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My Tributes Privacy Policy

 News Corp Australia  

APN Newspaper Pty Ltd

1. INTRODUCTION

This Privacy Policy applies to each company listed in Section 9 below ("Company", "us" or "we"). It explains how we collect, use and disclose information about you.

 

This Privacy Policy applies to information which identifies you, or from which you can reasonably be identified, such as your full name or name and postal address ("personal information"). This Policy describes how we handle the personal information we collect when we provide our services. Our services include: home delivery subscription, digital services subscription, advertising, websites, mobile sites, applications ("apps"), and widgets, competitions and customer surveys (collectively, "Company Services").

This Privacy Policy does not apply to personal information collected by our journalists and photographers for the purpose of gathering news. We handle the information we collect in the course of journalism in accordance with the Australian Press Council Privacy Standards, which can be found at: http://www.presscouncil.org.au/privacy-principles.

This Privacy Policy otherwise applies to information about anyone who interacts with us, including advertisers, subscribers and people who use Company Services (both registered and unregistered users).

 

2. WHAT INFORMATION DO WE COLLECT?

 

We collect personal information to provide Company Services and for our business operations. If you choose not to provide the information we request from you, we may not be able to provide you with the services you require. We describe the main types of personal information we collect and the main reasons why we collect that information below.

Registration Information is the information you provide to Company when you register for or acquire a Company Service. This may include information you provide us to:

  • create an account;
  • become a subscriber;
  • become an advertiser;
  • post comments;
  • receive a newsletter; or
  • enter a competition.

Registration Information includes, for example, your name, delivery or postal address, email address, gender and birthday.

You are able to use some Company Services without providing any personal information (for example when browsing our digital products as a casual user) or by providing an alias. We usually tell you when you are able to use Company Services in this way.

Public Information and Posts include comments or content that you post to the online Company Services and the information about you that comes with those posts. This may include your name, user name, comments, likes, tweets, status, profile information and picture(s). Public Information and Posts are available to everyone who views our websites and may be displayed in search results on external search engines, even after you cancel your account with us.

Information from third party Social Media. If you access or log-in to a Company Service through a third party social media service or connect a Company Service to your social media profile, we may also include information from that social media service. This may include:

  • your user name for that service;
  • any information or content you have permitted the social media service to share with us (such as your profile picture(s), email address, followers or friends lists); and
  • any other information you have made public (including other posts you make using your social media profile).

We do not collect your social media profile password. When you access Company Services through your social media profile, or when you connect a Company Service to your social media profile, you authorise us to collect and handle your personal information in accordance with this Privacy Policy.

Activity Information – cookies and other technologies. When you visit Company's websites (including to access and use Company Services) we may collect information about your visit. For example, in order to connect you to the Company Services, our servers receive and record information about your computer, device, and browser, which may include your IP address, browser type, and other software or hardware information. If you access the Company Services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data, or other transactional information from that device.

For more information about cookies and tracking technologies and how to block cookies, see our Cookie Policy.

Information from Other Sources. We may supplement the information we collect about you with information from other sources. This may include information from publicly available sources (such as other published content) and data providers, as well as information from our business partners or related and affiliated companies in Australia or internationally.

Information in relation to other persons who deal with us. When you apply for a job or contract with us we may collect information about you to help us decide whether to offer you the job or contract. For example, we may collect information about how to contact you, your education or work history, or other information included in your CV or résumé. We may collect this information from you, or from any recruitment consultant, your previous employers, or other referees. This Privacy Policy does not apply to our collection, use and disclosure of information:

  • we hold about you once you become an employee;
  • we keep after your employment relationship with us ends,

where that collection, use or disclosure relates to your employee relationship with us and the records we hold about you as an employee.

Company also collects personal information about our suppliers and individuals employed by our suppliers (including service and content providers), contractors, dealers, related companies, agents and corporate customers. We will explain why we are collecting this information and how we will use that information, unless it obvious from the circumstances.

 

3. HOW DO WE USE YOUR INFORMATION?

 

We use the information we collect about you to provide Company Services to you. As part of our service to you we may use your personal information:

  • to fulfill administrative functions associated with these services (for example billing, credit and account management);
  • to enter into contracts with you or third parties;
  • to measure and improve Company Services and their individual features;
  • to improve your experience by delivering content (including editorial, marketing and advertising) we think you will find relevant and interesting;
  • for other marketing and client relationship purposes;
  • to allow you to comment on content, and participate in games, competitions, or rewards programs;
  • to provide you with customer support; and
  • to respond to your enquiries.

Where your personal information is contained in an advertisement which we publish for you, we may also use your information to publish that advertisement in other media. We do this in accordance with our terms and conditions for the initial publication. If you include personal information in any posts or in a letter, email or text message to an editor or journalist, we may publish your name and suburb to identify you as the author of that post if we publish it in any media.

When we collect your information, we may explain that we will use and disclose your information in other ways. For example, if you win a competition, we may disclose your information to relevant regulatory authorities and publish your details in accordance with the competition terms.

We may also remove certain information or alter the information we collect about you so you can no longer be identified from that information. We do this so that we can use it or disclose it to third parties for other purposes.

We use the information we collect about you for the following additional purposes:

Research and data analysis. We may also use your information for research and data analysis to improve Company Services. We may do this research or engage a service provider to do this.

To allow service and content providers to assist us in providing and managing the Company Services. We may make your information available to certain third party service and content providers who help us manage or provide the Company Services or provide Company with related services. This might include providers of cloud services, website hosting service providers, debt collection service providers and direct marketing service providers. These third parties may be located in a range of different countries including the United Kingdom, United States of America and Singapore. Our agreements with these third party providers require them not to use your information except for the purpose for which your information was provided. We also require them to comply with relevant privacy laws.

To allow social sharing functionality. If you log in with or connect a social media profile with your Company Services account, we may share your personal information (including your user name, picture, tweets, likes and posts) with other Company Services users and your friends or followers linked to your social media profile. We may also share the same information with the social media service provider.

By logging in with or connecting your Company Services account with a social media profile, you authorise us to share your personal information with the social media service provider, other users and your friends or followers. You understand that the social media service provider may handle this information in accordance with its own privacy policy. If you do not want your personal information shared in this way, please do not connect your social media profile with your Company Services account and do not participate in social sharing on Company Services.

To provide co-branded services and features. We may offer co-branded services, such as competitions or other promotions together with a third party ("Co-Branded Services"). When this happens, we may share the information you submit in connection with the Co-Branded Service with the third party, or with our service providers who assist us to host Co Branded Services. The third party’s use of your information will be governed by their own privacy policy. We will obtain your consent to share your personal information with the third party. If you do not provide this consent, you may not be able to access that co-branded service.

To deliver relevant advertisements and content. Company and our advertisers may use the information we collect about you to provide you with relevant advertisements and content when you use Company Services. We may also use your personal information so that relevant advertising can be provided to you when you use services or visit websites of other organisations.

We may combine information that we hold about you with information about you that we collect from other trusted businesses with whom you also have a relationship or from public sources and we may associate your browser and/or device with other browsers or devices you use. We may also share information we hold about you with those trusted businesses so that they can do the same thing.

We and those trusted businesses do this in order to enable the development of consumer insights about you so that each of us can serve you better. This includes being able to better understand your preferences and interests, personalise your experience, enhance the products and services you receive, and to tell you about products and services. Where those insights are provided to others for their own marketing purposes, such insights do not contain any information that identifies you. We may also use third party service providers to undertake the process of creating these consumer insights.

For more information about this, please see our Data Usage Policy. In Section 6, below, we provide information about how to choose what advertisements you see when using the Company Services.

To contact you. From time to time, we may send you promotional materials or other information which we think may interest you. For example, we may send you an invitation to participate in various activities (such as customer surveys) or special offers.

To share with our Company Affiliates. Company may share your information with our related companies located in Australia or in other countries, including the United Kingdom and United States of America. If we share your information with our related companies, they can use your information in accordance with this Privacy Policy. However, if you access or use a service provided by one of our related companies, you should consider the privacy policy of that company, as it may be different to this policy.

To share with business partners. Company may share your information with business partners so they can send you marketing communications. This will only happen if you have expressly agreed to this.

To protect the rights of Company and others. We may share your information with other third parties where we are lawfully entitled to do so. This includes when we have a reasonable basis to believe that sharing your information is necessary to:

  • protect, enforce or defend the legal rights, privacy, safety, or property of Company, our related companies or their employees, agents and contractors (including enforcement of our agreements and our terms of use);
  • protect the safety, privacy, and security of users of the Company Services or members of the public;
  • protect against fraud or for risk management purposes;
  • comply with the law or legal process in any country; or
  • respond to requests from public and government authorities.

To complete a merger or sale of assets. If Company sells all or part of its business or assets, we may disclose your information to the party or parties involved in the sale transaction. We may also do this if Company is involved in a merger or transfer of all or a material part of its business. We may disclose your information prior to the sale, transfer or merger so that the party or parties involved can consider the transaction and complete any due diligence.

 

4. HOW DO WE PROTECT YOUR INFORMATION?

 

We use reasonable measures to safeguard the personal information we hold about you from loss, theft and unauthorised use, disclosure or modification, including:

System security We take reasonable steps to prevent unauthorised access to our online and computerised systems by using measures such as firewalls, data encryption, virus detection methods, and password restricted access.

Property security At our business premises, we may engage security personnel and use ID cards to restrict access to those premises.

Staff training We train our staff to handle your information in accordance with this Privacy Policy and applicable privacy laws.

Third parties We take reasonable steps to ensure that third parties who store or assist us to store your personal information adopt appropriate security measures.

5. HOW CAN YOU ACCESS YOUR INFORMATION?

If you would like to access, review, correct or update your personal information, you may contact us (see section 8). When you contact us, please provide your name and contact details (including your email address, address, and telephone number) and specify clearly what information you would like to access, review, correct or update. We will need to share your information with others who can help us respond to your request. We will try to respond to your request as soon as reasonably practicable. If we refuse your request we will generally tell you why.

6. HOW CAN YOU OPT OUT?

Online advertising. You can block certain advertisements by blocking or deleting cookies in your browser settings. However, we use cookies to provide some of our Company Services and you may not be able to use these Company Services if you do this. For more information about how we use cookies, see our Cookie Policy. Some third party providers use tracking technology other than cookies to deliver targeted advertisements to you. You can read more about this type of advertising at: http://youronlinechoices.com.au. To opt out of us serving you this type of advertising on our network, go to https://preferences.news.com.au/preferences.

Direct marketing. If you do not want to receive promotional messages from us, you can change your account settings or follow the unsubscribe instructions which we include at the bottom of our emails and text messages. If you have installed our app, you can stop push notifications by changing the settings in the app or on your mobile device.

If you have linked any of your social media profiles to your account for any Company Service, you can cancel that link by changing your account settings. If you need any assistance with changing your account settings, please call us (see Section 8).

7. OTHER IMPORTANT INFORMATION FOR YOU

Updates to Privacy Policy. We may modify this Privacy Policy at any time. The date at the top of this Privacy Policy tells you when it was last updated. Any changes to this Privacy Policy become effective when we publish it online. If you do not agree with changes to this Privacy Policy, you may be able to terminate your account with us.

Location of Data. Some Company Services are hosted in and managed outside of Australia, including in the United Kingdom, the United States of America and Singapore. In dealing with Us, you consent to this practice, understanding that your personal information may be accessible from or transmitted outside Australia.

Linked Services. Company Services (including Company's website) may display links to sites operated by unaffiliated companies, and may carry advertisements or offer content, functionality, games, newsletters, competitions or applications developed and maintained by unaffiliated companies. We are not responsible for the privacy practices of these unaffiliated companies. Once you leave the Company Services or click an advertisement you should check the privacy policy of that company to understand how it will handle your information.

Collection of Personal Financial Information by a Payment Service provider. Sometimes we allow you to use an unaffiliated payment service to purchase a product or make payments for Company Services (“Payment Service”). If you use a Payment Service, you will be directed to the webpage for that Payment Service. Any information you provide when using a Payment Service may be collected and used by the Payment Service provider in accordance with that provider's privacy policy. You should check the provider's privacy policy to understand how it will handle your information.

Data Retention. Even after you cancel your account with us, we will retain your information for as long as we reasonably need it for the purposes outlined in this Privacy Policy. For example, we may retain your information to prevent fraud, or to maintain systems security. We may also retain your information if required or allowed to by law, regulation or relevant standards and codes of conduct, or to fulfil our contractual obligations to a third party. In certain circumstances, including where we are prevented by technical or systems constraints, we may not be able to remove all of your personal information.

If you share your information with a social media service (including by posting information to that service), this information may not be removed even after you cancel your account. If you delete your account with us, your account information may still be accessible by others for a short period of time because of the way that your information is stored on the internet.

Sensitive Information. We ask that you not provide us with any sensitive information (such as information about your racial or ethnic origin, religious or other beliefs, health, criminal background or trade union membership) when using Company Services, or otherwise. If you do provide us with any sensitive information, you consent to us collecting and handling that information in accordance with this Privacy Policy.

Complaint. If you think we have breached the Privacy Act 1988 (Cth) or other applicable privacy laws, you can contact us (see Section 8) to make a complaint. When you contact us, please include your name and contact details (including your email address, address, and telephone number) and clearly describe your complaint. We will need to share your information with others who can assist in responding to your complaint. We will contact you within 7 days to let you know the next steps in resolving your complaint and to obtain any further information we need to consider your complaint. As soon as reasonably practicable and in any event within 30 days, we will let you know our decision. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (www.oaic.gov.au).

8. HOW YOU CAN CONTACT US

If you have questions about this Privacy Policy, or to request a hard copy, please contact our Privacy Officer at:

Email:

privacy@news.com.au

Mail:

National Privacy Officer, News Pty Limited, 2 Holt Street, Surry Hills, NSW 2010

Telephone: 

+61 2 9288 3000


 

9. LIST OF INCLUDED COMPANIES

  • Advertiser Newspapers Pty Ltd (ACN 007 872 997)
  • Advertiser News Weekend Publishing Company Pty Ltd (ACN 007 562 950)
  • Australia Independent Business Media Pty Ltd (ACN 126 233 743)
  • Business Spectator Pty Ltd (ACN 126 233 725)
  • Davies Brothers Pty Limited (ACN 009 475 754)
  • Duvir Holdings Pty Ltd (ACN 068 007 474)
  • Gold Coast Publications Pty Ltd (ACN 009 696 511)
  • Kidspot.com.au Pty Ltd (ACN 111 607 866)
  • Leader Associated Newspapers Pty Ltd (ACN 004 337 446)
  • Messenger Press Pty Ltd (ACN 007 563 439)
  • Nationwide News Pty Ltd (ACN 008 438 828)
  • News Digital Media Pty Ltd (ACN 000 529 457)
  • News Life Media Pty Ltd (ACN 088 923 906)
  • News Pty Limited (ACN 007 871 178)
  • Queensland Newspapers Pty Ltd (ACN 009 661 778)
  • Shespot.com.au Pty Ltd (ACN 138 256 961)
  • Sunshine Coast Publishing Pty Ltd (ACN 090 524 799)
  • The Cairns Post Pty Limited (ACN 009 655 752)
  • The Geelong Advertiser Pty Ltd (ACN 004 090 055)
  • The Herald & Weekly Times Pty Limited (ACN 004 113 937)
  • The North Queensland Newspaper Company Pty Ltd (ACN 009 655 690)
APN Newspapers Pty Ltd and its related bodies corporate (ARM, our, us, we) respect your right to privacy.

We are sensitive to the concerns that our clients, customers and online users may have with regard to the confidentiality, security and use of their personal information. ARM is committed to the protection of your personal information and would like to reassure you of our position on this matter. ARM has developed this Privacy Policy in line with the ‘Australian Privacy Principles’ (APPs) as established under the Privacy Act 1988 (Cth).

The purpose of this Privacy Policy is to tell you what type of information we collect, how we may use that information, whether we disclose it to anyone, the opportunities you have to access and correct the information we hold, and how you may make a complaint about a breach of the APPs.

We encourage you to check this policy regularly as this policy may change from time to time. If you have any suggestions or concerns that are not addressed in this policy, please contact us. Please take some time to read through this policy and understand our position on privacy before you provide us with any personal information.

Our commitment to privacy

Aside from the contents of this policy, the conduct of ARM is governed by the Privacy Act 1988 (Cth) and in particular the APPs. ARM also subscribes to the ‘Statement of Privacy Principles’ of the Australian Press Council. For more information, please click here.

Personal information we may collect

ARM will only collect personal information about you if it is reasonably necessary for our functions and activities. When submitting information to us, we may collect details such as your name, email, phone number and in some instances, your financial information (including credit card information) which may personally identify you. Some of this information is essential for us to be able to identify accurately who is using our services so that we may be able to respond to your requests and, as such, is indicated by mandatory fields. Mandatory information requirements are clearly identified and are denoted by an asterisk (*). When submitting a form, you will also be prompted if any mandatory data has not been completed. Other types of information are collected to help us provide better services. Information of this type is optional – you need only fill it in if you wish to do so.

You may be asked to provide ARM with personal information when you:

  • Register with one of our websites;
  • Send us your comments, suggestions or other information;
  • Report a technical problem;
  • Request sales and advertising information;
  • Subscribe to a newsletter;
  • Enter a competition, promotion or event; or
  • Order products or services using our website (or otherwise).

We also collect personal information in the normal course of business through meetings, phone calls, letters, faxes and emails, as well as via third party credit agencies, mailing lists, advertisers, commercial agreements, documents and dealings. All this information is subject to the APPs.

In addition, we may also collect information about you if you:

  • post comments or submit content which is publicly available which contains information about you – this may include information such as your name, user name, likes, tweets, status, profile information and pictures; and
  • log-in to or access one of our sites, services or activities through a third party social media service or connect one of our sites, services or activities to a third party social media service - this may include information such as your user ID, user name, information you have disclosed via the social media service and information or content you have permitted the social media service to share with us (for example your profile picture, email address, followers or friends lists).

When you engage in the activities described above, you are authorising us to collect, store, use and disclose such information and content in accordance with this policy.

ARM will not collect sensitive information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation. However if we do collect sensitive information we will do so in compliance with the APPs.

You have the option of not identifying yourself or dealing with us using a pseudonym in relation to particular matters. We will endeavour to make it clear where you may withhold your name or use a pseudonym.

Non-personal information we may collect

ARM may also collect non-personal information, such as your IP address or your browsing patterns, by using cookies on its websites. Cookies do not personally identify you, but assign a unique number to the visitor to track user navigation and customise site information to further improve the user experience on an aggregate and anonymous basis. Cookies can make using ARM's website easier and better - for example by storing information about your preferences on a website. The use of cookies is an industry standard and you'll find most major websites use them. One way to prevent the use of cookies is to activate the facility which is

available in most web browsers that enables the user to deny or accept cookies.

How we use your information

If we hold personal information about you that was collected for a particular purpose, we will not use or disclose it for another purpose unless: (a) you consent; (b) you would reasonably expect us to use or disclose it for that other purpose; or (c) it is required or authorised by law or a court/tribunal order.

ARM generally uses personal information, and you consent to us using your personal information, to:

  • provide you with products or services you have requested;
  • provide you with relevant advertising and promotional material;
  • conduct promotions or competitions, including Joint Activities;
  • help ARM manage and enhance its services and websites;
  • communicate with you; or
  • send you ongoing information and promotional material about opportunities, services and products (relating to our business or a third party business) in which ARM believes you may be interested.

We may also share your personal information with our Related Companies, Partners and others, as referred to below.

The information and feedback you provide through our websites may be used to identify ways of improving the websites and how we can make them more effective for your use.

Opting in or out and unsubscribing

At the time we collect information from you, you may be asked to "opt in" to consent to us using or disclosing your personal information, other than in accordance with this policy or any applicable law. For example, you may be asked to “opt-in” to receive further information or communications from us, our Related Companies or our Partners, as referred to below.

You will be given the opportunity to "opt out" or unsubscribe from receiving communications from us, our Related Companies or our Partners in accordance with this policy. Alternatively, you may contact us at the address below to “opt out” of, or unsubscribe from, any future communications.

ARM will use reasonable endeavours to comply as quickly as possible with that request, and in any event, within five business days.

If you receive communications purporting to be connected with us or our services that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact us.

Disclosure of your personal information

You consent to ARM disclosing your personal information to the authorised personnel of ARM and to:

  • our Related Companies;
  • our Partners;
  • third parties which we engage with in Joint Activities;
  • credit reporting agencies; or
  • parties involved in a business sale or restructure,

as referred to further below.

Related Companies

You acknowledge and agree that we may collect and share personal information about you with related bodies corporate, joint venture partners and affiliated companies and businesses (Related Companies) so we can provide you with the products and services you request and bring you information about products and services we offer. We will inform our Related Companies that information shared with them must be collected, used, disclosed and stored in accordance with this policy.

Partners

In some cases, we contract with other companies or individuals to work with us or provide goods or services for us (Partners) including business partners, distributors, suppliers and advertisers. Examples of the goods and services our Partners may provide are electronic communications, data storage, deliveries, direct marketing services, market research, prizes, advertising, public relations, debt collection, legal advice, accounting and audits. We provide our Partners only with such information about you as they need to provide their goods or perform their services and we impose strict requirements of security and confidentiality on them in how they handle your personal information. We make it clear that our Partners are not permitted to use your personal information other than as permitted under this policy.

Related Companies and Partners may be located in Australia and/or overseas countries, including New Zealand, Hong Kong, Ireland and the United States of America. You hereby consent to the disclosure of your personal information to such Related Companies and Partners overseas (as referred to above) and you acknowledge that as a result of your consent to such disclosure, clause 8.1 of the APPs does not apply.

Joint Activities

We may jointly conduct activities, such as competitions and other promotions, with sponsors, prize providers and other third parties (Joint Activities). We may share personal information you submit in connection with the Joint Activities with the third parties involved and you consent to us doing so. Information shared with such third parties will be collected, used, disclosed and stored in accordance with the third parties’ privacy policy. Terms and conditions for Joint Activities will inform you that your information is being shared and the terms upon which it may be used by the third party.

Credit Reporting

Credit information about you may be obtained from and provided to credit reporting agencies in accordance with applicable legislation.

Sale of business

If we sell all or part of our business, merge with another company or business, or restructure our business, we may transfer or disclose your personal information to the parties involved in the transaction.

Access and correction

ARM will take reasonable steps to ensure your personal information is accurate, up to date and complete. 

Access

Where ARM holds personal information about you, we will provide you with access to the information on request within a reasonable time. There are some exceptions to this where we may refuse to give you access and these are set out in clause 12.3 of the APPs. In that case, where required, we will give you written notice setting out the reasons for our refusal and the mechanisms available if you wish to complain about our refusal.

We will also give you access to the information in the particular manner you request if it is reasonable and practicable to do so. If we do not give you access in the manner requested, we will take reasonable steps to give you access in a way which meets both your needs and ours. We may also impose a reasonable charge for giving you access to your personal information.

Correction

If ARM is satisfied that your personal information is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct your personal information. In addition, if you request us to correct your personal information, we will take reasonable steps to do so within a reasonable time. If you request it, we will also take reasonable steps to notify any other Related Companies or Partners of the changes if we have previously provided your personal information to that entity. There is no fee for correcting your personal information. We may require you to provide particulars of your identity before providing you with access to, or making changes to, your personal information.

Security

ARM will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access and modification or disclosure. Any personal information that we receive is securely stored and access is restricted to authorised personnel of ARM, its Related Companies and Partners, as described above. Please contact us immediately at the address listed below if you become aware of any unauthorised use of your personal information.

Third party websites

You may follow links on our websites to other third party websites (Other Sites). We encourage you to always read the privacy policies on those Other Sites as they may also collect your personal information. ARM is not responsible for the information on, and the contents of, those Other Sites or their practices or policies. 

Contact us

If you: (a) have any questions or comments on this policy; (b) would like to access or correct your personal information; (c) would like a hard copy of this policy; (d) would like to know how we received your personal information; or (d) would like to make a complaint about a breach of the APPs or the use or disclosure of your personal information, then please contact ARM’s Privacy Officer at:

Privacy Officer

APN Newspapers Pty Ltd

PO Box 1578

Milton QLD 4064

Phone: 1300 130 590

Fax: (07) 5456 6920

Email: privacyofficer@newsregionalmedia.com.au 

ARM takes complaints about breaches of the APPs seriously and will investigate any complaint we receive and respond to you as soon as reasonably practicable.