Privacy Policy | Momentum

PURPOSE OF POLICY

Momentum Worldwide Pty Limited (Momentum or we, us, our) is committed to protecting Personal Information we hold in accordance with the Australian Privacy Principles (APPs), set out in Schedule 1 of the Privacy Act 1998 (Cth) (Privacy Act).

The purpose of this policy is to detail:

how we collect, use and disclose Personal Information;
how we store and secure Personal Information; and
how your Personal Information can be accessed and kept up to date.

While the Privacy Act may not apply to Momentum’s handling of employee records, our approach is to protect the Personal Information within employee records in the same way we do all other Personal Information.

DEFINITIONS

Cookies:

means a small piece of data sent from a website and stored in a user’s web browser while the user is browsing that website. Every time the user loads the website, the browser sends the cookie back to the server to notify the website of the user’s previous activity. A cookie is sometimes known as a HTTP cookie, web cookie or browser cookie.

Direct Marketing:

means a form of advertising in which marketing materials are provided to consumers in order to communicate information about a product or service. Types of direct marketing materials include, but are not limited to:

short message service (SMS) texts
email
telephone
database marketing
flyers
catalogue distribution, and
promotional letters.

Disclosure:

means releasing Personal Information to a person or organisation external to Momentum for example, a Supplier.

Opt-out:

means a method by which individuals can avoid receiving unsolicited product or service information. This is usually associated with Direct Marketing activities.

Personal Information:

means information or an opinion (including information or an opinion forming part of a database and whether or not recorded in a material form) about an individual whose identity is apparent or can reasonably be ascertained form the information or opinion. Personal information includes but is not limited to:

a written record which may include your name, address and other details about you
photographs, images, video or audio footage, and
fingerprints, retina prints, blood or DNA samples.

Sensitive Information:

means a subset of Personal Information which is more sensitive and includes, but is not limited to, information about a person’s health, political affiliations, sexual preferences, criminal record, racial or ethnic origin and biometric information.

Unsolicited Information:

means Personal Information which Momentum has taken no active steps to collect (for example, an employment application having been sent to Momentum by an individual on their own initiative, rather than in response to a job advertisement).

PERSONAL INFORMATION WE MAY COLLECT

Momentum may collect Personal Information for the performance of our activities and to provide services to Suppliers and members of the community.

The types of Personal Information Momentum collect includes, but is not limited to the following:

contact information such as a person’s full name, postal address, home and mobile phone numbers, email address and country of residence
details of your family or household structure (such as the number of children you have)
details of any organization on behalf of which you submit information
gender
date of birth
full name of any legal guardian
username and password
profile picture
video, and
information relating to marketing preferences and behaviour.

Sensitive Information is a subset of Personal Information. Momentum collects Sensitive Information on a limited basis and primarily in relation to its employees in connection with employment functions.

In all other cases, we only collect Sensitive Information where it is reasonably necessary for our functions or activities and either:

the individual has consented; or
we are required or authorised by or under law (including applicable privacy legislation) to do so.

If required, Momentum may ask you to provide us with additional Personal Information from time to time.

Providing your Personal Information to Momentum is voluntary and if you do not wish for your Personal Information to be collected, we request that you do not submit it. If you do not provide your Personal Information to us, we may not be able to provide you with services.

HOW WE MAY COLLECT PERSONAL INFORMATION

Momentum is committed to collecting Personal Information by lawful and fair means. We collect personal information in a number of ways, including, but not limited to:

over the phone
through written correspondence (such as and email)
in person (for example, at job interviews, Supplier meetings and client meetings)
through our website (for example, if an individual submits an inquiry, completes a survey or applies for a role)
in competition entry forms
through electronic systems such as smartphone and tablet applications, and
through third parties (such as a direct marketing database).

Momentum may collect unsolicited Personal Information where the Privacy Act permits. If Momentum receives unsolicited Personal Information that cannot be collected in accordance with the Privacy Act, Momentum will destroy or de-identify the information as promptly as practicable, provided it is lawful to do so.

Momentum’s policy is to not use Personal Information without taking reasonable steps to ensure that the information provided is accurate, complete and up to date; nor will it use Sensitive Information for the purposes of direct marketing.

Momentum will not attempt to match de-identified or anonymous data collected through surveys or online search devices (such as Cookies) with information identifying an individual, without the consent of the individual.

Personal Information collected is de-identified or destroyed once it is no longer in use (after any mandatory retention period that may apply).

COLLECTION NOTICES

Momentum will take reasonable steps to notify individuals of certain matters at or before the time of collecting Personal Information, or as soon as practicable afterwards. These matters include, but are not limited to, the following:

the purposes for which we are collecting the Personal Information
who we are and how to contact us
whether the collection is required or authorized by or under an Australian law, court or tribunal order
any third-party organisations (or types of third parties) to whom we may disclose your Personal Information
whether those third-party organisations are located overseas and, if practicable, the countries in which they are located
information on how to access and correct your Personal Information,
information on how to make privacy complaints, and how Momentum will deal with those complaints, and
the consequences (if any) for you if all or part of your Personal Information is not provided to us.

Typically, Momentum will include information in the collection notice you may be asked to acknowledge at the time of collection. You are encouraged to read the terms of any collection notice carefully.

Where Momentum collects Personal Information from a third-party, Momentum will take reasonable steps to make sure that the third party has notified the individual of those matters set out above.

WHY WE COLLECT PERSONAL INFORMATION

Momentum collects Personal Information for the following purposes:

provide our products and services to our clients
Event Management
Campaign Management
Promotional prize fulfilment
Product development
Marketing
Accounting and business purposes
Where you contact us with an enquiry
To pursue, preserve or protect Momentum’s legal rights or as otherwise required by law, and
for any other purpose that is necessary to fulfil one or more of Momentum’s functions or activities.

It is not mandatory for visitors to Momentum’s website to provide personal information unless such information is required to answer an enquiry or provide a service.

If you consent to receiving Direct Marketing communications from Momentum or its affiliates, your consent will remain current until you advise otherwise; however, you may opt-out of receiving Direct Marketing materials at any time in accordance with the terms set out in the direct marketing communication. At your request, Momentum may provide you with details of any third parties who have provided us with your Personal Information for the purposes of Direct Marketing communications, unless this is unreasonable or impracticable for us to do so.

WHEN WE MAY DISCLOSE PERSONAL INFORMATION

Momentum may disclose Personal Information to our affiliate companies and other third parties in order to provide services to Suppliers and members of the community.

Third parties may include, but are not limited to:

financial institutions for payment processing
prize fulfillment agencies
educational service providers
government and regulatory bodies (such as the Australian Taxation Office, Centrelink and Department of Immigration and Citizenship)
referees whose details are provided to Momentum by job applicants, and
Momentum’s contracted service providers.

Momentum may disclose Personal Information for other reasons, but only where it has your consent to do so, the Privacy Act authorises the disclosure or the disclosure is authorised by law.

Momentum requires third-parties to which it discloses personal information to restrict their use of such information to the purposes for which it has been provided by Momentum in accordance with this Privacy Policy and the Privacy Act.

Momentum will take reasonable steps to ensure that its contracts with third-party service providers include requirements for their compliance with this policy and the Privacy Act.

Except as provided in this Privacy Policy, Momentum, will not now, and does not intend to, sell, transfer or rent Personal Information about any individual to unaffiliated third parties; except where consent has been obtained from the individual.

CROSS-BORDER DISCLOSURES

Momentum may disclose personal information to third parties located overseas in situations including, but not limited to, the following:

data collection (for example, names, training hours and titles for Global statistics);
where cross border campaigns require local storing of personal information; and
where cross border suppliers oversee prize fulfillment on behalf of Momentum or its affiliates.

Momentum is committed to comply with the requirements of the Privacy Act that apply to cross border disclosure of personal information, as well as with any legal requirements applicable in the relevant jurisdiction.

DATA AND QUALITY ASSURANCE

Momentum stores Personal Information in electronic and paper files.

Momentum is committed to the regular and ongoing review of its collection and storage practices , including measures to:

ensure the Personal Information we collect, use and disclose is accurate, up to date, complete and relevant; and
take all reasonable steps to protect the Personal Information that we hold from misuse, interference and loss as well as from unauthorized access, modification or disclosure.

Momentum encourages individuals to inform us of any changes to their Personal Information. Momentum will take steps to destroy or de-identify personal information in accordance with the Privacy Act.

Momentum is not responsible for the privacy or security policies of third-party websites. Momentum encourages you to read such privacy and security policies before supplying them with any personal information.

ACCESS TO AND CORRECTION OF PERSONAL INFORMATION

All individuals have a right to request access to the personal information that Momentum holds about them and to request its correction. Individuals wishing to lodge a request to access or correct their personal information can do so by contacting Momentum in one of three ways:

by writing to Momentum at Unit 10 / 2 Pyrmont Bridge Road | Pyrmont, NSW 2009;
by emailing Momentum at finance@momentumww.com.au; or
by telephoning Momentum at +61 02 8333 0000.

Momentum will you to access your Personal Information, subject to the Privacy Act. Momentum will also provide access in the manner that has been requested, provided it is reasonable and practicable to do so. Momentum may however charge a fee to cover our reasonable costs to locate the requested information and provide it to the individual lodging the request.

If a request has been lodged by an individual for Momentum to correct their personal information, or if Momentum is satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, Momentum will take reasonable steps to correct that information to ensure that the information is accurate, up to date, complete, relevant and not misleading, having regard for the purpose for which it has been collected and held.

Momentum will respond to Personal Information access and correction requests in a reasonable period after the request is made in accordance with the Privacy Act.

FOURTH PARTIES

In conducting business, Momentum regularly interacts with Third Party Suppliers and Partners (collectively referred to as Fourth Parties), on its own behalf and as an independent supplier or agent for clients.

From time to time, Fourth Parties may require Momentum and our subcontractors to adhere to the Fourth Parties’ privacy policies and procedures (in addition to this policy).

In such cases, Momentum:

takes steps to ensure the Fourth Parties’ privacy policies and procedures comply with the Privacy Act
provides copies of the Fourth Parties’ privacy policies and procedures to our subcontractors, and
takes reasonable steps to ensure our employees and any subcontractors understand the terms of the Fourth Parties’ privacy policies and procedures (including by way of briefings or/or training).

As at the date of this policy, Momentum is complying with the following Fourth Parties’ privacy policies and procedures for the work we do for those Fourth Parties:

American Express - https://www.americanexpress.com/us/company/privacy-center/online-privacy-disclosures/
Lion Co - https://lionco.com/legal/privacy-policy/
Microsoft - https://privacy.microsoft.com/en-ca/

See the link to the privacy policies of those Fourth Parties and contact Momentum’s Privacy Officer if you require further information about these arrangements and what impact, if any, they may have on the handling of your Personal Information.

Please contact Momentum’s Privacy Officer if you have any queries about the personal information that Momentum holds, or the way in which Momentum handles that personal information.

Individuals wishing to lodge a query or complaint about the way in which Momentum has collected or handled their personal information are encouraged to do so in writing to the following address:

Privacy Officer

Momentum Worldwide Pty Limited

Unit 10 / 2 Pyrmont Bridge Road

Pyrmont, NSW 2009

Australia

E: finance@momentumww.com.au

P: + 61 02 8333 0000

F: + 61 02 8333 0001

Momentum’s Privacy Officer will endeavour to take any steps necessary to resolve your complaint in a timely manner.

Alternatively, you may contact the Office of the Australian Information Commissioner if you are concerned with how we are handling your Personal Information. Their contact details are:

Post Office of the Australian Information Commissioner

GPO Box 5218, SYDNEY NSW 2001

Email enquiries@oaic.gov.au

Phone 1300 363 992

All enquiries regarding Fourth Party privacy should be directed to the Momentum Privacy Officer.

CHANGES TO OUR POLICY

We take our compliance with the Privacy Act seriously. Momentum reviews this policy on a regular basis to reflect changing legislation or business needs and it may be amended from time to time.

The current version will be made available on our website and a copy may be obtained free of charge from our Privacy Officer.

We also provide training and provide other materials to our employees and suppliers to foster a strong privacy culture.