Privacy Policy

ACE RADIO PRIVACY AND CREDIT REPORTING PRIVACY POLICY

1. OVERVIEW OF THIS POLICY

This Policy details how we comply with the Privacy Act, including the Australian Privacy Principles and the Credit Reporting Code, which have been introduced under the Privacy Act.

This Policy does not apply to the collection or use of information about corporations.

If you would like a hardcopy of this Policy, please contact Mark Taylor on 03 9928 4888.

2. DEFINITIONS

2.1. APPs means the Australian Privacy Principles introduced under the Privacy Act;

2.2. Credit Reporting Information is used in this Policy to describe Credit Information, as defined in the Privacy Act, including, where the context requires, information obtained from Credit Reporting Bodies, as defined in the Privacy Act;

2.3. Information is used in this Policy to describe Personal Information, Sensitive Information and Credit Reporting Information collectively;

2.4. Personal Information means information or an opinion about an identified individual or an individual who is reasonably identifiable:

2.4.1. whether the information or opinion is true or not; and

2.4.2. whether the information or opinion is recorded in a material form or not;

2.5. Privacy Act means the Privacy Act 1988 (Cth) as amended from time to time;

2.6. Sensitive Information is defined in the Privacy Act to include things such as race, sexual orientation, political opinions, members of a trade association or trade union, criminal record or health information.

3. THE TYPE OF INFORMATION WE COLLECT

3.1. Personal Information

Personal information that we collect and hold is information that is reasonably necessary for the proper performance of our functions and activities as a supplier of services.

While the type of Personal Information we collect and hold may vary, generally it will include the following:

3.1.1. identification information, such as your name, date of birth and address;

3.1.2. telephone numbers and e-mail addresses;

3.1.3. licence details;

3.1.4. credit information, such as details relating to credit history, credit capacity, and eligibility for credit;

3.1.5. credit card information;

3.1.6. Government identifiers (such as your tax file number);

3.2. Sensitive Information

We may at times, subject to this Policy, also collect and hold Sensitive Information.

3.3. Credit Reporting Information

The type of Credit Reporting Information we collect and hold includes:

3.3.1. identification information, such as age, date of birth, drivers licence number;

3.3.2. credit-related information, such as:

3.3.2.1. the type of credit you have obtained and the terms upon which it was obtained;

3.3.2.2. the day on which the credit is entered into and the day on which it is terminated or otherwise ceases to be in force;

3.3.2.3. repayment history information and default information;

3.3.2.4. scores, ratings, summaries, evaluations and other information relating to your credit worthiness;

3.3.3. certain administrative information relating to credit;

3.3.4. information which has bearing on your creditworthiness which is relevant to evaluating your eligibility for credit, such as:

3.3.4.1. insolvency information;

3.3.4.2. credit infringement information;

3.3.4.3. court judgments made in relation to your past or present credit arrangements.

4. COLLECTION

We collect Information only by fair and lawful means where it is reasonable and practicable to do so. We do so in order to conduct our business, to provide and market our services and to meet our legal obligations.

If you do not provide us with Information we reasonably request, we may not be able to provide the requested services to you. We also may not be able to provide you with the information about the services that you may want.

4.1. How we Collect Information

4.1.1. We collect Information that you provide:

4.1.1.1. when visiting our websites;

4.1.1.2. in applications or resumes you lodge with us;

4.1.1.3. during telephone, or in person, conversations with us; and

4.1.1.4. in written correspondence to us (including email correspondence).

4.1.2. We also collect Information provided by other people when it is necessary for a specific purpose, such as checking information that you have given us or where you have consented, or would reasonably expect us, to collect your Information in this way.

If it is unclear to us whether you have consented to the collection of Information from a third party, we will take reasonable steps to contact you to ensure that you are aware of the reason and purpose of the collection.

If we collect Information from a third party, we will inform you that the Information has been collected and the circumstances of such collection.

4.1.3. We will also collect Information about you if we are required to do so under an Australian law. If so, we will inform you of this, including details of the law requiring the collection.

4.1.4. We may also collect Information about you from a range of publicly available sources including newspapers, journals, directories, the internet and social media sites.

4.2. Specific Technology Issues

It is important that you understand that there are risks associated with use of the internet and you should take all appropriate steps to protect your Information. You can contact us by land line telephone or post if you have concerns about making contact via the internet.

We may use cookies when you visit our website (www.aceradio.com.au) and, as a consequence, we may collect certain information from you such as:

4.2.1. your browser type;

4.2.2. your location;

4.2.3. your IP address;

4.2.4. information about when and how you use our website;

4.2.5. information about your past internet usage, such as websites you visit before coming to our website; and

4.2.6. [insert other information collected when a person visits your website].GJ to complete

4.3. Unsolicited Information

Where we receive unsolicited Information about you, we will check whether that Information is reasonably necessary for our functions or activities. If it is, we will handle this Information in the same way we do other Information we seek from you. If not, we will destroy or de-identify it.

5. REASON FOR COLLECTION, DISCLOSURE & USE

5.1. Personal Information

We may use and disclose your Personal Information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act. In general, we use and disclose your Personal Information to:

5.1.1. conduct our business;

5.1.2. provide and market our services;

5.1.3. communicate with you and assist you with enquiries;

5.1.4. comply with our legal obligations;

5.1.5. help us manage and enhance our services;

5.1.6. gain an understanding of your needs;

5.1.7. establish an account for you;

5.1.8. give you access to specific sections of our website; and

5.1.9. improve your online experience with us.

5.2. Sensitive Information

In accordance with the Australian Privacy Act, we may share user information with partner businesses when outsourcing the provision of products or services. In such cases, information will only be shared with partner organisations for the purpose of assisting with customer support and handling enquiries, and will be handled in compliance with privacy requirements.

We will not collect Sensitive Information about you unless:

5.2.1. we obtain your explicit consent to collect and use such Sensitive Information, or:

5.2.2. the Sensitive Information is reasonably necessary for one or more of our functions or activities; or

5.2.3. the collection of the Sensitive Information is required or authorised by or under Australian law or a court/tribunal order; or

5.2.4. a permitted general situation exists in relation to the collection of the Sensitive Information by us; or

5.2.5. a permitted health situation exists in relation to the collection of the Sensitive Information by us.

5.3. Credit Reporting Information

We collect, use and hold your Credit Reporting Information:

5.3.1. to determine payment terms for the services we provide;

5.3.2. for day to day administration purposes; and

5.3.3. to satisfy our legal obligations.

In addition, we use Credit Reporting Information that we obtain from Credit Reporting Bodies to derive information in relation to your creditworthiness and eligibility for credit. This is known as “Credit Eligibility Information”.

We may disclose Credit Reporting Information about you to Credit Reporting Bodies and debt collection companies where you are in payment default. We will only make a disclosure in these circumstances if we have given you written notice of our intention to disclose and at least 14 days has passed since giving you such notice.

The types of Credit Reporting Information that we may disclose includes:

5.3.4. identification information; and

5.3.5. information that you have defaulted on a payment due to us and the amount of the default.

Subject to paragraphs 5.4 and 5.5, we will not disclose Credit Reporting Information, including Credit Eligibility Information, about you unless you have authorised the disclosure or it is otherwise in accordance with Australian law.

5.4. Disclosure to Related Entities

We may disclose Information to our related entities.

5.5. Overseas Disclosure

We may also disclose Information to certain overseas recipients. Before disclosing Information to an overseas recipient, we will take reasonable steps to ensure that the overseas recipient does not breach the APPs with respect to the Information.

6. MARKETING

We may use and/or disclose your Information in order to:

6.1. provide you with news and information about our services;

6.2. provide you with marketing and promotional material that we believe you may be interested in; or

6.3. seek your feedback on our services.

Only with your express consent will we use or disclose Information about you for the purposes of direct marketing. You can ask us not to do this at any time by writing to Mark Taylor email; mtaylor@team.aceradio.com.au

We will not sell your Information.

7. SECURITY & MANAGEMENT

We take reasonable steps to protect your Information against misuse, interference, loss, unauthorised access, modification and disclosure. The protective steps we take include:

7.1. confidentiality requirements of our employees;

7.2. document storage security policies;

7.3. security measures for restricted access to our systems; and

7.4. deletion, destruction or de-identification of Information where it is no longer required by us.

8. CORRECTION



We aim to ensure that the Information we hold is accurate, complete and up-to-date. We encourage you to contact us in order to update any Information we hold about you. Our contact details are set out at the end of this Policy.

If you contact us regarding an apparent inaccuracy in relation to your Information and we are satisfied that the Information is inaccurate, out-of-date, incomplete, irrelevant or misleading, then reasonable steps will be taken to correct the Information within 30 days, or a longer period as we agree with you in writing.

We will not charge you for a correction.

If we determine that the correction is not required, we will provide you with written notice stating the reasons why the correction was not made and refer you to our complaints procedure.

If a correction is made to any Information that was previously disclosed to a third party, as long as it is reasonable to do so, we will give each such recipient written notice of the correction within a reasonable period. We will also notify you that the correction has been made.

9. ACCESS TO YOUR INFORMATION

You are entitled to access your Information held by us.

If you wish to access your Information, you must lodge a request for access by contacting Mark Taylor by email at mtaylor@team.aceradio.com.au or by post to ACE Radio, 8C, 18 Albert Road, South Melbourne 3205

We may charge a fee to cover our reasonable costs in meeting an access request. You will be provided with access to your Information within 30 days of the request (unless unusual circumstances apply).

We are not required to give you access to your Information if:

9.1. it would be unlawful to do so; or

9.2. denying access is required or authorised by Australian law or a court/tribunal order; or

9.3. to do so would likely prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body.

If we do not give you access to your Information you will receive written notice that explains the reason for the refusal.

10. COMPLAINTS

Complaints about alleged breaches by us of the Privacy Act, the APPs, the Credit Reporting Code or this Policy can be made by contacting Mark Taylor, Chief Executive Officer, ACE Radio Broadcasters P/L by email: mtaylor@team.aceradio.com.au If you do not consider that your complaint has been adequately dealt with by us, you may make a further complaint to the Office of the Australian Information Commissioner, which has complaint handling responsibilities under the Privacy Act.

11. ACCESS TO THIS POLICY

This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment.

The most current version of this Policy is available at our website www.aceradio.com.au or can be obtained by contacting our Privacy Officer:

E-Mail: mtaylor@team.aceradio.com.au

Phone: 03.9928.4888

Postal Address: ACE Radio Broadcasters P/L 8C,18 Albert Road, South Melbourne Vic 3205

12. FURTHER INFORMATION

If you have any questions about privacy-related issues please contact our Privacy Officer.

For further information about privacy, the protection of privacy and credit reporting can also be found on visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au

ACE RADIO CCTV PRIVACY POLICY

Document Number: ACE-CCTV-001
Effective Date: March 24, 2025

ACE Radio is committed to ensuring the privacy, safety, and security of all individuals accessing our facilities. This CCTV Privacy Policy outlines how we use, store, and manage CCTV footage collected from our premises, including studios, offices, and transmitter sites.

1. PURPOSE OF CCTV MONITORING

The primary purpose of CCTV at ACE Radio is to:

• Ensure the safety and security of staff, visitors, and assets.
• Monitor access to restricted areas.
• Deter unauthorized activities or security incidents.
• Support the investigation of suspected violations of company policies or criminal activity.

2. SCOPE OF CCTV COVERAGE

• CCTV cameras are in public and restricted areas within our facilities, including entrances, hallways, parking areas, transmitter sites, and studios.
• No cameras will be placed in areas where individuals have a reasonable expectation of privacy, such as restrooms or changing areas.

3. TYPE OF DATA COLLECTED

• The CCTV system captures video footage, which may include images of employees, contractors, visitors, and any other individuals present on ACE Radio property.
• CCTV footage may also record interactions with ACE Radio assets located in public areas, such as equipment, vehicles, or any other company property.
• Cameras do not record audio unless explicitly stated and compliant with applicable laws.

4. STORAGE AND RETENTION OF DATA

• CCTV footage is stored securely in a restricted-access system.
• Footage will be retained for a maximum of 90 days, unless required for a longer period for investigation or legal purposes.
• Once the retention period has expired, data is securely deleted.

5. ACCESS TO CCTV FOOTAGE

• Access to CCTV footage is strictly limited to authorized personnel, such as security staff, facility managers, or legal representatives, as required.
• Footage may also be shared with law enforcement agencies when necessary for criminal investigations or as required by law.
• Requests from individuals to view footage involving them will be evaluated on a case-by-case basis, in compliance with privacy laws.

6. THIRD-PARTY DATA SHARING

• ACE Radio will not share CCTV footage with third parties for marketing or other non-security-related purposes.
• In cases of security breaches, criminal investigations, or legal proceedings, footage may be shared with relevant authorities or legal entities.

7. SECURITY MEASURES

• CCTV data is protected by encryption and other industry-standard security practices to prevent unauthorized access or misuse.
• Regular audits and reviews of the CCTV system are conducted to ensure compliance with our policies and applicable regulations.

8. COMPLIANCE WITH THE PRIVACY AND DATA PROTECTION ACT 2014

• ACE Radio complies with the Privacy and Data Protection Act 2014 in relation to the collection, use, disclosure, and storage of CCTV footage. We ensure that all personal information collected via CCTV is handled in accordance with this Act.
• Any processing of personal data will be conducted in a manner that ensures its confidentiality and security, adhering to the principles set out in the Act.

9. YOUR PRIVACY RIGHTS

Individuals have the right to:

• Request information on whether they have been recorded by our CCTV system.
• File a complaint regarding the handling of CCTV data with relevant privacy authorities.

10. POLICY UPDATES

ACE Radio may update this policy from time to time to reflect changes in technology, regulations, or operational needs. Any changes will be communicated to employees and posted in visible areas within the premises.

11. CONTACT INFORMATION

For questions or concerns regarding this CCTV Privacy Policy, please contact:

ACE Radio 📞 03 9928 4888