About this policy

Brandleaders (Cohort Australia Pty Ltd ABN: 54600161386) provides permission based marketing services to major high street and online brands. We provide a service designed to deliver sales leads from consumers who have consented to be contacted.

Brandleaders has a wealth of lifestyle and demographic data that we collect directly and openly from consumers. We do this by publishing a variety of online consumer surveys and conducting a range of permission based direct mail and telemarketing activity on a range of different websites. Brandleaders allows consumers to engage with specific brands or categories of products and services they have indicated they wish to hear from. Brandleaders provides a range of other services to companies using our database.

One of Brandleaders’ key business objectives is commitment to open and transparent information practices – informing individuals about how we collect and use personal information and protect the information privacy of those individuals. Personal information is information about an identified individual or one who is reasonably identifiable.

Brandleaders complies with the AU Privacy Act 1988 including the AU Privacy Principles and other AU regulations such as the AU Do Not Call Register Act 2006, the AU Spam Act 2003, UK Data Protection Act 1998, General Data Protection Regulation 2018 (GDPR) and the (EC Directive) Regulations 2003 which govern how it must handle personal information (Privacy Act). Our Privacy Policy explains how we do this.

Brandleaders may change the Privacy Policy to reflect changes in our practices and privacy regulation. Any changes will come into effect when an updated Privacy Policy is posted to our website.

 

What personal information do we collect and what is it used for?

Brandleaders collects personal information from individuals when they respond to one of our surveys or petitions. We collect personal information about you, your contact details, your interests, subjects about and persons from whom you may like to receive communications and information, your interactions and communications with us including your participation in competitions and surveys. We may also collect information via technology, including cookies from our website when you visit.

We will use this personal information in our interactions with you, including to promote our website and to send you information, surveys, quizzes and petitions about charities or causes that you may be interested in. We may provide your personal details to charities we think may be of interest to you. They may send you direct marketing communications and information about products and services.

We may share your contact information with our partner WINR Data Pty Ltd. (WINR) and their global partners for the purpose of:

• ID Protection – preventing others from misusing your details. This may include ID validation for anti-money laundering, anti-fraud, preventing crime, asset recovery, debt collection and reuniting people with unclaimed assets.
• Advertising – providing offers that are relevant to you. This may involve data analysis, matching, profiling and predicting behaviours so you may receive advertising that is more relevant to you.

WINR and their partners will retain your information for as long as necessary to perform these functions. You can opt-out of all WINR activity by contacting their Privacy Officer https://www.winrdata.com/privacy-policy

These communications may be sent in various forms, in accordance with applicable marketing laws including the Australian Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will try to use that method whenever practical.

Other than as set out in our Privacy Policy, we will not disclose your personal information without your prior consent.

 

How do I unsubscribe?

If at any time you don’t want us to use personal information about you to offer to you products or services which we think will be of interest to you, including products and services available from third parties, you can tell us, and we will stop doing this. Please either contact our Privacy Officer at the contact details below or use the opt-out facilities in our marketing communications.

 

What personal information do we collect?

We will collect personal information about you that you provide to us in response to questions in, for example, surveys, petitions and promotions. In addition, we may collect the following personal information about you from your use of our website:

• Your name (or internet or social media username or handle), address, phone numbers, postcode and email addresses
  your age, birth date, gender, occupation, profession or job title
• information that you provide to Brandleaders, Cohort or the Vocal Minority directly through our website when entering a survey or indirectly through use of the Brandleaders website or online presence

We may collect personal information:

• when you engage with our goods or services, including our website and digital media platforms
• over the phone, in correspondence, in person, via our websites and related social media platforms
• when you sign up as a community member where registration is made available
• during conversations between you and our representatives
• during any written communications between you and our representatives
• when we engage you to provide us with goods or services
• when you apply for a position with us or send us an expression of interest, directly or via a third party or third-party service
• when you register to enter any surveys, quizzes or petitions on our websites, social media sites or via our digital platforms or assets
• when you register for any of our services, including alerts, blogs, newsletters, or other subscription services

 

Cookies and other tracking technologies

In some cases, we may also collect personal information or other information about you using cookies or other tracking codes. When you use our websites, we may send your device or browser a cookie or other tracking code. Tracking codes help with things like site navigation and user-friendliness. We also use tracking codes to see traffic patterns, which areas of our websites are visited most or least, and then improve our online presence and services. Tracking code may also tell us which products or services you view. We may use that information to send you news about and offers of products or services.

We may log IP addresses (the electronic addresses of computers connected to the internet), MAC addresses, Bluetooth numbers, NFC numbers, IMEI numbers and other personal information about you to analyse trends, administer our websites or digital platforms, track users’ online movements, and gather broad demographic information.

If tracking code is used, held or disclosed by us so that you are reasonably identifiable as a person associated with information derived through use of that tracking code, this information will be personal information about you under this policy.

Where tracking code is used, held or disclosed by us so that you are not reasonably identifiable as a person associated with information derived through use of that tracking code, this deidentified information is not treated as personal information under this policy.

Most web browsers accept cookies and other tracking code automatically. You can disable cookies and other tracking code, but it might restrict your ability to access certain areas of our websites.

 

Why do we collect, hold, use and disclose personal information about you?

Our primary purpose in collecting, using and otherwise handling and disclosing personal information about you is to promote use of our websites and to select and offer to you products or services which we think will be of interest to you, including products and services available from third parties.

As well, we may use, handle and disclose personal information about you for related secondary purposes, such as:

• processing and responding to any complaint made by you
• complying with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country)

 

What happens if we can’t collect personal information about you?

If you do not provide us with the personal information described above, some or all of the following may happen:

• we may not be able to provide products or services requested, either to the same standard or at all, or assess any application you have made to us
• our websites may not work as well as they are designed to
• we may not be able to provide you with information about products or services that you want, including discounts, sales, special promotions or competitions
• we may be unable to tailor the content of our websites to your preference and your experience of our websites may not be as enjoyable or useful

 

To whom may we disclose personal information about you?

We disclose personal information to our clients and advertisers, third party agents, service providers and contractors only for purposes consistent with the reasons for collecting the information set out in this Privacy Policy.

Some of the recipients of the personal information, including some of our service providers, are based overseas, in a wide variety of countries (including NZ, US, EU, Philippines, India). Before we disclose personal information to local or overseas recipients we take reasonable steps to ensure they have privacy practices that are at least as protective as the AU Privacy Principles. You consent to the disclosure of your personal information on that basis.

We may disclose personal information to any person or authority where we are required to by law.

Other than set out in our Privacy Policy, we will not disclose your personal information without your prior consent.

 

How can you get and correct personal information about you?

You can request to access the personal information we hold about you. If we do, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you).

Sometimes, we cannot grant access to personal information (for example, if it interferes with the privacy of others or would breach confidentiality). If that happens, we will send you the written reasons for any refusal.

If we provide you with access to personal information we hold about you, and you believe the information is inaccurate, out of date, incomplete, irrelevant or misleading, you may ask us to amend it. We will consider if the information requires amendment. Even if we do not agree that there are grounds for amendment, we will add a note to the personal information stating that you disagree with it.

 

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please email a full description of the issue to our Privacy Officer at the details below. We will treat your requests or complaints confidentially. Our Privacy Officer will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options to resolve them. We take these complaints very seriously and aim to ensure that your complaint is resolved in timely and appropriate manner.

 

Security

We take reasonable steps to ensure personal information about you is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold personal information in either hard copy or electronic form on our servers and secured third party servers. We destroy or deidentify personal information when it is no longer needed.

As our websites are linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the secure transmission of information you communicate to us over the internet. Similarly, we cannot guarantee that information you supply will not be intercepted during its transmission over the internet. Because of this, any information you send to us online is at your own risk.

 

Links

Our websites may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party websites. We are not responsible for the privacy policies or the content of any third-party websites. Third-party websites are responsible for informing you about their own privacy practices.

 

Cookie Policy Full Policy

A cookie is a small text-only file which is stored on your computer or mobile device when visiting a website to help it function or to track your visits. Our website requires cookies to work correctly. By opting-in to the website you agree to the use of cookies. Further information can be obtained at www.addaboutcookies.org. The table below explains the cookies that are used.

Cookie	Name	Purpose
Google Analytics	_ga __utma __utmb __utmc __utmv __utmz	These cookies allow us to collect information about how visitors use the website. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at http://www.google.co.uk/intl/en/analytics/privacyoverview.html

 

Changes to our Privacy Policy

We may modify this Privacy Policy from time to time. If we do, we will post our updated Privacy Policy on our websites.

 

For more information

If you have any questions about the content of this policy, please contact our Privacy Officer:

Cohort Post: PO Box 825, Surry Hills NSW 2010
PH: 1300 886 489
Email: consumercare@cohort.com.au
This policy was last updated on 10 August 2023