1.0 Your privacy and the law
1.1 - RPG Toms Pty Ltd ACN 625 027 625 recognize the trust you are placing in us through your dealings with us. We do everything we can to maintain that trust. Our staff are employed on the basis that they will protect information about you. Your rights to privacy are also protected by the Australian Privacy Principles in force under the Privacy Act 1988 (Cth). These privacy laws place strict requirements on us to treat certain information collected as confidential, to store your information securely and to allow you easy access to check and correct your information.
2.0 - Definitions
APPs means the Australian Privacy Principles in the Privacy Act.
CRB means a credit reporting body.
Credit information has the same meaning as in section 6N of the Privacy Act, which, for ease of reference, could include information such as consumer credit liability information, repayment history information, types and amounts of credit you have sought, default information, and personal insolvency information. Please refer to the Privacy Act for a complete list of all types of credit information.
Credit eligibility information has the same meaning as in section 6 of the Privacy Act, which, for ease of reference, could include information such as credit reporting information about you that has been disclosed by a credit reporting body or information derived from such information and which has a bearing on your credit worthiness. Please refer to the Privacy Act for a complete list of all types of credit eligibility information.
Personal information has the same meaning as in section 6 of the Privacy Act, which, for ease of reference, means information or an opinion about an identified individual or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not,
and personal information includes sensitive information.
Privacy Act means the Privacy Act 1988 (Cth).
Sensitive information has the same meaning as in section 6 of the Privacy Act which, for ease of reference, means information or an opinion about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information, biometric information for automated verification or identification purposes and biometric templates.
We, our, or us means Retail Prodigy Group Pty Ltd ACN 149 570 801 and each of its related bodies corporate.
You or your means authorised distributors, retail customers, service providers, contractors, job applicants (or any individual personnel of those foregoing persons) and any other individuals whose personal information we may collect, disclose, use or otherwise handle.
3.0 - What types of personal information do we collect?
3.1 - We generally collect and hold: Your name, date of birth, postal and email address, user name, password, telephone, credit or debit card details, billing and account details, purchase history, information obtained from any form or application which we may ask you to complete (whether electronic or paper-based), and other information we consider necessary to provide our goods or services to you.
4.0 - How do we collect and hold your personal information?
4.1 - We generally obtain personal information about you by collecting it:
Directly from you. For example, via forms you complete for us, user accounts you create through our websites, orders you place with us and through your interactions with us and our staff, such as via our websites, over the phone, via email or in person, interactions you have with us and our staff, such as via our live chat on our websites, written and video reviews submitted to our websites.
From our service providers and contractors. For example, from our authorised distributors, third party service providers, marketing agencies, and other personnel who assist us or who provide goods or services to you on our behalf.
From other people involved in your business. For example, from officers, employees, contractors or agents of your company in connection with an order being placed with us or an application for credit.
From other people relevant to your relationship with us. For example, from:
- trade contacts or trade references you have provided to us, if we are considering trading with you or providing credit to you or an entity related to you.
- your current or past employer (with your prior consent), if you are applying for a job with us.
- credit reporting bodies, if we are considering providing credit to you or an entity related to you.
4.2 - We will not collect sensitive information about you without first obtaining your consent. Unless one of the limited exemptions under the Privacy Act applies, we will only collect your sensitive information if you consent to such collection and if such sensitive information is reasonably necessary for one or more of our functions or activities.
4.3 - We hold your personal information in various ways, including in paper and electronic form. We take reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification and disclosure including through implementation of password protected digital storage solutions as well as keeping paper forms in secure filing systems.
5.0 - For what purposes do we use personal information?
5.1 - Unless you consent otherwise or where we are otherwise permitted to do so by law, personal information will only be used for the purposes for which it was provided (primary purpose) or for a purpose (secondary purpose) related, or in the case of sensitive information directly related, to the primary purpose. Some examples of the purposes we ordinarily use personal information for are detailed below.
Generally, we will use your personal information:
- to provide you with requested goods or services (including contacting you and our delivery agents to make delivery or payment arrangements, issue reminders or arrange returns, contact you concerning the status of an order/purchase, answer questions, respond to your inquiries or requests. Also for gift registries or wish lists).
- for our internal management purposes, to manage our relationship with you, personalise and improve our services, our websites and stores and to manage the payment and recovery of amounts payable to us by you.
- to enable us to conduct our business generally, such as notifying our freight and shipping contractors or our insurers, undertaking quality assurance, internal teaching and data processing and handling.
- to tell you about our products or services that might better service your business or personal requirements or other opportunities in which you may be interested.
- to comply with any law.
- for other purposes which are reasonably necessary in connection with our normal functions and activities.
If you are applying for a job or contract with us (or via a third-party service provider), we may also use your personal information:
- to assess and determine your eligibility or suitability for a job or contract with us.
- to, with your permission, contact professional or other reference(s) you have provided in connection with a job application to discuss your experience/employment.
If we are considering providing credit to you or an entity related to you, we may also use your personal information:
- to obtain credit information related to you, and to undertake credit reference checks and otherwise assess your credit worthiness (or the credit worthiness of an entity related to you).
6.0 - Who will we disclose your personal information to?
6.1 - Generally, we may disclose your personal information:
- to any person you consent to receiving such information (e.g. when you place an order with us, you consent to us providing your name and delivery address to our delivery contractors to enable delivery)
- to our staff and management (e.g. for business decision, data processing, marketing and administrative purposes)
- to our service providers, advisors and contractors who assist us in operating our business (e.g. IT service providers) or who assist us in providing products or services to you (e.g. our freight and shipping contractors or insurers)
- to any person we are required or authorised by law to disclose your personal information
6.2 - If you are applying for a job or contract with us, we may also disclose your personal information:
- to any professional or personal reference(s) you provide in connection with your job or contract application
- to our insurers for our own professional insurance purposes
6.3 - If we are considering providing credit to you or an entity related to you, we may also disclose your personal information to the following CRBs:
- Veda Advantage Ltd – (www.veda.com.au);
- Dun & Bradstreet (Australia) Pty Ltd – (www.dnb.com.au);
- Experian – (www.experian.com.au).
6.4 - If you fail to make a payment to us, as and when due, or commit a serious credit infringement
- If you fail to make a payment to us, as and when due, or commit a serious credit infringement, we may disclose details of such events to CRBs. A CRB may use such information (and other personal data provided to them by us) in reports given to other credit providers to help assess your creditworthiness. You may have certain rights to request that CRBs do not use credit reporting information about you if you believe on reasonable grounds you have been or are likely to be a victim of fraud.
6.5 - We do not ordinarily disclose your personal information to overseas recipients.
7.0 - Dealing with us anonymously
7.1 - You have the option of not identifying yourself or using a pseudonym when dealing with us unless we are required by law or a court or tribunal to deal with individuals who have identified themselves or it is impractical for us to deal with you if you have not identified yourself. However, if you do so, you may not be able to access, or use, all or part of our goods and services.
8.0 - Cookies
9.0 - Direct marketing
9.1 - From time to time we may use your personal information to provide you with marketing materials in relation to offers, specials, products and services that we have available.
9.2 - We will not collect, use or disclose your sensitive information for the purpose of direct marketing without your written consent.
9.3 - You may opt out of receiving marketing communications from us at any time by following opt out instructions provided in such marketing communications.
10.0 - Accuracy of your personal information
10.1 - While we will endeavour to ensure that the personal information collected from you is up to date, accurate and complete, we will assume that any personal information provided by you is free from errors and omissions.
10.2 - You may request that we update or vary personal information that we hold about you using the contact details set out below. In some circumstances where we correct a record, we may still require the retention of the original record.
- 0 - Requesting access to your personal information
11.1 - You may obtain access to personal information which we hold about you by contacting us using the contact details set out below. When you request copies of your personal information held by us we will endeavour to provide you with such personal information as soon as reasonably practicable, provided however that there may be occasions when access to personal information we hold about you is denied. Such occasions would include where release of the information would have an unreasonable impact on the privacy of others. If we refuse to provide you with access to or correct your personal information, we will provide you with an explanation in writing.
We may require you to verify your identity and specify what information you require. We will give you reasons if we deny access.
11.2 - We ask that requests for access to personal information be made in writing. Photo identification may be required. A fee will not apply to making a request for access to your personal information. A fee may apply and be charged to cover our costs in collating, copying and providing certain information to you.
12.0 - Making a complaint about a breach of your privacy rights
12.1 - If you are of the view we have breached the APPs, the Privacy Act, or any related privacy code in dealing with your personal information, you may make a complaint by writing to us using the contact details set out below and we will endeavour to provide you with confirmation as to how we propose to deal with the complaint as soon as reasonably practicable.
12.2. - If you are not satisfied with our response to your complaint, you may make a complaint to the Office of the Australian Information Commissioner by visiting the following website and following the steps:
13.1 - We reserve the right to change this policy at any time. The updated policy will be available on our website.
14.0- Contact us
14.1 If you wish to request access to your personal information or make a complaint about possible breaches of privacy, please direct your enquiries to:
Retail Prodigy Group Pty Ltd
Level 1, 19 Carpenter Street
Brighton, Victoria 3186
Phone: 1300 866 728