Privacy Policy
In this Privacy Policy, “Special” “we”, “us”, and “our” means Special Group (Australia) Pty Ltd (ACN 169 198 403) and Special Group (Melbourne) Pty Ltd (ACN 641 946 367), jointly and severally.
Special is in the business of providing creative advertising services. We also own and operate our website: https://au.specialgroup.com/ (the “Website”). For the avoidance of doubt, this Privacy Policy applies only to Special’s operations in Australia. For information about how Special Group offices in other countries treat your personal information, please see their respective websites.
By providing personal information to us, including via the Website and your dealings with our business, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.
We are committed to protecting your privacy. This Privacy Policy is applicable to your use of the Website and your dealings with our business. This policy has been developed to ensure that such information is handled appropriately and in accordance with applicable laws, including the Privacy Act 1988 (Cth) (the “Privacy Act”). The Privacy Act incorporates the Australian Privacy Principles (the “APPs”). The APPs set out the way in which personal information must be treated.
Before providing us with any information, you should read this Privacy Policy so that you understand and are comfortable with the ways that we collect, store and use the information that is shared with us by you, whether as a person who engages with our business or as a visitor to the Website.
Please note that this Privacy Policy should be read in conjunction with (and is subject to) any other privacy statement or collection notice that Special may provide to you when we collect your personal information or provide a particular offering or service.
1. Who does the Privacy Policy apply to?
This policy applies to any person for whom we currently hold, or may in the future collect, personal information.
We collect personal information from a variety of people who interact with our business, including our employees, potential employees, clients and their personnel, suppliers and their personnel, business contacts, shareholders and website users.
2. What information does the Privacy Policy apply to?
This Privacy Policy applies to personal information. In broad terms, “personal information” is information that is about an identified, or reasonably identifiable, individual. This may include a person’s first and last name, mailing address, email address, tax and billing information, telephone numbers and/or other online contact information.
Personal information can also include data that is usually non-personally identifiable on its own, such as location data or IP addresses, data about personal attributes or online identifiers, but that taken with other data or information, may identify a person either directly or indirectly.
Sensitive information
For your understanding, “sensitive information” may include information relating to a person’s racial or ethnic origin, religious beliefs or affiliations, political opinions, philosophical beliefs, health or genetic information, sexual preference, membership of professional or trade associations or unions or criminal record.
Our general practice is not to collect sensitive information about you unless it is needed for the purposes of providing services to you or obtaining services from you.
However, if sensitive information is collected, it will only be as a result of its voluntary provision by you with your informed consent. If you do volunteer information to Special, including sensitive information, by doing so you are providing consent for us to collect, store and use that information for the primary purpose for which it was collected.
3. How do we use personal information?
We take reasonable steps to use personal information for the primary purpose for which we collect it. The primary purpose for which we collect information varies, depending on the reason that you are dealing with us.
Generally, the personal information we will collect from you will usually include your name, title, address and e-mail address and phone numbers. If necessary for the purposes of providing services to you or for providing you with other information relating to our business, we may collect other personal information from you. However, we do not collect personal information that we do not need.
We may use your personal information to:
- manage our contractual and/or employment relationship with you;
- assess your suitability for employment for the role for which you are applying, as well as future roles that may become available;
- facilitate communication with you;
- operate and manage our business operations including or being part of the provision of our services to our clients and their employees/contractors and their customers; and
- comply with legal requirements; and
- identify and assess what is being said about Special and our clients on social media.
Personal information may also be used by us for secondary purposes, including where:
- you have consented to us using your personal information for that secondary purpose,
- that use is within your reasonable expectations as to how we might use your personal information
- that secondary purpose is related to the primary purpose of collection.
For example, we may collect and use your personal information to:
- keep record of transactions to assist in future enquiries and enhance our customer relationship with you;
- service delivery purposes (including so that Special can contact client and supplier personnel);
- provide you with updates and alerts that are relevant to you or your business; and
- send you offers and promotional material or to invite you to events (where you have opted in to receiving such marketing communications).
4. How and when do we collect personal information?
Our usual approach to collecting personal information is to collect it directly from you when you visit our Website, request our services (including by requesting our pitch for services), apply for employment with Special and from other ways in which you interact with our business.
We may also collect personal information in other ways, including by optional, voluntary submissions of information which may include:
- through marketing and business development events;
- from our subcontractors and agents;
- through referrals from individuals or other entities; and
- from forms such as our customer feedback forms.
We may also collect data via automatic processes when users visit or access our Website or our other online platforms. We generally collect non-personally identifiable information in these processes, but sometimes personal information may be collected. For example, we may:
- use cookies and other tracking technologies to track user activity and engagement with our services promoted on our Website and to record information about Website traffic and usage;
- track activity relating to your interactions with our direct mail communications; and
- track activity relating to your interactions with links contained on our Website.
Some cookies may be associated with personal information about you and some may not. Wherever possible, we anonymise and pseudonymise the information we collect via cookies or other tracking technologies. If you choose to reject cookies, you may still use our Website, however you acknowledge and agree that access to our content and some of the functionality of our Website may be restricted.
We may also obtain information from third party sources. We may use analytics tools and other third party technologies to collect non-personally identifiable information in the form of various usage and user metrics when you use or access our Website or other services. For example, we use Google Analytics features to collect data about traffic to our Website using tracking technologies. The information that is collected by Google Analytics for us is not personally identifiable and is pseudonymous or aggregated data that does not identify any individual user.
Third party analytics companies may combine the information collected for us with other information they have independently collected, but we take care to ensure that the information collected for us is pseudonymous or anonymous so that users cannot be identified when the information is combined.
While we seek to minimise the personal information we collect, if you do not provide us with the personal information we request, we may not be able to provide you with the services and other assistance you seek.
5. How do we secure personal information?
We take measures, including the implementation and maintenance of physical, electronic and managerial procedures, in an effort to assure the security, integrity and accuracy of all personal information that we collect and to protect your personal information from misuse, loss, unauthorised access, modification, disclosure or unauthorised access. This includes:
- implementing procedures for identifying and managing privacy risks at each stage of the information lifecycle, including collection, use, disclosure, storage, destruction or de-identification;
- implementing security systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure;
- implementing mechanisms to ensure any agents or contractors who deal with us comply with the APPs; and
- allowing individuals the option of not identifying themselves, or using a pseudonym, when dealing with us in particular circumstances.
We will take reasonable steps to destroy or permanently de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.
In limited circumstances, it may be possible for you to use a pseudonym or remain anonymous when dealing with us (for example, making a general enquiry with us).
However, if you would like to obtain a service from us (for example, requesting advertising services or applying for a role with us), we will need your personal information in most instances in order to provide you with that service.
6. In what situations will we disclose your personal information?
Generally, personal information will not be disclosed to individuals or organisations outside of Special without your prior consent. However, personal information may be disclosed in the circumstances described in this section.
When we do disclose information to third parties, we use non-personally identifiable information wherever possible and we require third parties to only collect and use personal information in accordance with this Privacy Policy and for no purpose other than providing us with agreed services.
Those third parties may include:
- our contractors, subcontractors and clients;
- our employees, including those employed by overseas Special Group entities;
- government bodies and regulators (including for mandatory reporting purposes);
- business support service providers (including third-party service providers that provide services such as billing, payment processing, customer service, email deployment, advertising and marketing, security and performance monitoring, maintaining or servicing accounts, processing or fulfilling orders and transactions, verifying customer information, research, data hosting, auditing, and data processing);
- any other third party we deem necessary in connection with providing you with our services; or
- if required by a court or pursuant to applicable law.
We do not sell, rent or trade personal information about you to or with third parties.
7. Will we disclose personal information outside Australia?
We may disclose personal information outside of Australia to:
- our third party service providers for the purposes of storing such information, including providers located in the United States (such as Google Workspace Enterprise Plus); and
- our employees, including those employed by overseas Special Group offices.
When you provide your personal information to us, you consent to the disclosure of your information outside of Australia for this purpose. We will take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the APPs and this Privacy Policy.
Other than as set out above, we do not disclose personal information outside of Australia without first obtaining your consent.
8. Job applicants
Special collects personal information about and from individuals who apply for employment with us or our related companies. The information we collect may include the applicant’s:
- personal contact details (including phone, email and home address) and gender;
- educational and employment history, relevant qualifications and experience including information which you provide regarding clients with whom you’ve worked in the past;
- eligibility to work in Australia; and
- referees’ contact details.
In the case of prospective employees, the primary purpose the information is collected is to assess the individual's suitability for employment.
In relation to job applicants, we may collect this information directly from the job applicant or indirectly from a third party, including from a recruitment agency.
If you do not provide us with the information we request, we may not be able to process or assess your job application. We may share personal information provided by job applicants or suppliers with our related companies where we reasonably believe there may be a suitable opportunity for you to work with one of our related businesses.
9. General Data Protection Regulations
In accordance with the General Data Protection Regulations (“GDPR”), we will not target or track the activity of users in the European Union and European Economic Area (“EU Users”) without your express consent.
In adherence to the GDPR, Special does not direct personalised advertising and marketing to any users, including EU Users, who have not consented to receiving such marketing material. This includes tracking activity using personal information or targeting users with advertising that uses personal information.
10. How do you make complaints and access and correct your personal information?
It is important that the information we hold about you is up-to-date. You should contact us if your personal information changes.
Access to information and correcting personal information
- You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.
- We will grant you access to your personal information as soon as possible.
- In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.
Complaints
You can lodge a complaint about an alleged privacy breach by following the below process:
- The complaint must be firstly made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint.
- In the unlikely event the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.
- EU Users have the right to lodge a complaint with the relevant supervisory authority in their member state. We encourage you to contact us first wherever possible, so that we can respond to your concerns. We will do our best to resolve them promptly in accordance with relevant laws and policies.
Who to contact
A person may make a complaint or request to access or correct personal information about them held by us. Such a request must be made in writing to: privacy@specialgroup.com and/or Special Group, 270 Devonshire Street, Surry Hills NSW 2010.
11. Changes to the policy
We may update, modify or remove this policy at any time without prior notice. Any changes to the Privacy Policy will be published on our Website.
This Privacy Policy is effective December 2024. If you have any queries regarding this Privacy Policy, please contact us via the contact details provided above.