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This policy contains information about:
- the kinds of personal information we collect and hold;
- how we collect and hold it;
- the purpose for which we collect, hold, use and disclose it;
- your right to access and seek correction of it; and
- how you may complain about privacy matters.
Can you deal with us anonymously?
Generally, you can deal with us anonymously (i.e. without identifying yourself). In certain circumstances however, we will ask you to provide personal information where it would be impracticable to deal with you anonymously. These circumstances include where you order goods online, request a service, enter a competition, when you pick goods from our warehouse that you ordered by phone or online or in circumstances where we are required by Australian law to collect such personal information.
Why do we collect, hold, use and disclose personal information?
We collect, hold, use and disclose personal information for a number of purposes connected with our business operations, which include:
- providing you with products and/or services requested;
- dealing with requests, enquiries, complaints, consumer guarantee or warranty claims, and other customer care related activities;
- marketing our products and services and providing advice on our products;
- developing and improving our products and services;
- in connection with our loyalty or reward programmes and competitions;
- the operation and administration of accounts or subscriptions that you have with us;
- payment processing;
- carrying out certain checks (for example, for our fraud or theft prevention processes, if you wish to open an account with us, obtain credit from us or pick-up goods in-store that have been ordered online);
- interacting with companies or organisations with whom we have a business relationship (where you work for, or otherwise represent, such an organisation);
- reconciling payments from suppliers in relation to goods or services provided to you by those suppliers; and
- carrying out any activity in connection with a legal, governmental or regulatory requirement that we have to comply with, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution.
We may also use and disclose your personal information for other purposes related to those described above to facilitate our business operations.
We retain all documents, both hard copy and electronic, in accordance with our normal document retention practices for accounting, legal and business purposes. If personal information is included in such a document it will be retained, even though its retention may not the primary purpose for keeping the record.
Generally, you have no obligation to provide any personal information requested
by us. However, if you choose not to do so there may be circumstances when we
cannot provide you with the goods or services that you want.
What personal information do we collect?
The kinds of personal information we collect or which we may hold about you may include:
- your name;
- your address;
- your date of birth;
- your telephone number(s);
- your e-mail address;
- payment information;
- transaction information;
- your user name and password on sites managed by us;
- information on how you use our products and services;
- your Internet Protocol ("IP") address, server address, domain name and information on your browsing activity when visiting one of our websites;
- your user name for social networking sites that you use to refer to, or in conjunction with, our goods and services; and
- personal preferences regarding products and services.
How do we collect and hold your personal information?
We collect personal information in a number of ways including:
- when you order goods or services from us (either online, in-store or over the telephone);
- when you set up an account with us;
- when you purchase certain products or extended warranties from us;
- when you buy goods on lay-by or on a payment plan;
- when you pay for goods by cheque;
- when you subscribe to our catalogues or mailing lists;
- when you enter competitions or promotions that we run;
- when you provide us your details for customer care purposes;
- when you browse one of our websites
- when you submit an enquiry using one of our websites;
- when you complete surveys or provide online feedback or product reviews; and
- when you publicly comment about us on social media sites (for example so that we can answer questions about our products).
Generally, we will collect your personal information directly from you. However, we also hold information, collected incidentally, concerning individuals who work for companies or organisations that have a business relationship with us. We hold personal information in a number of ways, including:
- as part of customer records and other electronic documents on which personal information is contained which are stored on our information technology systems and servers operated by third parties who provide services to us in connection with our business; and
- by securely storing hard copy documents on which personal information
is contained, at our various premises and using third party document management
and archiving services.
When you create an account with us your details will be added to our marketing database to receive information relating to our products and services. You may also choose to receive such information by subscribing to our marketing database via one of our websites.
To opt-out of receiving our marketing materials, you will need to unsubscribe
from our marketing database. To do this, simply select the "unsubscribe"
option in one of the emails that you receive from us. Please note that if you
have an account with us, we may still need to send you essential information
about your account.
Sharing your personal information
We may disclose or receive personal information or documents about you to/from:
- organisations that provide services to us in connection with our business, including customer support, payment processing, administration, archival, data storage, hosting, research, mail and delivery, installation, distribution, logistics, marketing, auditing, share registry, consulting, financial and legal advisory, banking, debt collection, security or technical services and the operation of our websites.;
- if you return goods to us to be repaired, our repairs system administrator, the manufacturer of the goods and authorised repairers;
- law enforcement agencies to assist in the prevention, investigation and prosecution of criminal activities;
- parties involved in any third party acquisition or potential acquisition of an interest in us or our assets;
- our insurers and insurance brokers; and
- to other third parties where you have specifically consented to the disclosure of information to these third parties.
Disclosure of personal information to overseas recipients
It is our policy to require all of our overseas sharing of personal information to be done in a way which requires observance of strict privacy and security standards, both during transit and at the overseas destination.
We may allow your personal information to be shared or stored with trusted partners in countries other than your own location. We do this:
- where we store our data with a trusted service provider who is in the business of providing data storage and processing services. Examples are those who store and process our email and mobile application data. These services commonly involve diverse geographic locations which change from time to time for reasons which include data protection and processing efficiency. Where these services are used by us, it is not practical for us to notify you of which country your personal information may be located in; and
- when our business which collected your personal information is in a different country to your location;
How we deal with your personal information if you apply for a job with us
If you apply for a job with us, you may be required to provide us with certain personal information, including your name, employment and educational background, and other personal information which we may require you to provide, or which you choose to provide us, in relation to your job application.
We will hold, use and disclose that information solely for the purpose of considering your application. In particular, in considering your application, it may be necessary for us to disclose some of that information to third parties to verify the accuracy of that information. In such circumstances, we will disclose only such information as is necessary in the circumstances.
In considering your application, we may also collect personal information about you from third parties, including those you nominate as your referees in your application.
Security of your personal information
We will take reasonable steps to ensure that the personal information that we hold is stored in a secure environment protected from misuse, interference and loss and any unauthorised access, modification or disclosure.
How to access, correct and update your personal information
Upon your request, we will provide access to your personal information that we hold (except in certain circumstances set out in the Privacy Act 1988 (Cth)). We reserve the right to charge you a reasonable fee for providing access to your personal information if your request requires substantial effort on our part. We will, of course, require some proof of your identify before providing information to you.
You may also request us to correct the personal information that we hold about you. If you do so and we are satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take such steps as are reasonable in the circumstances to correct your personal information to ensure that, having regarding to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
To request access to the personal information that we hold about you, or to update or correct that personal information, please send a written request to The Privacy Officer, BrandNet Pty Ltd, either by email to email@example.com or by post to PO Box 166 FYSHWICK ACT 2609.
In addition if you are a subscriber to our marketing database you can also update your details via the "unsubscribe" option in one of the emails that you receive from us.
How to make a complaint
If you are concerned that the way we collect, hold, use or disclose your personal information may be in breach of the Australian Privacy Principles, please send written details of your complaint to The Privacy Officer, BrandNet Pty Ltd, either by email to firstname.lastname@example.org or by PO Box 166 FYSHWICK ACT 2609.
How we will handle complaints
After receiving a complaint, we will consider whether we need any further information from you to properly consider and investigate the complaint, and may request such information from you. We will then:
- conduct internal review with the business units involved in the collection, holding, use or disclosure of your personal information which is the subject of your complaint, and evaluate whether we believe that such collection, holding, use or disclosure of your personal information was in breach of the Australian Privacy Principles; and
- notify you of the results of our investigation of your complaint.
If the conclusion of our investigation is that our collection, holding, use or disclosure of your personal information was in breach of the Australian Privacy Principles, we will take steps to remedy the breach as soon as reasonably practicable.
We will endeavour to notify you of the results of our investigation of your complaint within 30 days of receiving your complaint. However, if your complaint involves complex matters or requires extensive investigation and consultation, it may not be possible to respond within this timeframe.
If you are not satisfied with our response to your complaint you are entitled under the Privacy Act 1988 (Cth) to make a complaint to the Office of the Australian Information Commissioner. Information about how to make a complaint is available from the Office of the Australian Information Commissioner's website (www.oaic.gov.au).
Additional information for users of our websites
If you visit our websites (www.brandnet.com.au; www.militaryshop.com.au; www.armyshop.com.au; www.salt.asn.au; www.airforceshop.com.au; www.contactgear.com.au; www.coderedgear.com.au; www.cgaustralia.com.au; www.sandsofgallipolli.com.au; www.australiagreatwar.com.au; www.capitalchemist.brandnet.com.au; www.soldieron.militaryshop.com.au; www.kokodachallenge.militaryshop.com.au and www.militaryimages.com.au) (the "Websites") to read, browse or download information, our system may record information such as the date and time of your visit to the Websites, the pages accessed and any information downloaded. This information is used (i) for statistical and reporting purposes; (ii) for website administration, security and maintenance purposes; and (iii) to direct you to material on our Websites that we believe will be of interest to you.
Like many websites, our Website may use "cookies" from time to time. Cookies are small text files that we transfer to your computer's hard drive through your web browser to enable our systems to recognise your browser and your log-in status. Cookies may also be used to record non-personal information such as the date, time or duration of your visit, or the pages accessed, for website administration, statistical and maintenance purposes. Any such information will be aggregated and not linked to particular individuals. The default settings of browsers such as Internet Explorer usually allow cookies, but users can easily erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of our Websites may not function fully for users that disallow cookies.
While we take great care to protect your personal information on our Websites
and use state-of-the-art data transmission encryption. Unfortunately no data
transmission over the Internet can be guaranteed to be 100% secure. Accordingly,
we cannot ensure or warrant the security of any information that you send to
us or receive from us online. This is particularly true for information you
send to us via email. We have no way of protecting that information until it
reaches us. Once we receive your transmission, we use our best efforts to ensure
its security in our possession.
The Websites may contain links/ plug-ins to other sites. We are not responsible for content of, or the privacy practices or policies of, those sites.
Please remember that when you use a link to go from our Website to another Web site, our Privacy and Security Policy is no longer in effect. Any browsing and interaction with other Web sites, including Web sites that have a link on our Web site, is subject to that Web site's own rules and policies. Please read those rules and policies before proceeding.
If you have any queries or concerns, further information can be obtained by contacting our Privacy Officer by Privacy Officer, BrandNet Pty Ltd, either by email to email@example.com or by calling 02 61232990. Alternatively, you can write to us at: The Privacy Officer BrandNet Pty Ltd PO Box 166 FYSHWICK ACT 2609.
BrandNet Pty Ltd ABN 84 119 908 557
Dated: 08 April 2014