SCRUB CITY (“WE/US/OUR”) ARE COMMITTED TO PROTECTING AND RESPECTING YOUR PRIVACY
This policy (together with any privacy notice displayed on www.scrubcity.com.au (“our site”) or otherwise notified to you) sets out the basis on which we will process any personal data we collect from you or that you provide to us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.aoic.gov.au
INFORMATION WE MAY COLLECT FROM OR ABOUT YOU
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
We may collect and process the following data about you:
• Information that you provide by filling in forms on our site or other electronic means, by telephone or by visiting our stores or attending our events. This includes information provided at the time of registering to use our site, subscribing to our service or requesting further services or searching for a product. We may also ask you for information when you enter a competition or promotion sponsored by us, and when you report a problem with our site. The information you give us may, as well as other information, include your name, address, e-mail address, phone number, financial and credit card information.
• If you contact us, we may keep a record of that correspondence or communication.
• Details of transactions you carry out through our site, at our store or by other means, the fulfillment of your orders and any subsequent communications regarding your purchase.
• Details of your visits to our site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
• Closed circuit television recordings within our stores for safety and security purposes.
To understand how we use these types of data, please see “How We Use Data About You” below.
We do not routinely collect any “special categories” of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and bio-metric data), nor do we collect any information about criminal convictions and offenses. If we need to process any such data for a particular purpose we will explain this to you at the time and will gain your consent to such processing.
We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration and to analyze our customer base by aggregating such data into anonymized reports. We may report this aggregated information to our advertisers as statistical data about our users’ browsing actions and patterns, but this anonymized data does not identify any individual. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
HOW WE USE DATA ABOUT YOU
We will only use your personal data when the law allows us to do so and relying on a relevant basis for lawful processing in each instance. We will use your personal data in the following circumstances, relying on the basis of processing indicated:
Where we need to perform the contract we are about to enter into or have entered into with you.
• To provide you with information, products or services that you request from us (contact details).
• To carry out our obligations arising from any contracts entered into between you and us (contact details, payment information and any information relating to personalisation or relationship status).
Where it is necessary for our legitimate interests (or those of a third party) and we have undertaken an assessment to determine that processing for those interests (listed below) does not outweigh your interests and fundamental rights, considering the nature and impact of the processing and any relevant safeguards we can put in place.
• To ensure that content from our site is presented in the most effective manner for you and for your computer (online identifiers (including cookies), location data and other technical information).
• To provide you with information, products or services that we feel may interest you, (where you have consented to be contacted for such purposes to the extent consent is required by law) (contact details and any information relating to personalisation preferences or relationship status).
• To allow you to participate in interactive features of our service, when you choose to do so (online identifiers(including cookies), location data and other technical information).
• To notify you about changes to our service (contact details).
• To maintain a basic amount of information about you and your purchase history, in order to provide you customer service tailored to your tastes and any special occasions/anniversaries of which we may be aware (contact details, payment history and any information relating to personalisation or relationship status).
Where we need to comply with a legal or regulatory obligation.
• To retain basic transaction details for the purpose of tax reporting (contact details and transaction history).
Where you have consented to the processing.
• To use certain non-essential cookies on our site (see our cookie policy for further information) (online identifiers, location data and other technical information). You have the right to withdraw consent to such use at any time by contacting us but please note that some or all parts of our site may no longer be accessible to you.
• To send you direct marketing communications via email or fax (contact details). You have the right to withdraw consent to any such use at any time by contacting us.
OTHER USES/TYPES OF DATA
Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please contact us if you would like further details of any additional purposes of processing. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods). If this happens we may have to cancel any order you have placed to buy goods and we may be unable to offer any services.
Please note that we may process your personal data without your knowledge or consent where required or permitted by law.
If you provide us with any personal data relating to relatives, partners or other individuals it is your duty to make such persons aware that their personal data may be shared with us and to provide them with appropriate information about how their personal data may be processed by us.
MARKETING
As indicated above, we may use your data to provide you with information about goods and services which may be of interest to you and we may contact you about these by post or telephone. If you are an existing customer, we will only contact you by electronic means with information about goods and services similar to those which were the subject of a previous sale or enquiry.
If you do not want us to use your data in this way, please tick the relevant box on the form. If you are a new customer, or where we permit named third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
COOKIES
Our site uses cookies to distinguish you from other users of our site, which helps us to provide you with a good experience when you browse our site and also allows us to improve our site. For detailed information on the cookies we use and the purposes for which we use them see our Cookie Policy.
If you choose not to allow the use of cookies, you may not be able to use our site in full or at all.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to third parties:
• Where we use third party service providers to assist with order fulfillment or otherwise to provide support services.
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective buyer or seller of such business or assets.
• If Boodles or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements, or to protect the rights, property or safety of Boodles, our customers or others; this includes exchanging information with other companies, organizations and authorities for the purposes of fraud protection and credit risk reduction.
We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on this page and, except in the case of minor updates, will be notified to you by email.