Last Revised: 2017
We realize that our customers and online visitors are concerned about the security of their personal information. We take these concerns seriously and respect the privacy rights of all individuals. ‘Personal information’ is in general terms, information about an identifiable individual. The collection, usage and disclosure of personal information is governed by applicable United States privacy legislation. If you seek more information about what constitutes personal information please refer to the applicable law or relevant government website, where it is defined and discussed more exhaustively. This Policy also deals with information other than personal information that may be transmitted or accessed through our website, in clause 8.
We encourage you to read this Policy before using this website. Your use of this website indicates that you agree with all the terms of this Policy; please do not use the website if you disagree with any part of this Policy. If you have any questions about this Policy, please contact our Privacy Officer using the details in clause 7.
1. Collection of Personal Information
Generally individuals do not need to provide personal information in order to access or use this website. However, sometimes in the course of our business, we will solicit or seek to collect personal information from you. We will our make best efforts to only collect the amount and types of information necessary to fulfil the purposes the information is being collected for. The circumstances in which we will collect information from you are discussed in clause 2.
The personal information we collect includes, but is not limited to:
· Name, postal address, e-mail address, shipping address, mobile phone number, telephone number, fax number;
· Any other contact information;
· Your comments, inquiries and requests;
· Any other details that are relevant to a competition, registration process or promotion;
· Any identifiers that we generate for you such as usernames or passwords;
· ‘Clickstream data’;
· Any other information that you consent to us collecting; and
· Any other information that we are required or permitted by law to collect.
If you do not want us to collect your personal information, do not provide it to us. Please note that where we do collect your personal information, it may be transferred between our offices and our related entities, located in other jurisdictions across the United States and the world.
2. Use of Personal Information
There are a number of circumstances in which we will solicit or obtain personal information from you. These circumstances arise when we seek to use your personal information for a purpose that arises in the course of our business. Your personal information will not be used for purposes other than those for which it was collected, unless you consent to it being used for a different purpose, or the law requires it. To see how that consent might be supplied, see clause 4.
The purposes for which we will use your personal information include:
· Administering games, competitions, contests and promotions, including contacting potential winners and delivering awards;
· Facilitating our training programs for pharmacists and health-care professionals;
· Facilitating subscriptions, memberships and registrations to receive newsletters or other material related to our activities;
· Providing responses to comments, requests and inquiries;
· Interacting with and contacting all our website visitors more generally, including offering promotions through any medium;
· Facilitating the purchase and delivery of our products or services whether online or offline, including the provision of associated warranties if and where they apply;
· Maintenance, administration and management of our business, including the collection of accounts;
· Disclosures necessary to the efficiency and operations of our business, including disclosures to contractors, affiliates, strategic partners, service providers, regulators and transacting parties;
· Disclosures related to business transactions or legal requirements;
· Meeting legal, regulatory, insurance, security and processing requirements;
· Statistical purposes that use clickstream data gathered from our website;
· Any other purpose so identified that would be considered obvious to a reasonable person where you have voluntarily given us personal information;
· For such other uses authorized, required or permitted by law.
3. Disclosure of Personal Information
Your personal information may be disclosed in the following circumstances. These disclosures require your consent, unless required by law. Your personal information will not be disclosed for purposes other than those for which it was collected, unless you consent to a different disclosure or the law requires it. To see how that consent might be supplied, see clause 4. We will never sell or rent your personal information outside of the circumstances identified below.
3.1 Authorized Staff and Contractors
Your personal information may be disclosed to employees, contractors or other third parties who require access to that information, whether incidentally or directly, in order to fulfil the requirements of their job. This includes technical maintenance and repairs conducted on our computers, data or networks. When you provide us with any personal information, you are taken to have consented to this disclosure.
3.2 Business Transactions
Your personal information may be disclosed to parties connected with any business transactions relating to Hydration Pharmaceuticals Pty Limited as trustee for the Hydration Pharmaceuticals Trust or its assets, for the purposes of evaluating and/or performing those transactions.
3.3 Legal & Regulatory
Your personal information may be disclosed as necessary to meet legal, regulatory, self-regulatory, insurance, audit and security requirements. This includes compliance with warrants, subpoenas or other legal processes required by applicable United States or foreign laws.
3.4 Subsidiaries, Affiliates and Related Entities
We may disclose personal information to our affiliates, related companies, our service providers and their authorized agents in order to:
· Facilitate these entities roles in carrying out the operation and/or promotion of our business.
· Aid administrative and management processes.
· Provide these bodies with aggregate information. This aggregate information will not identify individuals.
3.5 Strategic Partners
We sometimes maintain relationships with companies that are not our affiliates or our related entities. We may share some of your personal information with these partners. Because these third parties will use your personal information in accordance with their own privacy practices, you should check their websites for information regarding their privacy practices.
3.6 Service Providers
We may disclose personal information to our service providers. Service providers perform tasks that help us to operate our business, including tasks that involve handling your personal information. We take reasonable measures to protect your personal information while handled by these service providers.
4. User Consent
Applicable laws require that you consent to the collection, use and disclosure of your personal information. They also require that you be advised of the purposes for which the information is and will be collected, used and disclosed. As such, if you do not understand the purposes for which information is collected, or is to be used or disclosed, you should not provide us with that personal information.
In determining the form of consent required for each collection, usage and disclosure of personal information we will take into account the sensitivity of the information being sought. When assessing what purposes the consent is given for, we will take into account the reasonable expectations of an individual giving that consent. We may often notify you of the purposes for which we collect, intend to use, or disclose your personal information by general reference to this Policy when we seek to obtain that information.
For the most part we will seek express consent, and we will always seek express consent when someone might consider the relevant information to be sensitive. There are circumstances where you will be deemed to have given implied consent. This will never occur in relation to information that someone might consider to be sensitive. Implied consent is given when at the time of consent, the purpose of collection, use or disclosure would be considered to be obvious to a reasonable person, and the person giving consent provides their information voluntarily to us. To reiterate the point: if you do not understand the purposes for which information is being collected, or is to be used or disclosed, you should not provide us with that information. This may, in some limited circumstances, include refraining from using our website.
There a number of ways in which we will ascertain that people consent to us collecting, using and/or disclosing their information. These include, but are not limited to:
· Application and registration forms, the filling out of which will be deemed to indicate express and/or implied consent.
· Check boxes that allow users to ‘opt in’.
· Verbal consent provided over the telephone.
· In relation to clickstream data, the fact that an individual chooses to use our website.
· The provision of information to us in relation to a specified or obvious purpose.
Note that consent can also be given by an authorized representative, like a legal guardian, or a person with power of attorney. You have a right to withdraw your consent at any time, subject to any legal or contractual restrictions and reasonable notice. Please contact our Privacy Officer in order to do this; they will inform you of the implications of withdrawing consent.
5. Personal Information about Minors
We understand how important it is to protect the privacy of children. As such, we do not collect, use or disclose on our website any information whatsoever relating to an individual whom we know to be under 13 years old without the prior, verifiable consent of his or her parent or guardian. Should any such information be inadvertently collected, used or disclosed, the child’s parent or guardian has the right, upon request to our Privacy Officer, to view the information provided and/or to request that it be deleted.
In general, we do not intend to collect personal information from individuals under 18 years old without the consent of their parent or guardian. If you discover that your child has provided us with personally identifiable information without your consent, we ask that a parent or guardian of the child contact our Privacy Officer to have this information deleted from our records.
6. Access, Corrections and Destruction
Personal information that we maintain is kept as accurate, as up-to-date and as complete as is necessary. What is deemed necessary relies on the purposes the information is used for and the interests of the individual the information relates to. In general, information we maintain will have a degree of accuracy, completion and currency sufficient to minimize the possibility of a decision being made about an individual based on inappropriate information. We do not update information routinely except where such a process is necessary to fulfil the purpose the information was collected and is used for. Information we use on an ongoing basis is generally accurate and up-to-date, subject to other limitations.
You have a right to request access to or correction of personal information about you that we maintain, where you believe that information might be out of date or incorrect. However, please note that there be may be circumstances in which your request is not granted or made subject to conditions. You also have the right to withdraw your consent to use the personal information about you that we maintain. Where you successfully demonstrate the inaccuracy or incompleteness of personal information, we shall amend that information as required. This may involve correcting, deleting or adding information.
6.1 Privacy Officer
Please contact the Privacy Officer using the details provided in clause 7 in order to:
· Inquire whether we hold personal information about you
· Request access or corrections to personal information about you that we possess or control.
· Withdraw your consent to our use of your personal information.
· Inquire about any of our policies and procedures relating to personal information
· Make complaints about our application of or adherence to relevant privacy laws.
· Request an account of third parties to whom we have disclosed your personal information.
6.2 Limitations on right to Access and Corrections
· Access or corrections may in some circumstances be subject to legal restrictions.
· There may be circumstances in which we expect you to provide updated information to us. These circumstances will only come about when it is reasonable for us to expect this.
· We may take reasonable steps to confirm your identity before we grant access or make corrections to information; you may be required to provide sufficient information.
· In some circumstances we may not be able to provide access to your personal information. These circumstances may include, but are not limited to, circumstances where that information contains confidential commercial information, circumstances where information about you contains personal information of other persons and circumstances where information is subject to solicitor-client privilege.
· Where it is not possible for us to provide a list of the organisations to which we have actually disclosed information, we will provide a list of organisations to which we may have disclosed information.
· Where we refuse to grant you access or to make corrections to your personal information, we will provide reasons for our refusal.
Please note that we only keep personal information for as long as it is required to fulfil the purposes it was collected for. After this we anonymise or erase this information. However, where personal information has been used to make a decision about an individual, we will retain that information long enough to allow that individual to access the information after the decision has been made. When information is destroyed or erased, care will be taken to prevent unauthorized parties gaining access. To inquire further about our guidelines and procedures relating to retention and destruction of personal information, please contact our Privacy Officer.
7. Privacy Officer
Our Privacy Officer is responsible for ensuring we comply with this Policy and all relevant privacy laws. Please contact our Privacy Officer using these details:
Altamira Guitars LLC
PO Box 9314
South Yarra, Victoria, 3141
Please note that the Privacy Officer may not be responsible for day-to-day processing of information. Also note that the Privacy Officer may at times delegate other individuals to act on his or her behalf.
8. Other Information
While using our websites, ‘cookies’ may be stored on your computer. Cookies are identifiers that our web-server sends to your computer in order to identify the computer being used for the duration of the session. They allow us to improve your experience with this website in a variety of ways, such as tailoring our website to better match your interests and preferences. They also allow us to observe your movements around this website, and to re-market to you when you use participating third party websites. Cookies do not include personal information and are read only by the server that placed them. Cookies are unable to execute any code or virus.
Please note that it is your responsibility to block cookies that will be – or delete cookies that are – stored on your hard drive. While our website may store cookies on your computer, we cannot block cookies from it or delete cookies on it. Most Internet browsers are set-up to accept cookies automatically. However, with most browsers, you are able to erase cookies from your computer, deactivate the storing of cookies or adjust your browser’s settings so that you are notified before a cookie is stored. You should refer to your browser’s instructions to learn more about how to do these things. Please note that if you choose to erase or block cookies, some features and sections of our website may be unavailable to you or may not function properly.
8.2 Links to and from our website
This website will often contain links to the websites of third parties. These links may direct users to a variety of content, including, but not limited to, studies, government websites, the websites of our affiliates or associates, social media pages and news websites. While we endeavour to only link to websites that share our own high standards of decency and fairness, we cannot control, nor do we take responsibility for, any content, policies or actions of linked websites. When you use linked websites you should be aware that you are subject to their privacy policies, not ours. We also accept no responsibility for the content, policies or actions of any website which links to this website without our consent.
We use reasonable and appropriate safeguards to protect your personal information in our possession against loss, theft and unauthorized access, modification or disclosure. These safeguards include physical, organizational and technological measures and are periodically reviewed in order to sure they are adequate in light of technological developments. These measures are adapted to the sensitivity of the information about you that we possess. Our authorized employees, agents and contractors will have access to your personal information where it is necessary for them to fulfil their job requirements. We acknowledge that our responsibility extends to information that has been transferred to a third party for processing, and during such processing we will provide a comparable level of protection.
Despite the measures we employ, please note that no network, particularly the internet, is ever 100% secure. Any information disclosed online can potentially be obtained and used by third parties. As such, we are not responsible for any loss, corruption or unauthorized acquisition of personal information provided to this website. Moreover, we are not responsible for any damages resulting from such loss, corruption or unauthorized acquisition.
10. Changes to this Policy
In order to accommodate changes to our business, website, and to legal and technological developments, we reserve the right to change and adjust this Policy as we see fit. The terms that govern our collection, use and disclosure of your personal information will be the terms of this Policy in effect at the time that information is collected, used or disclosed.
If you are concerned about changes to our policy, please contact our Privacy Officer using the details set out in clause 7. We will take reasonable steps to notify individuals where changes to this Policy will result in us using, collecting or disclosing their personal information for purposes materially different than those originally proposed. However, we strongly suggest that all users of this website review this Policy frequently in order to note any changes made. This is because any usage of this site is deemed to indicate acceptance of the terms of this Policy at the time of such usage, including any changes made.
Where clickstream data is deemed to be personal information. By using our website you consent to our collection of click stream data. Please note that we collect and use our clickstream data anonymously, and as such it may not always be considered to be personal information under applicable laws.
This information includes data about things like when you accessed the site, how much time you spent on it, and the areas of the site you visited. Clickstream data is sometimes considered to be personal information for the purposes of the applicable laws. Please note that our click stream data is kept anonymous and is not used to identify you. By using our website you consent to the collection of this click stream data, whether it is considered personal information or not.