1. Introduction
1.1 Andzen is committed to protecting your personal information and complying with our obligations under the relevant data protection laws, including the Privacy Act 1988 (Cth) (Privacy Act) and Australian Privacy Principles (if you are located in Australia), and the EU General Data Protection Regulation (Regulation (EU) 2016/679) (if you are located in the European Union) (GDPR). If you are located in another jurisdiction, additional local requirements will comply.
1.2 This Privacy Policy explains how we use and disclose the Personal Information we collect about you, what controls you have to limit the use of that Personal Information and the procedures that we have in place to safeguard your privacy.
1.3 In this Privacy Policy:
(a) “Andzen”, “we”, “us” or “our” means Andzen Pty Ltd ACN 155 884 996, and its associated entities as appropriate;
(b) “Personal Information” means information about you which personally identifies you or may reasonably be used to personally identify you;
(c) “Sensitive Information” has the meaning given to that term in the Privacy Act;
(d) “Services” means the ecommerce and other related services provided by Andzen from time to time;
(e) “Website” means https://andzen.co/ or any other website from time to time from which the Services are promoted and/or delivered; and
(f) “you” means you and anyone acting on your behalf or with your implied authority.
1.4 Please read this Privacy Policy carefully. Your use of any part of our Website or Services will constitute your consent to the collection, transfer, processing, storage, disclosure and other uses of your Personal Information in accordance with this Privacy Policy. If you do not agree with the terms and conditions of this Privacy Policy, please do not use our Website or Services.
2. What Personal Information we collect
We collect and hold various types of Personal Information, including:
(a) identity data including your name, and company name;
(b) contact data including your contact details such as your billing address, email address and telephone number;
(c) financial data including banking, credit card, billing or other payment information;
(d) transaction data including details about payments to and from you and other details of services you have purchased from us;
(e) technical data including your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Website;
(f) marketing and communications data including your preferences in receiving marketing from us and our third parties and your communication preferences; and
(g) other information necessary for or incidental to the provision of the Services.
3. When we collect Personal Information
We will only collect Personal Information about you:
(a) when you access or use our Website;
(b) when you register for one of our Services;
(c) when you enquire about one of our Services or complete an online form on our Website; or
(d) you otherwise communicate or register your details with us through via email, telephone, our Website or social media.
4. Use and disclosure of Personal Information
4.1 We may hold, use and disclose your Personal information for the following purposes:
(a) to communicate with you about your use of the Services or any changes to the Services;
(b) facilitating interactions with you in the course of operating our business;
(c) responding to your enquiries and information requests;
(d) where we are required to do so by law; or
(e) for any other purposes for which you have consented from time to time.
4.2 From time to time we may require third parties to carry out certain business functions on our behalf in connection with the Services, such as for our administrative, operational and marketing purposes. We will only pass on your information to third party contractors, if it is necessary for us to perform the Services or if you have provided your prior written consent. Any Personal Information that you choose to provide to us or to other companies using our Services will only be used in support of the intended purposes stated at the time at which it was collected and subject to any preferences indicated by you.
4.3 We may also convert your Personal Information into statistical or aggregated form to better protect your privacy, or so that you are not identified or identifiable from it. Anonymised data cannot be linked back to you. We may use such anonymised data, and disclose it to third parties for statistical analysis and strategic development purposes, and to help us understand and improve the use of our Website.
5. Cookies
5.1 To improve your experience on our Website, we may use ‘cookies’: small data files that are served by our platform and stored on your device. Cookies, such as Google Analytics, and salesforce may be used for recording preferences, helping to ensure the security and authenticity of users, conducting internal analytics, conducting research to improve our offering, assisting with marketing and delivering certain website functionality.
5.2 For example, when you log in to an account on our servers, we store a number of session cookies to remember your login and allow us to let you securely access the account on the Website. When you use subscription forms, we also use session cookies to allow you to safely and securely complete a form. These session cookies are necessary for the reliable operation of our forms and are anonymous.
5.3 You may refuse to accept cookies by selecting the appropriate setting on your internet browser. However, please note that if you do this, you may not be able to use the full functionality of our Website.
6. Direct marketing
6.1 We will only send you direct marketing communications and information via mail, email and social media platforms about our Services with your consent. This information is generally used to help assess the effectiveness of our Services and communications. If you do not provide your consent to receive direct marketing communications, you may opt-out of receiving marketing communications from us by contacting us at the details below or by using opt-out facilities provided in our communications. We do not provide your Personal Information to other organisations for the purposes of their direct marketing, without your prior consent.
7. Overseas disclosure
It is unlikely that we will need to disclose your Personal Information to an overseas recipient or otherwise store your Personal Information overseas. If we are ever required to do so, we will only pass on Personal Information about you as an individual (as opposed to anonymised information) to third parties overseas, where we have obtained enable us to perform Services requested by you.
8. GDPR compliance
If your Personal Information is governed by the GDPR, you may have additional rights as set out below:
8.1 Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
8.2 Object to processing of your Personal Information. You may object to us processing of your Personal Information even if we are relying on a legitimate interest (or those of a third party), where there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
8.3 Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios:
(a) if you want us to establish the information’s accuracy;
(b) where our use of the information is unlawful but you do not want us to erase it;
(c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
8.4 Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
8.5 Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
9. Security of your Personal Information
9.1 We follow strict security procedures to prioritise the security of your Personal Information whilst it is in our possession.
9.2 We take reasonable steps to:
(a) ensure that Personal Information we collect is accurate, up-to-date, complete and relevant, other than where it is only collected to provide advice in respect of a particular point in time, in which case we will seek to ensure it is accurate, complete and relevant as at that particular point in time;
(b) ensure that Personal Information we use or disclose is accurate, up-to-date, complete and relevant, having regard to the purposes for which Personal Information is used or disclosed;
(c) use industry standard technology to encrypt your Personal Information, and protect it from misuse, interference and loss, and from unauthorised access, modification or disclosure; and
(d) destroy or de-identify Personal Information which we no longer need for the purposes for which it was collected, except where it is necessary to retain it in order to maintain ongoing records for our clients.
9.3 We cannot guarantee the security of information transmitted via the internet. As such, transmission of Personal Information via the internet is at your own risk and we cannot be held responsible for the security of such information you provide to us.
10. Retention of Personal Information
10.1 We will only retain your personal data for a limited period of time and for no longer than is necessary for the purposes for which we are processing it for. This will depend on a number of factors, including any legal or regulatory requirements that we are required to follow and the type of information that we hold about you.
11. Third party websites
11.1 For your convenience and to improve the usage of the Website and Services, our Website may contain links to third-party websites, applications or resources, which are outside of our control and for which this Privacy Policy does not apply. Our Website may contain links to other websites which are outside our control and are not covered by this Privacy Policy. If you access other websites using the links provided, the operators of these websites may collect information from you which will be used by them in accordance with their privacy practices, which may differ from ours.
11.2 Andzen is not responsible for third party websites, applications or resources. If you access such websites, applications or resources, you do so at your own risk and we make no representations or warranties regarding third parties’ privacy practices. We encourage you to read the privacy statements/policies of every website, application or resource you use. Our Privacy Policy does not cover the use of cookies by any third parties.
12. Updating your personal information
12.1 If you wish to update any of your Personal Information at any time, for example if you change your e-mail address, or you do not wish to receive information about a particular product or service, please update your details as instructed on the Website or by contacting us directly and your details will be updated as soon as is reasonably practicable.
13. Accessing your Personal Information
13.1 We are committed to maintaining accurate, timely, relevant and appropriate information. Where requested, we will provide you with a copy of the Personal Information that we hold which relates to you, provided that the request is made in accordance with the Australian Privacy Principles (contained in the Privacy Act), the GDPR, or other relevant legislation. We will also update any inaccurate information about you if you inform us that the information is inaccurate, out of date, incomplete, irrelevant or misleading.
13.2 There are no charges for requesting access to or the correction of your Personal Information, however if the volume of information we hold is excessively large, we reserve our rights to charge you any reasonable administration fees of up to $10 (including fees for photocopying) associated with your request, to cover our administration costs.
13.3 You can contact our privacy officer regarding access to or correction of your information by any of the following methods:
13.4 Email: [email protected]
13.5 Post: 17 Brereton St, South Brisbane, Qld, 4101
13.6 Phone: +61 7 3503 6779
13.7 We will respond to those requests within 30 days in accordance with our obligations under the Act. If we refuse a request to access or correct Personal Information, where reasonable, we will provide you our reasons for doing so and information about your ability to complain about such refusal.
13.8 In order to protect the confidentiality of your Personal Information, details of your information will only ever be passed on to you where we are satisfied that the information relates to you. Accordingly, when writing to us, please state your name, postal address and mobile phone number and provide brief details of the information that you require, so that we may confirm your identity before passing on any Personal Information which relates to you.
14. Making a complaint
14.1 If you have a complaint about our Privacy Policy or the collection, use, disposal or destruction of your Personal Information, your complaint should be directed in the first instance to our privacy officer at the details set out above.
14.2 We will investigate your complaint and attempt to resolve any breach that might have occurred in relation to the collection, use or destruction of Personal Information held by us about you in accordance with the Privacy Act. If you are not satisfied with the outcome of this process, then you may contact the Office of the Australian Information Commissioner.
15. Privacy policy changes
15.1 We may change this Privacy Policy at our discretion. If we do so, the latest version of our privacy policy will be available on our Website at https://andzen.co/legal/ and it will apply to all your Personal Information held by us at that time.
16. Further information
16.1 If you require any further information or have any queries regarding our Privacy Policy or privacy practices, please contact our privacy officer at the details set out above.
16.2 Should you wish to read more information on the Privacy Act, we recommend that you visit the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.