Shopper Media Group Privacy Policy

Shopper Media Group Operations Pty Limited ABN 696 288 067 80 (“SMG”) and its related bodies corporate (SMG, us, our) recognise the importance of protecting the personal information you supply us and are bound by the Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles.  Personal information is collected, used, disclosed and protected as set out in this Privacy Policy.

By using our in-centre free WiFi service (Service), you expressly consent to our collection, use and disclosure of your personal information in the manner set out in this Privacy Policy.

What is your personal information?

When used in this Privacy Policy, the term ‘personal information’ has the meaning given to it in the Privacy Act.  In general terms, it is any information that can be used to personally identify you.  This may include your name, address, age, sex, telephone number, email address, profession or occupation and other information you may provide to us.  If the information SMG collects personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What personal information does SMG collect and hold?

SMG collects personal information for the purpose of its provision of Services to you and the operation and administration of the organisation. This information typically includes:

  • your name, address, phone and facsimile numbers and email addresses (contact information);
  • your age, birth date, gender, income, and occupation, profession or job title;
  • any additional information relating to you that you provide to SMG directly through our Service or indirectly through use of SMG’s websites or online presence, through our representatives or otherwise; and
  • information you provide to SMG through customer surveys or visits by our representatives from time to time.

SMG may also collect some information that is not personal information because it does not identify you or anyone else.  For example, SMG may collect anonymous answers to surveys or aggregated information about how, when and where users use our Service.

How do we collect your personal information?

SMG collects your personal information directly from you unless it is unreasonable or impracticable to do so.  SMG collects personal information that you provide us:

  • via our websites and related social media platforms;
  • during any written communications between you and our representatives;
  • when you register to enter any competitions on our websites or social media sites;
  • when you register for any of our services, including WiFi networks, alerts, blogs, or other subscription services; and


In some cases, SMG may also collect your personal information through the use of cookies.  When you access our Service, we may send a ‘cookie’ (which is a small unit of data temporarily stored on the hard disk of your computer by your browser) to your computer.  The information contained in the cookies may assist us with functions such as improved navigation and a high level of user friendliness. It also enables us to keep track of products or services you view so that, if you consent, SMG can send you news about those products or services. SMG also use cookies to measure traffic patterns, to determine which areas of our websites have been visited and to measure transaction patterns in the aggregate.  SMG uses this to research its users’ habits to improve its Service.

Our cookies do not collect personal information.  The majority of web browsers automatically accept cookies.  If you do not wish to receive cookies, you can adjust your browser to disable cookies but this may restrict your ability to access certain areas of our websites.

We log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the websites, track users’ movements, and gather broad demographic information.

What happens if we can’t collect your personal information?

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

  • we may not be able to provide the Service to you, either to the same standard or at all;
  • we may not be able to provide you with information about products or services that you may want, including information about discounts, sales, special promotions or competitions; or
  • we may be unable to tailor the content of our Service and websites to your preferences and your experience of our Service may not be as enjoyable or useful.

For what purposes do we collect, hold, use and disclose your personal information?

SMG collects personal information about you for the purpose of its provision of Service to you and the operation and administration of the organisation.  In addition, SMG may collect, hold, use and disclose your personal information for the following related purposes:

  • providing products, services, deals and competitions offered by us and/or our commercial associates, partners and sponsors to you and sending communications requested by you;
  • providing you with access to protected areas of our Service;
  • assessing the performance of our Services and improving the operation of those Services;
  • tailoring and personalising Service and website content and deals offered by us and/or our commercial associates, partners and sponsors, depending on your location and interests;
  • conducting business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
  • conducting research from time to time based on the information SMG collects from you;
  • administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of SMG and its contractors, service providers or other third parties;
  • updating our records and keeping your contact details up to date;
  • providing your updated personal information to our related bodies corporate, contractors, service providers or other third parties;
  • processing and responding to any complaint made by you; and
  • complying with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.

SMG will not share, sell, rent or disclose your personal information other than as described in this Privacy Policy.

To whom may SMG disclose your information?

SMG may disclose and transfer your personal information for the purposes outlined above and related purposes:

  • to our employees, related bodies corporate, members of our online community, contractors, or service providers located in Australia and overseas including without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators and professional advisors such as accountants, solicitors, business advisors and consultants, for the purposes of providing services in connection with the operation of our Service or our business, fulfilling your requests or enquiries, and to otherwise provide products and services to you;
  • to our agents, affiliates and related bodies corporate located in Australia and overseas;
  • to suppliers and other third parties with whom we have commercial relationships, for business, marketing and related purposes; and
  • as required or authorised by law including to law enforcement, government or other organisations or where permitted under the Privacy Act.

SMG may combine or share any information that SMG collects from you with information collected by any of our related bodies corporate (within Australia).

Do we disclose your personal information to anyone outside Australia?

SMG may disclose personal information to our services providers, related bodies corporate and their service providers located overseas for some of the purposes listed above.

SMG will take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

Direct marketing materials

SMG may send you direct marketing communications and information about our products and services and those of our sponsors and commercial partners that SMG considers may be of interest to you.  These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth).  If you indicate a preference for a method of communication, SMG will endeavour to use that method whenever practical to do so.  At any time, you may opt-out of receiving marketing communications from us by contacting us using the contact details below or by using the opt-out facilities provided in the marketing communications and SMG will then ensure that your name is removed from our mailing list.

How can you access and correct your personal information?

You have certain rights to access personal information held by SMG to request access or to find out what information we have about you, please contact our Privacy Officer (see details below).  Where SMG holds information that you are entitled to access, SMG will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you).  SMG may charge you a reasonable fee to cover our administrative and other reasonable costs in providing you the information. SMG will not charge you for simply making the request and will not charge for making any corrections to your personal information.

There may be instances where SMG cannot grant you access to the personal information it holds.  For example, SMG may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality.  If that happens, SMG will give you written reasons for any refusal.

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

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

If you believe that your privacy has been breached, please email with a full description of the issue. SMG will treat your requests or complaints confidentially. SMG’s Privacy Officer will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved.  SMG aims to ensure that your complaint is resolved in timely and appropriate manner.


SMG takes reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure.  SMG may hold your information in either hard copy or electronic form on our servers and secured third party servers. Personal information is destroyed or de-identified when no longer needed.

SMG accepts no responsibility or liability for acts or omissions of third parties in relation your personal information.

As our websites and Services are linked to the internet, and the internet is inherently insecure, SMG cannot provide any assurance regarding the security of transmission of information you communicate to us online.  SMG also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.


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

Contacting us

If you have any questions about this Privacy Policy, please contact our Privacy Officer using the details set out below.

Privacy Officer, Shopper Media Group
Post:     Level 10, 75 Miller Street, North Sydney NSW 2060

Changes to our Privacy Policy

SMG may modify its Privacy Policy from time to time and if it does so, it will post any updated Privacy Policy on our website.  We encourage you to check the SMG website ( periodically to ensure that you are aware of our current Privacy Policy.

This Privacy Policy was last updated on 30 January 2019.