This Privacy Policy sets out the approach which SMS Broadcast will take in relation to the treatment of Personal Information. It includes information on how SMS Broadcast collects, uses, discloses and keeps secure, individuals' Personal Information. It also covers how SMS Broadcast makes the Personal Information it holds available for access to and correction by the individual.
1.1 SMS Broadcast will only collect Personal Information where the information is necessary for SMS Broadcast to perform one or more of its functions or activities. In this context, "collect" means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 SMS Broadcast collects Personal Information primarily to supply customers with the products and services ordered from it and its related companies. SMS Broadcast also collects and uses Personal Information for secondary purposes including:
(i) billing and account management;
(ii) business planning and product development; and
(iii) to provide individuals with information about promotions, as well as the products and services of other SMS Broadcast companies and other organisations.
1.3 SMS Broadcast will not collect Sensitive Information from individuals except with consent and only where it is necessary for SMS Broadcast to collect such information for an activity or function.
1.4 SMS Broadcast will not collect Personal Information secretly or in an underhanded way.
2.1 SMS Broadcast Uses Personal Information primarily for the purposes listed in 1.2 above.
2.2 SMS Broadcast will not use Sensitive Information for Direct Marketing.
2.3 SMS Broadcast may use Personal Information to avoid an imminent threat to a person's life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.4 SMS Broadcast will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
2.5 SMS Broadcast will not attempt to match de-identified or anonymous data collected through surveys or such online devices as "cookies", with information identifying an individual, without the consent of the relevant individual.
3.1 SMS Broadcast may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.
3.2 SMS Broadcast may Disclose Personal Information to unrelated third parties to enable outsourcing of functions (such as billing), where that is Disclosure or Use for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual's Reasonable Expectations.
3.3 SMS Broadcast will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
3.4 SMS Broadcast may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.
3.5 SMS Broadcast may Disclose Personal Information to avoid an imminent threat to a person's life or to public safety.
3.6 SMS Broadcast does not generally sell or share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved. If the consent provided is conditional, SMS Broadcast will take steps to ensure (by contract) that the use of its customer list by third parties does not exceed the scope of the consent.
4.1 SMS Broadcast will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 SMS Broadcast will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years, unless the law requires otherwise.
5.1 SMS Broadcast requires employees and contractors to perform their duties in a manner that is consistent with SMS Broadcast' legal responsibilities in relation to privacy.
5.2 SMS Broadcast will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within SMS Broadcast who have a genuine "need to know" as well as "right to know".
5.3 SMS Broadcast will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6.1 SMS Broadcast will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 SMS Broadcast will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting SMS Broadcast Customer Service, as per the details on the back of this document. While some requests for access may be handled by Customer Service, it may be necessary for your request to be escalated to the SMS Broadcast Customer Relations Group.
6.4 SMS Broadcast will not charge a fee for processing an access request unless the request is complex or is resource intensive.
7.1 SMS Broadcast websites include a copy of this SMS Broadcast Privacy Policy.
8.1 SMS Broadcast will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. SMS Broadcast may however request visitors to provide Personal Information voluntarily to SMS Broadcast (for example, as part of a competition or questionnaire).
8.2 SMS Broadcast will allow its customers to transact with it anonymously wherever that is reasonable and practicable.
9.1 SMS Broadcast will take reasonable steps to limit the amount of Personal Information it sends to unrelated organisations overseas.
SMS Broadcast means MessageMedia Europe Limited (Company Number 3771735)
Personal Information means 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.
Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.
Reasonable Expectation means a reasonable individual's expectation that their personal information might be Used or Disclosed for the particular purpose.
Sensitive Information means:
(a) information or an opinion about an individual's:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual preferences or practices; or
(ix) criminal record;that is also personal information or
(b) Health Information about an individual.
Use means the handling of Personal Information within SMS Broadcast.
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If you require further information regarding SMS Broadcast's Privacy Policy, you can contact SMS Broadcast Customer Service Centre on:
Online: via www.smsbroadcast.co.uk
Email: contact@smsbroadcast.co.uk
Phone: 020 3327 0090
Mail: 1 Old Street Yard
London, EC1Y 8AF, UK
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