Trail Towns Privacy Policy

1. Purpose of our Policy 

Trail Towns Productions Pty Ltd (“Trail Towns”) and its related bodies corporate (we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their Personal Information (as defined below). 

This document is our Privacy Policy and it tells you how we collect and manage your Personal Information on our website and online store (collectively the “Services”) in this Privacy Policy. 

Please read this Privacy Policy carefully. By providing Personal Information to us, you consent to our collection, holding, use and disclosure of your Personal Information in accordance with this Privacy Policy. 

Please contact us if you have questions - our contact details are at the end of this Privacy Policy. If you do not wish to provide Personal Information to us, then you do not have to do so, however this may limit your ability to use or access the Services.

2. How this Privacy Policy works

The Privacy Policy applies to your information when you access or use the Services.
We respect your rights to privacy under Australian privacy laws as applicable, including, but not limited to the Privacy Act 1988 (Cth) (the “Act”), the Australian Privacy Principles (the “Principles”) and the European Union’s General Data Protection Regulation (“GDPR”), and we comply with the Principles requirements in respect of the collection, management and disclosure of your Personal Information.

3. What is your Personal Information?

When used in this Privacy Policy, the term “Personal Information” has the meaning given to it in the Privacy Act 1988 (Cth) and the GDPR, respectively. In general terms, it is any information that can be used to personally identify you.  

We have provided a more detailed list of some of the information we may collect below. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered Personal Information.

We consider the protection of privacy of children very important. The Services are not directed to individuals who are under the age of 18 without its parents or legal guardian consent and supervision,  and we do not solicit nor knowingly collect Personal Information from children under that age.  If we learn that Personal Information has been collected on the Services from persons under 18 years of age and without verifiable parental consent and supervision, then we will take the appropriate steps to delete such information.

4. For what purposes do we collect, hold, use and disclose your Personal Information?

We collect Personal Information about you so that we can provide the Services to you. 

The main purposes for which we may collect Personal Information include:

• to give you access to Trail Towns exclusive content;

• to allow you to purchase goods and services from Trail Towns’ online shop;

• to give you access to our social media channels;

• to provide you with an opportunity to engage with us by being part of our email newsletter;

• to open and administer a personal account on our site;

• to provide you with assistance and advice in relation to our content, goods and services; 

• to prevent and address technical problems and issues;

• to answer enquiries and provide information when you visit our website and purchase goods and services; 

• to give you access to our Series partners’ websites and social media channels;

• for the administrative, marketing (including direct marketing), planning, ongoing services development and for research purposes of Trail Towns, its related bodies corporate, contractors or service providers;

• to update our records and keep your Personal Information up to date;

• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in cooperation with any governmental authority in Australia; and

• for any other purpose with your consent and any purpose reasonably related to any of the above purposes.

5. What Personal Information do we collect and hold?

We may collect the following types of Personal Information:

• your name, mailing or street address, email address, telephone number, age or date of birth;

• financial information related to you such as any bank, credit card or PayPal details (or similar third party payment platform) used to transact with us;

• technical information such as your IP address when accessing our systems or your actions when using our website; and

• information about your online and offline preferences, decisions and other information for statistical purposes.

We may also collect some information that is not Personal Information because it does not identify you, or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our Services.

6. How do we collect your Personal Information?

We collect your Personal Information directly from you through the information you provide to us:

• when you request information through our website;

• when you access or subscribe to Trail Towns content;

• in your subscription to our email newsletter;

• when you access or purchase goods and services in our online store; 

• when you give us feedback of our services; and

• when we provide you with support services.

7. What happens if we can’t collect your Personal Information?

If you do not provide us with the Personal Information described above, some or all of the following may happen:

• we may not be able to provide the requested services to you, either to the same standard or at all;

• we may not be able to provide you with bespoke information about Trail Towns content;

• we may not be able to sell you our products;

• we may not be able to provide you with support services; and

• we may not be able to provide you with Trail Towns’s news and updates.

8. To whom may we disclose your information?

We do not sell Personal Information about you to advertisers, our Series partners or other third parties but we may share such information in the ways set out below but provided that, where we do so disclose your Personal Information to a third party, we will use best endeavours to ensure that the third party’s privacy policies and procedures are in accordance with the Principles.

We may disclose your Personal Information to third parties as follows:

• our employees, related bodies corporate, contractors, agents or service providers for the purposes of providing the Services; 

• third parties in connection with a change of ownership or control of all or part of our business (such as a merger, acquisition, reorganization) or any related entity of Trail Towns Productions Pty Ltd;

• public authorities or agencies when the disclosure is required or authorised by or under an Australian law or a valid and final court/tribunal order, or in the good faith belief that such action is necessary to: (a) comply with a legal obligation or in response to a request from law enforcement or other public authorities anywhere in the world; (b) protect and defend our rights or property; (c) act in urgent circumstances to protect the personal safety or security of our users, customers, and contractors/employees; or (d) enforce our legal terms or otherwise protect ourselves against any legal liability; and

• any organisation for any authorised purpose with your express consent in advance.

9. Cookies

When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer or mobile. This enables us to recognise your computer and mobile and optimise and simplify your use of the website without requiring you to register or login again. 

We also use cookies to measure aggregated website traffic patterns and provide and manage access for enhancing the website user experience. If you do not wish to receive cookies, you can set your browser so that your computer or mobile does not accept them. 

10. Direct marketing materials 

We may use some of the information we collect for marketing purposes, including sending you direct marketing communications and information that we consider may be of interest to you, such as new Trail Towns episodes content, products, events or other opportunities. These communications may be sent in various forms, including mail, SMS and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth) as amended. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below).

11. How can you access, correct or delete your Personal Information?

You may request access to any Personal Information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it within a reasonable time (usually by emailing this information to you). 

We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your Personal Information. 

There may be instances where we cannot grant you access to the Personal Information we hold or in the manner requested by you. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal. 

If you believe that Personal Information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. 

If you wish to be removed from our newsletter email list, you may do so through the link provided at the bottom of each news email for that purpose.

If you wish to remove your user account, you may do so through your account settings, and any personal identifiable information associated with your account will be deleted (or otherwise de-identified) as soon as is reasonably practical or as required by any applicable law. 

Please note that we may retain your Personal Information: 

• for archival or backup purpose as required pursuant to records retention obligations and Trail Towns policies; or 

• as required by law.

12. Opting “in” or “out”

We may offer you the option to have us not collect your Personal Information, however this may prevent us from offering them some or all of our Services and may terminate your access to some or all of the Services you access. You will be aware of this when you:

• Opt In. Where relevant, you will have the right to choose to have information collected and/or receive information from us; or

• Opt Out. Where relevant, you will have the right to choose to exclude yourself from some or all collection of information and/or receiving information from us.

13. Do we disclose your Personal Information to anyone outside Australia? 

We may disclose Personal Information to third party service providers located overseas when required for the provision, operation, stability and reliability of our Services. We agree to use best endeavours to ensure that any overseas recipient of your Personal Information does not breach obligations that we have under these Privacy Policy relating to your Personal Information, including the Australian Privacy Principles.

We may also utilise the following third party service providers to collect, use, store, process and distribute Personal Information about you:

As indicated above, when you access or use Trail Towns’ Services from outside of Australia, you may be sending information (including Personal Information) to the United States the above third partie’s servers are located. 

14. How do we protect your Personal Information?

We use “best practice” physical, electronic, technological and managerial means, methods and procedures to safeguard and secure your Personal Information from misuse and loss and from unauthorised access, modification or disclosure. 

Trail Towns services providers use best practice encryption technology (including use of SSL and HTTPS protocols as updated and upgraded from time to time) and other administrative and organisation measures in relation to the secure storage, access and transfer Personal Information. However, since our website is linked to and uses the public internet, we cannot guarantee that the information you supply will not be intercepted while being transmitted to and from us or otherwise accessed by third parties. Accordingly, any Personal Information or other information which you transmit to us online is transmitted at your own risk. Any “eligible data breach” from the Services will be notified to you and to the corresponding authorities pursuant to the Notifiable Data Breaches Scheme set out in the Act, the Principles and the GDPR as applicable. 

15. Links and Third Party Advertisement 

Our Services may contain marketing, advertising and links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website, unless otherwise required by the Act and the GDPR. Third parties who operate those websites are responsible for informing you about their own privacy practices.

16. Contacting us

If you have any questions about this Privacy Policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below. We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your request to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

Please contact us at

Privacy Officer 

privacy@trailtowns.tv

17. Changes to our Privacy Policy

We reserve the right to update or change our Privacy Policy at any time. Your continued use of our Services will constitute your acknowledgment of the acceptance of such updated or changed Privacy Policy terms. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us, or by placing a prominent notice on our website.

This Privacy Policy was last updated on 22 October 2021.