In collecting, using, storing and disclosing and otherwise managing your personal information, we will comply with the ‘Privacy Act’, which:
- if you are located in Australia, means the Privacy Act 1988 (Cth) ; or
- if you are located in New Zealand, means the Privacy Act 1993 (NZ).
- mailing or street address;
- email address;
- telephone number and other contact details;
- age or date of birth or photographic identification, for example where required to comply with age restrictions;
- payment information, including bank account details, credit card details, credit histories;
- employment and educational information, including your job title, previous experience, academic and professional qualifications and third party references;
- associated company name(s) and details;
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
- information you provide to us, including through surveys, questionnaires, meetings, phone calls, interviews and during other communications with you; or
- any other personal information that may be required in order to facilitate your dealings with us.
Personal information includes information or an opinion about an individual that is identified or reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details.
What personal information do we collect?
The kinds of personal information collected and held by us will vary depending on your particular dealings with us.However, generally speaking, the types of personal information we may collect from you include:
You do not have to provide us with any personal information, however, if you do not provide personal information that we request, we may not be able to complete a transaction you have entered into, finalise payment of a product or service you have ordered, make delivery of a product you have ordered, grant credit terms, validate your entry in a promotion, or otherwise provide you with the products, services or benefits you have requested.
We will not normally collect sensitive information about you from you or any third party. Sensitive information includes information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, health or medical conditions, genetic or biometric information, sexual orientation, or criminal convictions and offences. We will only use or collect this information if necessary to comply with laws and regulations or where you provide this information voluntarily or otherwise consent for us to do so.
We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:
- deal with us in relation to us providing you with products, services or benefits or have other dealings with us;
- register on our website or app;
- in person (such as in store);
- request information, products or services from us or otherwise provide us with your information;
- communicate with us or submit information through correspondence, chats, email, social applications, services or websites;
- interact with our websites, services, content and advertising;
- enter into a promotion conducted by us or a third party;
- when you complete a survey; or
- invest in our business.
- from our related bodies corporate, including Founders First Limited (ACN 622 810 897);
- from suppliers who have appointed us as sales agent to sell goods on their behalf to you as a customer (each a Brand Supplier);
- from our business partners who partner with us for promotional activities; and
- from third parties who provide services to us.
There may be occasions when we collect your personal information from someone other than you, for example:
In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract.
Why do we collect, use and disclose personal information?
Some examples of the purposes for which we may collect, hold, use and disclose your personal information include:
- to enable us to supply you with information you request from us;
- to establish and maintain your relationship with us;
- to provide the products or services you have requested from us or a Brand Supplier and keep a record of them;
- to assist us to make our services and products more valuable or useful to you;
- to enable you to access and use our website and services;
- negotiating, concluding and performing contracts, managing business relationships;
- administering real estate leases and licences;
- to provide credit to you, which may include disclosures to credit reporting agencies or bodies or other credit providers;
- to operate, protect, improve and optimise our website and services, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
- to register you for events or promotions;
- to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
- to comply with our legal and regulatory obligations, security obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;
- to consider your employment application; and
- to consider your proposed investment in our business.
We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
Do we use your personal information for direct marketing?
We and/or our carefully selected business partners may send you direct marketing communications and information about our services and products. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act.
Direct marketing may be sent to you by:
- us or our related bodies corporate, including Founders First Limited (ACN 622 810 897); and
- third parties who provide services to us.
- our products and services;
- the products and services of other parties;
- promotions run by us or other parties including our Brand Suppliers; or
- keeping you informed of new developments we believe may be of interest to you.
The direct marketing may relate to:
You may opt-out of receiving this direct marketing from us or third parties by contacting us using the details set out below or through the unsubscribe function that will be made available to you with each direct marketing communication.
To whom do we disclose your personal information?
- our employees and related bodies corporate, including Founders First Limited (ACN 622 810 897);
- third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
- to Brand Suppliers;
- professional advisers (including legal and accounting firms, auditors, consultants, insurers and other professional advisers), dealers and agents;
- payment systems operators (eg merchants receiving card payments);
- our existing or potential agents, business partners or partners;
- our sponsors or promoters of any competition that we conduct via our services;
- people or entities who acquire (or are considering acquiring) our assets or businesses (or any part of them) or an interest in us or our related bodies corporate;
- specific third parties authorised by you to receive information held by us; and/or
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Disclosure of personal information outside Australia
We are likely to disclose some of your personal information, for the purposes described above, to organisations (including our third party suppliers and cloud providers) located outside of Australia, including in the United States of America.
Using our website and cookies
We may collect personal information about you when you use and access our website.
While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.
We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information.
In addition, we take reasonable steps to destroy or permanently de-identify personal information when we no longer need it.
However, we cannot guarantee the security of your personal information and do not accept responsibility for the security of information you send to or receive from us over the internet, or for any unauthorised access or use of that information.
Accessing or correcting your personal information
We take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up to date.
You have a right to seek access to and correction of your personal information that is collected and held by us.You can request access to and correction of the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information and charge a fee for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information.
Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
Effective: 4 November 2020