Privacy Policy

Approved by the Board on 24 August 2023 (Resolution Number #709)

Contents

Policy Objective
What information does ACMI collect?
When does ACMI collect personal information?
Children under 13 years
Buying Tickets
Using the Lens
Our Customer Database
Sharing with Third Parties
Social media
Website usage measurement
Cookies and Other Data Technologies
Storage & Security
Can I access or correct my personal information held by ACMI?
Review date

Policy Objective

ACMI respects the privacy of individuals. ACMI will comply with the following legislation:

• Privacy and Data Protection Act 2014
• Public Records Act 1973
• Health Records Act 2001
• Freedom of Information Act 1982

in the collection, use, storage, provision of access to, amendment of and disposal of personal information.

This Policy applies to visitors and users of ACMI’s website(s). By visiting ACMI website(s) you are accepting and consenting to the practices described in this policy.

This Policy also applies to all individuals and entities who interact with ACMI, this includes (but is not limited to) agents, contractors, subcontractors, employees, representatives, users of ACMI’s services, volunteers, and participants in ACMI events.

We may amend this Policy from time to time. The current version of this Privacy Policy will be posted on our website.

What information does ACMI collect?

ACMI collects both personal information as defined in the Privacy and Data Protection Act 2014 and non-personal information and data.

Personal information is information or an opinion that is recorded in any form, whether true or not, about an individual whose identity is apparent or can reasonably be ascertained.

When does ACMI collect personal information?

ACMI will collect personal information where necessary to undertake our functions as defined by the Film Act 2001 and deliver our services. When we collect personal information, we will take reasonable steps to ensure you are aware of:

1. who is collecting your information (i.e. ACMI) and how to contact us, along with an awareness that you may gain access to your own information,
2. the purpose for collecting the information,
3. which individuals or organisations this information would usually be disclosed to (where relevant)
4. any law that requires the particular information to be collected (where relevant), and
5. the main consequences, if any, if you do not provide the information.

ACMI generally collects personal information where relevant and necessary for the following functions:

• ticketing
• visitor feedback and comments, participation in market research and evaluation, education, community programs, public enquiries
• provision of personalised visitor content
• collections, research and exhibitions
• memberships & subscriptions
• marketing and communications
• fundraising
• governance
• stakeholder management (including complaint handling and resolution)
• staff and volunteers – recruitment and employment
• commercial, including online transaction services to purchase goods or services, and general operations
• via CCTV footage for security purposes

ACMI will collect personal information in a lawful, fair manner. Where practicable and reasonable, personal information will be obtained directly from the individual concerned. If you provide any personal information about another individual as part of a transaction with ACMI eg as part of a grant application, you must ensure that the other individual is informed and has given you their prior consent.

Any personal information collected by ACMI will only be used for the purposes for which it was collected or as otherwise permitted in accordance with the Information Privacy Principles. We may disclose personal information to authorised contractors, subsidiaries, service providers and third party affiliates, as required by law or other regulation, or as set out below (see “Sharing with Third Parties”).

You can access and browse ACMI’s website without disclosing personal information, however to access personalised online content or certain services such as our on-demand streaming service or to make a purchase from our online store, you will need to provide certain personal information such as a valid email address.

Children under 13 years

ACMI does not intentionally solicit personal information from children. Visitors under 13 years of age should obtain a parent or guardian’s permission before submitting any personal information to ACMI.

Buying Tickets

ACMI tickets purchased using a credit card online are processed by Windcave Pty Ltd. This company keeps your financial information in a secure location and encrypts your details.

When you buy tickets on ACMI’s website for programs or events run by, or in partnership with, other organisations, you will be given the option to opt-in to hear from those organisations. If you do so, ACMI may provide your personal information to those third party organisations.

ACMI does not require that you provide personal information when purchasing a ticket over the counter on our premises. In order to better understand our customers, you may be asked for your postcode or information about how you found out about an event. Providing this information is always optional. However for certain events and programs, tickets may not be available to purchase over the counter.

Using the Lens

ACMI provides all visitors to the ACMI museum at Federation Square with the opportunity to take and use a Lens. The Lens allows visitors to select or ‘collect’ objects and media to watch or play when they get home. In the museum a Lens does not require a visitor to provide any personal information. At home, in order to provide access to view the specific objects and media that a visitor has collected, a visitor is required to create an account by providing a valid email address. This can be any email address that you can receive messages at – including free anonymous email services such as Maildrop.cc or similar. This email address will be stored in ACMI’s customer database.

Our Customer Database

ACMI maintains a database of customer information in order to promote its programs. This information is stored and managed within Tessitura, a Customer Management and Ticketing system trusted and used by arts organisations around the world and certified to PCI-DSS standards. This information is used for printed mail as well as email. You will only be added to this database if you ask to receive this information. You can opt out of this at any time. To do this, click on the unsubscribe link within each email or newsletter type you have previously subscribed to.

ACMI does not sell or rent its customer database to other businesses. ACMI may, from time to time, provide you with information about third party products and services we think will interest you. In these cases, your personal information is never available to the third party.

ACMI may use de-identified information for evaluation and research purposes, and in some cases, disclose de-identified Information to third parties.

ACMI will not assign to or use unique identifiers for individuals unless it is necessary to carry out one of our functions efficiently or if it is otherwise required by law.

Sharing with Third Parties

As part of providing our services and to fulfil our functions, ACMI uses third party service providers to store and process your personal information. This includes third parties that store data on secure databases outside of Australia.

Examples of third party service providers that ACMI may disclose your personal information to include:

• Windcave Pty Ltd and Stripe Payments Australia Pty Ltd for the secure processing of online financial transactions. You can view their privacy policies at https://www.windcave.com/privacy-policy and https://stripe.com/en-au/privacy
• Atlassian products such as Jira, Confluence and Atlassian Cloud Services – for internal communication, and managing customer enquiries and complaints. You can view their privacy policies at https://www.atlassian.com/legal/privacy-policy
• Tessitura for customer relationship management and ticketing
• Tessitura’s TNEW product for online ticketing
• Prospect2 for email marketing
• Shift 72 for the provision of on-demand video streaming services
• Shopify for managing ACMI’s online shop
• Cloudflare for content delivery and security
• Google Analytics for measuring and monitoring website performance
• Envoy Inc for office management

Social media

If you choose to engage with ACMI via social network channels including Twitter, YouTube, Instagram or Facebook you should be aware of the following:

• Any information you post on social media sites is potentially accessible to anyone else engaging with the same social media.
• Your individual privacy settings for profiles and accounts on social media networks are your responsibility. ACMI has no control or jurisdiction over these settings.

Website usage measurement

ACMI’s website uses Google Analytics, a web analytics service provided by Google, Inc. (Google).

Google Analytics currently uses cookies, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google. What Google does with your behavioural data is explained in the Google Privacy Center.

You may block or refuse Google Analytics by selecting the appropriate settings on your browser or using a privacy enhanced browser such as Brave or Tor; however please note that if you do this you may not be able to use the full functionality of this website. By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Cookies and Other Data Technologies

ACMI uses cookies, and may use pixel tags, web beacons, clear GIFs or other similar technologies, to collect small anonymous units of data sent to a visitor’s browser by a website the visitor visits (Browser Data). Such cookies and similar technologies cannot retrieve any other data from your hard drive, pass on a computer virus, or capture your email address. However they will remain on your computer for a period of time as a record for future visits to this website.

ACMI uses Browser Data to:

• understand our customers and their preferences;
• facilitate and improve a customer’s website browsing experience;
• better understand how ACMI’s websites are used;
• provide customised messages and advertising personalised to customers’ interests;
• measure or understand the effectiveness of advertising we serve to customers;
• report on audience insights and statistics to the government departments that fund us and to donors, sponsors and promotional partners.

ACMI may use Browser Data, data from third parties, and Google Analytics to deliver targeted advertisements or content to a customer about products and services, based on the webpages visited and the way in which that customer or visitor accesses ACMI’s websites.

ACMI engages with third parties to enable delivery of targeted advertising and promotional content when customers visit ACMI’s websites or third party websites. Targeted content may advertise ACMI’s goods and services or the goods and services of a third party. Organisations which ACMI works with and discloses data to (such as Browser Data) include companies providing advertising services or data analysis and also Google Analytics.

ACMI may also permit cookies or similar data technologies of government departments that fund us to be used on our website to measure audience engagement and also to target relevant advertising to you when you visit other websites.

The Browser Data ACMI collects does not include any personal information. However, if a customer is logged into their member account or if a customer makes a purchase from us, the Browser Data ACMI collects may be linked with that member’s or customer’s personal information. To the extent that the data or information constitutes personal information, ACMI will only use the information in accordance with the Privacy & Data Protection Act 2014 and the IPPs.

You can configure your browser to prevent the collection of Browser Data, erase Browser Data or notify you when you receive a cookie, providing you with the opportunity to either accept or reject it. You can also refuse all cookies by turning them off in your browser or deleting all cookies from your computer if required. If a customer disables the collection of, or deletes, Browser Data on their web browser they may not be able to gain access to the full functionality of ACMI’s website(s).

ACMI also recommends using a privacy enhanced browser such as Brave or Tor which can remove or block browser fingerprinting.

Storage & Security

ACMI uses its best efforts to ensure the personal information we hold is accurate, complete and up-to-date. ACMI relies on individuals to provide accurate and current information, and to notify us when details change.

ACMI will retain personal information for so long as is necessary for us to administer activities, perform our functions and comply with our obligations (for example under the Public Records Act 1973). ACMI will de-identify or destroy personal information if it is no longer required for any purpose in accordance with approved retention and disposal directions under the Public Records Act 1973.

To protect personal information from misuse, loss or unauthorised access, modification or disclosure, ACMI will provide secure information storage systems and procedures for the management of both physical and electronic information. ACMI is bound by the Victorian Protective Data Security Framework in order to protect personal information. If ACMI transfers personal information outside Victoria we will comply with the legislative requirements relating to trans-border data flows.

Can I access or correct my personal information held by ACMI?

Please contact the ACMI Privacy Officer to discuss any privacy concerns or request access or other changes to the personal information that ACMI may hold about you, on email: PrivacyOfficer@acmi.net.au or (03) 8663 2200.

Where lawful and reasonable, ACMI will provide individuals with access to the personal or health information we hold about them. If access would infringe upon the privacy of others, or there are other issues with providing access, a formal application under the Freedom of Information Act 1982 may be required.

Please note:

This privacy policy does not extend beyond the ACMI website. ACMI links to other websites. These websites are responsible for their own privacy practices, and you should check those websites for more information about how they will handle your personal information.

Review date

This policy is to be reviewed prior to August 2025. The Executive Director, Commercial & Operations is the position responsible for facilitating this review and handling all enquiries and proposed changes to the policy.

The table below sets out the history of reviews and amendments to this policy: