We will review this policy from time to time. We will make any updated policy available via our website (www.stltones.com/pages/privacy-policy). Please contact our Privacy Officer if you have any questions about this document.
Last update: 12 July 2022.
1. Types of information that we collect and purpose of collection
‘Personal information’ is information or an opinion, in any form (whether true or not), that can be used to identify you (such as your name, age, address and, in some circumstances, your financial information). If the information identifies you or you are reasonably identifiable from it, the information will be considered Personal Information.
Personal information may also include anonymous aggregate data (such as your IP address, your operating system) where that data could be used by us to reasonably identify you.
The kinds of Personal Information we collect and hold about you will depend on the circumstances of collection, including whether we collect the information from you as a mailing list subscriber, purchaser of our goods or services, job applicant or in some other capacity.
For example, if you are a mailing list subscriber, we may collect your full name, email address, country, postcode and year of birth. If you purchase our goods or services, we collect additional information such as date of birth, address, phone number, information about goods or services ordered, billing and payment details, your enquiries or complaints and your transaction history with us. For recruitment purposes, we may collect and hold Personal Information about prospective employees, such as your tax file number, date of birth, driver’s licence number and employment history. We may also need to collect sensitive information about you such as your membership in professional or trade associations and certifications from police checks. Unless the collection of sensitive information is permitted under Privacy Act, we will only collect sensitive information with your consent where that information is reasonably necessary for our business.
2. How we collect your personal information
We collect your personal information when you interact with us directly via our website stltones.com and social media accounts. We also collect your personal information when you purchase goods or services from us and when you join competitions or giveaways organised by us.
Collection through social media platforms: When you interact with us using social media platforms, you are also providing personal information to the operators of these social media platforms. Such information is subject to those operators’ policies governing privacy. We are not responsible for the privacy practices and policies of these operators even if you accessed these platforms from our website. We encourage you to read and understand these operators’ privacy policies before providing them with your personal information. Collecting personal information from other sources: Sometimes we collect personal information about you from other sources where you have consented to the collection of the information from someone else, we are authorised by law to collect the information from someone else or it is unreasonable or impracticable to collect the information from you personally. If you apply for a position with us, we collect your personal information from third parties such as, recruitment service providers, referees, former employers, educational institutions and, if appropriate, health providers and police.
At all times this information is collected by lawful means and in a manner that respects your privacy. If we receive unsolicited personal information about you from a third party and it is clear to us that we should not have received that information, we will destroy or securely delete that information (if it is lawful and reasonable for us to do so).
2.4. Notification of collection of personal information
If we collect your personal information from third parties in circumstances where you may not be aware that we have collected your personal information, and that information can be used to identify you, we will take reasonable steps to notify you of the collection and the circumstances that surround the collection.
2.5. Use of tracking tools
Cookies are text files placed in your computer’s browser to store your preferences. These cookies collect information on how you and other visitors use our website.
Google Analytics is a service which transmits website traffic data. It will not identify individual users and IP addresses with any other data held by Google.
Hotjar is a combination of various online tools that we use to track the behaviour of the people who use and visit our website. The tracking tools that we use do not contain, use or store any personally identifiable information. We use tracking tools to maintain our site, identify and analyse trends and to obtain broad demographic information. We do not use information transferred through cookies for any promotion or marketing purposes, nor is that information shared with any third parties.
Most browsers are initially set to accept cookies or other tracking tools. If you prefer, you can set your browser to refuse these by selecting the appropriate settings or blockings, deleting or disabling them in your browser or device permits.
3.1. Use and disclosure of personal information
We use personal information for a variety of purposes to effectively conduct our business including: (a) to administer the supply of products and services to you; (b) to contact and communicate with you; (c) to run competitions, promotions and marketing campaigns including direct marketing; (d) to conduct market research and website development; (e) for internal record keeping; (f) to consider applications for current and future employment; and (g) to comply with legal and regulatory requirements. We will not use or disclose personal information we hold about you that was collected for a particular purpose for another unrelated purpose, unless: (a) you have consented to the use or disclosure of the information for another purpose; (b) we use that information for a secondary purpose that is related to the primary purpose, the information is not sensitive information and you would reasonably expect us to use or disclose the information for that secondary purpose; or(c) the use or disclosure is otherwise permitted under the Privacy Act and other applicable legislation.
3.2. Disclosure to third parties
To help us carry out our business functions and to the extent permitted by law, we may disclose personal information about you to third parties, including:(a) our related entities being Unified Music Group Pty Ltd and Red Hill Entertainment Pty Ltd;(b) our business partners in the music, entertainment and marketing industries; (c) our external service providers, including mail houses, couriers, payment processors or payment gateway providers and e-commerce website providers;(d) our professional advisers, such as auditors and lawyers;(e) an individual’s representatives, including any person who has authority to act on their behalf;(f) debt collection agencies and credit reporting bodies;(g) government and regulatory authorities (as required or authorised by law or a court/tribunal order); and(h) any other person where you have given your consent.
We will take reasonable steps to ensure that these third parties are bound by privacy obligations in relation to your personal information. We will not sell, gift, rent or trade your Personal Information to anyone.
3.3. Disclosure overseas
In some circumstances, we may need to disclose your personal information to third party suppliers and service providers located overseas including PayPal, Shopify, Braintree and Afterpay. We take reasonable steps to ensure overseas recipients of your personal information do not breach the Privacy Act.
Our website contains features or links to websites and services provided by third parties such as social media platforms, e-commerce platforms, online streaming services and external payment gateways. These third-party service providers have their own privacy policies and may disclose your personal information to overseas recipients.
4. Direct marketing
4.1. Opt out from direct marketing
We may use your personal information to send you marketing materials about our products and services and promotions. You have a right under the Spam Act 2003 (Cth) to opt out from direct marketing and you can opt out at any time by:(a) contacting the Privacy Officer in accordance with paragraph 8.1 of this policy; or(b) opt-out from, receiving further marketing material via any opt-out mechanism contained in our marketing correspondence.
4.2 Mobile Direct Marketing
We may use SMS/text messaging to send to you marketing materials. Please refer to our Mobile Terms of Service.
5 Protecting personal information
5.1 Storing personal information
We store your personal information in different ways, including in physical and electronic form on site and with third party storage providers.
We maintain physical, electronic and procedural security measures to safeguard your personal information and to secure and protect it from misuse and unauthorised access, disclosure or interference by:(a) physical security measures for access to systems, including restricting access to authorised personnel only, control of access to buildings and use of user identifiers and passwords;(b) electronic security systems such as firewalls and data encryption, backup and recovery of systems, use of rostering, staff management and finance software, use of secure payment portals and Secure Socket Layer (SSL); and(c) procedural security measures, including imposing confidentiality obligations on employees, consultants and contractors, providing them with training and requiring them to comply with strict privacy and security policies and procedures including account decommissioning for exiting staff.
5.2 Security Breach
Although we take care with your Personal Information, we cannot 100% guarantee that there will not be any security breaches. We acknowledge our obligation to report any data breach that is likely to risk the rights and freedoms of natural persons to the Australian Information Commissioner. If possible, and where this data breach poses a risk of serious harm to you or your rights and freedoms, we will also inform you.To the extent permitted by law, we accept no liability for any breach of security or direct hacking of our security or any unintentional disclosure, loss or misuse of any information or data or for the actions of any third parties that may obtain any information or data.
5.3. What happens if we no longer need your personal information?
If we no longer need your personal information for any purpose, we will take reasonable steps to destroy or permanently de-identify the information, unless the information is contained in a Commonwealth record or we are required by law, or a court/tribunal order, to retain the information.
6. Access to, and correction of, personal information
6.1. Access to personal information
You may request access to personal information we hold about you by contacting our Privacy Officer in accordance with paragraph 8.1 of this policy.
We will respond to a request for access within a reasonable time, and give you access in the manner you request, if it is reasonable and practicable to do so, unless an exception in the Privacy Act applies. (For example, if providing this access may disclose information about another person we may need to refuse to grant you access.). We may need to verify your identity before we give you access to your personal information. Depending on the nature of the request, we may charge you a small fee to access that information.
6.2. Requesting correction
You may request us to correct any information about you which you think is inaccurate, incomplete or out of date. We will respond to a correction request within a reasonable time. If we correct your personal information that we have previously disclosed to another entity, and you ask us to tell the other entity about the correction, we will take reasonable steps to tell the other entity about the correction, unless it is impractical or unlawful to do so.
6.3. Refusal to allow access to, or correction of, personal information
If we refuse to allow you access to your personal information or to correct that information, then we will provide you with the reasons for our decision and will inform you of mechanisms available to complain about the refusal.
You have the option to remain anonymous, or to use a pseudonym when dealing with us where it is lawful and practical to do so. However, without your personal information we may not be able to provide you with our products and services.
8. Complaints about personal information
If you have any complaints about our privacy practices or would like further information, please contact our Privacy Officer:
Telephone: 0414 422 354
Mail: 51 Wangaratta St, Richmond VIC 3121 Australia
8.2. External complaint mechanism
If you are not happy with the outcome of the Privacy Officer’s investigation or we have not replied to you within a reasonable time, then you can raise your concern with:
The Office of the Australian Information Commissioner
Telephone: 1300 363 992
Mail: Office of the Australian Information Commissioner
GPO Box 5218 Sydney NSW 2001
Mobile Terms of Service
STL Tones Group – Mobile Terms of Service
The STL Tones mobile message service (the Service) is operated by STL Tones Group Pty Ltd (ACN 621 071 065) (STL Tones, we, or us). Your use of the Service constitutes your agreement to these terms and conditions (Mobile Terms). We may modify or cancel the Service or any of its features without notice. To the extent permitted by applicable law, we may also modify these Mobile Terms at any time and your continued use of the Service following the effective date of any such changes shall constitute your acceptance of such changes.
Last updated: 12 July 2022
By consenting to STL Tones’s SMS/text messaging service, you agree to receive recurring SMS/text messages from and on behalf of STL Tones through your wireless provider to the mobile number you provided, even if your mobile number is registered on any Do Not Call list. Text messages may be sent using an automatic telephone dialing system or other technology. Service-related messages may include updates, alerts, and information (e.g., order updates, account alerts, etc.). Promotional messages may include promotions, specials, and other marketing offers (e.g., cart reminders).
You understand that you do not have to sign up for this program in order to make any purchases, and your consent is not a condition of any purchase with STL Tones. Your participation in this program is optional.
We do not charge for the Service, but you are responsible for all charges and fees associated with text messaging imposed by your wireless provider. Message frequency varies. Message and data rates may apply. Check your mobile plan and contact your wireless provider for details. You are solely responsible for all charges related to SMS/text messages, including charges from your wireless provider.
You may opt-out of the Service at any time by following the prompts at the bottom of any message from us or click the unsubscribe link (where available) in any text message to cancel. You'll receive a one-time opt-out confirmation text message. No further messages will be sent to your mobile device, unless initiated by you. If you have subscribed to other STL Tones Group mobile message programs (if any) and wish to cancel, except where applicable law requires otherwise, you will need to opt out separately from those programs by following the instructions provided in their respective mobile terms.
For Service support or assistance, email email@example.com.
The wireless carriers supported by the Service are not liable for delayed or undelivered messages. You agree to provide us with a valid mobile number. If you get a new mobile number, you will need to sign up for the program with your new number.
To the extent permitted by applicable law, you agree that we will not be liable for failed, delayed, or misdirected delivery of any information sent through the Service, any errors in such information, and/or any action you may or may not take in reliance on the information or Service.