THE VILLAGE ROADSHOW GROUP OF COMPANIES - PRIVACY POLICY

1. INTRODUCTION

1.1 Village Roadshow Group of Companies

Village Roadshow Ltd and its subsidiaries (collectively, “Village” or “we” or “us”) operate a wide variety of entertainment businesses including the operation of cinemas, theme parks, indoor games facilities, the production and distribution of films and DVDs and the provision of marketing solutions.

Through these varied operations, Village from time to time gathers information from
customers and other parties with whom we deal for a variety of reasons including to enable us to provide the services.

Village takes seriously its obligations in respect of the personal information it gathers. To safeguard that information, Village has implemented a program to ensure compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”).

This Privacy Policy outlines how Village deals with “personal information”, as defined in the Privacy Act.

2. WHY VILLAGE COLLECTS PERSONAL INFORMATION

2.1 Nature of Information

The personal information which Village collects will depend on the circumstances of collection and the type of service involved.  In most cases the personal information will concern customers but also newsletter subscribers, suppliers and other parties we deal with (for the purposes of this Privacy Policy, all such people are described as “customers”). 

The personal information may include:
• name, gender, date of birth, contact details;
• payment details (such as credit/ debit card number and expiry date) provided in connection with the purchase of our products and services; and 
• loyalty program membership number and details including buying history, opinions and product preferences.

Village (or its agent) collects certain information of shareholders for registration purposes, such as name, address, number of shares held, tax file number and bank account details.  Village is required to maintain a register of shareholders under the Corporations Act 2001 (Cth).

2.2 How Village Collects Personal Information

Village may collect personal information when a customer uses our services or purchases our goods, registers to receive our newsletters or other communications, registers to be part of one of our loyalty programs, enters one of our competitions or promotions, visits our websites, completes a survey or otherwise interacts with us. 

There may be occasions when Village collects personal information about a customer from a third party.  These third parties may include agents and other people who sell products or services to customers for us or who interact with customers on our behalf; third parties that run competitions and other promotions for us; and sharebrokers when shares in Village are purchased.  

In accordance with the APPs, where practical, customers may deal with Village anonymously. However, frequently it is necessary to collect personal information during the course of transactions.

2.5 Customer consent

Wherever practical, Village will obtain the express consent of customers to the collection of personal information. In some situations, Village will interpret a customer’s actions as indicating that a customer consents to the collection of personal information. This may occur where the customer has provided personal information for a particular purpose and that purpose cannot be achieved without Village making use of the customer’s personal information.

2.6 What happens if Personal Information is not provided?

Village may not be able to provide a proper service to customers if personal information is not provided upon request.

2.7 Cookies 

Village uses “cookies” to facilitate the use of its websites.  Cookies are small units of data sent to a user’s browser by a website the user visits. The main reasons Village uses cookies are:

• to improve a customer’s website browsing experience
• to better understand how its websites are used and to allow improved navigation for its customers
• to enable it to present customised messages and offerings to customers. 

The cookies Village uses do not store any personal data or otherwise collect personal information.  However if a loyalty club member is logged into their account, the information Village collects via cookies may be linked with their personal information.  

You can configure your Internet browser to erase cookies from your computer's hard drive, block cookies or to receive a warning before a cookie is stored.  If a user disables the use of, or deletes, cookies on their web browser then they may not be able to gain access to all the content and facilities of Village’s websites.

2.8 Google Analytics

Village’s websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). The following is a Data Privacy Statement in relation to the use of cookies by Google Analytics:
Google Analytics is a web analysis service provided by Google.  Google utilises the data collected to help Village analyse how users use the websites. The information generated by the cookie about a customer’s use of the website (including its anonymised IP address) will be transmitted to and stored by Google on servers in the United States.

Google will use this information for the purpose of evaluating customer use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
You can prevent Google from detecting a cookie that is generated because of and related to your usage of this website (including your IP address) as well as processing of these data by downloading and installing this browser plugin: http://tools.google.com/dlpage/gaoptout?hl=en

Importantly, we do not combine the anonymous information collected through Google Analytics with personally identifiable information.

USE OF REMARKETING TOOLS

Village may use Google remarketing, Facebook remarketing, pixel tags, web beacons, clear GIFs or other similar technologies to collect information of a customer’s visit to any one of its websites and deliver specific advertisements to that customer about products and services based on the pages visited and the way in which the customer accesses the website. These advertisements may be delivered by third party vendors when you visit our websites or other Internet websites.

3. USE AND DISCLOSURE OF PERSONAL INFORMATION

3.1 Use of Personal Information

Village may use personal information for the following purposes:

(a) to provide and administer goods and services, such as verifying a customer’s identity; contacting customers about orders and bookings; processing payments; 
(b) to provide and operate Village’s competitions, promotions and events;
(c) to distribute Village’s newsletters and other communications itself or with the assistance of third party services providers;
(d) to provide customer support, including resolving and providing assistance for orders or tickets or to respond to other enquiries or requests;
(e) to conduct marketing activities for Village’s products and services, or products and services of third parties, and to conduct market and other research to improve Village’s products, services and marketing activities;
(f) to register any shareholding customers may have in Village and to contact them in  relation to any shareholding;
(g) to conduct market research and analysis;
(h) to facilitate participation in loyalty programs;
and
(i) to maintain records and comply with Australian law.

3.2 Disclosure of Personal Information

In general, only officers, employees or contractors of Village may view personal information.  Village will only disclose to other parties where Village believes that access is necessary to
achieve the purpose for which the personal information was collected. Village may disclose personal information to a service partner (such as auditors, accountants and lawyers) and other professional services firms to comply with our legal obligations, including to various law enforcement agencies, regulatory authorities and government bodies.  Village may also disclose personal information to couriers, computer security companies and hosting services or a related company or person, for example, a related body corporate or someone with whom Village shares a common commercial interest.  To the extent that these third parties are located in Australia and Village discloses personal information to them, they are subject to privacy legislation which prevents the personal information being used for any other purposes. 

3.3 International transfers 

Village may disclose personal information to overseas service providers. Village will only do so in compliance with all applicable Australian privacy laws and will ensure the overseas service providers handle the personal information in accordance with the APPs. Village will take reasonable steps to protect personal information regardless to which country it is transferred or transferred.  

3.4 Storage and Security

Personal information may be stored in hard copy form, on computer or both. Hard copy personal information is wherever practical, kept under locked security. Personalinformation stored on computer is wherever practical, password protected. Where possible and practical, Village will endeavour to comply with recognised Australian and international standards relating to information security. Village deletes and de-identifies personal information when the information is no longer needed by Village.

3.5 Updating Personal Information

Village monitors the quality and accuracy of personal information that it maintains and where practical, updates that information on a regular basis. Customers can update orcorrect their personal information at any time by contacting Village’s Privacy Officer

Village has adopted the position proposed by the Privacy Commissioner that a young person is able to give their consent when he or she has a sufficient understanding and maturity to understand what is being proposed. When obtaining personal information from minors, Village’s staff will make an objective determination before collecting that information as to whether the persons involved would be able to provide informed consent to the use of their personal information.

5. COMPETITIONS

Personal information gathered during competitions run by Village will be governed by the principles set out in this Privacy Policy unless an express statement is made in relation to privacy in the conditions of entry for the competition.

6. DIRECT MARKETING 

Personal information collected for direct marketing purposes will only be collected, used or  disclosed with the consent of the customer. However, in some circumstances where Village cannot practically obtain the consent of a customer, Village may still engage in direct marketing, but will:

(a) include an 'unsubscribe' facility so customers can unsubscribe from the mailing list at any time or contact the Privacy Officer to remove the customer’s details from the mailing list; and
(b) include a prominent statement to the fact that a customer may make such a request.

7. ACCESS TO PERSONAL INFORMATION

Customers wishing to request access to, or correct, personal information held by Village should contact the Privacy Officer using the contact details in the section below titled “Who to Contact”. Village will provide access to the information held about the individual, including for the purpose of correcting or updating that information, unless there is an exception which applies under the APPs. Any request to provide access to this information will be dealt with within a reasonable time. If Village refuses to provide a customer with access to their personal information, Village will provide written reasons and advise the customer how they may complain about the refusal.  Loyalty programs members can update their profile information online or by contacting the Privacy Officer using the contact details in the section titled “Who to Contact”.

8.3 Third party intermediary

If Village withholds access to personal information, Village will consider whether the provision of access to an independent third party will meet Village’s and the relevant customer’s needs

9. CONTRACTORS

Village may from time to time employ subcontractors to provide services to it. In these
situations, personal information may be collected about those subcontractors. This Privacy
Policy applies equally to those subcontractors.

10. WHO TO CONTACT

Village is committed to working with its customers to obtain a fair resolution of any complaint or concern about privacy.¬¬

If you have a concern about your privacy or a query on how your personal information is collected or used please contact Village using the details below. We will  respond to your query or complaint within a reasonable time. If you are not satisfied with Village’s response, you may also contact the Office of the Australian Information Commissioner.

Write to us at:
Privacy Officer
Village Roadshow Limited
Level 1,500 Chapel Street
South Yarra, Victoria 3141
Email: privacy@roadshow.com.au

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