By accessing and using this Website, you agree that you have read and understand this Policy and you accept and consent to the privacy practices (and any uses and disclosures of information) that are described in this Policy.
This policy sets out the personal information management practices of Oaktree. It covers the following areas:
- Application of Policy
- Responsibilities of personnel
- Collection of personal information
- Collection of sensitive information
- Use and disclosure of personal information
- Cross-border disclosure
- Credit card & paypal security
- Accessing and updating personal information
- Security of personal information
- Information security
- Data tracking
- Links to other websites
- Changes to Policy
- Contact details
APPLICATION OF POLICY
This policy applies to all Oaktree personnel, including volunteers and other individuals with whom we conduct business in Australia. Oaktree will endeavour to handle your personal information in accordance with this Policy and the Australian Privacy Principles.
RESPONSIBILITIES OF PERSONNEL
It is the responsibility of all personnel to:
- be familiar with this Policy; and
- comply with this Policy.
COLLECTION OF PERSONAL INFORMATION
Personal information is any information or opinion about an individual which makes their identity reasonably ascertainable. Oaktree, through the Live Below the Line campaign, only collects personal information that is necessary for its functions and activities. Such information will only be collected with the consent of the individual or otherwise in accordance with the law. The type of personal information that Oaktree collects about an individual depends on the nature of that individual’s particular involvement with Oaktree. Some examples of the type of information collected are: name, age, address and emergency contacts.
As with many other Websites, the Web servers used to operate this Website may collect certain non-personal data pertaining to users of this Website and the equipment and communications method that they use to access the Internet and this Website. Without combining these data with other sources of information, they do not readily or personally identify individuals. They may reveal such things as the Internet protocol (“IP”) address assigned to an individual’s computer, specific pages that an individual accessed on this Website or immediately prior to visiting this Website, and the length of time spent in a visit to this Website. The purposes for which this information is collected and used include facilitating website operation and system administration, the generating of aggregate, non-identifiable statistical information, monitoring and analysing website traffic and usage patterns, and improving the content and content delivery with regard to this Website and the content, materials, opportunities, and services that we describe or make available on this Website.
If you have provided your consent, you may receive updates from Oaktree about our mission to fight extreme poverty as well as updates on Oaktree’s initiatives, including the Live Below the Line campaign. If at any time you would like to unsubscribe from Oaktree’s email list, you may do so by clicking the unsubscribe link in the email. Oaktree may also use “cookies” (small text files stored on users’ computers) to help track and customise access and use of this Website. Cookies store and retain information that helps us recognise individuals when they return to this Website following a previous visit. Most popular Internet browser packages allow one to configure the browser so as not to accept cookies. However, setting your browser to reject cookies may, in certain instances, prevent you from taking full advantage of this Website and the materials, products, and services that we make available on this Website.
COLLECTION OF SENSITIVE INFORMATION
For the purposes of this section, sensitive information includes the following:
- information or an opinion about an individual’s:
- racial or ethnic origin; or
- political opinions; or:
- membership of a political association; or
- religious beliefs or affiliations; or
- philosophical beliefs; or
- membership of a professional or trade association; or
- membership of a trade union; or
- sexual orientation or practices; or
- criminal record;
- that is also personal information; or
- health information about an individual; or
- genetic information about an individual that is not otherwise health information; or
- biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
- biometric templates.
Oaktree may collect sensitive information from individuals. Such information will only be collected where necessary for conducting Oaktree’s activities. Oaktree will not collect sensitive information about an individual without first obtaining his or her consent.
Individuals who provide information will always have the option of providing such information anonymously or using a pseudonym, except in relation to matters where it is impracticable for Oaktree to deal with individuals who have not identified themselves.
USE AND DISCLOSURE OF PERSONAL INFORMATION
Oaktree will generally use and disclose personal information for the purpose, and purposes related to the purpose, for which the information was collected, or where the individual has consented to the use or disclosure. Oaktree reserves the right to use or disclose personal information about an individual for the purpose of direct marketing provided that the following criteria have been met:
- Oaktree collected the information from the individual; and
- the individual would reasonably expect Oaktree to use or disclose the information for that purpose; and
- Oaktree has provided an effective means by which the individual may request not to receive direct marketing communications from Oaktree; and
- the individual has not made such a request to Oaktree.
In addition, Oaktree may disclose personal information to third party service providers who assist Oaktree in providing its services. These may include companies which assist with data processing and analysis, research, mail services or maintenance. Personal information will only be disclosed to those third party service providers on a confidential basis so that the service provider can effectively provide those services.
Oaktree uses internet providers based overseas and it is possible that personal information about an individual may be disclosed to them. It would not be practicable for Oaktree to provide a list of countries where such recipients are likely to be located.
In the event that Oaktree does disclose personal information about an individual to an overseas recipient, such as a third party service provider, Oaktree will take such steps as are deemed reasonable in the circumstances to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to the information.
DISCLOSURE WHEN REQUIRED BY LAW
Oaktree may otherwise use or disclose personal information where required or authorised by law, which may include emergency situations and assisting law enforcement agencies.
CREDIT CARD & PAYPAL SECURITY
SecurePay, Stripe and PayPal all adhere to international PCI (payment card industry) compliance standards for data security.
Payment Card Industry Data Security Standard (PCI DSS) is a set of 12 requirements that all businesses who handle credit or debit card payments must comply with. The PCI Security Standards require all merchants, regardless of size or number of transactions, who accept, store, transmit or process any cardholder data to comply with PCI DSS. You can find out more about PCI here.
ACCESSING AND UPDATING YOUR PERSONAL INFORMATION
Oaktree takes steps as are reasonable in the circumstances to make sure that the personal information collected, used and disclosed is accurate, complete and up-to-date. Individuals have the right to request access to, or the correction of, any personal information held by Oaktree about them. They are asked to send a request to firstname.lastname@example.org. As much detail as possible should be provided by the individual about the particular information sought, in order to enable Oaktree to retrieve it. A reasonable access fee may be charged to cover the costs of providing that information. The information will be provided within a reasonable period of time after the request is made.
If Oaktree either receives a request to correct information or is satisfied that, having regard to the purposes for which the information is held, the information is inaccurate, incomplete or out of date, Oaktree will take such steps as are necessary in the circumstances to correct that information.
In certain circumstances, Oaktree may not be required by law to provide the individual with access to, or to correct, personal information. If this is the case, reasons will be given for that decision. If Oaktree corrects information about an individual that it previously disclosed to another APP entity and the individual requests Oaktree to notify the other APP entity of the correction, Oaktree will take such steps as are reasonably necessary to give that notification unless it is unlawful or impracticable to do so.
SECURITY OF PERSONAL INFORMATION
Oaktree takes reasonable steps to protect all of the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure. This protection applies in relation to information stored in both electronic and hard copy form.
In relation to any personal information retained by Oaktree which is no longer necessary for any purpose for which the information is used and which Oaktree is not required to retain under Australian law, Oaktree will take reasonable steps to destroy or de-identify the information.
Oaktree uses firewalls and other industry standard security technology, as well as industry standard security practices, to protect personal and confidential information that we receive and to prevent that information from being accessed by unauthorized persons. For example, we work to protect the security of information submitted through this Website during transmission by using Secure Sockets Layer (SSL) software, which encrypts information. The information that you submit through the Site is gathered on computers, and stored in a data centre, protected by industry standard security practices. The number of employees that have physical access to our data centre, and to the computer on which personal information is stored, is limited.
Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. Once we receive your transmission, we make our best effort to ensure its security on our systems
You are responsible for the use and safeguarding of any login ID that we issue to you regarding the use of this Website and any associated passwords. It is important that these be protected in order to protect against unauthorised access to data regarding your account, and to your computer.
URLs contained in emails may contain an ID that enables us to correctly identify the person who takes an action using a web page. Oaktree uses these URLs to simplify the process of signing petitions and filling out surveys. We may occasionally present a shortened URL that references a longer URL which contains an ID - we do this to simplify the display, to prevent links from becoming broken when copied, and to ensure compatibility with email programs which do not handle long URLs. When a shortened URL is displayed in an email, you will see the full URL in the browser's address bar when you access the page.
LINKS TO OTHER WEBSITES
We may revise or amend this Policy at any time at our sole discretion. If we make any substantive changes in the way we collect or use personally identifying information provided by users, we will post a prominent announcement on our web site home page and post the changes on this page. We will never change our policies and practices to make them less protective of user information collected prior to the effective date of any changes without the consent of affected users. We encourage users to visit this page periodically to review our current policy.
If you have any questions about this privacy statement, your personal information, or the practices of this Site, you can contact us at email@example.com
If you wish to make a complaint about a breach (or alleged breach) by Oaktree of this Policy or of the Australian Privacy Principles, you are requested to follow the mechanism set out on the Oaktree Complaints page. This can be accessed via the following URL:http://www.oaktree.org/complaints.
In the event that you are not satisfied with the resultant decision made by Oaktree, you may explore further options in external dispute resolution. Alternatively, you may make a complaint to the Commissioner under Part V of the Privacy Act 1988.