Frankly Privacy Policy

Our privacy commitment

Frankly Agency Pty Ltd (‘we’, ‘us’, ‘our’ and ‘Frankly’) is committed to protecting the privacy of your personal information. This policy explains how Frankly manages the personal information that we collect, use and disclose and how to contact us if you have any further queries about our management of your personal information. This policy does not cover personal information collected or held by Frankly or any of its related bodies corporate (as applicable) about its employees.

Frankly is bound by the Australian Privacy Principles in thePrivacy Act 1988 (Cth) (Privacy Act)which regulate how we may collect, use, disclose and store personal information, and how individuals may access and correct personal information held about them. Frankly is also required to comply with the Spam Act 2003(Cth) and the Do Not Call Register Act 2006 (Cth).

We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy.

If you have any questions regarding Frankly’s Privacy Policy or would like us to send you a copy of this policy please contact our PrivacyOfficer using the details provided below. Our Privacy Policy may be amended from time to time. The current version will be posted on our website.

What is personal information?

Personal information is any information or an opinion, in any form and whether true or not, about an identified individual or an individual who is reasonably identifiable. Examples include an individual's name, address, contact number and email address.

Sensitive information is a special category of personal information. Sensitive information includes health information and information about a person's race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual preferences and criminal history.

How does Frankly collect and hold your personal information?

Frankly will only collect personal information about you by lawful and fair means. Frankly collects personal information in a variety of ways. It is Frankly’s usual practice to collect personal information directly from you (or from your authorised representative), for example when:

  • you enquire about or seek a quotation for a product or service offered by us; or
  • you contact us by telephone, mail, email or online; or
  • you visit our website (including when you request a quote or to be contacted by us);
  • we supply any other products or services to you; or
  • you enter into any trade promotions, competitions or other offers with Frankly or its partners; or
  • you fill in and submit a form on our website; or
  • communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites.

Sometimes we collect personal information about customers or potential customers from a third party or a publicly available source, or from marketing and similar lists legally acquired by us.

If you provide us with personal information about another person (such as a family member), please make sure that you have their consent to do so and that you tell them about this policy.

What kinds of personal information does Frankly collect and hold?

The kinds of personal information that we collect and hold about you will depend on the circumstances of collection, including whether we collect the information from you as a customer, provider, contractor, supplier, stakeholder, job applicant or in some other capacity.

For example, if you request a quote for a product or service offered by us, we may collect your name, address, email address, telephone number, date of birth and any other information required to provide you with the quote. If you deal with us in some other capacity (for example, as a provider, a supplier or a stakeholder), we may collect your name, contact details and any other information you choose to provide to us.

In general, we may collect the following personal information from you:

  • name;
  • mailing or street address;
  • email address;
  • telephone number and other contact details;
  • age or date of birth;
  • credit card information;
  • your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard weblog information;
  • details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
  • any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
  • information you provide to us through customer surveys; or
  • any other personal information that may be required in order to facilitate your dealings with us.

Any personal information that you provide via our website or contact centre (for example, for comparison purposes, to obtain a quote or to purchase products) is collected and stored by Frankly.

To provide some of our services, we may be required to collect and hold your sensitive information . We will only collect sensitive information about you with your consent (unless we are otherwise allowed or required by law to collect that information).

If you provide your personal information to a third party via Frankly (for example, to purchase products or services on a third party website which is linked to Frankly) that information is collected and managed by those third parties. You should familiarise yourself with their privacy policy prior to deciding whether you wish to provide them with your information.

We may record and monitor calls that you make to us in certain circumstances. For example, calls to our contact centre are recorded and monitored for training and customer service purposes and to meet our regulatory obligations.

If you provide us with information about another person, you must obtain that person’s permission to give us the information and inform them of this policy. If we are not able to collect your personal information, we may not be able to provide you with our products or services or do business with you or the organisation with which you are connected.

How does Frankly use your personal information?

We use personal information for a variety of reasons including to:

  • provide services and products to you;
  • answer your inquiries and deliver customer service;
  • tell our customers and prospective customers about other products, services or promotional offers that we think may be of interest to them;
  • ensure we comply with the requirements of our suppliers;
  • maintain and improve our customer service;
  • meet our regulatory and legal obligations;
  • manage and resolve any legal or commercial complaints and issues;
  • consider job applicants for current and future employment;
  • manage our relationships with our suppliers and stakeholders;
  • carry out internal functions, including training; and
  • conduct marketing research and analysis.

We may also use your information for other purposes required or authorised by or under law, including purposes for which you have provided your consent. That consent may be written, verbal or implied from your conduct.

In what circumstances will Frankly disclose your personal information?

In the course of conducting our business and providing our products and services to you, we may disclose your personal information.

We may also disclose your personal information to, where appropriate:

  • our employees;
  • any person interested in purchasing our business or assets;
  • specific third parties you agree to whom we may disclose your personal information;
  • professional advisers (such as lawyers or auditors)
  • our contracted service providers, including:
  • information technology service providers;
  • payment systems operators and financial institutions; and
  • organisations authorised byFrankly to conduct sales, promotional, research or marketing activities;
  • law enforcement agencies or government authorities; and
  • any persons acting on your behalf including those persons nominated by you, executors, trustees and legal representatives.

We may disclose your personal information to third parties for other purposes required or authorised by or under law, including purposes for which you have provided your consent. That consent may be written, verbal or implied from your conduct.

In all circumstances where your personal information is disclosed, we will take all steps reasonable to ensure that these third parties undertake to protect your privacy.

Direct marketing

If you are a customer or a potential customer, we may contact you with information about products and services offered by Frankly, as well as our business partners, which we think may be of interest to you. When we contact you it may be by mail, telephone, email, SMS or social media. We will generally give you the opportunity to express a wish not to receive direct marketing communications. Your consent to receive direct marketing communications in the above ways will be deemed to have been given if you do not opt out of receiving direct marketing communications from us, and will remain current for an indefinite period of time unless and until you advise us otherwise. You can opt out of receiving direct marketing at any time (see below).

If you want to know how we obtained your personal information, please contact our Privacy Officer using the details provided below and we will let you know unless it is impracticable or unreasonable to do so.

How can you opt out of receiving direct marketing?

If you wish to unsubscribe from future marketing or promotional material, please click the “Unsubscribe” link at the bottom of the marketing email you will have received. On completing the unsubscribe process an onscreen confirmation message will appear.

Does Frankly disclose your personal information to overseas recipients?

Some of our service providers, consultants, agents or other organisations that we may disclose your personal information are or may be located outside Australia.

For example, we may share your information with our third parties in Canada, Chile, China, Hong Kong, countries within the EuropeanUnion, India, Japan, Malaysia, New Zealand, Philippines, Russia, Singapore,South Africa, South Korea, Sri Lanka, Taiwan, the UAE, the United States ofAmerica, and Vietnam.

Your personal information may be stored in a secure and encrypted form overseas (e.g. in data storage and cloud computing facilities operated by us or by third parties on Frankly’s behalf).

Use of Government Identifiers

Frankly will not use Australian Commonwealth government-related identifiers, such as Medicare numbers, or a driver's licence number, as its own identifier of individuals.

Data quality and Security

We may store your information in hardcopy and/or in electronic form. We will take reasonable steps to ensure that your personal information is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.

This may include a range of systems and communication security measures, as well as the secure storage of hard copy documents. In addition, access to your personal information will be restricted to those properly authorised to have access.

We rely on the personal information we hold in conducting our business. Therefore, it is very important that the information we hold is accurate, complete and up-to-date. If you believe that your personal information is inaccurate, incomplete, out of date, irrelevant or misleading, please contact our Privacy Officer using the details provided below and we will take reasonable steps to correct that information.

Website usage

Our website is professionally hosted and operates in a secure environment. You should however be aware that there is always an inherent risk in transmitting your personal information via the Internet.

Cookies are pieces of information that a website transfers to your computer for record-keeping purposes. The information collected may be used by Frankly to improve and customize your experience on our website.

In addition, we may collect aggregated non-personally identifiable data from our website to help us maintain and improve delivery ofFrankly's online services and marketing. This aggregated information assistsFrankly to improve content and website navigation.

When you visit any of our online resources, our system may certain collect information about your visit for statistical purposes, including:

  • server address;
  • top level domain name (for example .com, .gov, .au, etc.);
  • the date and time of your visit to the site;
  • the pages you accessed and documents downloaded during your visit;
  • the previous site you visited;
  • whether you've visited our site before; and
  • the type of browser used.

We record this data to maintain our server and improve our services. There are several methods and packages that we use to collect visitor behaviours on each of our online platforms. Like a number of commercial website operators, Frankly uses tools to measure and analyse internet usage across our websites. This enables Frankly to track the number of unique browsers to our websites.

Links to third party sites

Whilst links to third party websites are provided on our website, we are not responsible for the content or practices of these third party websites.

These links are provided for your convenience and do not represent Frankly's endorsement of any linked third party website. We recommend that you check the privacy policies of these third parties prior to providing them with your personal information.

How you can access or correct your personal information

You can request access to the personal information we hold about you by contacting our Privacy Officer using the details provided below.We will generally provide you with access, subject to some exceptions permitted by law.

Access to personal information may be refused in a number of circumstances, such as where:

  • providing access would have an unreasonable impact on the privacy of others;
  • the request is frivolous or vexatious;
  • the information relates to existing or anticipated legal proceedings and would not normally be accessible as part of those proceedings;
  • providing access would be unlawful;
  • denying access is required bylaw;
  • providing access would be likely to prejudice enforcement related activities conducted by an enforcement body;
  • giving access would reveal evaluative information in connection with a commercially sensitive decision-making process; or
  • giving access would pose a threat to the life, health or safety of any individual or to public health or safety.

If we deny or restrict access to the information you have requested, we will give you written reasons for this decision when we respond to your request. We may charge a fee to cover our costs of providing access to you and will advise you of any fee payable before we provide you with access.

How you can make a privacy complaint

Please contact our Privacy Officer using the details provided below if you have any concerns or complaints about the manner in which we have collected or handled your personal information. We will investigate your complaint and respond to you in writing within 30 days.

If you consider your privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, you can contact the Australian Information Commissioner on 1300363 992 or visit their website at www.oaic.gov.au.

How to contact us

If you:

  • have queries, concerns or complaints about the manner in which your personal information has been collected or handled byFrankly;
  • would like to request a hard copy of this privacy policy or discuss any issues relating to this policy or privacy matters generally; or
  • would like to request access to or correction of the personal information we hold about you;
Please contact our Privacy Officer:
  • by telephone on 03 8691 0799
  • by mail to Level 13, 10 Queens Rd, Melbourne VIC3004
  • by email to privacy@Frankly.com.au.
Updated 14 October 2019