Title Publishing Privacy Policy

At Title Publishing (Title Publishing Pty Limited ABN 70 085 967 022), we support the protection of customer's privacy rights as a fundamental element of our business. We recognise the importance of protecting your personal information and will ensure that our relationship is as exclusive as you want it to be.

This Privacy Policy will answer your questions about the kind of information we collect and how we use it. If you have any further questions or if you wish to receive more information on Title’s Information practices and privacy policy, please contact our Privacy Officer at privacy@intermedia.com.au.

What information do we collect?
In the course of doing business, Title Publishing may collect information about its customers such as: names, addresses, telephone numbers, credit card information and e-mail addresses, depending on the nature of the transaction with us. Any information that personally identifies you may be used by Title to: - inform you about products and services;
- improve the products and services we offer; and
- otherwise better meet the needs and preferences of our customers.
It should be clear why the information is being collected each time you are asked, for example, being asked to supply an address so a product can be sent to you.

We will not collect from you any sensitive information revealing your race, ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships or details of health or disability. Exceptions to this include:

- where you have given express consent to Title to do so;
- the use of this information is authorised by law or is considered reasonably necessary to enforce the law; or
- when the information is necessary for the establishment, exercise or defence of a legal claim.
Title, as an information company also collects information about certain businesses. This information about businesses does not include information about individuals at these businesses beyond their commercial activities or beyond what they voluntarily disclose in the course of Title’s research activities.

Web Logging
Title web sites record standard information such as time, date and URL of request (the web page you arrived from) via our web servers. This information is recorded by all web servers and is used to improve the functionality, structure and performance of our web sites.

We track the pattern of visitor usage across the sites by issuing an anonymous user ID via a cookie (a cookie is a small data packet given to your web browser by our web servers, the browser stores the message in a text file in your computer). This user ID is sent back to our servers each time you view a page from our servers. This ID is deleted at the end of your session. In addition, we may use a persistent cookie to hold user preferences on site operation. These preferences are accessed by your browser to configure the operation of the site to your requirements but are not downloaded back to our web servers. If you choose to save your password this will also be stored on your local machine in a persistent cookie not downloaded to the server. Cookies can make using the sites easier for you by storing information about your preferences on the web sites. This will enable you to take full advantage of the services and features that our sites offer. If you prefer not to receive cookies, you may be able to change the settings of your Internet browser to disable cookies or to warn you when cookies are being used. This may preclude you from using some services or enhanced functionality.

How we use your personal information
Title operates a number of businesses that process personal information about individuals. In general, our policy is that we only use or disclose personal information for the purpose that was specifically or reasonably apparent at the time of collection. The personal information that you provide us will be used in order to process your request as well as to assist you in subscribing to Title’s products and services. We may use this personal information or data for another purpose if:
- you would reasonably expect us to use the personal information for that other purpose; and
- the other purpose is related to the original purpose of collection, for example, sending you correspondence on new features and services.
Title may use some of your information for the purposes of direct marketing in relation to promotional activities where it is impractical for us to gain consent. However, in these circumstances, we will provide an express opportunity when we contact you to decline receiving from Title specified marketing communications via an opt-out mechanism (e.g. depending on the circumstances, Title may give you the option of declining to receive from Title further marketing communications generally, marketing communications regarding a particular brand or a particular type of marketing communication). This includes direct marketing material relating to all Title Publishing s brands and imprints (e.g. The Title Group Pty Ltd, Interpoint Events Pty Ltd, Title Publishing Pty Ltd, Inmedia Publishing Pty Ltd). At any time you may choose not to receive these marketing communications by contacting us at privacy@intermedia.com.au

Disclosure of personal information to third parties
Title may be required by law enforcement or judicial authorities to provide personally identifiable information to the appropriate governmental authorities. If such a request is received, we will provide this information upon receipt of the appropriate documentation. Personal information collected may be disclosed to third parties by Title, for example:
- If you are informed at the time of collection of the information that such a disclosure may take place.
- For purposes related to the purpose for which the information was collected, for example, to complete a transaction on your behalf or provide you with a service that you requested. In some cases we contract with other companies to perform services for us. Examples of this include sending mail, faxes and emails; processing orders; providing marketing support; deliveries; market research; debt collection agencies and storing back-up copies of our databases. We will provide them only with such information about you as they need to perform their services, but we will impose strict requirements of security and confidentiality on them in how they handle your personal information. Also, they will not be permitted to use information about you for any purpose except to perform the services we have asked them to provide.
- We may share information about you with other business units across Title Publishing so we can provide you with products and services you have requested, and in order that they or Title can bring you information about other Title products and services.
- Title may sell, trade or rent to third parties personal information regarding subscribers to its products. These details could be used by those third parties for various purposes including direct marketing. However, if you do not wish your details to be transferred to such third parties, please send an email to privacy@intermedia.com.au

Access and correction to information we hold about you
Where practicable you will have access to the information that you provide to us and can update that information if your circumstances have changed. You may request this information by writing to: Privacy Officer, Title Publishing Pty Limited, Suite 39, 100 Harris Street Pyrmont NSW 2009 or sending an email to us at privacy@intermedia.com.au
Exceptions to this include:
- where providing access will provide a serious threat to life or health of any individual or pose an unreasonable impact on the privacy of an individual;
- your request for access is frivolous or vexatious;
- where information relates to existing legal proceedings between Title and you; or
- where providing access would be unlawful or may prejudice an investigation of possible unlawful activity.

Changing information
If you wish to change your personal information, which is inaccurate or out-of-date, you must notify us by sending a letter or fax signed by you; and the record will be changed. Your notification should be marked to the attention of our Privacy Officer.

Links to third parties
Some of the pages on Title’s web sites may be hosted by third parties. If personal information is collected from one of those pages and provided to us, we will treat that information in accordance with this Privacy Policy; and as if it was collected directly by Title.
Title’s web sites contain links to third party web sites that are not operated or controlled by us. Please note that Title is not responsible for the privacy or security practices of those third party web sites and those sites are not covered by this Privacy Policy. Third party web sites should have their own privacy and security policies, which we encourage you to read. Other companies that place advertising on our web sites may collect information about you when you view or click on their advertising or content through the use of cookies or other means. We cannot control this collection of information. You should contact these advertisers or content providers directly if you have any question about their use of the information they collect.

Security of your information online
Data transmission over the Internet cannot be guaranteed to be 100% secure. While we will strive to protect your personal information from misuse, loss and unauthorised access, we cannot guarantee the security of any information you transmit to us or receive from our online products and services. These activities are conducted at your own risk.

What to do if you have a problem or question
If Title becomes aware of any ongoing concerns or problems you may have with Title’s handling of your personal information, we will work to address these concerns. If you have any queries relating to our Privacy Policy, or you have a problem or complaint, please contact us at privacy@intermedia.com.au

Changes to this Privacy Policy
We may amend this Privacy Policy from time to time by posting an updated version of this policy on our web sites.

Additional information
For further information about privacy issues and the protection of privacy, visit the Australian Federal Privacy Commissioner's web site at www.privacy.gov.au
Title Publishing’s Privacy Standards regarding its activities as a Media Organisation
The Private Sector amendments to the Commonwealth Privacy Act 1988 exempt from its ambit acts and practices by media organisations in the course of journalism when the organisation is publicly committed to observing a set of privacy standards.
Accordingly, Title Publishing Pty Limited has developed such a set of standards. These standards apply to all activities of Title involved in the collection, preparation and dissemination of the following material for the purpose of making it available to the public:
- news, current affairs and information; and
- material consisting of commentary or opinion on, or analysis of, news, current affairs or information.
These standards apply to all such activities undertaken by Title including those activities undertaken under, or in connection with, Title Publishing Pty Ltd, Interpoint Events Pty Ltd, The Title Group Pty Ltd, Inmedia Publishing Pty Ltd brands and imprints.
Complaints arising from such activities can be made by contacting Title’s Privacy Officer at privacy@intermedia.com.au.

Background
The Privacy Act 1988 recognises the need to balance respect for privacy with the public interest in allowing a free flow of information through the media. One way the Privacy Act aims to address this balance is by providing an exemption for acts done, or practices engaged in, by a media organisation in the course of journalism. This exemption will apply if the media organisation is publicly committed to observing standards which deal with privacy in the context of the activities of a media organisation, and those standards have been published in writing either by the organisation or a body representing a class of media organisations.
These Standards deal with privacy only in the context of Title’s activities in the course of journalism as a media organisation and are published by Title for the purposes of the Privacy Act exemption. Title has published a separate Privacy Policy regarding its other personal information handling practices.

Application of Privacy Standards
These Standards apply to ‘personal information’. This term is defined by the Privacy Act as information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
These Standards recognise the public interest in allowing a free flow of information through the media. For the purposes of these Standards, ‘public interest’ means anything involving a matter capable of affecting people at large so they might be legitimately interested in, or concerned about, what is going on, or what may happen to them, or to others.

Title’s Privacy Standards
Title publicly commits to observe the following standards dealing with privacy in the context of its activities done in the course of journalism as a media organisation:
1. Collection of personal information
When gathering news, current affairs or information, authors should only use personal information in the public interest. In doing so, authors should not unduly intrude on the privacy of individuals and should show respect for the dignity and sensitivity of people encountered in the course of gathering news, current affairs or information.
News, current affairs or information obtained by unfair or dishonest means should not be published unless there is an overriding public interest. Generally, authors should identify themselves as such.
Public figures necessarily sacrifice their right to privacy, where public scrutiny is in the public interest. However, public figures do not forfeit their right to privacy altogether. Intrusion into their right to privacy must be related to their public duties or activities.
2. Use and disclosure of personal information
Personal information gathered by authors should only be used for the purpose for which it was intended.
A person who supplies personal information should have a reasonable expectation that it will be used for the purpose for which it was collected. Some personal information, such as addresses or other identifying details, may enable others to intrude on the privacy and safety of individuals who are the subject of, or referred to in, news coverage or a publication; or the privacy of those individuals’ families. To the extent lawful and practicable, authors should only disclose sufficient personal information to identify the persons being reported in the news, or referred to in a publication, so that these risks can be reasonably avoided.
3. Quality of personal information
Title should take reasonable steps to ensure that the personal information it collects is accurate, complete and up-to-date.
4. Security of personal information
Title should take reasonable steps to ensure that the personal information it holds is protected from misuse, loss or unauthorised access.
5. Anonymity of sources
All persons who provide information to media organisations are entitled to seek anonymity. The identity of confidential sources should not be revealed, and where it is lawful and practicable, Title should ensure that any personal information which it holds derived from such sources does not identify the source.
6. Correction, fairness and balance
Where individuals are singled out for criticism, the publication should ensure fairness and balance in the original published material. Failing that, and provided that Title in its absolute discretion decides that it is commercially viable to do so, a reasonable opportunity for a balancing response will be provided for those publications which are published periodically.
Title will take steps to correct any of its records containing personal information which has been published and which is found to be harmfully inaccurate, so as to avoid the harmful inaccuracy being published again. 7. Sensitive personal information
Title’s publications should not place any gratuitous emphasis on the race, ethnic origin, political opinions, religion, philosophical beliefs or sexual orientation of an individual. Nevertheless, where it is relevant and in the public interest to report and express opinions in these areas, Title’s publications may do so.
Members of the public caught up in newsworthy events should not be exploited. A victim or bereaved person has the right to refuse or terminate an interview or photographic session at any time.
Unless otherwise restricted by law or court order, open court hearings are matters of public record and can be reported by the media. Such reports need to be fair and balanced. They should not identify relatives or friends of people accused or convicted of crime unless the reference to them is necessary for the full, fair and accurate reporting of the crime or subsequent legal proceedings; or analysis of the legal principles or concepts involved in the matter.
8. Complaints or concerns
If Title becomes aware of any ongoing concerns or problems you may have with its compliance with these Standards, Title will work to address these concerns. If you have any queries relating to these Standards, or you have a problem or complaint, please contact Title at privacy@intermedia.com.au
9. Changes to these Standards
Title may amend these Standards from time to time by posting an updated version on this website.
10. Additional information
For further information about privacy issues and the protection of privacy, visit the Australian Federal Privacy Commissioner's website at www.privacy.gov.au