Privacy Policy

Your privacy is important to us. We are committed to protecting your privacy and to ensure that we uphold your trust. Our Privacy Policy is created in compliance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles. It covers how we collect, use, disclose, and store your information. By accessing and using our website or by submitting information to us, you consent to us using and disclosing your personal information in the ways described in this Privacy Policy.

1. Why we collect your personal information

Positive Media Ltd. is a non-profit organisation with the vision ‘to see every life alight with the love of Jesus’. Our activities are centred around our community radio license granted by the Australian Communications and Media Authority (ACMA) to serve Christians and those interested in spirituality. This license gives us the opportunity to broadcast community radio 24 hours per day throughout the year to provide a voice of hope into the city of Melbourne. We engage with our community through the following activities:

1.  We communicate content that transforms lives through improving the Personal, Community & Spiritual Wellness of our audience.
2. We interact with our audience through them listening to our broadcast, phoning or texting into our station shows, participating in our competitions and attending events.
3. We encourage our audience to volunteer in the running of the station, to donate to the running of the station either through regular or ‘one off’ giving and to advocate for us with their community.
4. We provide sponsorship opportunities for supporters of the station, and we participate in selected community events.

The aim of these engagements with our community is to assist them in finding, developing, and cementing their transformational journey within Christianity. To participate in certain programs or activities, we need to collect some information from those who want to be involved, enabling us to communicate with them and provide the requested services.

2. What personal and sensitive information we collect

“Personal information” includes information about an individual who is either identified in the information or their identity can be ascertainable from it. It includes information and opinions obtained from the individual or from a third party. The information that we collect about you will vary depending on the nature of involvement and the activities that you choose to be involved in. We endeavour to only ask you for information that is reasonably necessary for the activities you seek to be involved in. You are not required to provide the personal and/or sensitive information that we request, but if you choose not to provide it, it may hinder or prevent your involvement or inclusion in some activities and communications. The information that we collect includes:

• contact details (name, address, telephone numbers, email, etc.)
• personal details (birthdate, marital status, gender, etc.)
• family details (spouse, children, etc.)
• education qualifications and occupation information (profession, job title, etc.).

Some personal information is considered ‘sensitive information.’ At times we may collect sensitive information about you, but only with your consent, including:

• health information
• religious information (church affiliation, spiritual milestones)
• professional and practice information
• criminal record; and
• credit card details.

3. How we collect your information

We collect information directly from you unless it is unreasonable or impractical to do so. At times we do collect information about you from third parties, but only where necessary to provide you with services or where you request your details to be passed on to us. We collect personal information about listeners, supporters, donors, volunteers, employees, contractors, and visitors by:

• any of the forms on our website, mobile app, other electronic means, or paper forms (contact form, newsletter sign-up, community calendar, event registration, competition entries, etc.);
• donation forms
• face-to-face meetings
• email or social media message or conversation
• SMS/text messages
• phone calls; and
• voice or image recording.

4. Unsolicited collection of personal or sensitive information

At times we may discover personal or sensitive information about you from a third party. If it is not necessary for conducting Positive Media Inc activities, or we are unable to advise you, we will take steps to destroy or de-identify the information if it is lawful and reasonable to do so.

5. Security and holding of your personal information

We take reasonable steps to protect the personal and sensitive information we hold from interference, misuse, loss, unauthorised access, modification, or disclosure. Our IT systems are password protected and adhere to applicable security standards. Only authorised personnel are permitted to access your data. Where we use cloud storage, we take reasonable steps to ensure that the providers we use have privacy policies in place that comply with Australian privacy regulations and principles. It is our policy to permanently de-identify personal information where reasonable and possible; and destroy personal information once there is no longer a legal or other need for us to retain it.

6. How we use your information

We only use your personal and sensitive information for the reason we collect it as outlined above and for the purpose(s) for which it was collected and for any other purposes that you consent to, or as otherwise reasonably expected or permitted by law. Ways that we may use your information include to:

• Give you access to our websites and to the content and other things on our websites
• Enter you into competitions and promotions (upon request)
• Market our products and services (or those of other people) to you, including by email
• Manage and respond to any complaints or queries you have in relation to our services
• Inform you of changes to our websites, or our business, or to the content and other things available from the websites; and
• Conduct our internal business purposes – for example, to research and develop the websites and our other products and services

7. Anonymity and Pseudonymity

Where practicable and lawful, we will endeavour to provide you with the option of interacting anonymously or by using a pseudonym. However, this may prevent us from practically and effectively communicating with you.

8. Direct marketing

At times we will use your personal information to directly communicate with you about topics which we think you would be interested in, and be of benefit to you, such as events or courses. We may also contact you about donation opportunities that are in line with previous donations you have made to us. These communications will typically be in the form of email or SMS text message. We will always give you the ability to opt-out of these communications, unless the communication is required for involvement in a specific event, or as part of a service you have requested.

9. Accessing your personal information

You can gain free access to your personal and sensitive information by requesting it from us. In some circumstances, we may need to deny your access request, for example where:

• granting you access would have an unreasonable impact on someone else’s privacy; or
• any other reason as consistent with the Privacy Act.

In such a situation we will provide you with an explanation in writing for why access is denied, including information on the process for a complaint regarding the refusal.

10. Correcting your personal information

We take reasonable steps to ensure that the personal information we hold and collect is relevant, accurate, complete and up to date. However, the accuracy of the information we hold depends to a large extent on the information you provide. Please keep your details current by:

• letting us know if there are any errors in the information, we hold about you; and
• keeping us informed of any changes to your information, such as changes to your name or address.

11. Online privacy

We are committed to protecting your privacy on our websites and mobile app. All access to our public websites and mobile app is anonymous, except for any areas where you login with your own account or enter your personal information. When you visit our public websites and mobile app, a record of your visit is logged which includes the following data:

• The date, time, and length of your visit
• Your IP address and/or domain name
• Your operating system and device type (type of browser and platform); and
• The pages and resources you accessed and the documents you downloaded.

A cookie is a small file with a unique ID which your browser saves to your computer. It does not contain any personally identifiable information, but it enables websites to track visitor movements and preferences. We may place cookies on your device to enable us to deliver ads about our services or promotions to you when you visit third-party websites that use the same Google advertising platform. This cookie only knows that you visited our website or app and does not contain any personally identifiable data. If you prefer to disable cookies, instructions for doing so can be found in the Help section of your web browser. Note that disabling cookies on our website will prevent us from being able to display advertisements to you on third-party websites that promote our services, or those of our station sponsors which may be relevant to you. Our website and mobile app may contain links to third party websites, and third-party websites may also have links to our website. Our privacy policy does not apply to other websites. The operators of other websites may collect your personal information. We encourage you to read the privacy policies of any website or mobile app you link to from our website or mobile app.

12. Disclosure of your information

At times we may make some personal information available to strategic partners that work with us to provide services or assist us in our mission, but only where they have agreed to protect the shared data, or where we have your consent to do so. We also make some personal and sensitive information available to some key Positive Media Inc volunteers and contractors, where they have agreed to protect the shared data, for them to provide services or perform certain functions under the oversight of staff. This does not reduce our commitment to your privacy. We work with our staff, volunteers, contractors and strategic partners to ensure that your privacy is respected and secured in line with this policy. Any disclosure of your personal information to recipients other than our strategic partners, volunteers or contractors will only occur if we have your permission, or:

• the disclosure is required or authorised by law or court order; and
• doing so does not breach the Australian Privacy Principles; and
• the recipient of the information is subject to a law or binding scheme that has the effect of protecting the information that is substantially like the way in which the Australian Privacy Principles protects the information.

We may sometimes share non-personal, non-sensitive and de-identified information with research organisations.

13. Privacy questions and complaints

If you have any questions or concerns about our Privacy Policy or if you would like to make a complaint about a possible breach of local privacy laws, please contact us using the contact details below. We read all communications and reply where appropriate as soon as possible. To effectively address your complaint, we may request further information from you about it before we address it. If you are not satisfied with our response, you may refer your complaint to the Australian Information Commissioner (OAIC) on www.oaic.gov.au/. We may update our Privacy Policy from time to time. When we change the policy in a significant way, we will mention it in our regular email newsletter and post a notice on our website along with the updated Privacy Policy. This statement sets out our current Privacy Policy. It replaces any other Privacy Policy which we have previously issued. Privacy Officer Positive Media Inc. 333 Mitcham Road, Mitcham, Victoria, 3132 privacy@positivemedia.com.au Version: 30 October 2023