At Little Minx Milestones we pride ourselves on being true to our word, professional and diligent with all our stakeholder and customer interactions. Little Minx:
- is a member of the Australian Digital Marketing Association (ADMA)
- is owned and operated by a Certified Practising Marketer (Australian Marketing Institute)
- subscribes to the Health on the Net Foundation Code of Conduct
This document sets out the approach that Little Minx Milestones will take in relation to the treatment of Personal Information. It includes information on how Little Minx collects, uses, discloses and keeps secure, individuals’ personal information. It also covers how Little Minx makes the personal information it holds available for access to and correction by the individual.
Little Minx will only collect Personal Information where the information is necessary for Little Minx 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.
Little Minx collects Personal Information primarily to supply products and services directly from Little Minx with information and details of it’s products and services. Little Minx also collects and uses Personal Information for secondary purposes including:
- provision of products and services;
- accounting purposes; and
- business planning and product development.
Little Minx collects Personal Information in a number of different ways including both paper and online, electronic, by phone and in person. Little Minx will notify individuals (including, but not limited to, our customers) of the matters listed below at the time of collecting any Personal Information:
- the main reason that we are collecting Personal Information (this reason will be the Primary Purpose);
- other related Uses or Disclosures that we may make of the Personal Information(Secondary Purposes);
- that individuals can access the Personal Information that Little Minx holds about them;
- that individuals should contact Little Minx if they wish to access or correct Personal Information collected by us or have any concerns in relation to Personal Information;
Little Minx will not collect Sensitive Information from individuals except with express consent from the individual and only where it is necessary for Little Minx to collect such information for an activity or function.
Little Minx will obtain an individual’s consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose that would be within the relevant individual’s Reasonable Expectations. If Little Minx relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:
- individuals are clearly notified of their right to Opt Out from further Direct Marketing; and
- if the individual Opts Out of all Direct Marketing the Opt Out will be respected by Little Minx and implemented free of charge.
Little Minx will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
Little Minx may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual.
Little Minx may Disclose Personal Information to unrelated third parties to enable outsourcing of functions where that Disclosure or Use is for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations.
Little Minx 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.
Little Minx will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
Little Minx 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.
Little Minx requires employees and contractors to perform their duties in a manner that is consistent with Little Minx’s legal responsibilities in relation to privacy.
Little Minx 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 Little Minx who have a genuine “need to know” as well as “right to know”. Little Minx will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
If you have any questions in relation to Privacy please do not hesitate to contact us