ROGER DAVID ONLINE STORE
Updated April 2014
Roger David Stores Pty Ltd (ABN 95 004 091 016) (we, us, our) is committed to protecting your personal information, in accordance with applicable Australian privacy laws. This Policy explains how we collect, use, disclose and otherwise handle personal information.
1.2 What is personal information?
Personal information is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable (for example, your name, email address and phone number).
1.3 Our obligations
We are required to comply with the Australian Privacy Principles (APPs) in the Privacy Act. The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, security, accessibility and disposal
We are also required to comply with more specific privacy legislation in some circumstances, such as:
applicable State and Territory health privacy legislation (including the Victorian Health Records Act ) when we collect and handle health information in the relevant jurisdiction; and
the Spam Act and the Do Not Call Register Act.
1.4 Employee records
2. What we collect
The type of personal information that we collect about you depends on the dealings you have with us. For example, if you:
make an in-store purchase, we may collect your credit card details and purchase details
pre-order goods, put goods on hold or lay-by goods, we will collect your name and appropriate contact details
make an online purchase, we will collect your name, email address, order details, billing address, shipping address or store pick up information and payment details
create an online account with us, we will collect your name, email address, password, email preferences, details of any orders you place and any store credit and gift card balance
sign up for our emails, we will collect your name, email address and postcode
enter a Roger David competition or promotion, we will collect your name, contact details and any other information you provide when submitting your entry
work for a supplier, we may collect details such as your name, job title, address, telephone number and email address
send us an enquiry or provide us with feedback, we may collect your name, contact details, details of your enquiry or feedback and information about our response
apply for a job with us, we will collect the information you include in your job application, including your cover letter, resume, contact details and referee details
2.2 Sensitive information
Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection, such as health information. We only collect sensitive information where it is reasonably necessary for our functions or activities and either:
the individual has consented; or
we are required or authorised by or under law (including applicable privacy legislation) to do so.
2.3 Collection of information other than personal information through our website
When you visit our website without logging in as a user, some of the information that is collected about your visit is not personal information, as it does not reveal your identity.
Site visit information
For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.
We use and disclose this information in anonymous, aggregated form only, for purposes including statistical analysis and to help us identify the most effective areas of the website and improve the less popular ones. You are not individually identified, however we reserve the right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.
A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users (unless you have logged into your account), although they do identify the user's internet browser.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website
Online behavioural advertising
We use advertising programs that place cookies on your computer to collect information about your browsing history (including on external websites). This information, which does not identify you personally, is collected in order to improve your online experience by customising the advertising you see to your interests (including the display of more relevant ads on external websites). You can opt out of these programs at any time by clicking here.
2.4 What if you don't provide us with your personal information?
We will provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. For example, you can browse on our website, pay cash in-store for purchases and make general phone queries without identifying yourself.
In some cases however, if you don't identify yourself we may not be able to provide you with the product or service that you are seeking. For example, you must identify yourself to register an online account, make online purchases or arrange for products to be delivered to you.
3. How we collect personal information
3.1 Methods of collection
We may collect personal information in a number of ways, including:
in person (for example, if you make an in-store purchase)
through our website (for example, if you submit the "contact us" form, create an online account or order goods online)
through our social media pages (for example if you provide us with your information through the Roger David Facebook page or our Twitter or Instagram accounts)
over the telephone
through written correspondence (such as letters, faxes and emails)
on hard copy forms (for example, competition entry forms)
3.2 Collection notices
Where we collect personal information about you, we will take reasonable steps to provide you with certain details about that collection (such as why we are collecting the information and who we may share it with). We will generally include this information in a collection notice.
3.3 Unsolicited information
Unsolicited personal information is personal information we receive that we have taken no active steps to collect (such as an employment application sent to us by an individual on their own initiative, rather than in response to a job advertisement).
We may keep records of unsolicited personal information if the Privacy Act permits it (for example, if the information is reasonably necessary for one or more of our functions or activities). If not, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.
4. Why we collect personal information
The main purposes for which we collect, hold, use and disclose personal information are to:
process transactions for products or services, both in-store and online
deliver products and services to customers
operate our loyalty program
promote ourselves and our products and services, including through direct marketing, events, competitions and social media (see under heading 4.2 below)
to procure products and services for our business
perform research and statistical analysis, including for marketing, customer satisfaction and product and service improvement purposes
protect the security of our offices, stores, staff, customers and merchandise (including fraud and loss prevention)
answer queries and resolve complaints
recruit staff and contractors
We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection, or which are required or authorised by or under law, or for which you have provided your consent.
4.2 Direct marketing and opting out
We may use your personal information to let you know about us and our products and services (including promotions, special offers and events), either where we have your express or implied consent, or where we are otherwise permitted by law to do so. We may contact you for these purposes in a variety of ways, including by mail, email, SMS, telephone and online advertising.
Where you have consented to receiving marketing communications from us, your consent will remain current until you advise us otherwise. However, you can opt out at any time, by:
contacting us (details under heading 11 below)
using the email preferences page on our website
- using the unsubscribe facility that we include in our electronic messages (such as emails, SMSes and MMSes)
Notification of source
If we have collected the personal information that we use to send you marketing communications from a third party (for example a direct mail database provider), you can ask us to notify you of our source of information, and we will do so, unless this would be unreasonable or impracticable.
5. Who we may share your personal information with
We may share your personal information with third parties where appropriate for the purposes set out under heading 4, including:
financial institutions for payment processing
referees whose details are provided to us by job applicants
regulatory, investigative or government bodies
our contracted service providers, including:
- delivery and shipping providers
- information technology and data storage providers
- research and statistical analysis providers
- hard copy and electronic mail houses
- external business advisers (such as recruitment advisors, accountants, auditors and lawyers)
In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services.
6. Cross border disclosure of personal information
Personal information may be disclosed to a third party located overseas if you ask us to deliver goods outside Australia and we use an overseas delivery agent in the relevant country to fulfil the order.
7. Use of government related identifiers
We will not:
use a government related identifier of an individual (such as a Medicare number or driver's licence number) as our own identifier of individuals; or
otherwise use or disclose such a government related identifier,
unless this is permitted by the Privacy Act (for example, use of an identifier to verify an individual's identity or uses or disclosures required or authorised by or under an Australian law).
8. Data quality and security
We hold personal information in a number of ways, including in electronic databases, email contact lists, and in paper documents held in drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. We take reasonable steps to:
make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and
destroy or permanently de-identify personal information that is no longer needed for any purpose permitted by the APPs.
You can help us keep your information up to date, by letting us know about any changes to your details, such as your address, email address or phone number.
The steps we take to secure the personal information we hold include website protection measures (such as firewalls and anti-virus software), security restrictions on access to our computer systems (such as login and password protection), controlled access to our corporate premises, policies on document storage and security, personnel security (including restricting access to personal information on our systems to staff who need that access to carry out their duties), staff training and workplace policies.
Online credit card payment security
We process payments using EFTPOS and online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.
While we endeavour to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone or post (details under heading 11 below).
If you have an online account with us, you can also help to protect the privacy of your personal information by maintaining the confidentiality of your password and by ensuring that you log out of the website when you have finished using it. In addition, if you become aware of any security breach, please let us know as soon as possible.
Third party websites
9. Access and Correction
Please contact us (details under heading 11 below) if you would like to access or correct the personal information that we hold about you. We may require you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.
We will generally provide you with access to your personal information, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (eg by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you have an online account with us, you can also access your account information by logging into your account through our website.
If you ask us to correct personal information that we hold about you, we will take reasonable steps to correct that information. If we refuse to correct personal information in the manner you have requested, you may ask us to associate your request with the information and we will take reasonable steps to do so.
Except in the case of more complicated requests, we will endeavour to respond to access and correction requests within 30 days.
If you have a complaint about how we have collected or handled your personal information, please contact us (details under heading 11 below).
We will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week. If we are not able to do so, we will ask you to submit your complaint in writing.
In most cases, we expect to investigate written complaints and provide a response within 30 days of receipt. If the matter is more complex and our investigation may take longer, we will contact you and tell you when we expect to provide our response.
If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner (see here for further information).
11. Our contact details
Please contact us if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details are set out below.
Mail: Roger David Privacy Officer, 16-20 Claremont Street, South Yarra, Victoria, 3141
Telephone: (03) 9829 9600
12. Changes to this Policy