We are Dry July Limited (ACN 135 429 346) as Trustee for Dry July Foundation (ABN 88 497 552 964).
- the Dry July Website (at http://www.dryjuly.com) (the Dry July Website); and
- the Dry July program (Dry July), which is an annual website-based initiative where an individual or group can take on the challenge of a month long sponsored abstinence from alcohol and funds raised go directly to benefit the lives of people affected by cancer.
- how we may collect your personal information;
- how we will handle the personal information which we collect; and
- how and why we may use and disclose this information from time to time.
You should review this page regularly.
You should direct any questions or complaints to our Privacy Officer at [email protected] We will endeavour to respond to any complaint within a reasonable time (usually 30 days). If you are not satisfied with our response, you may take your complaint to the Office of the Australian Information Commissioner.
The types of Personal information which may be collected by us, and how we collect that information
The main types of personal information that we may collect include:
- Information relating to Your Account: In accordance with Our Agreement we require all Participants to have an active account with us (Account). To open your Account you must provide us with certain personal information and we will collect and hold this information. This personal information may include, for example, your name, address, email address, post code and phone number. We require this to be able to identify you and for security purposes. If you choose not to provide the personal information we request, we will not be able to let you open or keep open your Account. We may also collect information relating to your use of your Account.
- Your Content: You may post on, upload to, or make available to the Dry July Website your content and information, including information about you and the actions you take, any photos, video, or text or other forms of content (Your Content). Your Content will be publicly available. You grant us a licence to Your Content under Our Agreement. If you authorise a third party to post or make available any personal information about you on the Dry July Website, you consent to that content being used by us in accordance with Our Agreement with that third party.
- Being a part of Dry July: If you are a Participant or Donor, we may collect and hold information in relation to your participation with Dry July (including historical information about any previous Dry July campaigns that you have participated in). This may include information such as who you sponsor or who sponsors you, donations made by you or related to you (if you are a Participant) and purchase orders placed by you. If you choose to use our opt-in services, we will ask you for the information needed to send the communication or have it sent to you and we may keep information about our communications with you.
If you interact with us for purposes other than those outlined above, we may collect and handle personal information in connection with those purposes on a case by case basis and in accordance with applicable privacy laws.
While we generally collect personal information directly from you, depending on the circumstances, we may also collect personal information from publicly available sources and third parties, such as recruitment agencies and your previous employers (such as if you apply for an employment or other position with us), and from our contractors, service providers and business / charitable partners.
If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.
Information we will not collect
We do not collect any credit card or debit card information from you.
Social media platforms
We use social media platforms such as Facebook, Twitter, Instagram, YouTube, TikTok and LinkedIn to communicate with the public about our services and businesses. We may collect the information that you choose to share with us through these platforms, including photos, videos and comments and posts.
These social media platforms have their own privacy policies, and may handle your information for their own purposes. You can access the privacy policies for each platform on their respective websites.
If you choose to use these social media platforms to communicate with us, with other Participants or Donors, or with members of the public, please be mindful that certain pages within these platforms may be publicly available. We encourage you to use the privacy settings available on each platform. If you would like to contact us directly, you can do so by sending an email to [email protected] or calling 1300 DRY JULY.
We use Brandwatch Social Media Management (formerly Falcon.io) to help us monitor and understand how consumers are reacting to our brand and campaigns online (including on publicly available websites and on social media platforms). You can find Brandwatch's privacy documentation (which includes explanations about how Brandwatch collects and uses personal information) on Brandwatch's website: https://www.brandwatch.com/legal-documents/privacy/.
The Dry July Website may contain links to other websites operated by third parties. We make no representations or warranties in relation to privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices and procedures.
Purposes of collecting, using and disclosing your personal information
Your personal information may be collected, held, used and disclosed by us to:
- verify your identity;
- if you are a Participant, enable you to open and use Your Account;
- if you are a Participant, have a profile page on the Dry July Website;
- keep track of your participation in previous Dry July campaigns (including for the purpose of making this information available to you via Your Account on the Dry July Website);
- enable you to be a Participant or Donor;
- enable you to otherwise access and use the Dry July Website, including uploading and sharing Your Content;
- troubleshooting and rectifying or altering Dry July;
- facilitate the sharing of Your Content;
- administer and manage Dry July and the Dry July Website;
- administer and manage your access to and use of the Dry July Website;
- communicate with our Payment System;
- implementing and conducting risk management, cyber security or fraud protection activities in connection with Dry July and the Dry July Website;
- maintain, improve, undertake research into and develop Dry July and the Dry July Website;
- communicate with you, or permit other people to communicate with you, in accordance with Our Agreement;
- provide you with information about future Dry July events and initiatives which may be of interest to you;
- optimise and customise the user experience (including content and advertising) for users of the Dry July Website;
- conduct marketing and advertising activities (including using email marketing and Internet-based advertising services);
- communicate with you (including, but not limited to, emailing you tax donation receipts); and
- otherwise manage and operate our business and comply with our legal and regulatory obligations.
Storage and Security
We hold personal information in a range of formats, including secure physical records and electronic files (on our intranet system or in cloud storage), and in some cases, records on third party servers, which may be located overseas.
We use a range of security measures to protect the personal information we hold, including by ensuring that data centres are subject to identity and access management and employees and third parties are subject to information security obligations.
We will take reasonable steps (as required by law) to destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law. We may need to retain records containing personal information to comply with record keeping obligations, and for other legitimate business purposes (such as quality assurance).
The Terms and Conditions which form part of Our Agreement also contain further information about our information security practices.
With your consent or where otherwise permitted by law, we may send you certain communications from us or third parties in relation to marketing, news about Dry July, news about beneficiaries, or other information available from time to time.
You may opt out at any time if you no longer wish to receive direct marketing messages from us. You can make this request:
- by clicking on an unsubscribe link in an email you receive from us;
- via the "Account Settings" on the Dry July Website; or
- by contacting [email protected]
As with many organisations, we use third party service providers to assist us with our marketing activities. We may also share your information for third party marketing and research purposes in certain circumstances (for example, where you have opted-in to receive these third party communications). Please see the "Disclosure of your personal information" section below for further details.
We use email analytics to track and measure the success of our email newsletters, fundraising e-mails and other email campaigns. This involves using various tracking technologies (such as tracking pixels) to collect information about how our emails have performed (for example, which of our emails you have opened). We use this data to analyse and improve the performance of our email campaigns and marketing activities.
We use Google Analytics to measure and improve the performance of our websites.
We may also use Advertising Features, which is a function within Google Analytics that uses additional Google advertising cookies and other tracking technologies to provide us with various advertising-related services.
For more information, please refer to Google's explanation (available on its website here: www.google.com/policies/privacy/partners/) about:
- how Google collects and processes data when you visit websites (such as ours) that use Google Analytics and other Google services; and
- how you can disable or opt-out of these types of data collection and processing.
By using our websites, you consent to Google collecting and processing data about you in the manner and for the purposes set out above.
We may also collect and use information about you for the purposes of online targeted advertising services that help our advertisements (ads) to reach you (and other people who may be interested in our products and services) on websites, apps and social media platforms across the Internet.
These online targeted advertising services are provided by third party vendors.
The advertising service providers that we currently use include:
- Meta (which operates Facebook and Instagram);
- Google (which includes YouTube);
- TikTok; and
Other services require us to use limited amounts of your personal information to target and serve ads. For example, we may include your information in a customer list that we provide to selected online advertising service providers (such as Meta, LinkedIn, Google and Twitter) so that we can conduct audience-based advertising. This allows us to show our ads to you (if you also use those platforms) and to other users of those platforms who share similar characteristics with you. The customer list is generally hashed (to improve security and confidentiality) before it’s provided to the service provider to target and serve our ads.
The data that is collected through these cookies and other tracking technologies, or provided by us, may be combined with other data (supplied by our advertising service provider, or third parties) to improve the targeting and serving of ads.
Our online advertising service providers also help us by measuring the effectiveness of our ad campaigns (e.g. conversion tracking) and providing us with advertising analytics that we use to inform and optimise our ad campaigns. These analytics are based on data that may be collected through cookies and other tracking technologies. The data that we receive through these analytics services is generally aggregated and non-identifying.
We may permit third party vendors (including the advertising service providers listed above) to deploy cookies and other tracking technologies on and through our website and emails to collect or receive information about you from our websites, our emails and your activities elsewhere on the Internet. This information may be used to provide measurement / analytics services and to target and deliver ads, as described above.
By using our websites and social media pages or otherwise interacting with Dry July (whether as a Participant, Donor, supporter or member of the public), you consent to our third party advertising service providers collecting, receiving and processing data about you in the manner and for the purposes set out above.
Your choices in relation to Internet Advertising
Your web browser and/or mobile device may provide you with settings that allow you to disable or opt-out of some of the tracking technologies that are used to collect data that is used for analytics and ad targeting and serving purposes (such as cookies, device identifiers and advertising identifiers). These options may vary depending on the specific web browser or mobile device that you are using. Please refer to your web browser or mobile device manual for further information.
You can learn more about opting out of receiving interest-based Internet ads in general at www.optout.aboutads.info and www.networkadvertising.org/choices. You can also opt-out of certain online targeted advertising networks directly by visiting:
- the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/; and
- the Network Advertising Initiative’s opt-out portal: https://optout.networkadvertising.org/
You can also learn more about how our advertising service providers collect and use data for interest-based advertising purposes (and what options they offer for managing how your data is collected and used as part of their services) by visiting the following pages on their websites:
- Instagram: https://help.instagram.com/1415228085373580
- Google (including YouTube): www.google.com/policies/privacy/partners/
Other people's information
If you provide to Dry July or post on or make available to the Dry July Website any personal information of another person, you must:
- have that person's prior written consent to do so;
- ensure their consent allows us to use and disclose their personal information in the same way that we may use and disclose your personal information.
Disclosure of your personal information
In order to be able to manage Dry July and operate the Dry July Website, and without limiting the section titled "Purposes of collecting, using and disclosing your personal information" above, we may disclose your personal information to third parties for the following purposes:
- if you are a Participant, to allow you to open and use your Account;
- so you can access and use the Dry July Website, including uploading and sharing Your Content;
- so we can administer, manage and support Dry July and the Dry July Website for you (including your access to and use of the Dry July Website);
- so we can ensure your donations and purchase orders are properly accounted for with the Payment System provider;
- so we can fulfil your purchase orders;
- so we can conduct risk management, cyber security or fraud protection activities in connection with Dry July and the Dry July Website;
- so we can undertake research into and develop Dry July and the Dry July Website to make it better; and
- so we can conduct our marketing and advertising activities to increase awareness about Dry July.
The types of organisations to which we disclose information for these purposes include:
- organisations which carry out IT services for us related to Dry July and the Dry July Website including our physical housing, monitoring and backup of the servers for the Dry July Website, support and maintenance for the Dry July Website; and
- organisations which provide services to enable fulfilment of your purchase orders.
Some of the third parties we disclose personal information to are located overseas. For example, some of the service providers we use may utilise offshore servers and other data hosting and processing facilities located outside of Australia (including in Singapore and the United States).
If you consent to the disclosure of your personal information overseas, Dry July will not be responsible for ensuring overseas entities' compliance with Australian privacy law (including the Australian Privacy Principles) in relation to that personal information.
If you are a Participant we will display your name and image on your profile page of the Dry July Website. Your email address or other contact information will not be displayed in any form through the Dry July Website. If you are a Donor we will normally display your name on the profile page of the Participant to whom you have made a donation. When making a donation, you have the option of checking a box marked "Anonymous Donation". If you check this box, your name will not be disclosed to the Participant nor will your name be displayed on the Dry July Website.
If you are a Participant, we may also provide your postcode information from your Account to Google Maps (but not other personal information) so Google Maps can display information about your participation in Dry July. This is unlikely to identify you.
We may also disclose information to third parties you have indicated you want to share your information with for a particular purpose, including through opting-in to a particular form of communication (by checking a box or by other means that allows Dry July to pass your information onto third parties). This may include beneficiaries, third parties that provide goods or services, or our sponsors or supporters who may wish to contact you from time to time. They may also include marketing, market participation and research companies.
Where consent has not been provided we may still provide information which has been de-identified (so that it is no longer personal information and does not identify you) to:
- organisations which carry out marketing, market and participation research for us for the purpose of carrying out such research and providing us with advice; and
- organisations which provide us with support, sponsorship or are beneficiaries.
We take reasonable steps to ensure that any third parties who we disclose your personal information to are bound by confidentiality and privacy obligations in relation to the protection of your personal information.
In addition, we may disclose your personal information:
- to your authorised representatives or your legal advisers (when requested by you to do so);
- as required, permitted or authorised by law, including to government and regulatory authorities and other organisations; and
- to our professional advisers, including our accountants, auditors, insurers and lawyers.
Disclosure of your personal information to your nominated beneficiary
Where you have elected to opt-in to receive communications from the beneficiary that you have nominated, we will share your personal information with that beneficiary. The personal information we will share with that beneficiary if you make this election will be your name, email address, state, postcode, telephone number (if disclosed by you) and amount raised in the relevant Dry July campaign.
Changes to personal information
Management of personal information in your Account and Your Content is governed by you. You are responsible for changing these as required by you from time to time.
We require your assistance to ensure that the personal information we collect, use and disclose and which you use and disclose to us is accurate, complete and up-to-date. We ask that you:
- let us know if there are any errors in your personal information which we have collected; and
- keep us up-to-date with changes to your personal information which we have collected such as your name or e-mail address.
If you have difficulty in doing this, you should contact us for help by emailing us at [email protected]
You have a right to request access to (and/or correction of) the personal information we hold about you. In order to do this, please email us at [email protected] or call 1300 DRY JULY.
If you have any queries about our privacy practices or would like to make a complaint, then please contact us using the details above. We take all complaints seriously, and will respond to your complaint within a reasonable period. If we do not resolve a complaint to your satisfaction, then you may take your complaint to the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Email: [email protected]
Removing, requesting data deletion and correcting information
If you request us to remove or delete your personal information from our database or you wish us to amend or change the information we hold about you on our database, we will remove, delete, amend or change any such information on your request in accordance with your rights under applicable law.
Such request should be made by email at [email protected] or by post at the following address:
Dry July Foundation
705, 6A Glen Street