Desire Skin Pty Ltd (“DS”, “we”, “us” and “our”) recognises the importance of safeguarding your personal information.
Your privacy is important to us and we want to manage your personal information in a professional and responsible manner.
The Privacy Act sets standards for the way we must deal with personal information by regulating:
- The way we collect your personal information;
- The way we use and disclose it;
- Our data quality and security for storage of your personal information;
- Any direct marketing we conduct;
- Your right of access and correction of your personal information;
- How we handle any privacy complaints; and
- Any international transfer of Information.
Collection of Personal Information
Personal information is any information or opinion (whether true or not), which either identifies you or from which your identity can reasonably be determined.
We only collect your personal information where that personal information is necessary for one or more of our functions or activities.
The types of personal information we collect may differ depending on your relationship with us. Personal information includes:
- In the case of our brand ambassadors, representatives, and supporters who register their interest to receive more information about the business – your full name, physical address, email address, phone number/s, date of birth and occupation;
- In the case of the general public contacting our customer service function wishing to make a complaint, provide feedback, submit an enquiry, request a call-back or request a product replacement – your full name, physical address, email address and phone number/s;
- In the case of the general community of supporters and subscribers who wish to be kept informed of our latest business news, promotions, events or products or to receive our regular company newsletter – your full name, physical address, email address and phone number/s;
- In the case of customers purchasing our products via our online store or through an online corporate order – your full name, physical address, email address, phone number/s and credit card details
- In the case of customers who have created a Track Your Impact user profile – your email address (or if you have registered your profile using your Facebook or Google account, your public profile and personal details linked to those accounts and made available to our Track Your Impact application.)
- In the case of our suppliers, key customer account managers and distributors – your name, physical address, email address and phone number/s;
- In the case of market research participants – your name, physical address, email address, phone number/s; age, gender and occupation;
- In the case of workforce candidates (including potential employees, contractors and volunteers) – information which may be contained in a resume and which may be recorded during any interview or pre-employment checking; and
- In the case of trade credit applicants, information which we may require to assess your credit worthiness, for example your credit or business history.
- In the case of general Website visitors and users, customer demographics information (such as age range, gender and location) obtained through various analytics tools.
Collection of Sensitive Information
Sensitive information is personal information that includes information about your:
- Racial or ethnic origin;
- Political opinions;
- Sexual preferences or practices;
- Criminal record; or
Sensitive information has extra protection under the law. In general, we do not collect sensitive information about you. However, we will only collect this information if it is necessary to do so and you have consented to its collection.
For example, if you report a health concern or issue related to our products, we would ask you for details of any illness or injury you have suffered and other health related details. We may also require you to undertake a police check as part of your employment with us or if you have been invited to participate in a projects trip to visit one of our funded programs.
We will not use or disclose your sensitive information other than as allowed by the law or with your consent.
Can you choose not to disclose your personal information?
If you contact us to make a general inquiry about our business or products, you do not have to identify yourself or provide any personal information unless you require us to get back in touch with you at a later stage or if you would like us to send you further information or products.
You can also notify us that you wish to deal with us by not identifying yourself or using a pseudonym. However, if we are not able to collect personal information about you we may not be able to provide you with the products, services, information or assistance you require.
For example we will not be able to send you information about our products if you have not provided us with a valid email address or phone number.
How secure is my personal information?
We collect personal information from you in the following ways:
- When you contact our customer service function in person, via telephone or email;
- When you sign up as a brand ambassador via our web page;
- Address or by using your Facebook or Google account to create a profile);
- When you sign up to receive our newsletter or other marketing materials;
- When you complete your purchase order details in our online store;
- When you enter a competition or register for an event;
- When you apply for employment with us and during the recruitment process;
- When you conduct business with us;
- When you agree to participate in a market research initiative;
- When you apply for trade credit with us;
- When you provide your information to our staff;
- When you supply goods and/or services to us;
- When you submit any Personal Information through a Facebook Lead Ad; and
- When you visit or use our Website.
When collecting this personal information, we will do so only by lawful and fair means and not in an unreasonably intrusive way. Desire Skin may use third party service providers to collect and store personal information on our behalf.
Where it is reasonable and practicable to do so, we will only collect personal information about you from you directly and not from third parties. However, in some instances, this will not be practicable. In some cases, we collect personal information about you from publicly available sources (such as the internet) and from third parties (such as mutual contacts or your referees provided during the recruitment process if you apply for a job with us).
How secure is my personal information?
Desire Skin takes reasonable steps to protect and store your personal information, including limiting access to such information to internal employees on a need-to-know basis and using password protected servers.
However, when submitting any personal information about yourself on the internet, it is important to note that internet security is not absolute. Desire Skin takes reasonable steps as required by the Privacy Act to ensure that our website is protected from outside sources, and we encourage you to make sure your computer is adequately protected. If you post personal information on our website, we will consider that you have consented to the collection of this information.
Use of your personal information
We will use your personal information for the primary purpose for which it was collected. The primary purpose of collection is the main reason we collect your personal information in the first instance.
The primary purpose for collecting your personal information will vary depending on the nature of your relationship with us.
- In the case of our brand ambassadors, representatives, and supporters – the primary purpose would be to send you information about our business, products, giving-model and upcoming events;
- In the case of the general public contacting our customer service function – the primary purpose would be to respond to your complaint, feedback, enquiry or to send you information or replacement products;
- In the case of our general community of supporters or subscribers – the primary purpose would be to keep you informed of our latest business news, direct marketing initiatives, promotions, events or products or to receive our regular company newsletter;
- In the case of customers purchasing our products via our online store or through an online corporate order – the primary purpose would be to enable us to complete your order and to keep you informed of future online store promotions and direct marketing initiatives;
- In the case of customers who have created a Track Your Impact user profile – the primary purpose would be to update you on the progress of the projects which you have helped fund as well as monitor your overall usage activity and funding statistics on the Track Your Impact application;
- In the case of our suppliers, distributors and key customer account managers – the primary purpose would be to maintain a business relationship with you;
- In the case of market research participants – the primary purpose would be to understand and better serve our customers, and improve the quality and level of the products we offer to customers;
- In the case of workforce candidates (including potential employees, contractors and volunteers) – the primary purpose would be to consider your application as well as consider you for any future suitable job opportunities;
- In the case of trade credit applicants, information which we may require to assess your credit worthiness, for example your credit or business history;
- In the case of Facebook Lead Ads, for direct marketing and other digital marketing campaigns; and
- In the case of Website visitors, information to help us develop marketing insights as well as help inform our digital strategy.
We will only use personal information beyond the primary purpose where it is related to that purpose or where you consent to the further use.
Do we disclose your personal information to third parties?
When you provide your personal information to us it may be transferred to our service providers, including those located outside of Australia.
The types of persons and organisations to which we may disclose your personal information include the following:
- Organisations with whom we have arrangements or agreements for the purpose of promoting our products or services and any agents used by us in administering such arrangements or agreements;
- Our employees, agents, contractors and external advisers who carry on our functions and activities or who assist us to carry on our functions and activities from time to time;
- Organisations who are contracted by us to perform certain services, including to maintain our website;
- our legal advisors, when needed; and
- Other parties to whom we are authorised or required by law to disclose information.
DS does not sell or share your personal information with any other company for that company’s direct marketing services.
For clarity, we may share your personal information to our service providers who may use the personal information for direct marketing services on our behalf, however, we will not share your personal information with other companies for the purpose of those companies marketing their own products to you unless we specifically ask for and receive your permission to do so.
Although we do not actively disclose your Personal Information to third parties, we do engage digital service providers such as Google and Facebook which will have access to certain Digital Information relating to you. Please refer to the section below relating to Digital Information.
Can you remove your personal information from our records?
If you do not wish to receive ongoing promotional news or information about our products and services, you can request to be withdrawn from our contact list or marketing database at any time, either by contacting us or by using the opt out function contained in our direct marketing, newsletter or other emails.
Once you have made this request, DS will remove your personal details and will no longer continue to engage in any direct marketing communications with you.
We are obligated by law to retain some types of personal information, such as employee records, for a set period of time. As such we will not allow removal of such personal information.
How long will we keep your personal information?
In general, we will retain and use your personal information to communicate with you indefinitely until you “opt out” of these communications by informing us that you no longer wish to receive such communications.
For certain types of personal information, particularly employee records, we are obliged to retain these for seven (7) years after an employee finishes their employment with us. If you submit your personal information as part of a job application, your details are stored on a secure recruitment database for our records. This allows us to consider your application for future vacant positions if you are unsuccessful in obtaining a position with us at first instance. It is our usual practice to request your permission to contact you about future job vacancies. You are entitled to request that we remove your information from this database.
Digital Information & Cookies
DS has implemented certain Google Analytics Advertising Features on the Website. These include Data Collection for Google Analytics Search & Display Network Remarketing, Audience Demographics & Interests Reporting and Display Network Impression Reporting.
These features may provide us with marketing insights into certain customer attributes and preferences when using the internet and various digital platforms (“Digital Information”). However, given that this information may not always be personally identifiable information, it may not constitute Personal Information. Nevertheless, our use of such Digital Information shall be governed by this Policy.
“Cookies” are a standard for storing small pieces of data on a web client (ie. the web browser on your computer). DS websites store a unique ID on your web client in order to identify you while using the website. As part of the Google Analytics Features used on the Website, DS may also use Google Analytics cookies and advertising cookies.
You can opt-out of the Google Analytics Advertising Features you use, including through your browser Ads Settings, Ad Settings for mobile apps, or any other available means. Please refer to Google Analytics’ currently available opt-out add-on to your web browser to prevent access to your Digital Information.
Links to Other Sites
Please keep in mind that whenever you give out personal information online, for example, via message boards or chat, that information can be collected and used by people you do not know. DS does not guarantee the security of any information you disclose online and you do so at your own risk.
Accessing and amending your personal information
Under the Privacy Act 1988 you have rights of access to and correction of personal information that we hold.
To access your information is generally a free service. Sometimes, we may ask that you send this information to us in writing to assist us. On occasion, if further more detailed personal information is in our archives, a small fee may be charged to cover the cost of obtaining the information for you. We will inform you of any charges payable upon your request.
You may request access to the personal information we hold about you and seek the correction of such information by contacting our customer service function at email@example.com
DS aims to respond to requests for access to personal information within thirty (30) days.
The Privacy Act does permit us to deny you access to your personal information in certain circumstances, including if:
- There is current or pending litigation regarding the personal information;
- The request is frivolous;
- Permitting access would be in breach of the law;
- Providing the information would pose a threat to health or public safety; or
- Providing the information would interfere with another person’s privacy.
Any denial of a request for access to personal information will be accompanied by an explanation setting out our reasons for doing so.
Where any information is not accurate, up-to-date or complete, you can request that the information be amended.
In some instances where it is not practical to update your personal information, we may choose to note your desired changes and place them together with the original personal information on our records.
Enquiries and Complaints
If you wish to access or correct your personal information, or if you have any concerns or enquiries about how we deal with your personal information, you should contact us at firstname.lastname@example.org
The privacy legislation requires us to respond to your request in 30 days, and you must allow us the full 30 days to respond before you can escalate any complaint you may have.
We will at first seek to deal with you via phone. If your complaint is not satisfactorily resolved after the phone call, we would meet with you in person.
Last updated on: September 2, 2019
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