Privacy Policy for Customers

Audience
This policy applies to you if you are:
• a visitor to our website; or
• a customer who has ordered or requested the goods or services that we provide.

Personal information
Personal information includes:
• certain information collected on registration as customer through our credit control procedures;
• certain information collected on submission; and
• optional information that you provide to us voluntarily (see below).

but excludes:
• information that has been made anonymous so that it does not identify a specific person;
• permanently de-identified information that does not relate or cannot be traced back to you specifically;
• non-personal statistical information collected and compiled by us; and
• information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).

Common examples
Common examples of the types of personal information which we may collect and process include your:
• identifying information – such as your name, date of birth, or identification number of any kind;
• contact information – such as your phone number or email address;
• address information – such as your physical or postal address.

Sensitive personal information
Depending on the goods or services that you require, we may also collect sensitive personal information including your:
• financial information – such as your bank account details;
• criminal information – such as information about your commission or alleged commission of any offence or about any related legal proceedings.

Acceptance
Acceptance required
You must accept all the terms of this policy when you order our goods or request our services. If you do not agree with anything in this policy, then you may not order our goods or request our services.

Legal capacity
When you order goods or request services from us you consent that you have the legal capacity or required authority to do so.

Deemed acceptance
By accepting this policy, you are deemed to have read, understood, accepted, and agreed to be bound by all of its terms.

Your obligations
You may only send us your own personal information or the information of another data subject where you have their permission to do so. Like we will take all reasonable measures to protect your personal information, you agree to likewise protect our personal information.

Changes
We may change the terms of this policy at any time . We will notify you of any changes by placing a notice in a prominent place on the website or by sending you an email detailing the changes that we have made and indicating the date that they were last updated. If you do not agree with the changes, then you must stop ordering our goods or services. If you continue to order our goods or services following notification of a change to the terms, the changed terms will apply to you and you will be deemed to have accepted those updated terms.

Collection
We will use your personal information to fulfil your account, provide additional services and information to you as we reasonably think appropriate, and for any other purposes set out in this policy.

On order or request
When you order our goods or request our services from us, you will be asked to provide us with additional information on a voluntary basis.

Recording calls
We may monitor and record any telephone calls that you make to us, unless you specifically request us not to.

Purpose for collection
We may use or process any goods or services information, or optional information that you provide to us for the purposes that you indicated when you agreed to provide it to us. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including:
• goods or services purposes – such as collecting orders or requests for and providing our goods or services;
• marketing purposes – such as pursuing lawful related marketing activities;
• business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
• legal purposes – such as handling claims, complying with regulations, or pursuing good governance.

We may use your usage information for the purposes described above and to:
• remember your information so that you will not have to re-enter / re-provide it to us.

Consent to collection
We will obtain your consent to collect personal information:
• in accordance with applicable law;
• when you provide us with any registration information or optional information.

Use
Our obligations
We may use your personal information to fulfil our obligations to you.

Messages and updates
We may send administrative messages and email updates to you about products and services. In some cases, we may also send you primarily promotional messages. You can choose to opt-out of promotional messages.

Disclosure
Sharing
We may share your personal information with:
• other divisions or related companies within the group of companies to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services, and communications (they will only use this information to send you marketing communications if you have requested their goods or services. In some cases, we may send out bulk communication for marketing purposes to all our customers or a select few. You may opt out of such communication by notifying us via phone call or e-mail), but we will not disclose communication with you to any of our other customers.
• our goods or services providers under contract who help provide certain goods or services or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services (our contracts dictate that these goods or services providers only use your information in connection with the goods or services they supply or services they perform for us and not for their own benefit);
• credit bureaus to report account information, as permitted by law;
• banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria); and
• other third parties who provide us with relevant services where appropriate.

Regulators
We may disclose your personal information as required by law or governmental audit.

Law enforcement
We may disclose personal information if required:
• by a subpoena or court order;
• to comply with any law;
• to protect the safety of any individual or the general public; and
• to prevent violation of our customer relationship terms.

No selling
We will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.

Marketing purposes
We may disclose aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.

Employees
We may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.

Change of ownership
If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, we may assign our rights to the personal information we process to a successor, purchaser, or separate entity. We will disclose the necessary details to you at the stage we deem it necessary. We are not obligated to divulge any possible change of ownership during the due diligence investigation stage, as it applies. If you are concerned about your personal information migrating to a new owner, you may request us to delete
your personal information.

Security
We take the security of personal information very seriously and always do our best to comply with applicable data protection laws. We authorize access to personal information only for those employees who require it to fulfil their job responsibilities. We implement disaster recover procedures where appropriate.

Accurate and up to date
We will try to keep the personal information we collect as accurate, complete and up to date as is necessary for the purposes defined in this policy. From time to time, we may request you to update your personal information through authorised phone calls or mail.

Retention
We will only retain your personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:
• retention of the record is required or authorised by law; or
• you have consented to the retention of the record.

During the period of retention, we will continue to abide by our non-disclosure obligations and will not share or sell your personal information.

We may retain your personal information in physical or electronic records at our discretion.

Transfer to another country
We may not transfer your personal information outside the country from which it was collected to a foreign country without your permission.

Updating or removing
You may choose to correct or update the personal information you have submitted to us, by contacting us by phone or email.

Limitation
We are not responsible for, give no warranties, nor make any representations in respect of the privacy policies or practices of linked or any third-party websites.

Enquiries
If you have any questions or concerns arising from this privacy policy or the way in which we handle personal information, please contact us.

Revision history
3 June 2021