This policy covers our treatment of personal information that we collect. This policy does not cover the privacy practices of third parties that we do not own or control, such as our partners or advertisers. In addition, we may provide links to other services and on occasion links to other sites that may interest you. Sites that are owned independently of Assemble should have their own privacy policies. For your best on-line experience, we encourage you to review their privacy policies before submitting personal information to them.
2. Information Assemble gathers
Information Assemble gathers about you generally falls into one of the following categories:
information about preferences, interests and opinions relevant to our services and activities (e.g. preferred home size)
additional information about people who work with us (or are being considered for a role working with us), e.g. skills, experience, qualification and background checks, performance, work conduct, training, drug/alcohol tests, use of our IT and other resources, and
information collected through technology, which includes tracking information collected as you navigate the Assemble website.
Some of the personal information we collect about people who work with us is collected pursuant to laws including the Fair Work Act, Superannuation Guarantee (Administration) Act, the Income Tax Assessment Act and other tax laws, Corporations Act, occupational health and safety acts and workers compensation acts.
3. Storage of data
Any personal information provided by you to Assemble may be retained by us. Please let us know if there is any personal information you do not want us to retain. Where we no longer have a permitted basis for retaining your personal information (including where we are no longer required by law to keep records relating to you), we are obliged to take reasonable steps to destroy or de-identify it.
4. How Assemble collects personal information:
4.1 Registration and other direct submission
Registration for Assemble requires that you supply certain personal information including, in most cases, a unique email address and demographic information. You may opt out at any time if you do not wish to, or no longer wish to, receive marketing promotional information. See below for further details. We may also collect other personal information that you provide to us directly.
4.2 Registration for our website via third-party tools
You may choose to log-on, create, or enhance your profile on Assemble with the Facebook Connect feature on Assemble. By doing this, you are asking Facebook to send us registration information from your Facebook profile. We may set up similar facilities with other third party tools from time to time. We treat that information as we do any other information you give us when you log-on, register, or create a profile.
4.3 User generated comments and public activities (including comments and Facebook and Twitter sharing)
We offer you opportunities to engage in public activities on Assemble’s websites. “Public Activities” are any actions you take on Assemble’s websites, Twitter, Facebook and other social media that are designed to be visible to other users on Assemble’s websites, including comments and posting to Facebook or Twitter and other social media. Any information you disclose in your Public Activities, including your screen name, any image or photo, becomes public and may be used by Assemble for online and offline promotional or commercial uses in any and all media. If you choose to engage Public Activities, you should be aware that any personal information you choose to submit there can be read, collected, and used by other readers of these areas (who may be located outside Australia), and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums and Assemble has no responsibility to publish, take down, remove or edit any Public Activities.
If you have signed up for an Assemble account, we will track and aggregate your Public Activities on Assemble’s websites. If you choose to participate in Public Activities, you are electing to share and display such Public Activities on Assemble’s websites. Also, Public Activities may be included in RSS feeds, APIs, and made available to other websites in other formats. As a result, your Public Activities may appear on other websites, blogs, or feeds.
4.4 Contests, sweepstakes, and special offers
Assemble may collect information provided by you voluntarily in connection with contests, sweepstakes, and special offers.
4.5 Surveys, panels, and market research
Assemble may collect personal information from you in connection with voluntary surveys.
4.6 Reports, analysis, etc
Sometimes we generate new personal information related to information we already hold, for example reports and analysis.
4.7 Third parties
We collect some personal information via third parties, such as those described in section 6 below.
4.8 Publicly available information
We may collect personal information that is already available publicly.
4.9 Activity records
We may keep records of your interactions with us and activities relating to our business, operations and websites. This information will not always be personal information, as some of it does not allow you to be identified as an individual. Following are some examples of activity records:
4.9.1 Device Information
We may collect information about the computer, mobile telephone, smart phone, or other device you use to access Assemble’s websites.
4.9.2 Cookies and web beacons
4.9.3 Analytics Technologies
We have hired third parties to provide us information, reports and analysis about the usage and browsing patterns of the users of Assemble. This information is collected to analyse trends, administer the site, track users’ movements around the site, and gather aggregate information about our user base. We do not generally aim to tie this data to personal information.
4.9.4 Log files and reading history
We automatically log certain information about your use of Assemble’s websites. This information includes reading history of the pages you view. We may use this information to provide you with customised recommendations based on your reading history. We also use log files in aggregate usage of Assemble.
4.9.5 CCTV and monitoring records
We may keep records in relation to things like CCTV, site access, telephone recordings and our workers’ use of our IT resources
5. Why we collect personal information
We collect, use and disclose personal information for purposes including the following:
5.1 Services you request
Assemble uses personal information you supply to provide you with the service you have requested. For example, if you subscribe to Assemble, we may use your email address to send you a confirmation notice and your mailing address to send you the publication. We may also use the information to communicate with you about new features, products, or services and/or to improve the services we offer by tailoring them to your needs. Similarly, if you enter an online contest, sweepstakes, or giveaway, we will use the information you provide to notify you.
We perform statistical, demographic, and marketing analysis of users of Assemble for product development purposes and to generally inform advertisers about the nature of our users. We also use this information to improve customer relationships.
5.3 Account Related Emails
5.4 Promotional Emails
Assemble may also periodically email you newsletters and other messages about products and services that we think may be of interest to you. You may choose not to receive these sorts of messages in the future by following the “unsubscribe” instructions located at the bottom of each email.
This includes updating our records where appropriate.
5.6 Human resources purposes
For example, we use personal information for recruiting, training and managing people that work for us.
5.7 Safety and security
We take steps to protect the safety and security of our people, premises and property.
5.8 Identity and background checks
We may conduct identity and background checks where legally required or appropriate for risk management purposes.
5.9 Legal Requirements
We may conduct investigations into suspected unlawful and inappropriate conduct. We also handle personal information in connection with complying with our legal obligations and defending our legal rights and interests. This may involve cooperating with official investigations or legal proceedings, including, for example, in response to subpoenas, search warrants, court orders, or other legal proceedings.
5.10 Acquisition or Transfer
As our business changes, we may buy or sell various assets. This may involve collection, use and disclosure of personal information in connection with the sale or potential sale.
6. Disclosure of personal information
We may disclose personal information to third parties such as:
6.1 Third party service providers
These include providers of credit-card and billing processing, shipping, email distribution, list processing, and analytics or promotions management
6.2 Related entities and partners
We may share personal information with our related entities, and with carefully selected partners.
This includes your and our representatives.
6.4 Professional advisors
Our lawyers, accountants, auditors and other professional consultants and advisors.
6.5 Government authorities, courts and third party lawyers
E.g. in connection with lawful information requests.
6.6 Other disclosures in connection with human resources
These may include academic institutions, professional and trade associations, referees and other persons seeking a reference.
6.7 Website users
Where you participate in Public Activities (described above), your comments and posts will be publicly available.
Some of the third parties described above may be located in the USA, Japan or other countries. While those parties will be subject to privacy and confidentiality obligations in many cases, they will not always be bound by the specific requirements of Australian privacy laws. Where you agree to this policy, we will not be responsible if they do not meet those requirements.
7. How information is kept secure
Some of the measures we use to protect the security of personal information we hold are set out below. Which measures are used may depend on the circumstances.
7.1 Network Security
We have implemented a variety of commercially standard encryption and security technologies and procedures to protect information that is stored in our computer systems, including personal information, from unauthorised access. Please be aware that no method of transmission over the internet, or method of electronic storage, is 100% secure, thus we strive to use commercially acceptable means to protect your personal information, but we cannot guarantee its absolute security.
7.2 Management Procedures
We also maintain standard physical and electronic procedural safeguards that limit access to your personal information to our employees (or people working on our behalf and under confidentiality agreements) who, through the course of standard business activities, need to access your personal information.
8. Special Note for International Visitors
Assemble’s website is intended for and directed to users in Australia. If you are accessing the Assemble website from the European Union, Asia, the US or any other region with laws or regulations governing personal data collection, use and disclosure that differ from Australian laws, please be advised that through your continued use of the Assemble website which is governed by Australian law, this Privacy Notice and our Disclaimer, you are transferring your personal information to Australia and you consent to that transfer.
9. Your privacy rights
If you would like to access and/or correct your personal information, or make a privacy complaint, please contact us as follows, making your request to the attention of our Privacy Officer: Lucy Goldsmith
We may need to verify your identity and may ask for your request in writing.
We may need to engage or consult with other parties in order to investigate and deal with your issue. We will keep records of your request and any resolution.
If we are unable to provide access to or correct your personal information, we will provide written notice which includes reasons for refusal and the available complaint mechanisms.
Last updated: 22 October 2020 Assemble Communities Pty Ltd ABN 44 624 001 645