Lovatts Media Group Pty Ltd Privacy Policy

This Privacy Policy document was last updated on: Tuesday 5 February 2019

Lovatts Media Group Pty Ltd ABN 99 003 314 681 (we, us, our, or Lovatts Media) recognises the protection of your privacy. We also understand that our consumers, audiences and stakeholders want clarity about how we manage the personal information that you provide us with. We have implemented data practices and this Privacy Policy to comply with the requirements of the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles set out in the Privacy Act, and the European Union General Data Protection Regulations.

This Lovatts Media Group Pty Ltd Privacy Policy sets out our approach to ensure you (our customers, audience and/or stakeholders) are informed about how we collect, hold, and use your personal information, and under what circumstances we may disclose your personal information. The Privacy Policy also outlines your rights to, and the method of, gaining access to, seeking corrections of, and having deleted your information we hold. Finally, the Privacy Policy provides information about how you can approach us about your privacy-related concerns and complaints, and how we will deal with such communications.

Through this Privacy Policy we have aimed to be as clear, open and transparent as possible about these matters, but if you have any questions, do not hesitate to contact us at  Email: subs@lovattsmedia.com   or by phone + 61 2 4302 1517 or toll free 1800 254 199 (NZ toll free 0800 254 177) or by post to PO Box 995, Terrigal NSW 2260 Australia.

Lovatts Media Group Pty Ltd ABN 99 003 314 681 owns, publishes, and operates the following magazines, brands, and websites:

Websites

Magazines

Christine’s Big Crossword
Colossus Crosswords
Mega Crosswords
Cluewords
FindaWord
Code Crackers
Crossword and Puzzle Collection
Variety Bumper Puzzles
Acrostic Puzzles
Christine’s Large Print Crosswords
Christine’s Cryptic Crosswords Collection
Lovatts Inklings
Puzzle Fun for Kids
Handy Crosswords
Handy Sudoku
Handy BrainTrainers
Handy Code Crackers

Handy Binary & Hexoku
Handy Wordhunt
Handy Arrowords
Handy Cryptic Crosswords
Handy Puzzles
Handy Killer Sudoku
Handy Acrostic
Kids Bumper Puzzle Fun
Breathe Magazine Australia
Teen Breathe Magazine Australia
Nourish Magazine
Audrey Magazine
Mindful Puzzles
Mindful Parenting
Kit Magazine
Operation Ouch Magazine.

Personal Information and Sensitive Information

Personal information is defined in the Privacy Act as:

Information or an opinion about an identified individual, or an individual who is reasonably identifiable:

  1. whether the information or opinion is true or not; and
  2. whether the information or opinion is recorded in a material form or not (Personal Information).

Sensitive information includes things such as race, sexual orientation, political opinions, membership of a trade association or trade union, criminal record, or health information (Sensitive Information).

Information we collect from you

When you subscribe or purchase one of our publications, websites and/or purchase a product via one of our websites, become a member with one of our brands, sign up to our email newsletter, enter one of Lovatts Media’s competitions, or participate in one of our surveys, we will usually only ask for the following information: first name; surname; birth date; residential or professional address; billing address; shipping address, telephone number; email address.

Lovatts Media may ask you to nominate a User Name and a Password. From time to time, we may ask you to supply additional Personal Information for specific purposes. In such cases, we will clearly explain why we request that information and unless we are required or authorised by law to request that information from you, providing such information to us is optional. Under no circumstances will we request any information from you that may disclose any criminal convictions, your health and sexuality, your race or ethnicity, your political or religious beliefs.

We may conduct surveys or market research and may seek other information from you on a periodic basis. Participation in such activities is optional.

We run competitions and offer additional benefits to you and will ask you to provide us with your Personal Information for these purposes. Providing us with this information is optional to you. However, if you do not provide your Personal Information to us we may not be able to enter you into competitions or offer you additional benefits.

We will not collect Personal Information about you from third parties unless:

  • you consent to the collection of the information from someone else; or
  • it is unreasonable or impracticable to collect the information from you.

Information we collect via Select Publisher Services

Lovatts Media works with a third-party distributor, Select Publisher Services www.selectmagazines.co.uk in the United Kingdom to distribute our subscriptions to the European Market.

Select Publisher Services may disclose your Personal Information to Lovatts Media if the following applies:

  • we have your consent via an opt-in from newsletters, competitions, order forms or via telephone; or
  • for the purposes of Lovatts Media providing products, services or research in association with or on behalf of Select Publisher Services including your magazine subscription
  • for the purpose of Lovatts Media providing administrative, processing, analytical or other similar services to Select Publisher Services to assist Select Publisher Services in the provision of products and services to our customers; or
  • for the purpose of verifying information you have given Select Publisher Services, for example verifying your address for sending a magazine if it has been returned to Lovatts Media; or
  • for the purposes of improving our products, services and marketing communications
  • where we may transfer rights and obligations under any contract with you; or
  • information you provide upon entering a promotion or competition, in accordance with the terms of the promotion or competition; or
  • information you provide when taking part in a poll or survey
  • where we are required or permitted to do so by law or regulation

If you would like to no longer receive communications from Lovatts Media or from your Select Publisher Services subscription, please notify either Select Publisher Services or Lovatts Media at:

Select Publisher Services

Post:

The Data Privacy Manager,
62 Wimborne Road,
Bournemouth, BH3 7AR.

Email: data@selectps.com

Lovatts Media

Post:

Lovatts Media
PO Box 995,
Terrigal NSW Australia 2260


Email: subs@lovattsmedia.com

Phone: +61 2 4302 1517 or toll free 1800 254 199 (NZ toll free 0800 254 177)

Personal Information via the Website

Cookies make using the Website easier by storing information about matters such as your preferences on the Website. This allows the Website to be tailored to you for any of your return visits. Cookies will not be used to identify you personally.

If you would prefer not to receive cookies, you can alter your security settings on your web browser to disable cookies or to warn you when cookies are being used. However, by disabling the cookie function in your web browser you may impede your ability to use parts of the Website.

We collect certain information from you using cookies such as:

  • your browser type;
  • your location;
  • your IP address;
  • information about when and how you use our website;
  • information about your past internet usage, such as websites you visit before coming to our Website.

Your option not to provide your Personal Information

Providing us with your Personal Information is optional but may be required for us to be able to provide you with the services we offer. We require your consent to process your Personal Information for marketing purposes and to maintain your accounts with us and, by providing your consent, you are consenting to our storage, use, and disclosure of that information as outlined in this Privacy Policy. You don’t have to provide your consent and can withdraw it at any time. However, if you do not provide us with consent to maintain a subscription or membership account, your account and access to the associated services will be suspended or terminated. There are no consequences of withdrawing your consent to process your Personal Information for marketing purposes, and you can do so by emailing us at subs@lovattsmedia.com

Unsolicited Personal Information

Where we receive unsolicited Personal Information about you, we will check whether that information is reasonably necessary for delivering our products and services. If it is, we will handle this information the same way we do with other information we seek from you. If not, we will destroy or de-identify it.

Children and minor’s privacy

Although we will comply with this Privacy Policy in respect of information provided to us by persons under the age of 18 years, those persons must obtain the consent of a parent or guardian prior to purchasing our products, entering our competitions, submitting content to our websites, or using our Website, and the parent or guardian will be responsible for appropriately supervising the person’s use of our Website.


Lovatts Media will not intentionally collect data from children under the age of 13 years old and request that subscriptions be held by a person 18 years or older. If you believe that we might have any information from or about a child under 13, please contact our Privacy Officer at subs@lovattsmedia.com 

Disclosure and use of your Personal Information

We are the data controller of the Personal Information we collect from you. We take appropriate measures to ensure that all processing of your Personal Information by us, or by our service providers, is lawful. The lawful basis for the processing of your Personal Information will depend on the purposes for which we process your information.

Much of the Personal Information we collect from you is necessary for us to provide our products and services to you. This includes most of the information you provide to us when setting up a subscription or purchasing account.

Some of the processing we conduct is necessary in pursuit of our legitimate interests in developing our Website and services and ensuring that they deliver relevant and focused content to you.

Your Personal Information, including your email address, will be used, either on its own or as part of aggregated data, for the following primary purposes:

  • providing you with news and information about our services and functions;
  • purposes necessary or incidental to the provision of our services and functions;
  • to ensure the proper functioning of our Website including customising and improving your online experience with us;
  • personalising your experience with our products and services;
  • to assist Lovatts Media with our marketing, planning, product development, and research requirements; and
  • sending you marketing and promotional material that we believe you may be interested in and otherwise communicating with you about our products and services.

We will not use or disclose (or permit the use or disclosure of) Personal Information that could be used to identify an individual member in any circumstances except:

  • to ensure the proper functioning of our business and the Website;
  • to communicate promotional offers and special events to you;
  • where applicable law requires, or authorises, us or a company holding data on our behalf, to do so; or
  • where you have given express consent to us for a prescribed purpose.

Only with your express consent will we use or disclose Personal Information (including Sensitive Information) about you for the purposes of direct marketing.

If we are compelled by law to disclose your Personal Information to a third party, we will take reasonable steps to notify you of this in advance, wherever it is lawful and reasonable for us to do so. We will not sell your Personal Information.

Public Personal Information

Any Personal Information you choose to make publicly available on our Website, for example, by posting reviews on any of our pages, will be available to others. If you remove information that you have made public on our Website, other users may have already saved or downloaded that information, and copies may remain viewable in cached and archived pages of our Website.

Security of Personal Information

Lovatts Media may store your Personal Information electronically and in hardcopy form. We are committed to keeping your Personal Information secure regardless of the format in which we hold it and we take all reasonable steps to protect your information from misuse, interference, loss, and unauthorised access, modification or disclosure. However, your use of the Website is at your own risk and we accept no responsibility, whether we are deemed to have been negligent or not, in the event of a breach of your privacy. In the event that Personal Information is compromised as a breach of security, we will promptly notify those affected in compliance with applicable law.

Please note: No information transmitted over the internet can be guaranteed to be completely secure. However, we will endeavour to protect your Personal Information as best as possible, but we cannot guarantee the security of any information that you transmit to us or receive from us. The transmission and exchange of information is carried out at your own risk.

We use an outside platform, and a third-party credit card processing company to bill you if you purchase services, including but not limited to, the online purchase of a subscription or product via our websites. These companies do not retain, share, store, or use personally identifiable information for any purposes other than billing.

Access to your Personal Information

In most cases, you have the right to access the Personal Information that we hold about you. If you wish to access your Personal Information or obtain more information about how we process it, please contact our Privacy Officer at subs@lovattsmedia.com 

We will deal with all requests for access to Personal Information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require up to 90 days to retrieve.

The right to move, copy, transfer or restrict use of your Personal Information

You have the right to ask us for a copy of your Personal Information to correct, delete, or restrict (stop any active) processing of your Personal Information, and to obtain the Personal Information you have provided to us in a structured, machine-readable format, and to ask us to share (port) this data to another controller. If you would like to do any of these things, please contact our Privacy Officer at subs@lovattsmedia.com We will deal with these requests in the same manner as described above regarding access to your Personal Information.

The right to correction and removal of your Personal Information

The accuracy of the Personal Information we have requested from you is important to us. We will take all such steps as are reasonable in the circumstances to ensure that all information requested from you is kept accurate, up to date, and complete. However, we cannot undertake to ensure that such data, even where it includes Personal Information, is kept accurate, up to date and complete.

Should you suspect, or become aware, that Personal Information we hold about you is inaccurate, out of date, incomplete, or misleading, or if you would like your information deleted entirely, please contact our Privacy Officer at  subs@lovattsmedia.com  

We will deal with all requests for correction and removal of Personal Information as quickly as possible. Requests relating to a large amount of information, or information which is not currently in use, may require further time before a response can be given. If we refuse to change or delete the Personal Information as you request, we will provide you with reasons for our refusal unless doing so would be unreasonable in the circumstances. We will also provide details of how you may make a complaint about our decision. Further, in case of our refusal, you may request that we take reasonable steps to associate, with the relevant information, a statement that you view it as inaccurate, out of date, incomplete, or misleading.

Where we have corrected or deleted Personal Information about you, you may request that we take reasonable steps to give notice of the correction to any third party to which we have disclosed the inaccurate, out of date, incomplete, or misleading Personal Information.

Retention of your Personal Information

If you have a subscription, or have made a purchase with Lovatts Media, or are signed up to receive our communications, we will retain your Personal Information for as long as your account is active, or as needed to provide you with our services. We will also retain and use your Personal Information for as long as someone could bring a claim against us, and as necessary to comply with all other legal obligations and regulatory requirements, to resolve disputes, and to enforce our agreements.

Cross-border disclosure of Personal Information

To provide you with the best service possible, we may use ‘cloud’ based technology services to hold your data, including your Personal Information. As a consequence, your data, including your Personal Information (and if you have provided such information, your sensitive Personal Information) may be held in the data centres used by a provider of such ‘cloud’ based technology services.
It is important to note that, by subscribing, purchasing, or joining a Lovatts Media brand and community or by using one of Lovatts Media’s Website, you consent to your data, including your Personal Information (and where applicable, your sensitive Personal Information) being transferred to data centres located both in and outside of Australia. Your decision to subscribe, purchase, or join a Lovatts Media brand, or to use a Lovatts Media website, signals your consent to this technical arrangement under which Lovatts Media does not exercise any direct control over the management of your data in those data centres.

Disposal of Personal Information no longer required

If we hold Personal Information about you, and we no longer need that information for any purpose for which the information may be used or disclosed, we will take reasonable steps to destroy or de-identify that information unless we are prevented from doing so by law.

Unsubscribing from our email database

To unsubscribe from our email database, please do so via any link or function contained in an email, via the Website, or by sending an email to subs@lovattsmedia.com with “UNSUBSCRIBE” typed into the subject line of the email. Note that, while you maintain a subscription to Lovatts Media publications, you are unable to unsubscribe from certain types of emails, such as important updates (including information about your account, security concerns, and technical issues).

Links to other websites

This Privacy Policy applies only to our Websites, and not to websites owned by third parties. We may provide links to other websites which we believe may be of interest to our visitors. However, due to the nature of the internet, we cannot guarantee the privacy standards of other websites or be responsible for the contents of websites other than our own. This Privacy Policy is not intended to be applicable to any linked website.

Contacting us

If you have any concerns, complaints, questions, or would like more information about our Privacy Policy, or our privacy practices, please contact our Privacy Officer at 
Email: subs@lovattsmedia.com
Phone + 61 2 4302 1517
Toll-free Australian phone: 1800 254 199
Toll-free New Zealand phone: 0800 254 177
Post to: PO Box 995, Terrigal NSW 2260 Australia

If you consider that your complaint has not been adequately dealt with by us, you can make a further complaint to the Office of the Australian Information Commissioner, which has complaint handling responsibilities under the Privacy Act.

Amendments of this Privacy Policy

We reserve the right to modify or amend this Privacy Policy at any time.

For further information about privacy in general, please refer to the Office of the Australian Information Commissioner’s website: http://www.oaic.gov.au.

Privacy Policy last updated on Tuesday 5 February 2019.