1. Introduction
Windsor Smith Pty Limited ACN 004 353 977 and its affiliated companies, (“we, “us” or “our”) respect your privacy and are committed to protecting your personal information. This policy together with our website terms and conditions, https://www.windsorsmith.com.au/terms-and-conditions, will inform you as to how we collect and process your personal information through your use of and access to this website.
2. Changes to our Privacy Policy
Any changes we may make to our Privacy Policy will be posted on this website or, where appropriate, we will communicate the changes to you by email or other means.
3. Third party links
This website may include links to other websites, plug-ins and applications provided by others, including those acting on our behalf. Clicking on those links or enabling those connections may allow third parties to collect or share data about you, and have their own privacy policies. We do not control third party websites and are not responsible for their privacy policies or actions. When you leave our website, we encourage you to read the privacy policy and terms of use of every website you visit.
4. The personal information we collect about you
Personal information means any information about an individual from which that person can be identified. It does not include information where the identity of the individual has been removed (anonymous data).
We may collect, use, store and process personal information about you, including:
· identity information, including name, title, company name, job title, gender and date of birth;
· contact information, including billing address, delivery address, email address, telephone number(s);
· purchase and transaction information, including details about payments to and from you and other details of products you have purchased from us, bank account and credit card details;
· profile information, including your username and password, your interests, preferences and feedback;
· customer service information, including your customer service enquiries and comments;
· information we may obtain from our affiliated websites, such as https://www.lipstikshoes.com.au and https://www.windsorsmithoutlet.com.au; and
· technical and usage information, including through cookies, being details of your visits to or from this website, including where you came from, whether you accessed from a marketing campaign or directly, what search engine you used, links clicked and keywords used, and also your geographic location, traffic data, location data, preferences, website usage, page visits, browsing activity and other requests, comments or communication information.
5. If you fail to provide personal information
If you choose not to provide the personal information as requested, we may not be able to supply you with our products or services or the functionality of our website may be limited and certain personalised features of this website cannot be provided to you.
6. How is your personal information collected?
We use different methods to collect information from and about you including through:
· the forms you complete on this website, information we may obtain from our affiliated websites, https://www.lipstikshoes.com.au and https://www.windsorsmithoutlet.com.au, in physical stores, or by corresponding with us by post, telephone, email or otherwise. This includes information you provide when you:
o create an account on our website;
o become a VIP member or participate in our member activities and promotions;
o subscribe to our service or publications;
o enter a competition, promotion or survey;
o request marketing to be sent to you or respond to it;
o give us feedback; or
o submit payments via our website;
· your interactions and use of our website, such as your location data, website usage and other communication data.
7. Purposes for which we will collect or use your personal information
We collect and use your personal information for any of the following purposes:
· to register you as a new user and/or customer;
· to process, manage and deliver your orders, or otherwise fulfil our obligations arising from any contracts entered into between you and us;
· to manage our relationship with you, including notifying you about changes to our terms and conditions or Privacy Policy;
· to enable you to participate in competitions or promotions sponsored by us, or complete a survey, and to offer those to you;
· to administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
· to conduct and analyse market research;
· to use data analytics to improve our website, products/services, marketing, customer relationships and experiences; and
· to make suggestions and recommendations to you about goods, services and offers that may be of interest to you where you have opted in to receive such marketing information.
8. Third party marketing
Unless we have another lawful means for processing your personal information, we will obtain your opt-in consent before we share your personal information with any company outside of the Windsor Smith group of companies for promotional and marketing purposes.
9. Storage and security of your personal information
The information we collect from you may be transferred to, and stored at, a location in Australia or outside Australia.
We aim to have appropriate security measures, which aims to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know and who have a duty to process your personal information on our instructions and in accordance with applicable law to keep it confidential.
We have put in place procedures aimed to deal with any known or suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10. Disclosure of your personal information
We may share your personal information with the persons set out below:
· any member of the Windsor Smith Group, which means our subsidiaries, our ultimate holding company and its subsidiaries;
· third parties who help us to administer this website (such as our internet service providers and those who provide marketing services for us);
· third parties who help us to process payments on our website and in-store (such as Afterpay or PayPal);
· professional advisers, including lawyers, bankers, auditors, audit assessors and insurers who provide consultancy, banking, legal, insurance or accounting services;
· third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy;
· third parties, including authorities, where we are legally obliged to disclose your personal information to them.
11. Cookies
So that you can make full use of the personalised features on our website, your computer, mobile phone or other device (all referred to here as device) will need to accept cookies. You can set your browser to reject, refuse all or some cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly and certain personalised features of our website cannot be provided to you.
The cookies that we use fall into certain categories:
11.1. Technical: These are essential cookies that support the technical functionality of our website.
11.2. Analytics/Performance: We or third parties acting on our behalf use analytics software (such as Google Analytics) for tracking and reporting of website traffic or to manage web page code used for tracking and analytics on our websites. This information can be used to gain customer insight and improve the way our site works. Google Analytics does not collect any personal information.
11.3. Targeting/Advertising: Some cookies enable us to offer to you online interest-based ads.
Some of our cookies are provided by third parties and they are subject to their privacy policies.
If you wish to restrict, block or delete cookies from us or any other website, you can use your browser to do this. Each browser is different so check the help menu of your particular browser to learn how to change your cookie preferences. Any of your preferences will be lost if you delete cookies (including where you have opted out from cookies as this requires an opt-out cookie to be set).
By accepting cookies, you agree to the transfer, storing or processing of your personal information in accordance with this Privacy Policy.
12. How long do we retain your personal information?
We will retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
13. Your rights
Subject to our compliance with applicable laws, you have the right:
· to request us to access and/or correct your personal information;
· to request us to restrict the processing or object to the processing of your personal information; and
· to withdraw your consent that allows us to use or process your personal information.
If you wish to exercise any of the rights set out above, please contact us as set out below in section 14. We will not however be able to comply with your requests to the extent that it would cause us to breach any applicable laws or legal requirements with which we are required to comply.
13.1. No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of your other rights) under applicable law. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
13.2. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to help speed up our response.
13.3. Time limit to respond
We will try to respond to all legitimate written requests by you regarding your personal information as soon as practicable. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will let you know and keep you updated.
14. Contact
If you have any questions, concerns or complaints about how we handle personal information, or wish to exercise your rights as set out in this Privacy Policy or under applicable law, please contact us as follows:
· By post: Windsor Smith Pty Ltd, 78-86 Western Ave, Westmeadows VIC 3049.
· By email: customercare@windsorsmith.com.au