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Privacy Policy
Introduction
At Downee Pty Ltd ACN 623 960 001 (“we”, “us”, “our”, or “Downee”), your privacy is important to us. We are committed to protecting your privacy when collecting, handling and managing your personal information, and we seek to comply with our obligations in accordance the Privacy Act 1988 (Cth) (“Privacy Act”) including the Australian Privacy Principles (“APPs”).
The purpose of this Privacy Policy is to tell you:
- what kind of personal information we may gather about you;
- how we may use that personal information;
- whether we disclose your personal information to any third parties;
- how you may inquire, access and/or seek correction of your personal information and our access and correction handling procedure; and
- how you may alert us about an alleged breach of the APPs and our complaint handling procedure.
In this Privacy Policy, ‘personal information’ has the meaning set out in the Privacy Act. In general terms, personal information is information (whether fact, opinion or evaluative material) about an individual who is identifiable from, or who can be reasonably identified from, the information.
Some types of personal information are designated as ‘sensitive information’ under the Privacy Act, and these are subject to additional protection. For example, such as racial or ethnicity information, political opinions or associations, criminal records or health information.
Collection of personal information
The types of information that we collect from you will depend on the circumstances of collection and on the service that we are providing to you. This can include:
- If you request products or services from us, we may collect personal information such as your name and contact details (ie billing and/or postal address, phone number(s) or email address), payment details such as credit card details, and order details.
- If you sign up to use a particular service such as our newsletter(s) and e-newsletters, mail outs (about product updates and developments, special events or promotions), loyalty or rewards program(s) or enter into a competition conducted by us, we may collect personal information such as your name and contact details, your date of birth and your interests and any other information required to provide that service to you.
- If you participate in any surveys that we, or a third party service provider acting on our behalf, may conduct from time to time on our website, we may collect personal information relating to your survey responses.
- If you make an inquiry, provide feedback or make a complaint to us, we may collect your name and contact details.
- If you apply for a role as an employee or contractor with Downee, we may collect personal information contained in your application or résumé, and information recorded during any interview, or obtained through any pre-employment checks, and if you are successful, we may collect government-issued identifiers such as tax file numbers from you.
- If we engage you as a supplier or distributor for Downee, we may collect your name and contact details, your financial details, and government-issued identifiers such as your ABN.
You acknowledge that the personal information we collect from you is your own information or information which you have been authorized to provide us.
How much of your personal information that you choose to disclose to us is completely up to you. However, if you do not provide certain personal information to us, this may result in our being unable to provide you with the relevant product or service. We will make you aware of the purpose for which we collect the personal information and, where possible, the consequences of not providing it at the time of collection.
Sensitive information
We generally do not collect sensitive information from you. However, subject to obtaining your prior consent, we may collect sensitive information from you in the course of considering an application for employment.
Technical information
We may also collect information about visitors to our website. For example, we may collect:
- statistical information about the number of visitors to the websites and the date, time and duration of visits;
- the name of the domain/URL from which you access our websites; and
- the internet protocol address.
Unsolicited information
However, we do not collect personal information about a person unless they voluntarily provide that personal information to us. If we receive any unsolicited personal information, we will destroy or de-identify the personal information as soon as practicable if it is lawful or reasonable to do so.
Method of collection
We collect your personal information when you deal with us directly, including via our website(s) or via forms or correspondence (ie by mail or email), over the phone or in person, and when you sign up to receive newsletters, enter surveys or competitions, or when you apply to work with Downee or are engaged by Downee as a contractor.
We may also collect personal information through our related bodies corporate and our third-party service providers (such as data relating to survey responses) so that we may provide a better or more relevant product to you.
We use cookies, which are data files that are placed on your device and often include an anonymous unique identifier. We also use cookies and similar technologies to collect technical information. By using our website, you are consenting to the use of these technologies in accordance with this Privacy Policy.
Use of information
Use of personal information
We will use the personal information you have chosen to provide us for the purpose for which you provided it to us.
Generally, we will use your personal information for the following purposes:
- to provide the products and/or services you have requested from us;
- to process sales transactions (whether by phone, in store or online);
- to deliver the products or services to you;
- to register you for a service requested by you, such as our newsletter(s) and enewsletters, mail outs, rewards program(s) or competitions and administering such services;
- to manage warranty claims;
- to respond to any inquiries, feedback or complaints made by you;
- direct marketing of products and services which we believe may interest you, including product updates and developments, special events or promotions;
- assisting us to improve our products and services and making them more relevant to you;
- assisting us to improve our website(s); and
- otherwise managing our internal business operations and processes.
We may also use or disclose your personal information for a related secondary purpose which you would reasonably expect, such as for our administrative, marketing, planning, product or service development, quality control, survey and research purposes and for other purposes to which you have consented or otherwise permitted or required by law.
Use of technical information
We gather and use anonymous information to:
- monitor the use of our website;
- help us make improvements to the website; and
- save your selections on the website and offer relevant information and services to you.
Direct marketing
We will only use your personal information for the purpose of direct marketing activities, for Downee and our related bodies corporate, where we have obtained your consent to do so, or in circumstances where we have collected the information directly from you and you would reasonably expect that your personal information would be used or disclosed for this purpose.
We will provide you with the opportunity to “opt out” of receiving direct marketing materials at the time of collection and/or at any time afterwards by either unsubscribing from the email service or contacting our Privacy Officer via the contact details provided below.
Sharing your personal information
There will be occasions where it will be necessary for us to disclose your personal information to third parties.
We may disclose your personal information to the following types of third parties:
- contractors and third party service providers on a confidential basis that we use in the ordinary course of our business to assist with the delivery of our products or services. This includes organisations such as marketing agencies, data processing companies, delivery companies, data storage companies (which may use cloud computing storage systems which have the potential to make your personal information accessible by overseas entities) or finance agencies or debt collection agencies;
- our professional advisers (such as lawyers, accountants or auditors) and insurers;
- our employees and contractors who assist us in performing our functions and activities;
- other members of our corporate group for marketing purposes (subject to obtaining your prior consent);
- any potential third party acquirer of our business or assets, and advisors to that third party;
- third parties to whom you have authorised us to disclose your personal information (e.g. referees if you are applying for a job with us);
- government authorities or other third parties as required by law; or
- any other purpose that you have consented to.
If we disclose your personal information to third parties, Downee will use reasonable commercial efforts to ensure that such third parties only use your personal information to the extent reasonably necessary to allow the third party to comply with their obligations to us in a manner consistent with applicable laws. For example, where commercially practical, we will include suitable privacy and confidentiality clauses in our agreement with a third party service provider to which we disclose your personal information.
Protection of personal information
Transfer of information outside Australia
We may transfer your personal information to our related entities and third party service providers based in New Zealand. We may also transfer your personal information to service providers who will hold your information on a cloud computing system which may hold your data on servers located outside of Australia. However, where your personal information is disclosed to an overseas recipient or a cloud computing system, we will take appropriate measures to ensure that your personal information is handled in accordance with the APPs, the Privacy Act and our instructions in accordance with this Privacy Policy.
No sale of personal information
Under no circumstances will we sell or receive payment for licensing or disclosing your personal information.
Security
We operate secure data networks that are designed to protect your privacy and the security of personal information. We have implemented generally acceptable standards of technology and operational security to ensure personal information (in both physical and electronic form) is protected against loss, misuse, interference and unauthorized access.
Only authorized personnel and contractors are provided access to personal information and have agreed to ensure the confidentiality of this personal information. Reasonable steps are taken to destroy or permanently de-identify any personal information that is no longer required.
We review and update our security measures in light of current technologies. You should however be aware that the internet is not a secure environment and personal information sent via the internet (including email) cannot be guaranteed to be totally secure.
Accordingly, you transmit your personal information to us online at your own risk.
Please notify us immediately if you become aware of any breach of security.
Access and Correction
Access
If you are a subscriber to one of our online services or products or loyalty programs, you may access your personal information by accessing your subscriber/account details via the relevant facility on our websites. Otherwise, you may at any time, request access to personal information that we hold about you by making a request to our Privacy Officer at the address or email address below.
Correction
We will try to ensure that all information we collect, use or disclose about you is accurate, complete, up-to-date and relevant to the service being provided. If you are a subscriber to one of our online services or products, you may change your personal information by accessing your subscriber/account details via the relevant facility on our website(s).
Otherwise, if you discover or suspect that there is an error or information is missing, please forward your request for correction to our Privacy Officer in writing at the address or email address below.
Response
We will endeavour to process any requests for access and/or correct to personal information within a reasonable period of time.
Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested, or providing you with a summary of the information held. If we need to deny your request for access, we will let you know why and inform you how you may lodge a complaint regarding this decision. Generally, this will only be in cases where providing access would be unlawful or is subject to a potential legal claim or proceeding. We may charge a nominal fee for supplying personal information.
If your correction request is refused, our Privacy Officer will provide you within a reasonable period of time the reasons for such refusal and inform you of the complaint process (see below).
Complaints about privacy and our complaint handling procedure
If you have any complaints relating to our management of your personal information or if you believe there has been a privacy breach by us, please forward your complaint in writing to our Privacy Officer at the address or email address below.
Our Privacy Officer will consider the complaint and advise you of their decision in writing within a reasonable time from receipt of the complaint. If our Privacy Officer decides that there has been a breach of the APPs, we will endeavour to ensure that the breach is rectified within 30 days from the date of the decision and will update you in writing. If the breach has not been rectified within 30 days, then our Privacy Officer will inform our Managing Director in order to resolve the matter.
If you are still not satisfied after lodging a complaint with us and giving us a reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner.
For information about privacy generally, you may visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.
Exceptions
Where applicable, we will rely on the employee records exemption in the Privacy Act and any other applicable exemptions in the Privacy Act or other legislation.
Contact Privacy Officer
Please contact our Privacy Officer on the contact details below if you would like to:
- inquire about or request access and/or update your personal information;
- report an alleged breach of your privacy rights or make a complaint; or
- talk to our Privacy Officer about our Privacy Policy.
Our Privacy Officer’s contact details are:
Post: Privacy Officer, Downee Pty Ltd, 70-72 William Angliss Drive, Laverton North 3026
E-mail: privacyofficer@downee.com.au
Changes to this Privacy Policy
We may modify this Privacy Policy at any time, so please review it frequently. Any updates to this Privacy Policy will be posted on our website. Changes will take effect immediately upon their posting on our website. Your continued dealings with us, for example use of our website, will signify your agreement to this Privacy Policy as amended.
This Privacy Policy was last updated on 24 June 2024.