This privacy policy sets out how Disrupt Media Ltd (ACN 655 469 542) and its subsidiaries and related bodies corporates (“we”, “us”, “our” “DML”) treat the privacy of our customers and consumers, suppliers and people we have or might do business with, shareholders, prospective employees, audiences or users of our various radio, broadcast, publishing, technology, app and podcast services and others with whom we interact. 

In the course of conducting our business we may collect, handle, process and store personal information and if you submit your personal information to us, subscribe to or use our goods or services, or otherwise interact with us then you consent to such collection, handling, processing and storage. 

To the extent required by law, we are bound by and committed to the Australian Privacy Principles set out in the Australian Privacy Act (1988)(Cth.) (the “Australian Privacy Act”). 

In this privacy policy, the term “personal information” has the meaning in the Australian Privacy Act. In the Australian Privacy Act, personal information is any information or opinion about an identified or reasonably identifiable individual. 

It includes a subset of information that constitutes “sensitive information” as defined in the Australian Privacy Act. 

The personal information we typically collect about individuals may include, without limitation: 
 
(a) Name, addresses, email addresses and phone numbers; 
 
(b) Age, date of birth, marital status, income, interests, nationality and gender; 
 
(c) Credit card, superannuation, taxation, banking or other financial details; 
 
(d) Quotes, testimonials, opinions, photographs, audio, video and audio-visual footage; 
 
(e) Passport and identity card details; and 
 
(f) Employment history, experience and CV information. 
 

1. Collection and Storage of Personal Information. 

We may collect, handle, process and store personal information for our necessary business purposes including without limitation:  

 
(a) When providing or receiving goods or services; 
 
(b) When you subscribe to or sign up to become a user of our goods or services; 
 
(c) When you communicate or post content revealing your identity or the identity of another person on any of our assets, including our apps, websites, social media platforms, radio or TV stations/shows or streaming services; 
 
(d) When you correspond, call, post, complete a survey, or send us a message including without limitation via our websites, apps, surveys, forums, telephone, letter, email, message or social media platform; 
 
(e) When you ask or agree to be added to a marketing or newsletter list, including without limitation an email or SMS list; 
 
(f) When you enter into a competition or trade promotion (including through our related websites such as www.icanwin.com.au); 
 
(g) When you participate in a loyalty program that we run or administer; 
 
(h) When you ask for and we issue tickets to events for you; 
 
(i) When we arrange travel/ tours/ accommodation/ entertainment for you, your family, friends, colleagues, employees, clients or others; 
 
(j) When you participate in research, such as surveys that we run or are associated with; 
 
(k) When you download an app or stream content through an app that we are associated with; 
 
(l) When dealing with personnel from an organisation that is doing or considering doing business with us; 
 
(m) When you enter into a transaction with us using a credit card or method other than cash; 
 
(n) When we evaluate job applicants and personnel which may include collection of details such as employment history, educational qualifications, referees, emergency contacts and next of kin details. This may include “sensitive information” as defined in the Australian Privacy Act; 
 
(o) When receiving quotes, tenders or proposals; 
 
(p) When you advertise with us; and 
 
(q) When raising capital or undertaking due diligence. 
 

In some circumstances we may obtain personal information about you through a third party, for example, through a user of our goods or services, partner organisation, a business you work for and a prospective, current or future employee. 

2. Anonymity 

Where practicable, you have the right to interact with us and each other anonymously. However, for the purposes of conducting our business and offering goods or services it is not always possible to interact anonymously. 

3. Cookies 

We may use or engage other service providers who use ‘cookies’ to collect data (typically not personal information) relating to your general usage of our digital/online goods or services. 

This data may include IP-addresses, geographic location, browser versions, number & length of visits, how you navigate and similar such data relating to your navigation of our services and linked services and online stores. 

Cookies help us to improve and deliver better and more tailored goods & services. 

Cookies in themselves do not identify individual users and are not used to collect or store personal information about you. Depending on your device, you may refuse to accept some of our cookies by activating settings on your device. 

However, please note that if you select such settings you may be unable to access certain parts of our goods or services. 

We use Google Analytics Services. Google uses cookies and similar technologies to analyse overall trends and help us to understand how users use a website or app, how we can improve our websites and apps, and guarantee their security and continued proper functioning. The information generated by the cookie about your use of the website (including your IP address), or available device identifiers in an app, will be transmitted to and stored by Google on their servers. Google will use this information for the purpose of evaluating your use of our digital products, compiling reports on usage activity and providing other services relating to product activity and usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. 

For more information about the processing of data about you by Google, see Google's Privacy Policy. You can prevent data being used by Google Analytics by downloading and installing the Google Opt-Out Browser Add On provided by Google. For more information about the cookies used by Google, see Google Analytics Cookie Usage page. 

4. Use and disclosure of Personal Information 

In most cases we do not disclose personal information about users of our goods & services to other users, instead limiting the information that is disclosed between users to de-identified and anonymous information. We also frequently provide aggregated information that identifies trends and other sentiments without identifying the individuals who have provided the corresponding feedback or information. 

We use personal information for the purpose it was provided or collected, including without limitation: 

(a) For the purposes of collection described under heading 1 above; 
 
(b) If and when that information is included in feedback from a user; 
 
(c) To respond to enquiries received from you; 
 
(d) To perform authorised financial transactions with you; 
(e) To verify your identity and to assist you if you have forgotten any user ID, user name or password; 
 
(f) To seek user comments and feedback on our goods or services; 
 
(g) To communicate with you and provide you with information (whether by email, 
SMS/message services, post or other means) including, without limitation, to notify you of changes to our goods or services, where you have requested or consented to receiving this from us or where this provision is otherwise permitted under the Australian Privacy Principles or other applicable law; 
 
(h) To allow you to participate in interactive features of our goods or services when you choose to do so; 
 
(i) To receive and address feedback or complaints about us or our goods or services; 
 
(j) To protect our legal interests and fulfil our legal and regulatory obligations (if and to the extent necessary); 
 
(k) To investigate, mitigate and respond to allegations or in the course of resolving disputes or litigation; and 
 
(l) In other circumstances, with the relevant individual’s prior consent. 
 

We may use personal information for the purpose of marketing to users but only where such use complies with the Australian Privacy Act and any other applicable legislation. 

All users and others with whom we interact have the option to opt-out of or unsubscribe from receiving marketing communications from us. 

If you do not wish to continue to receive electronic marketing communications from us and/or selected third parties you should opt-out by clicking on the "unsubscribe" link in any email communications that we might send you. 

We may disclose your personal information to any DML Group companies. They will only use it for the same purposes that we may under this policy. 

We may disclose personal information to third parties who act for or on our behalf, for further processing in accordance with the purpose(s) for which the personal information was originally collected or may otherwise be lawfully processed, such as delivery of goods or services, performing contractual or statutory obligations, awarding prizes, payment processing, research or marketing activities, recruiting, engaging or managing employees, contractors or suppliers, reference checking, data management or technical support. 

We may also disclose your personal information to other third parties outside the DML Group if necessary, including without limitation:  

(a) Where we have your express permission to do so, including disclosing your personal information to our sponsors, advertisers and promotions partners where you have expressly consented (“opted in”) to being contacted by them; 
 
(b) Where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties; 
 
(c) If we or some or all of our business or assets are acquired by a third party, in which case relevant personal information may be one of the transferred assets; 
 
(d) If we are under a duty to disclose or share personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions or to protect our rights, property, or safety, our personnel or customers. This includes exchanging information with other companies and organisations for the purposes of investigation, fraud protection and credit risk reduction; 
 
(e) If we are seeking professional advice or assistance, including without limitation, legal, financial or recruitment services; or 
 
(f) To persons acting on your behalf including those persons nominated by you, including without limitation your executors, trustees and legal representatives. 
 

We would only use or disclose the type and amount of information necessary to carry out the relevant purpose. 

5. Disclosure and transfer of information overseas 
 

We do not otherwise disclose or transfer personal information outside Australia except if and in the context of: 

(i) arranging travel, accommodation or other goods or services to be provided in other countries, at your request or  

(ii) sharing your personal information within our group of companies or  

(iii) sharing your personal information with third parties solely in accordance with this policy, in circumstances where they may store your personal information in overseas locations, including the United States of America, United Kingdom, European Union, Singapore and Japan. 

Our personnel may access your personal information whilst travelling overseas. 

6. Security of personal information 
 

We hold personal information in our own premises, devices, secure databases and in secure storage facilities. We may also engage third party service providers to assist in storing, backing-up and processing certain types of personal information for us, some of which may be located overseas, including Australia, the United States of America, United Kingdom, European Union, Singapore and Japan. 

We take reasonable steps to protect your personal information, including by internal and external security measures and restricting access to those who have a need to know. 

We implement and maintain measures to prevent unauthorised access and regularly review our security. 

We treat website and credit card security seriously and endeavour to provide a secure, safe platform through which to conduct transactions. 

7. Links to Third Party Sites 
 

Whilst links to third party websites may be provided on our websites, apps or digital assets, we are not responsible for the content or practices of these third-party websites. 

These links are provided for your convenience and do not represent our endorsement of any linked third-party website. 

We recommend that you check the privacy policies of these third parties prior to providing them with your personal information. 

No links may be made to our websites, apps or digital assets without our prior written consent. 

8. Questions and concerns and access to / correction or updating of your personal information 
 

You have a right to access and if necessary, correct the personal information we hold about you, subject to the exceptions set out in the Australian Privacy Act. 

To obtain a copy of the personal information we hold about you, or if you wish to make a complaint about a breach of the Australian Privacy Act or this privacy policy, please write to us at: 

 
The Privacy Officer 
Disrupt Media Ltd 
Level 1, 111 Coventry Street, Southbank, Victoria 3006, Australia 
 

Or by email at: 

privacy@disrupt.radio 
 

Please provide sufficient detail about the information in question to help us locate it. If applicable we will then use commercially reasonable efforts to promptly determine if there is a problem and take the necessary corrective action within a reasonable time. 

We may charge a fee for giving you access to that information, which is reflective of the costs of providing the access. 

If you consider your privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, you can contact: 
 

The Office of the Australian Information Commissioner on 1300 363 992 or visit their website at www.oaic.gov.au. 

9. Changes to our privacy policy 
 

We may modify, alter or otherwise update this privacy policy at any time. We will post revisions on our website. We encourage you to review this policy from time to time. 

Last update: June 2023