This Privacy Policy sets out the approach that Park Avenue Florist will take in relation to the treatment of Personal Information. It includes such information on how Park Avenue Florist collects, uses, discloses and keeps secure, individuals’ personal information. In addition to this it also covers how Park Avenue Florist makes the personal information it holds available for access to and correction by the individual.
This policy has been drafted having regard to Park Avenue Florist’s obligations under the Privacy Act 1988 including the new National Privacy Principles. This Policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.
1. COLLECTION
1.1 Park Avenue Florist will only collect personal information where the information is necessary for Park Avenue Florist 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.
1.2 Park Avenue Florist collects Personal Information primarily to supply customers with the products and services ordered from it and its related companies. Park Avenue Florist also collects and uses personal information for secondary purposes including:
- billing and account management;
- business planning and product development;
- to provide individuals with information about promotions, as well as the products and services of Park Avenue Florist affiliated companies and other organisations; and
- to enhance the online shopping experience by displaying products and/or services that match the personal preferences of individuals based on their previous website browsing history and/or buying activity.
1.3 Park Avenue Florist will not collect Sensitive Information from individuals except with consent and only where it is necessary for Park Avenue Florist to collect such information for an activity or function.
1.4 Park Avenue Florist will not collect Personal Information secretly or in an underhanded way.
1.5 Park Avenue Florist will take steps to ensure that individuals on purchase lists are or have been notified of the information as outlined at 1.3.
2. USE
2.1 Park Avenue Florist 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 which would be within the relevant individual’s reasonable expectations.
2.2 Park Avenue Florist uses personal information primarily for the purposes listed in 1.2 above.
2.3 If Park Avenue Florist relies on the direct marketing exception to direct market to individuals it will ensure that:
- the individual is clearly notified of their right to opt out from further direct marketing;
- there is only one use of the information before the opt out right is given and this use applies across all Park Avenue Florist related business entities (if the information is shared between those business entities);
- the individual is given an opt out in all further instances of direct marketing if they have not previously chosen to opt out; and
- if the individual opts out of all direct marketing the opt out will be respected by Park Avenue Florist and all its business entities.
2.4 Park Avenue Florist will not use Sensitive Information for direct marketing.
2.5 Park Avenue Florist may use personal information to avoid an imminent threat to a person’s life or to public safety. It may also use personal information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 Park Avenue Florist will not use personal information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
3. DISCLOSURE
3.1 Park Avenue Florist may disclose personal information to related or unrelated third parties if consent has been obtained from the individual. This will include obtaining the individual’s consent for disclosures made under the credit reporting requirements of the Privacy Act.
3.2 Park Avenue Florist may disclose personal information between related business entities. Where information is disclosed to such a related business entity, that related business entity is bound by the original primary purpose for which the information was collected.
3.3 Park Avenue Florist may disclose personal information to unrelated third parties to enable outsourcing of functions (such as billing, customer relations management and order fulfilment), where that is disclosure or use for a related secondary Ppurpose and has been notified to individuals or where such disclosure is within the individual’s reasonable expectations.
3.4 Park Avenue Florist 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.
3.5 Park Avenue Florist may disclose personal information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.
3.6 Park Avenue Florist may disclose personal information to avoid an imminent threat to a person’s life or to public safety.
3.7 If a disclosure is not for a primary purpose; is not for a related secondary purpose; or upfront consent has not been obtained, Park Avenue Florist will not disclose personal information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
3.8 Park Avenue Florist does not generally sell or share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved. If the consent provided is conditional, Park Avenue Florist will take steps to ensure (by contract) that the use of its customer list by third parties does not exceed the scope of the consent.
4. INFORMATION QUALITY
4.1 Park Avenue Florist will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 Park Avenue Florist will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years from the date of the last customer interaction, unless the law requires otherwise.
5. INFORMATION SECURITY
5.1 Park Avenue Florist requires employees and contractors to perform their duties in a manner that is consistent with Park Avenue Florist’ legal responsibilities in relation to privacy.
5.2 Park Avenue Florist 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 Park Avenue Florist who have a genuine “need to know” as well as “right to know”.
5.3 Park Avenue Florist will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
6. ACCESS AND CORRECTION
6.1 Park Avenue Florist will allow its records containing personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 Park Avenue Florist will correct its records containing personal information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting Park Avenue Florist Customer Service, as per the details on the website.
6.4 Park Avenue Florist can charge a fee for processing an access request but will generally not do so unless the request is complex or is resource intensive.
7. OPENNESS
7.1 Park Avenue Florist Customer Service representatives will be the first point of contact for inquiries about privacy issues. Individuals wishing to make an inquiry or complaint regarding privacy should do so by contacting Park Avenue Florist Customer Service, as per the details on the Park Avenue Florist website.
7.2 Park Avenue Florist websites will contain a prominently displayed privacy statement and will include a copy of Park Avenue Florist Privacy Policy.
8. ANONYMOUS TRANSACTIONS
8.1 Park Avenue Florist will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. Park Avenue Florist may however request visitors to provide Personal Information voluntarily to Park Avenue Florist (for example, as part of a competition or questionnaire).