PRIVACY POLICY
The Studio.Co is the responsible entity. The Studio.Co is bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act) and we take these obligations seriously.
This Privacy Policy explains The Studio.Co information handling practices including in relation to personal information collected by The Studio.Co. Where appropriate The Studio.Co will handle personal information relying on the related bodies corporate exemption and the employee records exemption in the Privacy Act.
By using any of the The Studio.Co services, you confirm that you have read and agree to the terms of this Privacy Policy. By accepting this Privacy Policy, you expressly consent to the collection, use, disclosure and handling of your personal information in accordance with this Privacy Policy.
This Privacy Policy is incorporated into, and subject to, our Terms of Use, and is in addition to any other terms and conditions applicable to this website or any other services we provide.
We will post any changes to this Privacy Policy on this website, so we encourage you to check this Privacy Policy from time to time.
2. What Personal Information Is Collected and Why
2.1 Customers
2.1.1 What we collect
We collect information about individuals:
(a) who use our websites, mobile applications, social media and other online services (Online Services);
(b) who register, login or subscribe to join our programs, including shopper programs (Member Programs);
(c) who purchase gift cards or otherwise transact with us, participate in surveys or competitions and register for or use any of our services including the hire of mobility aids and other equipment;
(d) who are involved in or witness an incident in our property;
(e) to whom we provide other products or services from time to time.
The types of personal information we collect includes name, contact details, gender, identification information, payment details, registration and activity details relating to our Online Services (such as the date and time you accessed each page on our website; the fully qualified domain name from which you access our websites, or alternatively, your IP address; the URL of any webpage from which you accessed our websites; cookies which track your visits to our websites and the web browsers that you are using and the pages you accessed), Member Programs and other services, transaction details, interests and preferences, device details (including device identifiers, usage and location data), information submitted in forms, details of incidents involving you at our properties, enquiry/complaint details and records of communications and interactions.
The Studio.Co properties are under video and camera surveillance. When entering the The Studio.Co property the personal information and images of individuals may be collected by The Studio.Co.
We generally do not collect “sensitive information” as described in the Privacy Act. If we do, we will seek consent to collect it if required by law to do so.
We collect personal information from you and from other sources including publicly available information, your representatives, information service providers, other The Studio.Co companies and the parties with which we exchange information as described here.
2.1.2 Why
(a) General
We collect, hold, use and disclose your personal information for purposes including to provide, administer, improve and personalise our services, process payments, identify you, communicate with you (including direct marketing and investor communications), conduct promotions, investigate and deal with unlawful activity and misconduct, respond to lawful information requests from courts, government agencies and lawyers, protect our lawful interests and deal with your enquiries and concerns.
If a third party acquires or wishes to acquire, or makes inquiries in relation to acquiring, an interest in The Studio.Co we may disclose personal information to that third party or its advisors.
To help us understand and serve you better, we may combine personal information we hold about you with personal and non-personal information from different sources. For example, we may obtain demographic data from an information service provider to tell us about the interests of people in your postcode and use it to help us predict which products and services might appeal to you. These sorts of activities may be conducted in connection with our Online Services and Member Programs as described further below.
(b) Online Services
Users of our Online Services are not required to provide us with any personal information. However, we may not be able to provide the information or service a user requests – including access to, and use of, a Member Program – if the personal information which is indicated as mandatory is not provided.
We may also collect aggregated information which tells us about users of our Online Services but not the identity of those users, unless they register to join a Member Program (in which case, the identity of a user may become apparent). For example, we may collect information about the date, time and duration of visits and which pages or parts of those Online Services are most commonly accessed. We may also collect internet address domain names, the previous websites visited and the types of browser visitors are using. This information is used by us for internal research, statistical and website development purposes. It may also be used by us to provide users with offers, discounts, promotions, advertising, products, services and other content.
Our Online Services may use “cookies”. A cookie is a small message in a text file, and the message is then sent back to the server each time the browser requests a page from the server.
Cookies may be used by us for a variety of purposes. For example, we may use cookies to recognise a browser which has previously accessed our Online Services and customise our Online Services according to previous preferences and behaviour. Cookies may also be used to manage security and store information about the type of browser being used. With most Internet browsers, users can erase cookies from their computer’s hard drive, block all cookies, or receive a warning before a cookie is stored. However, some parts of our Online Services may not function fully for users who disallow cookies.
Our Online Services may, from time to time, contain links to the websites and online services of other organisations which may be of interest to you. Those other organisations are responsible for their own privacy practices and you should check those websites and online services for their respective privacy statements.
(c) Member Programs
If you join a Member Program, we may:
(i) collect and process personal information such as your name, email and other contact details (including any information provided by filling in forms using our Online Services); and
(ii) collect data about your usage history on our Online Services and other websites operated by third parties which allow your device to be added to one or more interest categories (for example “women’s shoes”).
We use this data for the purpose of analysing usage of our Member Programs, improving our content and product offerings, customising our content, layout and services and providing you with offers, discounts, promotions, advertising and services which are targeted to your interests.
Our Online Services may include functionality that makes use of the hosting device’s geographic position on approach and entry into a participating shopping centre. This means that if you joined a relevant Member Program, and you use one of those Online Services, you may be located by us or our service providers and contractors by reference to the location of your device. We may use this functionality to locate and send you offers, discounts, promotions, advertising, products, services or other content on your device.
If you do not consent to us:
(i) using data about your browsing activity to contact you and deliver offers, discounts, promotions, advertising or other content targeted to your interests; or
(ii) using data about your device location to provide you with location-based services available through a Member Program,
you are always free to delete your cookies and cease participation in the Member Program. In the case of (i), your device and browser may also give you options to turn off location services either generally or for particular apps or sites.
2.2 Licensees and Prospective Licensees
2.2.1 What we collect
The Studio.Co collects the following types of personal information from unincorporated Licenseess and guarantors during negotiations for, and during the term of, the lease/licence for premises, storage space, car park spaces and kiosks at The Studio.Co properties:
(a) Contact and insurance details;
(b) ABNs;
(c) Information as to Licenseess’ and guarantors’ financial standings and Licenseess’ business experience; and
(d) other assorted financial and trading information.
We collect personal information from you and from other sources including publicly available information, your representatives, information service providers, other The Studio.Co companies and the parties with which we exchange information as described here.
2.2.2 Why
This information is required to evaluate whether a lease or license should be granted to the Licensee; to assist The Studio.Co to manage the relationship and to monitor the performance of the property. Occasionally, the information may also be made available to others in connection with any transactions involving the ownership or management of the property.
If a Licensee provides The Studio.Co with direct debit or direct credit details, The Studio.Co may disclose those details to The Studio.Co’s bank to facilitate the provision of that service.
The Studio.Co properties are under video and camera surveillance. When entering NSH properties the personal information and images of individuals may be collected by The Studio.Co. This information may be used by The Studio.Co in connection with the management and security of the property.
2.4 Employees and Prospective Employees
(a) Prospective employees
If you apply for or we consider you for a position with us, we may also collect information about your qualifications, skills, experience, character and screening checks (including reference, background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks).
We collect personal information from you and from other sources including publicly available information, your representatives, information service providers, other The Studio.Co companies and the parties with which we exchange information as described here. We may also collect information about you through our employee referral program where someone you know recommends you to us.
We collect, use and disclose your personal information to assess your application, conduct screening checks and consider and contact you about other positions.
We may exchange your personal information with academic institutions, recruiters, screening check providers, professional and trade associations, law enforcement agencies, referees and your current and previous employers.
Without your personal information we may not be able to progress considering you for positions with us.
(b) Working with us
This section applies to our current and former employees and contractors in addition to the section regarding prospective employees above.
We may collect information relating to your current or former employment or engagement including information about your training, disciplining, resignation, termination, terms and conditions, emergency contact details, performance, conduct, use of our IT resources, payroll matters, union or professional/trade association membership, recreation, leave and taxation, banking or superannuation affairs. We are required or authorised to collect your personal information under various laws including the Fair Work Act, Superannuation Guarantee (Administration) Act and Taxation Administration Act.
We collect, use and disclose your personal information for purposes relating to your employment or engagement with us including engagement, training, disciplining, payroll, superannuation, health and safety, administration, insurance (including workcover) and staff management purposes. We may exchange your personal information with your representatives (including unions) and our service providers including providers of payroll, superannuation, banking, staff benefits, surveillance and training services. Without your personal information we may not be able to effectively manage your employment or engagement.
We may monitor and record your communications and interactions with us (including email, telephone and online) and operate audio and video surveillance devices in our premises for purposes including compliance auditing, maintenance, security, dispute resolution, training and where email abuse is suspected.
3. Exchange of Personal Information with Third Parties
We may share personal information within The Studio.Co and other companies owned or controlled by The Studio.Co.
We may also exchange personal information with our service providers and contractors such as organisations who provide archival, auditing, professional advisory (including legal, accounting and business consulting), debt collection, banking, marketing, advertising, communication, mail house, delivery, recruitment, call centre, contact management; technology, research, analytics, utility, cleaning and security services.
We may exchange personal information with regulatory authorities including police where required or authorised by law or to assist in the prevention, detection and management of unlawful conduct.
Some of the parties with which we exchange personal information are located outside Australia in countries like Singapore and United States of America. While these third parties will often be subject to privacy and confidentiality obligations, you acknowledge that:
(a) they may not always comply with those obligations or those obligations may differ from Australian privacy laws;
(b) we will not be accountable for the third party under the Privacy Act;
(c) you may not be able to seek redress under the Privacy Act; and
(d) the third party may be subject to foreign laws which might compel further disclosures of personal information (e.g. to government authorities).
4. Storage of Personal Information
We hold personal information in physical files, computer systems or in a database held by us and by service providers on our behalf. We regard the security of personal information as a priority and use a number of physical and electronic to protect it. Unfortunately, no data transmission over the Internet can be guaranteed as completely secure. So while we strive to protect such information, we cannot ensure or warrant the security of any information transmitted to us and individuals do so at their own risk.
A username and password may be essential for you to use some of our Online Services or parts of them. For your own protection, we require you to keep these details confidential and to change your password regularly (if applicable).
Security holder information is held by the registry in accordance with registry arrangements which require such information to be held securely.
5. Access, updating and further information
In most circumstances, you have a right to access any personal information which we collect and hold about you and to have it corrected if it is wrong. We may deny your request for access or correction in some circumstances, but if we do this, we will tell you why. Where we decide not to make a requested correction and you disagree, you may ask us to make a note of your requested correction with the information.
If you have registered your details for our Online Services or Member Programs, you may be able to access and update personal information on your profile, subject to any authentication and authorisation considerations, which exist to protect your security.
Please contact our Privacy Officer using the details set out below if you wish to:
ask any questions or provide feedback about this Privacy Policy or our approach to privacy;
make a request for access to or correction of any personal information that we may hold about you; or
make a complaint about the way in which we have handled your personal information.
Any information that we provide in response may be limited to the extent permitted by any applicable law.
Email: hello@thestudioco.com.au
USE OF DATA
We use the collected data for various purposes:
– to provide and maintain our Service;
– to notify you about changes to our Service;
– to allow you to participate in interactive features of our Service when you choose to do so;
– to provide customer support;
– to gather analysis or valuable information so that we can improve our Service;
– to monitor the usage of our Service;
– to detect, prevent and address technical issues;
– to fulfill any other purpose for which you provide it;
– to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
– to provide you with notices about your account and/or subscription, including expiration and renewal notices, email instructions, etc.;
– to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
– in any other way we may describe when you provide the information;
– for any other purpose with your consent.
RETENTION OF DATA
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
TRANSFER OF DATA
Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside the European Union and choose to provide information to us, please note that we transfer the data, including Personal Data, to the European Union and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.
DISCLOSURE OF DATA
We may disclose personal information that we collect, or you provide:
Disclosure for Law Enforcement.
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.
Business Transaction.
If we or our subsidiaries are involved in a merger, acquisition, or asset sale, your Personal Data may be transferred.
Other cases. We may disclose your information also:
– to our subsidiaries and affiliates;
– to contractors, service providers, and other third parties we use to support our business;
– to fulfill the purpose for which you provide it;
– with your consent in any other cases;
SECURITY OF DATA
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj
We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed of what Personal Data we hold about you and if you want it to be removed from our systems, please send us a request through the “Support” page of our Services.
In certain circumstances, you have the following data protection rights:
– the right to access, update or to delete the information we have on you;
– the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
– the right to object. You have the right to object to our processing of your Personal Data;
– the right of restriction. You have the right to request that we restrict the processing of your personal information;
– the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
– the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;
Please note that we may ask you to verify your identity before responding to such requests. Please note, that we may not able to provide Service without some necessary data.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
YOUR DATA PROTECTION RIGHTS UNDER THE CALIFORNIA PRIVACY PROTECTION ACT (CALOPPA)
CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. – See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/
According to CalOPPA we agree to the following:
– users can visit our site anonymously;
– our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the home page of our website;
– users will be notified of any privacy policy changes on our Privacy Policy Page;
– users are able to change their personal information by visiting the “Account” page of our Services.
Our Policy on “Do Not Track” Signals:
We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
YOUR DATA PROTECTION RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)
If you are a California resident, you are entitled to learn what data we collect about you and ask to delete your data. To exercise your data protection rights, you can make certain requests and ask us:
What personal information we have about you. If you make this request, we will return to you:
– The categories of personal information we have collected about you.
– The categories of sources from which we collect your personal information.
– The business or commercial purpose for collecting or selling your personal information.
– The categories of third parties with whom we share personal information.
– The specific pieces of personal information we have collected about you.
– A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.
– A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.
Please note, that you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.
To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.
We don't sell or rent your personal information to any third parties for any purpose. You are the only owner of your Personal Data and can request disclosure or deletion at any time.
Please note, that if you ask us to delete, it may impact your experience with us, and you may not be able to participate in certain programs or membership services that require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.
To exercise your California data protection rights described above, please send your request(s) through the “Support” page of our Services.
Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website: http://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180AB375. The CCPA took effect on 01/01/2020.
SERVICE PROVIDERS
We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
andcards
andcards is the developer of our Services. We encourage you to review andcards Privacy Policy: https://www.andcards.com/privacy/
ANALYTICS
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
We also encourage you to review Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.
Firebase
Firebase is analytics service provided by Google Inc.
You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: https://policies.google.com/privacy?hl=en
For more information on what type of information Firebase collects, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en
PAYMENTS
We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).
We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
Stripe:
Their Privacy Policy can be viewed at: https://stripe.com/us/privacy
WayForPay
Their Privacy Policy can be viewed at: https://wayforpay.com/en
Freedom.Pay
Their Privacy Policy can be viewed at: https://freedompay.money/kz/privacy_policy
KakaoPay
Their Privacy Policy can be viewed at: https://www.kakao.com/policy/privacy?lang=en
Links to Other Sites
Our Service may contain links to other sites that are not operated by us. If you click 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 have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
CHILDREN'S PRIVACY
Our Services are not intended for use by children under the age of 13 (“Children”).
We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.
CHANGES TO THIS PRIVACY POLICY
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
CONTACT US
If you have any questions about this Privacy Policy, please contact us through the “Support” page of our Services.