The RaRa Agency Privacy Policy

Last Modified: 9 July 2018

  1. Privacy Statement

Byrne Baby Byrne Pty Ltd ACN 150 443 913 trading as The RaRa Agency (we, us, our) consider your privacy to be important and we take our responsibility to protect it seriously. We understand that you are concerned about your privacy, along with the confidentiality and security of any personal information that you provide to us.

This privacy policy (Policy) sets out how we collect, hold, use and disclose information about individuals who deal or interact with us. We treat all personal information collected by us in accordance with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles contained within the Privacy Act and this Policy. If there is any inconsistency between the Privacy Act and this Policy, the Privacy Act will prevail to the extent of the inconsistency.

  1. Anonymity

Due to the nature of the goods and services we provide it is generally impractical for us to deal with you without knowing your name and your contact details. However, where it is practical for us to do so, we shall provide you with the option to deal with us anonymously or by using a pseudonym.

  1. Collecting personal information

Personal information is information or an opinion of an individual whose identity is apparent or can be reasonably ascertained. We collect a range of personal information, including from employees, contractors and customers, which is reasonably necessary for the purposes of conducting and improving our business, and delivering our products and our services. Where it is reasonable or practical to do so, we will endeavour to only collect personal information from you. Where it is not reasonable or practical to collect information from you, then we will notify you as soon as practicable after we have collected the information, tell you why we have collected the information and give you the opportunity to opt out of receiving any further communications from us. The personal information we collect is collected from a wide variety of sources including:

(a)                    through our website www.theraraagency.com.au (the Site);

(b)                    through the provision of our services;

(c)                     directly from our clients/customers/users;

(d)                    through marketing research;

(e)                    from persons conducting business or intending to conduct business with us, whether past, present, or future;

(f)                      via surveys;

(g)                    by otherwise having some form of contact with us such as such as by mail, telephone, email, internet, or intranet; and/or

(h)                    through any of our other business activities or events.

Personal information collected by us may include:

  • your name;
  • your gender;
  • your date of birth;
  • your address;
  • your occupation;
  • details about your business and/or employer;
  • your educational background;
  • your contact details such as your mobile number, telephone number and email address;
  • details of your photo identification (passport or driver’s licence);
  • details of your licenses, authorisations, certifications or other qualifications required for us to provide services to you;
  • if you are an employee or contractor, details of your licenses, authorisations, certifications or other qualifications required for the purposes of your employment or our engagement with you;
  • your preferences and opinions relating to our services; and
  • all logs, which may include information such as your internet protocol (IP) address, browser type, browser version, clickstream data, referring URLs, the pages of our Site that you visit, the time spent on any pages of our Site and other log related information relating to your use of our Site.

We endeavour to only collect personal information about you where it is reasonably required.

  1. Sensitive Information

From time to time we may be required to collect and disclose information relating to your membership to a professional or trade association or union, any criminal record you may have or your personal health information, including health and medical records provided to us by medical service providers (Sensitive Information). We will only collect and disclose such information where it is reasonably necessary for the conduct of our business, delivery of our goods and services or is required in the course of our commercial engagements, and not for any other reason. By engaging our services, continuing to utilise our services or dealing with us in any way, you hereby expressly consent to the collection and disclosure of your Sensitive Information.

Where you are an employee or contractor of The RaRa Agency, we may be required to provide Sensitive Information in the form of your health and medical records to customers that engage our services. Again, by accepting or continuing your employment with us, accepting or continuing your engagement with us, or otherwise dealing with us in any way, you hereby expressly consent to the collection and disclosure of your Sensitive Information.

  1. Use of personal information

We automatically gather information to monitor the use of our Site and provision of our services.  Much of the data we collect is aggregated, and this information is effectively anonymous to us.

In general we use personal information for providing our services and for evaluating, improving, personalising and developing our business, our Site and our services.  More specifically we use personal information for:

(a)                    where you are an employee or contractor, in our dealings with customers that require your personal information in order for us to provide our goods or services to them;

(b)                    where you are an employee or contractor, determining whether you are suitable for a position within our business;

(c)                     providing a service to you that has been requested;

(d)                    providing support to you;

(e)                    promoting and marketing our services (each person may opt-out of marketing and sales communications);

(f)                      obtaining credit history information about customers and potential customers;

(g)                    assessing, investigating and processing any instances of loss, theft or damage that arises out of, or incidental to, the use or hire of our equipment;

(h)                    our internal research and statistical purposes (including market segmentation, market analysis, trend identification and customer value analysis);

(i)                       training and recruitment of employees and contractors;

(j)                       processing and managing complaints and disputes, including reporting to third party dispute resolution providers; and

(k)                    enabling us to forward to you other information or material which we believe may be of interest to you (each person may opt-out of our information sharing communications).

  1. Disclosure of personal information

6.1                  Disclosure generally

We will only disclosure your personal information in limited circumstances. We may disclosure your personal information to our employees, contractors or service providers for the purposes of delivering our services and fulfilling your requests, conducting our business activities and in order to operate our website. We may also disclose your personal information in the course of our dealings with third parties with whom we have, or intend to have, commercial relationships. This includes debt collectors when payments are overdue.

Where you are an employee or contractor, we may be required to disclosure your personal information to a customer that we are dealing with, have dealt with in the past or intend to deal with in the future, in order to (among others):

(a)                    allow you to enter a customer site or premises in order to provide particular services;

(b)                    satisfy a customer that you have the necessary skills, qualifications and experience, and are otherwise fit to, provide particular services;

(c)                     enable us to prepare tenders, proposals, quotes or otherwise with a view to entering into a commercial transaction or relationship with a customer; or

(d)                    to otherwise conduct our business.

Aside from the above, we will only disclose personal information as legally required – either upon valid court order, as required under the Privacy Act, or where compelled by a law enforcement or governmental agency.

6.2                  Information you make public

Certain information you provide is available for others’ view. Any information you create or post in these locations will not be private.

We urge you to exercise caution when deciding to disclose your personal information in a  public space. You agree to assume all responsibility for all personal information that you have made public.

  1. Protecting your personal information

7.1                  Steps we take

The personal information that we collect may be stored from time to time within our internal systems, as well as third party servers and/or private clouds. We also store personal information in hard copy. We take reasonable steps to protect personal information we hold from:

(a)                    misuse, interference and loss; and

(b)                    unauthorised access, modification or disclosure.

The precautionary steps we take to protect personal information include:

  • adopting measures to protect our computer systems and networks for storing, processing and transmitting personal information;
  • adoption of procedural and personnel measures for limiting access to personal information by our staff;
  • conducting reviews of our information collection, storage and processing practices; and
  • such other security measures we consider reasonable and appropriate from time to time.

Notwithstanding that we use our best endeavours to protect all personal information we collect and hold, please be aware that we cannot guarantee its complete security and will not be responsible where it is obtained illegally or without our authority by third parties.

7.2                  Deleting your personal information

When personal information is no longer required to be kept by us, we will take reasonable steps to destroy or delete the personal information in a confidential manner.

  1. Cookies

Cookies are files with small amounts of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.

We use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, this may limit your ability to use some features of our products and services.

  1. Web beacons

Web beacons (also known as clear gifs, pixel tags or web bugs) are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of web users or to access cookies.

Unlike cookies which are stored on the user’s computer hard drive, web beacons are embedded invisibly on web pages (or in e-mail).

Web beacons may be used to deliver or communicate with cookies, to count users who have visited certain pages and to understand usage patterns.

Like many sites, we use web beacons to collect information which is done in accordance with this policy.

  1. Overseas disclosure

10.1              Disclosure for analytics

We may use Google Analytics to track your usage of our website.  Google Analytics is a web analysis service provided by Google. Google utilises the data collected to track and examine the use of the website, to prepare reports on the site’s activities and share them with other Google services.

Google may use the data collected to contextualise and personalise the ads of its own advertising network.  Personal data collected by Google includes cookie and usage data, which is processed in the USA. You can find Google’s privacy policy here: http://www.google.com.au/policies/privacy/.

10.2              Consent to overseas disclosure

Other than as contemplated in this clause 9, we will only disclose your personal information to an overseas recipient if:

(a)                    you consent to the transfer; or

(b)                    the disclosure of the information is required or authorised by or under an Australian law, other applicable law or a court/tribunal order.

We will take reasonable steps to ensure such overseas recipients do not breach the Australian Privacy Principles (APP’s) or are subject to laws or a scheme substantially similar to the APP’s.

  1. Third parties

Our Site, products and the services we provide may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit.

We confirm that we have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third party sites, products or services whatsoever.

You should be aware that your ability to opt-out of a third party tool or platform will depend on the conditions governing your agreement with that third party.

  1. Accessing and updating your personal information

12.1              Access to Personal Information

We will provide you with access to your personal information held by us unless:

(a)                    giving access would be unlawful; or

(b)                    denying access is required under the Privacy Act or any other applicable law.

12.2              Request for Access

To request access to your personal information, please send a request to contact@ra.bbabyb.com.au in writing making such a request. Following receipt of your request, we will contact you and either provide you with the information you have sought, or return to you with an explanation detailing why we will not provide you with the information. We may at our discretion charge an administrative fee to cover our costs associated with providing you access to your personal information. However, this fee will not apply to your act of making a request (only us fulfilling it), will not be excessive and will not apply to the correction of any of your personal information.

12.3              Amending your personal information

We endeavour to keep all personal information we hold accurate, up to date and complete. If at any time you wish to correct any of your personal information you may do so freely at any time by contacting us to request an amendment. If we elect not to correct your information, we will notify you, within a reasonable time, of the reason for our refusal, the mechanisms available for you to complain about our refusal and such other matters required by the Privacy Act.

If you wish to have your personal information deleted, please let us know and we will take all reasonable steps to delete it, unless we need to keep it for legal reasons.

  1. International users

If you are located outside the Australia and choose to provide your personal information to us, your personal information will be transferred to Australia and processed in accordance with this Policy.

  1. Complaints

We strive to ensure our compliance with this Policy and to regularly review our practices against it.

If at any time you have a complaint against us regarding our Policy, including a breach of the Privacy Act, we invite you to make a complaint via email to contact@ra.bbabyb.com.au . All complaints made will be dealt with in confidence. We endeavour to respond within 30 days of receipt of a complaint with a resolution or proposed resolution to the issue raised.

Please note that you may also make a complaint to the Office of the Australian Information Commissioner (OAIC) about the handling of your personal information.  Information on making a privacy complaint can be found on their website at http://www.oaic.gov.au/privacy/making-a-privacy-complaint.

  1. Variations

We reserve the right to vary this Policy from time to time without further notice to you. Any variations made will be updated on our website. We will not reduce your rights under this Policy without providing more. It is your responsibility to check our Policy periodically to ensure you are aware of any changes made to it.

  1. Further information

For any further information about this Policy please contact us by:

Byrne Baby Byrne Pty Ltd trading as The RaRa Agency

PO Box 5088,

MANLY, QLD, 4179