October 2021 | Version 1.0
This policy applies to you if you are:
- a visitor to our website;
- a customer who has ordered or requested the goods or services that we provide; or
- a candidate applying submitting a query or applying for an internship or vacancy via our website.
3 What is personal information?
3.1 Scope of personal information.
Personal information includes:
- certain information that we collect automatically when you visit our website;
- certain information collected on registration (see below);
- certain information collected on submission; and
- optional information that you provide to us voluntarily (see below);
- information that has been made anonymous so that it does not identify a specific person;
- permanently de-identified information that does not relate or cannot be traced back to you specifically;
- non-personal statistical information collected and compiled by us.
3.2 Common examples.
Common examples of the types of personal information which we may collect and process include your:
- identifying information – such as your name, date of birth, or identification number of any kind;
- contact information – such as your phone number or email address;
- address information – such as your physical or postal address; or
- demographic information – such as your gender or marital status.
3.3 Sensitive personal information
. Depending on the goods or services that you require, we may also collect sensitive personal information including your:
- financial information – such as your bank account details;
- sensitive demographic information – such as your race or ethnicity;
- medical information – such as information about your physical or mental health;
- sexual information – such as information about your sex life or sexual orientation;
- criminal information – such as information about your commission or alleged commission of any offence or about any related legal proceedings;
- employment information – including your membership of a trade union; and
- beliefs – including your political or religious beliefs.
4.1 Acceptance required
. You must accept all the terms of this policy when you order our goods or request our services. If you do not agree with anything in this policy, then you may not order our goods or request our services.
4.2 Legal capacity.
You may not access our website or order our goods or request our services if you are younger than 18 years old or do not have legal capacity to conclude legally binding contracts.
4.3 Deemed acceptance.
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.
5 Your obligations
You may only send us your own personal information or the information of another data subject where you have their permission to do so.
6 How do we collect personal information?
6.1 On registration.
When you submit an enquiry or if you register on our website, you will no longer be anonymous to us.
6.2 On order or request.
When you order our goods or request our services from us, you will be asked to provide us with additional information on a voluntary basis (goods or services information).
You will provide us with personal information when you attend an event that we host.
6.4 From browser.
. For information on how we deal with cookies, please refer to our Cookies Policy.
6.6 Web beacons
. Our website may contain electronic image requests (called a single-pixel gif or web beacon request) that allow us to count page views and to access cookies. Any electronic image viewed as part of a web page (including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any of your personal information. We merely use them to compile anonymous information about our website.
6.7 Optional details
. You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional goods or
6.8 Recording calls.
We may monitor and record any telephone calls that you make to us, unless you specifically request us not to.
7 Purpose for processing
7.1 Purpose for processing.
We may use or process any goods or services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including:
- goods or services purposes – such as collecting orders or requests for and providing our goods or services;
- marketing purposes – such as pursuing lawful related marketing activities;
- business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
- legal purposes – such as handling claims, complying with regulations, or pursuing good governance.
7.2 Usage information.
We may use your usage information for the purposes described above and to:
- remember your information so that you will not have to re-enter it during your visit or the next time you access the website;
- monitor website usage metrics such as total number of visitors and pages accessed; and
- track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.
7.3 Consent to collection
. We will obtain your consent to collect personal information:
- in accordance with applicable law;
- when you provide us with any registration information or optional information.
8.1 Our obligations
. We may use your personal information to fulfil our obligations to you.
8.2 Messages and updates
. We may send administrative messages and email updates to you about the website. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages.
8.3 Targeted content.
While you are logged into the website, we may display targeted adverts and other relevant information based on your personal information. In a completely automated process, computers process the personal information and match it to adverts or related information. We never share personal information with any advertiser, unless you specifically provide us with your consent to do so. Advertisers receive a record of the total number of impressions and clicks for each advert. They do not receive any personal information. If you click on an advert, we may send a referring URL to the advertiser’s website identifying that a customer is visiting from the website. We do not send personal information to advertisers with the referring URL. Once you are on the advertiser’s website however, the advertiser is able to collect your personal information.
9 Reasons we share personal information
. We may share your personal information with:
- other divisions or companies within the group of companies to which we belong so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications (they will only use this information to send you marketing communications if you have requested their goods or services);
- our goods or services providers under contract who help provide certain goods or services or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services (our contracts dictate that these goods or services providers only use your information in connection with the goods or services they supply or services they perform for us and not for their own benefit);
- credit bureaus to report account information, as permitted by law;
- banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria); and
- other third parties who provide us with relevant services where appropriate.
We may disclose your personal information as required by law or governmental audit.
9.3 Law enforcement
. We may disclose personal information if required:
- by a subpoena or court order;
- to comply with any law;
- to protect the safety of any individual or the general public; and
- to prevent violation of our customer relationship terms.
9.4 No selling
9.5 Marketing purposes.
We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.
We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.
9.7 Change of ownership.
If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request us to delete your personal information.
We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. Our hosting company will host our website in a secure server environment that uses a firewall and other advanced security measures to prevent interference or access from outside intruders. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate.
11 Accurate and up to date.
We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time we may request you to update your personal information on the website. You are able to review or update any personal information that we hold on you by accessing your account online, emailing us, or phoning us. Please note that in order to better protect you and safeguard your personal information, we take steps to verify your identity before granting you access to your account or making any corrections to your personal information.
12.1 Retention period.
We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:
- retention of the record is required or authorised by law; or
- you have consented to the retention of the record.
During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information unless provided otherwise in the policy.
12.3 Records form.
We may retain your personal information in physical or electronic records at our discretion.
13 Transfer to another country
We may transmit or transfer personal information outside of the country in which it was collected to a foreign country and process it in that country. Personal information may be stored on servers located outside the country in which it was collected in a foreign country whose laws protecting personal information may not be as stringent as the laws in the country in which it was collected. You consent to us processing your personal information in a foreign country whose laws regarding processing of personal information may be less stringent.
14 Your rights
14.1 Request what information we hold on you.
You may request access to your personal information to receive a copy of the personal information that we hold on you.
14.2 Updating or removing
. You may choose to correct or update the personal information you have submitted to us, by clicking the relevant menu in any of the pages on our website or contacting us by phone or email.
14.3 Withdrawal of consent or objection to processing.
You may withdraw your consent where we are relying on consent as a lawful justification to process. You may also object to our processing where we are relying on another lawful justification for processing. Please note that if you do so, we might not be able to provide services to you. We may also need to request additional information from you to verify your identity for you to access these rights. This is to ensure that your personal information is not disclosed to an unauthorized person.
We may change the terms of this policy at any time by updating this web page. We will notify you of any changes by placing a notice in a prominent place on the website or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop using the website and our goods or services. If you continue to use the website or our goods or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third party websites.
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