • Access: you have the right to request a copy of any personal information we hold about you. Any request for access to or a copy of your personal information must in writing, and we will endeavor to respond within a reasonable period and in any event within one month (in compliance with the GDPR).
  • Rectification: you have the right to the rectification of your personal data, if you consider that it is inaccurate.
  • Deletion: you have the right to request that we delete personal information that we process about you, except we are not obliged to do so if we need to retain such personal information in order to comply with a legal obligation or to establish, exercise or defend legal claims.
  • Restriction: you have the right to erasure of your personal information, if you consider that we do not have the right to hold it.
  • Portability: you have the right to ask us to transfer a copy of your personal information to you or to another service provider or third party where technically feasible.
  • Objection: you have the right to object to your personal information being processed for a particular purpose or to request that we stop using your information.
  • Complaint: If you are unhappy with our treatment of your personal information, and you have contacted us as set out below, you have the right to lodge a complaint with the local data protection authority.

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California Residents

If you are a California resident with whom we have an established business relationship, you may have the right under California Civil Code Section 1798.83 to receive free of charge no more than once per calendar year: (i) information identifying any third party(ies) to whom we may have disclosed, within the preceding calendar year, your personal information for that third party’s direct marketing purposes; and (ii) a description of the categories of personal information disclosed. To do so, please contact us at privacy@vinyl.group

stating your specific request and your name, address, email address and phone number. Please allow a minimum of 30 days for a response. This will not prohibit disclosure of information for non-marketing purposes.

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Children

Our Platforms are not intended to be used by children. By visiting our website or using our services in any way, you represent that you are at least the age of majority in your state or country of residence or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents use the website.

We will not knowingly collect any personal information from children under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from children under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.

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Changes to this Privacy Policy.

We may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes. We also attempt to make you aware of major changes to our Privacy Policy (for example by putting a notice up on our website(s)). This Privacy Policy may be translated into languages other than English. If there is a discrepancy between the English language version and any translated version of this Privacy Policy, the English language version will prevail.

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