Last Modified: July 10, 2020
SCOPE OF POLICY
TYPES OF INFORMATION WE COLLECT
We collect two basic types of information – personal information (as defined in this policy) and anonymous information (as defined in this policy) – and we may use personal and anonymous information to create a third type of information, aggregate information (also defined in this policy).
For example, we collect:
- Registration Information you provide when you create an account, enter a promotion, or link your profile on a third-party site or platform with your registration account, such as your first name and surname, country of residence, address, gender, date of birth, email address, username and password;
- Transaction Information you provide when you request information, contact us, or purchase a product or service from us, such as your postal address, telephone number, and payment information;
- Location Information, including location information provided by a mobile or other device interacting with one of our sites or applications, or associated with your IP address, where we are permitted by law to process this information;
- Activity Information about your use, and the use by any person(s) you authorize through your account, of our sites and applications, such as the content you view or post, how often you use our services, and your preferences; and
- Usage, viewing, technical, and device data when you visit our sites, use our applications on third-party sites or platforms, or open email we send, including your browser or device type, unique device identifier, and IP address.
HOW WE COLLECT YOUR INFORMATION
We collect information you provide to us when you request or purchase products, services, or information from us, register with us (including when you link your profile on a third-party site or platform with your registration account), participate in public forums or other activities on our sites and applications, respond to guest surveys, complete forms and questionnaires, or otherwise interact with us using one or more devices. You may provide information in a variety of ways, including by typing, video or voice command.
We collect information through a variety of technologies, such as cookies, Flash cookies, pixels, tags, software development kits, application program interfaces and Web beacons.
We collect information using analytics tools, including when you visit our sites and applications or use our applications on third-party sites or platforms.
We acquire information from other trusted sources to update or supplement the information you provide, or we collected automatically, such as when we validate postal information using third party services. Applicable law may require that you authorize the third party to share your information with us before we can acquire it.
USE OF YOUR INFORMATION BY THE CCA FAMILY OF COMPANIES
The member of the CCA family of companies that is the data controller for your information is responsible for and may use your information for the purposes described in this policy. Other members of the CCA family of companies may have access to your information where they perform services on behalf of the data controller (as a data processor) and, unless prohibited under applicable law, for use on their own behalf (as a data controller) for the purposes described in this policy.
Consistent with applicable law and choices and controls that may be available to you, we may use information collected from you, or from devices associated with you to:
- Provide you with the experiences, products, and services you request, view, engage with, or purchase;
- Communicate with you about your account or transactions with us and send you information or request feedback about features on our sites and applications or changes to our policies;
- Send you offers and promotions for our products and services or third-party products and services;
- Personalize content and experiences;
- Provide you with targeted advertising based on your activity on our sites and applications and on third-party sites and applications;
- Operate, understand, optimize, develop, or improve our sites, applications, products, services and operations, including by using guest survey research and analytics tools; and
- Detect, investigate and prevent activities that may violate our policies or be illegal.
SHARING YOUR INFORMATION WITH OTHER ENTITIES
We will not share your personal information with a third party outside the CCA family of companies.
We recognize the need to provide further privacy protections with respect to personal information we may collect from children on our sites and applications. Some of the features on our sites and applications are age-gated so that they are not available for use by children, and we do not knowingly collect personal information from children in connection with those features. When we intend to collect personal information from children, we take additional steps to protect children’s privacy, including:
- Notifying parents and guardians about our information practices with regard to children, including the types of personal information we may collect from children, the uses to which we may put that information, and whether and with whom we may share that information;
- In accordance with applicable law, and our practices, obtaining consent from parents and guardians for the collection of personal information from their children, or for sending information about our products and services directly to their children;
- Limiting our collection of personal information from children to no more than is reasonably necessary to participate in an online activity; and
- Giving parents and guardians access or the ability to request access to personal information we have collected from their children and the ability to request that the applicable personal information be changed or deleted.
DATA SECURITY, INTEGRITY AND RETENTION
The security, integrity and confidentiality of your information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect guest information from unauthorized access, disclosure, use and/or modification.
We regularly review our security procedures to consider appropriate new technology and methods.
Please be aware that, despite our best efforts, no security measures are perfect or impenetrable.
DATA TRANSFERS, STORAGE AND PROCESSING GLOBALLY
Additionally, when using or disclosing personal information transferred from the European Union, we use standard contractual clauses approved by the European Commission, adopt other means under European Union law for ensuring adequate safeguards, or obtain your consent.
We also apply the substantive requirements of standard contractual clauses when transferring personal information from Australia.
COMMENTS AND QUESTIONS
Aggregate information means information about groups or categories of guests, which does not identify and cannot reasonably be used to identify an individual guest.
Anonymous information means information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual guest.
Application means a program or service operated by us (or on our behalf) that may be displayed on various online, mobile or other platforms and environments, including those operated by third parties, which permits us to interact directly with our guests.
Children means individuals who we have identified are not of legal age to consent to the collection and processing of their personal information. In the United States and Latin America, the term “children” refers to individuals under 13 years of age.
The data controller is the subsidiary or affiliated entity of CCA that is responsible for the personal information collected and used within the scope of this policy from our sites and applications.
A data processor is a person or entity that processes personal information on behalf of a data controller (or data controllers) and is permitted to perform data processing only as directed by the data controller(s).
An IP address is associated with the access point through which you enter the Internet, and, is typically controlled by your Internet Service Provider (ISP), your company, or your school. We may use IP addresses to collect information regarding the frequency with which our guests visit various parts of our sits and applications, and we may combine IP addresses with personal information.
Member means a subsidiary or affiliated entity that is part of the CCA family of companies.
Parent and Guardian mean a part or legal guardian of a child.
Personal information means information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, email address, and telephone number. When anonymous information is directly or indirectly associated with personal information, the resulting information also is treated as personal information.
Our sites and applications may offer message boards, conversation pages, blogs, chat rooms, social community environments, profile pages, and other forums that do not have a restricted audience. If you provide personal information when you use any of these features, that personal information may be publicly posted and otherwise disclosed without limitation as to its use by us or by a third party.
CCA FAMILY OF COMPANIES
The CCA family of companies refers to CCA and its subsidiary and affiliated entities, which offer their products and services under various brand names.
These companies engage in a number of businesses, including professional services, consulting services, provision of technology services and the provision of telecommunication services.
The CCA brands include, among others, the following:
CCA (Aust) Pty Ltd
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