NAVA is strongly committed to protecting your privacy when you interact with us, our content, products and services. We are also bound by the National Privacy Principles contained in the Privacy Act 1988 (Cth).
NAVA’s online presence aims to provide you with media that inform, educate and inspire. Sometimes this means that we use information that you provide to us about yourself to customise that experience. We do this to improve the quality of our products and services. In providing our services to you, NAVA will be transparent about how and why we collect and use your information. In some cases, if you do not want us to collect or use your information in a particular way, then we will give you the opportunity to say so.
The purpose of this Privacy Policy is to explain:
- the application of this Privacy Policy
- the kind of information NAVA may collect about you, how we collect it, and how we use it
- how we may disclose that information
- how you can access the information we hold about you
- when we may use your information to contact you
- the protection of your personal information
- NAVA’s use of cookies to collect information, and how you can control or delete these cookies.
1. Application of this privacy policy
NAVA’s Privacy Policy applies to personal information collected by NAVA, whether we have asked for the information or not. In accordance with s7(1)(c) of the Privacy Act, it does not apply to acts done, or practices engaged in, in relation to its program material. In most cases, such acts and practices are governed by other relevant laws.
This policy applies only to NAVA. It does not apply to any other company or organisation, including those whose digital services have links to NAVA content or services. Third party services which have links to NAVA content or services will govern the use of personal information you submit to them, which may also be collected by cookies when you visit or use them. We do not accept any responsibility or liability for the privacy practices of such third party digital services.
NAVA will review its privacy policy regularly, and may update it from time to time. If we make changes, we will post those changes here.
2. Collection and use of personal information
2.1 Why does NAVA collect personal information
Personal information includes information such as your name and contact details. NAVA collects personal information about you:
- because you have provided it to us, as part of joining or subscribing to NAVA or if you contact us to provide feedback or to ask us questions, or you have interacted with one of our digital services, for instance by participating in social media;
- because we need it to provide a product or service that you have requested, for instance, if you join as a member, subscribe to an email list or apply for a grant from NAVA;
- because we would like to improve our services, for instance through the collection and analysis of statistical and research data and use of cookies (see below);
- because you work for us, or apply to us for a job, or work experience;
- for purposes directly related to any of the above.
NAVA will not collect personal information unless it is voluntarily supplied to us.
2.2 How we use your personal information
We use your information for the purposes for which it was collected, and related purposes (which are normally obvious when we collect it. These purposes include:
- to provide you with news and information about us and our services, or about another artist, gallery, organisation or business which we think might interest you;
- so that we can provide our service to you, manage and account for our services and improve our services;
- so that we can manage our relationship with you;
- to provide you with information about events or other services that might interest you; and
- to facilitate our internal business operations, including to verify your identity and fulfil our legal requirements.
2.3 How NAVA collects information when you use a digital service (website and social media)
Broadly, there are two types of information or data we collect: information that you specifically give to NAVA, and data that we collect automatically.
Information that you specifically give NAVA
For example, you may provide information about yourself when you are filling in a form or when you sign up as a Member. This type of information may include your name, email address and postal address. The information that you give us may be:
- Personal information that is required. In some instances, you must provide personal information if you wish to use a particular service or participate in an activity. For example, your age may be required if we need to confirm that you are eligible for some types of NAVA’s insurance.
- Personal information that is optional. You may choose to provide some personal information which is not required but is useful for us when provided as aggregated statistical information to share with government organisations that monitor access and equity issues. This type of information may also drive NAVA to improve or broaden the services we offer. If you choose not to provide this optional information, your membership or subscription will not be affected.
- Permissions. Sometimes you will be asked to confirm that you agree to a particular activity. For example, you may need to expressly agree that you would like to receive a newsletter or to confirm that you agree to the terms and conditions of a subscription.
We are committed to ensuring that the information we hold about you is accurate and up-to-date. You may make changes to the information you provided us (for example, if you change your email address) or withdraw the permission you gave NAVA for a particular service. We will make it clear as to how you do that when you provide us with personal information.
Data NAVA collects that tracks your activity
NAVA automatically gathers information to monitor the use of its digital services (including website and social media), like the numbers and frequency of visitors to NAVA websites. This information can include the IP address, domain name and browser type, the date and time of access, and details of the information downloaded. This information helps us improve our services by learning what our audiences use and don’t use. It can also help us identify if there are any problems with our services that need fixing. This data is usually collected using ‘cookies’. ‘Cookies’ are small files that are stored on your browser. Further information about NAVA’s use of cookies is provided below.
Most of the data we collect is aggregated, and this information is effectively anonymous to us.
In some cases we may collect data that can be linked to you individually. For example, when you log in to an NAVA digital service as a registered user, we may store records of information such as the comments you make, the pages you viewed or links you click on. Similarly, if you use our email newsletters we may collect data about the mails you open and the links you click on from that newsletter.
As well as helping to improve our services, we may use this data to provide recommendations that you might find helpful based on your activity. Though surveys usually collect aggregated data, we will make it clear to you if any survey information is being collected in a way that could personally identify you.
To the extent that this data does not constitute personal information, the National Privacy Principles do not apply and we may use this information for any purpose and by any means whatsoever.
3. Disclosure of personal information
3.1 Disclosure of personal information to third parties
- NAVA may disclose your personal information to third parties for the following purposes:
- to provide the service you wish to use,
- for research purposes relating to the performance, quality, maintenance and improvement of NAVA’s products and services,
- to customise and promote NAVA services which may be of interest to you,
- to provide technical support to you to use NAVA’s services
- if permitted or required by law; or
- otherwise with your consent.
In many cases, NAVA imposes contractual restrictions equivalent to those imposed on NAVA under the Privacy Act in respect of collection and use of personal information by those third parties. In some cases, such as social media networks, NAVA’s ability to impose contractual restrictions is limited. In those circumstances, NAVA will carefully consider the risks to the protection of personal information when entering into arrangements with third parties.
NAVA may disclose your personal information (excluding sensitive information about you) to third parties for the purposes of direct marketing NAVA’s services. NAVA will obtain your specific consent to disclose sensitive information for the purposes of direct marketing NAVA’s services. You will be able to opt-out of direct marketing at any time if you so choose. Under no circumstances will NAVA sell or receive payment for licensing or disclosing your personal information.
3.2 Information that you disclose publicly
NAVA provides content and services on a range of platforms with interactive features that you can contribute to. When using digital services (including online and mobile services and social media), we suggest that you use your discretion and exercise caution when providing your personal information. For instance, if you “share” information that is posted on an NAVA website using a social media tool, it is likely that you will be sharing your personal information. NAVA cannot protect personal information that you choose to share in this way.
Ultimately, you are responsible for maintaining the secrecy of your passwords and/or any personal information. Be responsible whenever you are online or using a digital service.
3.3 Information that is disclosed via other platforms or services
Some NAVA services may be integrated with external services, including social media networks. This may mean that information, for instance about your interests and activities, is tracked or pulled from other places (such as Facebook). If you are signed in to an NAVA service which is integrated with other media tools, this information may be available to others depending on the privacy settings you have in place on other platforms.
The number and nature of social media platforms is changing rapidly, and the way in which information is shared between them is becoming increasingly complex. To help you manage and protect your personal information, NAVA will ask you to opt-in before making your personal information available through an integrated service. You may also opt-out of your participation in most of NAVA’s digital services. Information about how to opt-out will be provided in the particular service. However, you should be aware that NAVA may continue to store personal information provided by you prior to you opting-out.
Your ability to opt-out of providing information to or via a third party tool or platform will depend on the conditions governing your agreement with that third party.
4. Accessing your personal information
You may request access to personal information that is held by NAVA about you. Requests for access will be dealt with by NAVA in accordance with the Freedom of Information Act 1982 and the Privacy Act. We may charge you a fee where access to your information is provided. We may refuse to provide access if the National Privacy Principles allow us to do so.
NAVA will take reasonable steps to make appropriate corrections to personal information so that it is accurate, complete and up-to-date.
NAVA welcomes feedback about privacy issues and will attend to all questions and complaints promptly.
You can contact the NAVA about any privacy issues as follows:
By email: nava@visualarts.net.au
By mail: National Association for the Visual Arts
PO Box 60
Potts Point NSW 1335
5. Use of your personal information to contact you
We will never knowingly send you unsolicited commercial electronic messages. More information on the Spam Act 2003 is available from the regulator’s website: http://www.acma.gov.au/spam.
We may use information that we know about your likes and interests to tell you about other NAVA programs, products and services when you are online. We may know about your likes and interests because you have provided that information, for instance via a social media platform, or because we have inferred this based on your browsing history, or other data related to your behaviour on NAVA digital services.
6. Protection of your personal information
NAVA will take all reasonable and feasible steps to ensure that your personal information is properly protected from misuse or loss, and unauthorised access, modification or disclosure.
At the same time, we are committed to providing innovative and interactive experiences, and to being available to audiences on multiple platforms. Some of those platforms are not operated or controlled by the NAVA, and our ability to protect your personal information is limited.
We encourage you to be vigilant about the protection of your own personal information when using third party digital services (such as social media platforms). As far as reasonably practicable, we will make sure that our relationships with those third parties include appropriate protection of your privacy.
6.1 Credit card information
Online credit card payments are currently processed using a third party payment service run by Pin Payments. Pin Payments takes several steps to prevent unauthorised disclosure or modification of sensitive information. Credit card information is encrypted and stored in a system completely isolated from Pin Payments. At no time is unencrypted card data stored on disk either inside Pin Payments' system or in the card storage system. Internally card information is referenced only through the use of a token. The token is not derived from card information in any way. Pin Payments’ Privacy Policy can be viewed here.
If you use your credit card and the transaction is manual rather than electronic, the details will be stored by NAVA for the period that financial records are required to be retained.
6.2 Removal and de-identification
Where NAVA no longer needs personal information for any purpose for which the information may be used or disclosed, NAVA will take reasonable steps to destroy or de-identify the information. You can contact NAVA to request that your personal information be removed from our system. Removal of your information from our membership system will mean that we can no longer contact you and you will no longer hold a NAVA Membership or have full access to the NAVA website. Where you have provided information to NAVA in a de-identified manner (for example responses to surveys) this information will not be removed.
7. Use of cookies across our digital services
NAVA uses a “cookie” system on its digital services. A “cookie” is a small data file placed on your machine or device which lets our digital service store information. This information allows us to make our digital services easier to use and more relevant.
NAVA uses cookies for interactive features, for instance, cookies allow our servers to keep track of your customer details between visits to the NAVA website. The information stored by the cookie includes data that is provided during online registration processes. Placing cookies on your device also means we can serve you tailor made promotional information that you might be more interested in. The promotional information can appear on third party digital services as well as NAVA digital services. It also allows us to control the number of times you see that promotional information and measure how effective the campaign has been.
The analytics systems used by NAVA use cookies to gather information regarding visitor activity on NAVA’s digital services. This is not used to identify personal details but is collated into aggregate results in order to evaluate and improve our services. When you use NAVA’s digital services, some information is logged automatically, such as your computer’s operating system, Internet Protocol (IP) address, access times, browser type and pages visited. NAVA engages independent measurement systems (such as Google Analytics) to perform these services.
7.1 Controlling and deleting cookies
Popular browsers will usually give users a level of control over cookies. You can set your browsers to accept or reject all, or certain, cookies. You can also set your browser to prompt you each time a cookie is offered.
Most cookies are easy to delete, and the Help function within your browser should tell you how. Some digital services may not load properly or function as intended if cookies are disabled, however it is up to you to determine the balance of convenience and computer privacy that you are comfortable with.
7.2 Cookies used by NAVA
NAVA uses the following types of cookies:
Session computer browser cookies – Session cookies let you move from page to page without the need to repeatedly sign in. For instance, these cookies are used by NAVA website to keep track of things such as what you put in your shopping cart. A session browser cookie is stored in the browser and deleted when the browser shuts down.
Persistent cookies – Persistent cookies are used to help us monitor the performance of our digital services by recording your browsing behaviour within the particular digital service.
These browser cookies can only be read by the company that places the cookies on the computer. Persistent cookies are saved to the hard drive until they expire. Unlike session browser cookies, they are not deleted when the browser is shut down.
Flash cookies – also known as Local Shared Objects, are used to track activity in Applications that are running in Adobe Flash Player. Designed for usability, they allow user’s custom settings to persist between visits.
NAVA uses web beacons in combination with cookies to track activity. Turning off a browser’s cookies will prevent web beacons from tracking activity.
7.3 Third party cookies
NAVA uses a number of suppliers who also set cookies on our digital services on our behalf in order to deliver the services that they are providing.
For instance, if we embed photos and video content from third parties such as Vimeo, those third parties may have set cookies relating to that content. If you then “share” that content, another third party cookie may be set by the service you have chosen to share content through. NAVA does not control these cookies, and does not block cookies set by third parties in these ways.
