Updated April 2019
We are committed to safeguarding the privacy of your personal data. We will only collect and use your personal data to:
This policy applies where we are acting as a data controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of your personal data. It covers:
Personal data is information about an individual that can be used to identify that individual. It does not include anonymized data where the personal identification has been removed.
If you are under the age of 13, you are not permitted to use or submit your data.
The groups of data that we collect are:
Usage Data – includes information about your use of our website/app and services, IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views, how your journey progresses, what you search for, what sales, products, and product categories you click on, your basket activity including added/removed products, vouchers and promo codes, login, logout, registration and forgot password attempts, website/app performance, customer service contacts and my account activities, including information about the timing, frequency and pattern of your service.
Technical Data – includes information about the devices you use to access our services, your internet IP address, username and password, browser type and version, operating system, geographical location, time zone settings and location, browser plug-in types and versions.
Account Data – includes your firstname, lastname, email, purchases/orders, shipments, product interests, preferences, feedback, survey responses, address preferences, payment preferences, voucher information, returns, refunds, language preference, country, invitation information and your cohort groups.
Identity Data – first name, last name, email, data of birth (optional), gender, billing address, shipping address and phone number.
Financial Data – information including your payment card details, payment attempt information, payment schedules, billing address, shipping address.
Marketing Data – information including your preferences for receiving marketing communication from us and our third parties and your communication preferences.
We collect, use and share aggregated data such as statistical or demographical data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. We will not be able to identify you from this data.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
In addition to the specific purposes for which we may process your personal data we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, to protect your vital interests or the vital interests of another natural person.
The purpose of processing your data:
To create your account and register you as a new customer – Identity and Usage Data. For Contract performance
To process and deliver your order including providing progress updates, processing payments, refunds, returns and collecting money owed and assist in fraud prevention and detection - Identity, Financial and Account Data for Contract performance and Legitimate interests
To manage our relationship with you including providing customer service, keeping you up to date about changes to the services we provide, terms and conditions or privacy policies and asking for feedback, reviews or participation in surveys – Identity, Account and Marketing Data for Contract performance and Legitimate interests
To allow you to enter a competition or receive a bonus from us - Identity, Usage and Marketing Data for Contract performance and Legitimate interests
To improve our business, services, websites/apps including experience, security, data analysis, support, reporting and storage of data including your preferences – Identity, Technical, Usage and Account Data for Legitimate interests and Legal Obligations
To deliver relevant website content, online advertisements and information for you and analyse the effectiveness of the content and advertising – Identity, Usage, Marketing and Technical Data for Legitimate interests
To use data to improve our websites/apps, products and services, marketing, customer relationships and experiences including market research, statistical and survey purposes – Account, Usage and Technical Data for Legitimate interests
To recommend sales, products and service discount and offered that may be of interest to you whist you browse our websites/app or via email, SMS, push notification or post - Identity, Usage and Marketing Data for Legitimate interests and Consent
To inform or remind you by email, SMS, push notification that a group of sales events have started/will start soon – Identity, Usage and Marketing Data for Legitimate interests and Consent
To inform or remind you by email, SMS, push notification of post of any uncomplete tasks such as abandoned baskets, incomplete checkouts, partial return requests or recently viewed products. Identity, Marketing and Usage Data for Legitimate interests
We may disclose and share your personal data with the parties below:
To any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) where necessary for the purposes, and on the legal bases, set out in this policy.
To our insurers and/or professional advisers where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
To our suppliers or subcontractors when necessary for the purposes included in ‘How we use your data’ such as:
To relevant third parties, where you have consented to receiving marketing communication from third parties, for the purpose of sending your such marketing communication.
To any third party to whom we may choose to sell, transfer, or merge parts of our business or our assets.
To our professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
We and our other group companies have offices and facilities in Australia, New Zealand, USA, England, Russia, Philippines, Singapore, Malaysia. The hosting facilities for our websites/apps are situated in Australia, USA, Germany and Singapore. We have suppliers in Australia, France, USA, UK and Singapore. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
Personal data that we process shall not be kept for longer than is necessary for that purpose or those purposes.
We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
You have the following rights in respect of your personal data:
(a) the right to access
You have the right to confirmation as to whether we process your personal data and, where we do, access to the personal data.
(b) the right to rectification
You have the right to have any inaccurate personal data about you rectified and to have any incomplete personal data about you completed. You can do this at any time by visiting the My Account section of our websites/apps.
(c) the right to erasure
In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
(d) the right to restrict processing
In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data.
(e) the right to object to processing
You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
(f) the right to data portability
To the extent that the legal basis for our processing of your personal data is consent and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
(g) the right to complain to a supervisory authority
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection.
(h) the right to withdraw consent
To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your personal data by using the Contact us link on the websites/apps.
We may send you marketing communications and promotional offers if you have created an account with us or purchased good from us and you have not opted out of receiving that marketing (you can opt out at any time).
We may use your Identity, Usage, Technical, Account and Financial data to send you relevant marketing material, primarily sale start notifications and other offers.
We may include with your order inserts advertising goods, services, or offers from third-party companies.
We will not provide your data to third parties for marketing purposes without your specific opt-in consent.
You always have full control of your marketing preferences. If you do not wish to continue receiving marking information from us at any time you can unsubscribe or ‘opt-out’ by using the unsubscribe link in the footer of all marketing emails. Alternatively, you can visit the ‘My Account’ section in the websites/apps to unsubscribe.
We will process all opt-out requests as soon as possible but please not that due to the nature of our IT systems it may take a few days for any opt-out request to be processed.
A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
Cookies that we use
Authentication - to identify you when you visit our website and as you navigate our website the cookies used for this purpose are:
Personalisation - to store information about your preferences and to personalise the website for you the cookies used for this purpose are:
Cookies used by our service providers
We allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
If you block cookies, you will not be able to use all the features on our website.
We use online advertising to keep you updated on what we’re up to and to show you our recent products and sale campaigns. We may target ads to you when you use other websites and apps based on your Usage, Identity, Technical and Account Data. This is common practice and we use a range of advertising technologies such as pixels, ad tages, cookies and mobile identifiers. We may also use specific services such as Facebook Custom Audience Service and Google’s Audiences.
This document was created using a template from SEQ Legal.