Approval Date 26 February 2019
Approved By J. Van Der Sommen
Version 1.2: 17 November 2020
1.1 Sample Room (Vic) Pty Ltd (ABN 99 159 300 464) trading as the Fashion Label Launchpad, Sample Room Mentoring Program and Expert Grading (‘us, we, or the Company‘) respect the privacy of visitors to our websites (‘Sites‘), our customers and other individuals who interact with us.
1.5 The Privacy Act 1988 (Cth) (‘Privacy Act’) includes thirteen (13) Australian Privacy Principles (‘APPs‘). The APPs regulate the way many companies collect, use, hold and disclose personal information.
1.6 We have decided to adopt an approach that is consistent with the Privacy Act, the APP’s and the APP guidelines.
2. HOW AND WHY WE COLLECT PERSONAL INFORMATION
2.1 The Company collects personal information in a number of ways. The most common ways we collect personal information include:
2.1.1. From application forms (online or hard copy or completed via telephone): when individuals apply to become members of the Site run by us, or subscribe to marketing or communications lists, for the purpose of providing news, information, offers and other services in accordance with terms and conditions of the Site or list.
2.1.3. From order forms (online or hard copy or via telephone): when goods and services are ordered by customers: for the purpose of fulfilling the order and delivering the goods, and to maintain our relationship with the individual concerned.
2.1.4. From telephone, email, written and in-person enquires: for the purposes of responding to enquiries.
2.1.5. Business cards: when you enter into transactions with us or otherwise interact with us in a business context including from your business card.
2.1.6. From online or hard copy surveys: for the purpose of reviewing and analysing the results and following up on results.
2.1.7. Any messages or comments submitted to us via the Site: for the purpose of responding to your message or comment.
2.1.8. From public registers including social networks such as LinkedIn: if you have made this information publicly available, for the purpose of obtaining your contact details.
2.1.9. From Sites through automatic processes such as cookies: Cookies are used to better understand users and improve the layout and functionality of our Sites by collecting information such as date, time and duration of visits and which pages are most commonly accessed. This tracking is conducted in such a way as to ensure the anonymity of visitors to Sites. While cookies may identify the computer or device, it should not identify the individual. With most internet browsers, users can erase cookies from their computer’s hard drive or device’s memory, block all cookies or receive a warning before a cookie is stored. However, some parts of this Site may not function fully for users to that disallow cookies.
2.2. Our Sites may collect other information that may or may not be personal information. For each visitor to the Site, our server automatically recognises and stores the individual’s “IP address” (eg. the domain name or Internet protocol address), the type of Internet browser being used, the address of the site that “referred” the individual to our website and clickstream data. If this information cannot be used or combined with other data to identify you, it will not be personal information.
2.3. Other than the specific purposes for which we may collect your personal information as set out in item 2.1 above, we generally collect personal information for the purpose of providing you with any goods or services that you request, to enable you to use the Sites, to update our Sites, to improve the services or goods that we provide, to develop our business, and to comply with Our legal obligations.
3. WHAT PERSONAL INFORMATION IS COLLECTED?
3.1. We aim to only collect personal information that is necessary to fulfil the purpose for which you have disclosed it, when you consent to the type/s of personal information being collected by Us, or as required by law.
3.2. You will typically be asked to provide contact information (such as your name, telephone number, postal address and email address). You may also be asked for demographic information (such as your age and gender) and/or profile data.
3.3. In some instances, we may need to ask you for additional information necessary to provide you with the goods or services you have requested. When we ask you for further information in addition to that you provide to us initially, we will tell you why we are collecting that information.
3.4. We aim to only collect information that is absolutely necessary to provide you with any service you have requested. If you would prefer to remain anonymous, we are happy to still deal with you provided that we don’t need to know who you are. Instances where this may be possible include where you are providing us with anonymous feedback that does not require a response.
3.5. We do not collect sensitive personal information.
4. ELECTRONIC COMMUNICATIONS
4.1. In some instances, where you have provided consent, we may use your personal information for the purpose of sending you marketing communications including by electronic means such as email, SMS, MMS. You may opt-out of receiving such messages at any time, by following the ‘unsubscribe’ instructions which we will include with the applicable marketing communication. We will give you the opportunity to opt-out within the message that we send to you. You may also opt-out by contacting us (using the details provided below).
4.2. In some instances, where you have provided consent, we may also send you electronic updates including via email, SMS, MMS relating to products or services you have ordered, used or enquired about, to keep you informed of changes to the Site, and the products or services offered via the Site. You may also opt-out of receiving such messages at any time, again by following the ‘unsubscribe’ instructions which we will include with the applicable marketing communication. We will give you the opportunity to opt-out within the message that we send to you. You may also opt-out by contacting us (using the details provided below).
5. STORAGE OF PERSONAL INFORMATION
5.1. Any information we collect about you will be kept securely by us or our service providers unless an event beyond our control disrupts the measures we have in place. We and our service providers use a range of measures to ensure the security of the data we keep and to prevent unauthorised access, destruction, use, modification or disclosure. We and our service providers have procedures in place with regards to staff access to personal information and ensure that only those staff who need to know have access to your information.
5.2. We will only store personal information for so long as it is required either to fulfil the purpose for which it was collected or to fulfil our obligations at law. We will conduct regular reviews of the personal information we hold and destroy or de-identify information no longer required.
6. DISCLOSURE OF PERSONAL INFORMATION
6.1. Generally, personal information will not be disclosed to individuals or organisations outside of the Company without your prior consent. However, in the circumstances described below, personal information may be disclosed to:
6.1.1. Service providers: There may be other companies that we rely on to provide goods or services to you, or third-party suppliers and service providers (including providers for the operation of our Sites and/or our business, as well as payment systems operators such as merchants receiving card payments). We may provide your personal information to these companies to facilitate our provision of goods or services to you (including via the Site).
6.1.2. Product, Service and Business Improvement: We may 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.
6.1.3. Professional advisers or agents: where such advisers will maintain confidentiality any personal information required, and any such agents are acting on our behalf.
6.1.4. Our sponsors or promoters of any competition that we conduct: where you have consented to your personal information being used for the purposes described in such competition’s terms and conditions;
6.1.5. Law enforcement or government bodies: There are exceptions under the Privacy Act with regards to the provision of personal information to law enforcement or government bodies. When a legitimate request is sent to us by a law enforcement or government body we will comply with that request and may provide personal information about you without your consent.
6.1.6. Companies related to us or who take control of part or all of our business: In providing personal information to us you will need to be aware of the possibility that, in future, another company may take control of part or all of our business. In that case, your personal information will be provided to that company.
6.2. If we disclose personal information to a third party under outsourcing or contracting arrangements (a service provider), we will take steps to ensure that they have:
6.2.1. Signed a binding agreement;
6.2.2. Handle the personal information in a manner consistent with the APPs (regardless of whether they are a small business, or would otherwise be exempt from the Privacy Act);
6.2.3. Only use the personal information in order to provide specific services or to perform the specific functions required; and
6.2.4. Store the personal information securely, and only for as long as is necessary to provide the required services to perform the required functions.
7. ACCESS TO PERSONAL INFORMATION
7.1. Under the Privacy Act, you have the right to seek access and to update or correct the personal information that we hold about you. If you wish to exercise your right under the Privacy Act to seek access to the personal information held for you, you should make the request in writing (to the address specified below).
7.2. Ordinarily we will not charge for providing access/copies of personal information we hold about you, and will generally respond to access requests of this type within 30 days. If we anticipate there being a fee (for the time we spend locating and compiling the information you have asked for) we will provide you with an estimate before proceeding. If a fee is payable it will be based on an hourly rate plus the cost of photocopying or other out of pocket expenses. For legal and administrative reasons, we may also store records containing personal information in archives. Access to these historical records may result in a charge being incurred (an estimate will be provided to you prior). Due to the nature of archive, requests for access to historical records may take longer to process than with current records.
7.3. You may correct the personal information we hold about you at any time, by you requesting this in writing (to the address specified below). We do not charge a fee to correct personal information held.
7.4. On review of your request, if we agree that the personal information held is not accurate, complete and up to date, it will be corrected by the appropriate person. If we do not agree, you will be provided with the reason(s) for the views and the opportunity to make a statement of your view and have it included with the information held.
8.1. You have a right to complain to us if you are concerned about your privacy, how we have dealt with your personal information or in relation to the Privacy Act.
8.2. If you are concerned about how we have dealt with your personal information you should first contact us (using the details set out below). We will endeavour to send you a written response within 10 business days.
8.3. If you are not satisfied with the way we have managed or attempted to resolve your complaint you may complain to the Office of the Australian Information Commissioner by calling them on 1300 363 992, via their website at www.oaic.gov.au or by mail to the Office of the Australian Information Commissioner, GPO Box 5218 Sydney NSW 2001.
9. LINKS TO THIRD-PARTY WEBSITES
10. ACCEPTANCE OF THESE TERMS
11. CONTACT DETAILS
Company Name: Sample Room (Vic) Pty Ltd trading as Fashion Label Launchpad, Sample Room Mentoring Program and Expert Grading
ABN: 99 159 300 464
Mailing address: 78 Islington Street, Collingwood VIC 3066 Australia