True Alliance Pty Limited (ACN 098 282 001) and its related bodies corporate (we, our, us) is a distributor for a number of leading fashion and sportswear brands in Australia and New Zealand.
True Alliance respects your rights to privacy and comply with all requirements under applicable privacy laws in respect of the collection, use, disclosure and management of your personal information. This policy describes how True Alliance will manage the personal information we collect about you through the use of our websites, social media pages and other forms of communication with us.
1. WHAT IS YOUR PERSONAL INFORMATION?
2. WHAT KINDS OF PERSONAL INFORMATION DO WE COLLECT AND HOLD?
We may collect the following kinds of personal information about you:
- mailing and street addresses;
- email address;
- phone numbers;
- date of birth;
- profession, occupation or job title;
- when you access our websites, information about your computer or mobile device including its model and IP address;
- your transaction history with us, including in respect of your purchases and participation in competitions or promotions relating to any of the brands we represent; and
- other personal information you voluntarily provide to us during the course of dealing with us, including when making inquiries about our products or services, responding to customer surveys, entering competitions or when providing details about a complaint.
3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We usually collect personal information directly from you unless it is unreasonable or impracticable to do so. When we collect personal information, we may do so when you communicate or interact with us, such as when you:
- make inquiries about us, our products and services or contact us for any other reason so that we can process, deal with and respond to your queries or other issues including any complaints;
- enter into a transaction with us, including in our branded stores or in respect of any of the brands we represent;
- contact, register with, post to, like or follow any of our social media websites, pages, forums or blogs;
- use or register on our websites;
- register for or attend any of our events, seminars or activities; or
- subscribe to a newsletter (for example, by filling out sign-up cards in our retail stores), fill out a form or survey, or enter or participate in competitions or promotions run by us or our brands or any third party affiliates
The collection of personal information on our websites or our social media pages will be clear from the context (e.g. request to complete information fields) or will state that personal information is being collected at the point of collection.
In addition we may collect information through click tracking (in relation to your use of our websites including the content you access and any services you utilise) and through log files or cookies (as further detailed below).
In some instances, we may collect personal information about you from third parties, such as marketing agencies or via affiliate programs, or where you have made inquiries about our products, services or brands. We may also collect personal information about you from event organisers (who may collect information about you when you register or participate in the event) where we sponsor or participate in the event.
4. WHAT HAPPENS IF YOU DO NOT PROVIDE YOUR PERSONAL INFORMATION TO US?
If you do not provide personal information that we request in connection with our business functions and activities, we may not be able to provide some or all of our products or services to you or be able to respond and assist in the manner required. For example, we may not be able to deliver or track your order or contact you. We also may not be able to provide you with information about products and services that you may want.
5. HOW WE HOLD YOUR PERSONAL INFORMATION?
All personal information you provide to us is stored on secure servers. We use a variety of technical and organisational security techniques, including encryption and authentication, to help with the protection and maintain the availability, security and integrity of your personal information.
We do not collect, store or have access to your credit card details of our retail customers. When retail customers use a credit card to make a purchase, the details are transmitted directly to a third party payment processor who arranges the transfer of funds from the customer’s bank account to our bank account. In contrast, if you are an individual who makes wholesale purchases from us for your business, we will collect and store your credit card details.
We are committed to protecting your information through the following measures:
- restricting access to your personal information to only those who need to use it for the relevant purpose;
- preventing unauthorised access to IT systems by using firewalls; and
- permanent monitoring of IT systems to detect and stop misuse of personal information.
As our websites and IT systems are linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Reasonable steps are taken to destroy your personal information once we no longer need it.
6. WHY DO WE COLLECT, USE, HOLD AND DISCLOSE YOUR PERSONAL INFORMATION?
We collect, use, hold and disclose your personal information for the following purposes:
- to provide our products and services to you, including the delivery to you of the products and services and information and services relating to our products, services, and brands;
- to record information regarding products purchased from us and to provide further services to you, such as product warranties and guarantees, and repair or replacement of products;
- to assist in providing better products and services to you by tailoring them to meet your needs;
- to provide you with access to protected areas of our websites;
- to assess the performance of the websites and to improve the operation of the websites;
- to keep our websites and other online presence relevant and of interest to you, for direct marketing including promotions, newsletters and competitions, to show you advertising and information that is most relevant to you and your interests, and to carry out
- analysis of market activity, market research and surveys;
- for verification of your identity for use of our websites, to conduct address verification or credit checks for invoicing and billing purposes;
- to provide you with further information about us or other websites or goods or services offered by us, our related companies or the brands whose products we distribute or which we consider may be of interest to you;
- to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
- for contracting with you;
- to update our records and keep your contact details up to date;
- to process and respond to any complaint made by you;
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country; and
- any other purpose which is stated to you at the time of collection or that you otherwise authorise.
7. WHO WILL WE DISCLOSE YOUR PERSONAL INFORMATION TO?
For the purposes stated in section 6, we may disclose personal information to the following parties:
- our related companies and affiliates;
- the owners of any of the brands we represent, as well as their related companies and affiliates;
- Cole Haan Australia is entitled to share personal information with Cole Haan LLC;
- other third party contractors and providers of goods and services, such as courier and delivery companies, marketing and promotion companies, training and training certification agencies, web analytics services, business support services, and information technology service providers;
- market research companies who undertake customer surveys for us;
- professional service firms providing services to us, such as legal or accountancy services;
- law enforcement agencies or regulatory agencies where required or authorised by or under a law or a court or tribunal;
- sponsors of events, competitions and promotions run by us or our affiliates. We will only share the information you provide to us relating to the events, competitions or promotions;
- any entity where required or authorised by or under a law or a court or tribunal;
- any other recipient which is notified to you at the time of collection or that you otherwise authorise; and
- as otherwise permitted by applicable privacy laws.
8. DO WE DISCLOSE PERSONAL INFORMATION OVERSEAS?
We take reasonable steps to ensure that the overseas recipients of your personal information do not breach any applicable privacy obligations relating to your personal information.
- We may disclose your personal information to the following overseas recipients with your consent or where the overseas disclosure is connected to the disclosure purpose for which the information was collected in the first place, such as the purposes listed in section 7:
- our related companies and affiliates located in Australia and New Zealand;
- our brand owners located in France, Hong Kong, Singapore, the UK and the USA;
- third party service providers of data storage and processing services located in Australia which may have servers or staff located overseas who may have access to the information in course of providing services to us.
These arrangements may change from time to time, including as a result of changes of our service provider or changes in our data protection practices.
If you want, you can disable your web browser from accepting cookies. If you do so, you can still access our websites, but not all services may be available.
We may automatically collect general statistical information on our websites about visitors to our websites, such as IP addresses, browsers used, dates visited, pages visited and number of visitors. However, such information does not refer to you by name or your contact details. We use this data in aggregate to improve our websites. We may provide such aggregated data to third parties, but in so doing, we do not provide personal information without your consent.
10. DIRECT MARKETING
We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth) and the New Zealand Unsolicited Electronic Messages Act 2007. You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.
We may sometimes share your personal information with third parties for the purposes of direct marketing. Those third parties may include our affiliates and brand owners in respect of competitions and promotions being run by them alone or jointly with us.
11. ACCESS AND CORRECTION OF YOUR PERSONAL INFORMATION
You have the right to access your personal information which we hold about you, subject to some exceptions. If you have an online account with us, you are able to log into your account and to access and update your personal information. Alternatively, you may ask us to help you access your personal information. Before we provide you with access to your personal information we may require some proof of identity. We will not charge you for simply making a request. If you wish to access the personal information we hold about you, please contact us using the contact details provided below.
You also have the right to request that we correct any inaccurate personal information we hold about you. If you wish to correct the personal information we hold about you, please contact us using the contact details provided below.
When contacting us to request access to or correction of any personal information we hold about you, we ask that you provide us with as much detail as you can about the information in question as this will help us to retrieve it.
If we do not agree to your request to provide you with access to your personal information or to amend your personal information, we will inform you of our decision within a reasonable period. If you wish to complain about this outcome or to attach a statement to your record that you believe the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, please see our complaints procedure below.
You may request further information about the way we manage your personal information, or lodge a complaint if you believe that we have breached your privacy, by contacting our Privacy Officer using the contact details below.
We will deal with any complaint by investigating it, and providing a response to you within a reasonable time, provided that we have all necessary information and have completed any investigation required. In some cases, we may need to ask you to put your complaint in writing so that we are sure that we understand it, and may also need to ask you for further information or to verify your identity. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will treat your complaint confidentially and respond to you within a reasonable time, usually in writing.
If you are dissatisfied with the outcome, please contact us. Alternatively, you may take your complaint to the Privacy Commissioner at the Office of the Australian Information Commissioner (OAIC) or to the New Zealand Office of the Privacy Commissioner (OPC). The contact details for the OAIC are available from the OAIC’s website at www.oaic.gov.au. The contact details for the OPC are available from the OPC’s website at www.privacy.org.nz.
13. CUSTOMER SIGN UP & REGISTRATION TERMS AND CONDITIONS
The Privacy Officer
True Alliance Brands Pty Limited
19 O’Riordan Street
Alexandria NSW 2015
Alternatively, you can email us at email@example.com or you can call us on +61 2 8306 3300 or +64 7 849 2947.