Privacy Policy
This Privacy Policy sets out the approach which Jenny’s Classroom & Toys2 will take in relation to the treatment of Personal Information. It includes information on how Jenny’s Classroom & Toys2 collects, uses, discloses and keeps secure, individuals’ Personal Information. It also covers how Jenny’s Classroom & Toys2 makes the Personal Information it holds available for access to and correction by the individual.
Jenny’s Classroom & Toys2 is a registered Australian Business with its Head Office Located in Orange NSW. Our ABN is: 12 111 056 403
This policy has been drafted having regard to Jenny’s Classroom & Toys2’s obligations under the Privacy Act 1988 (including the new National Privacy Principles) (the Privacy Act).
This Policy is a public document and has been prepared in light of National Privacy Principle 5, Openness.
- Collection
1.1 Jenny’s Classroom & Toys2 will only collect Personal Information where the information is necessary for Jenny’s Classroom & Toys2 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 Jenny’s Classroom & Toys2 collects Personal Information primarily to supply customers with the products and services ordered from it and its related companies. Jenny’s Classroom & Toys2 also collects and uses Personal Information for secondary purposes including:
- 1. billing and account management
- 2. business planning and product development; and
- 3. to provide individuals with information about promotions, as well as the products and services of Jenny’s Classroom & Toys2 affiliated companies and other organisations.
- 4. 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 Jenny’s Classroom & Toys2 will not collect Sensitive Information from individuals except with consent and only where it is necessary for Jenny’s Classroom & Toys2 to collect such information for an activity or function.
1.4 Jenny’s Classroom & Toys2 will not collect Personal Information secretly or in an underhanded way.
1.5 Jenny’s Classroom & Toys2 will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.3.
Use
2.1 Jenny’s Classroom & Toys2 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 Jenny’s Classroom & Toys2 Uses Personal Information primarily for the purposes listed in 1.2 above.
2.3 If Jenny’s Classroom & Toys2 relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:
- 1. the individual is clearly notified of their right to Opt Out from further Direct Marketing;
- 2. there is only one Use of the information before the Opt Out right is given and this Use applies across all Jenny’s Classroom & Toys2 Related Bodies Corporate (if the information is shared between those Related Bodies Corporate);
- 3. the individual is given an Opt Out in all further instances of Direct Marketing if they have not previously chosen to Opt Out; and
- 4. if the individual Opts Out of all Direct Marketing the Opt Out will be respected by Jenny’s Classroom & Toys2 and all its Related Bodies Corporate.
2.4 Jenny’s Classroom & Toys2 will not use Sensitive Information for Direct Marketing.
2.5 Jenny’s Classroom & Toys2 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 Jenny’s Classroom & Toys2 will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.
Disclosure
3.1 Jenny’s Classroom & Toys2 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 Jenny’s Classroom & Toys2 may Disclose Personal Information between Related Bodies Corporate. Where information is Disclosed to such a Related Body Corporate, that Related Body Corporate is bound by the original Primary Purpose for which the information was collected.
3.3 Jenny’s Classroom & Toys2 may Disclose Personal Information to unrelated third parties to enable outsourcing of functions (such as billing, customer relations management and order fulfillment), where that is Disclosure or Use for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual’s Reasonable Expectations.
3.4 Jenny’s Classroom & Toys2 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 Jenny’s Classroom & Toys2 may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.
3.6 Jenny’s Classroom & Toys2 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, Jenny’s Classroom & Toys2 will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
3.8 Jenny’s Classroom & Toys2 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, Jenny’s Classroom & Toys2 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.
Information Quality
4.1 Jenny’s Classroom & Toys2 will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 Jenny’s Classroom & Toys2 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.
Information Security
5.1 Jenny’s Classroom & Toys2 requires employees and contractors to perform their duties in a manner that is consistent with Jenny’s Classroom & Toys2’s legal responsibilities in relation to privacy.
5.2 Jenny’s Classroom & Toys2 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 Jenny’s Classroom & Toys2 who have a genuine “need to know” as well as “right to know”.
5.3 Jenny’s Classroom & Toys2 will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.
Access and Correction
6.1 Jenny’s Classroom & Toys2 will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 Jenny’s Classroom & Toys2 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 Jenny’s Classroom & Toys2 Customer Service, as per the details on the website.
6.4 Jenny’s Classroom & Toys2 can charge a fee for processing an access request but will generally not do so unless the request is complex or is resource intensive.
Openness
7.1 Jenny’s Classroom & Toys2 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 Jenny’s Classroom & Toys2 Customer Service, as per the details on the Jenny’s Classroom & Toys2 website.
7.3 Jenny’s Classroom & Toys2 websites will contain a prominently displayed privacy statement and will include a copy of this Jenny’s Classroom & Toys2 Privacy Policy.
Anonymous Transactions
8.1 Jenny’s Classroom & Toys2 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. Jenny’s Classroom & Toys2 may however request visitors to provide Personal Information voluntarily to Jenny’s Classroom & Toys2 (for example, as part of a competition or questionnaire).
- Google Adwords
9.1 This website, may at times uses the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Jenny’s Classroom & Toys2’s website. Of course, any data collected will be used in accordance with our own privacy policy and Google’s privacy policy.
9.2 You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.