Delsey Australia Pty Ltd Privacy Policy
This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from www.delseyaustralia.com.au (the “Site”).
We are committed to compliance with privacy laws which apply to our businesses and which set out standards for the management of personal information. This policy outlines our personal information management practices applying to the personal information of individuals in respect of their dealings with us, specifically:
- the kinds of personal information we collect and hold;
- how we collect and hold it;
- the purposes for which we collect, hold, use and disclose it;
- your right to access and seek correction of it;
- how you may complain about privacy matters; and
- our sharing of your personal information overseas.
There are some matters to which this policy does not apply. These are referred to at the end of this policy.
WHO ARE WE?
In this policy, ‘we’ and ‘Delsey' are, individually and collectively, DELSEY AUSTRALIA Pty Limited ACN 168 732 330 of PO Box 465 Cronulla NSW, 2230 and its related bodies corporate, including DELSEY, a French société anonyme with registered office at 215, avenue des Nations 93290 Tremblay en France. Established in France in 1946, Delsey manufactures, markets and distributes luggage and travel accessories worldwide.
PERSONAL INFORMATION WE COLLECT
The personal information we collect and hold is what we consider reasonably necessary for our business functions and activities. When we collect and hold personal information, it is generally of the kind we ask for in order to provide our products to you. This personal information may include your first name, surname, postal address, email address, phone numbers and date of birth. On occasions, we may also receive sensitive information and any other information which you consent to give us and to which we are permitted to collect under law. It will also extend to other personal information you make available to us including to create an account with us.
- When we collect personal information about you, we do so by making a record of it. We do this when:
- you communicate with us online, for example when you create account with us or place an order with us;
- you subscribe to our newsletter;
- you take part in any trade promotions, testimonials, surveys or focus groups we are involved in conducting;
- you deal with us in other ways involving a need for personal information to be provided such as when you make contact with us.
When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information.”
We collect Device Information using the following technologies:
- “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
- “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
- “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers, Paypal or Stripe username, email address, and phone number. We refer to this information as “Order Information.”
When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.
You have the option of not identifying yourself or of using a pseudonym when dealing with us. But not where this is impractical or where the law or a court order provides otherwise. Given that we may need to arrange delivery of products or facilitate the provision of services to you, it is often not possible to utilise our service without identifying yourself.
Personal information we hold is generally stored in computer systems. These may be operated by us or by our service providers.
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
WHY DO WE COLLECT, HOLD, USE AND DISCLOSE YOUR PERSONAL INFORMATION?
When we collect, hold and use your personal information, we do so primarily to:
- ensure that our products and services offered to you are tailored to your specific needs;
- maintain our customer records;
- allow you to participate in Delsey activities and promotions from time to time;
- respond to any request for products or services;
- fulfil orders placed with us by any means (including through our Site);
- provide newsletters; and
- maintain a record of enquiries, complaints and adverse event reports relating to Delsey products and services.
We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).
We may use some of your personal information to market to you and to others and for incidental purposes. Not all information collected in respect of you is used for marketing and the majority of information is collected solely for the purpose of providing products, access to the website and any account you may have with us, and our services to you.
We disclose personal information we collect for those purposes, and for incidental purposes. For example, we may disclose your personal information within our group, to service providers who assist us in our day-to-day business operations and as part of buying or selling businesses.
We may collect, hold, use and disclose your personal information for other purposes which are within reasonable expectations or where permitted by law. When marketing to you, your personal information is only ever used or disclosed for our own purposes. You may opt out of our direct marketing to you. Our direct marketing materials will tell you how to do this.
We may de-identify your personal information. We may do this for use and disclosure of the anonymous data for various data analytics purposes.
We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use NETO to power our online store--you can read more about how NETO uses your Personal Information here: https://www.netohq.com/privacy-policy. We also use Google Analytics to help us understand how our customers use the Site.
You can read more about how Google uses your Personal Information here: www.google.com/intl/en/policies/privacy. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
BEHAVIOURAL ADVERTISING
As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
You can opt out of targeted advertising by:
- FACEBOOK - https://www.facebook.com/settings/?tab=ads
- GOOGLE - https://www.google.com/settings/ads/anonymous
- BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.
HOW CAN YOU ENQUIRE ABOUT, ACCESS AND CORRECT YOUR PERSONAL INFORMATION?
We will provide you with access to any of your personal information we hold (except in limited circumstances recognised by law). If you wish to access your personal information or have an enquiry about privacy, please contact our Privacy Officer at:
Privacy Officer
- Delsey Australia Pty Ltd
- Post: Suite 305, 30 Kingsway CRONULLA NSW 2230 or PO Box 465, CRONULLA, NSW, 2230
- Email: contact[at]delseyaustralia.com.au
Telephone: +61423666962
Before we provide you with access to your personal information we may require some proof of identity. We may charge a reasonable fee for giving access to your personal information if your request requires substantial effort on our part.
If you need to correct personal information we hold, please contact our Privacy Officer at one of the above contact points.
HOW CAN YOU COMPLAIN ABOUT OUR MANAGEMENT OF PERSONAL INFORMATION?
If you wish to complain about a breach of the privacy rules that bind us, you may contact our Privacy Officer at one of the above contact points. We may ask you to put your complaint in writing and to provide details about it. We may discuss your complaint with our personnel and our service providers and others as appropriate.
Our Privacy Officer will investigate the matter and attempt to resolve it in a timely way. Our Privacy Officer will inform you in writing about the outcome of the investigation. If our Privacy Officer does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, our Privacy Officer will inform you that your complaint may be referred to the relevant privacy regulator for further investigation and will provide you with the regulator’s contact details.
OUR SHARING OF YOUR PERSONAL INFORMATION OVERSEAS
We may allow your personal information to be shared with those who are in countries other than your own location. We do this:
- where we have made a business decision to store our data with a trusted service provider who is in the business of providing data storage and processing services. Examples are those who store and process our email and mobile application data. These services commonly involve diverse geographic locations which change from time to time for reasons which include data protection and processing efficiency. Where these services are used by us, it is not practical for us to notify you of which country your personal information may be located in;
- for disclosures between our group companies. Desley Australia Pty Ltd's main business location is in Australia but we do business in a number of countries, including New Zealand, and some of our group companies, including our parent companies, are based in other countries including France and Hong Kong, China; and
- when our business that collected your personal information is in a different country to your location.
MINORS
The Site is not intended for individuals under the age of eighteen (18).
CHANGES
This privacy policy is current at the date below. We may change it periodically. If we propose to change this policy, we will display at least 2 weeks’ prior notice of the change on our website at www.delseyaustralia.com.au. Please return periodically to review our privacy policy and ensure your understanding is up to date.
PAYMENT INFORMATION
All pages that require you to enter your personal information or payment details on our site use 128 bit SSL encryption. To ensure that the page you are viewing uses 128 bit SSL encryption, you should look for the padlock icon in your browser.
OTHER PRIVACY TERMS AND LIMITS OF THIS POLICY
This is a policy only. There may be additional privacy notices and terms relevant to you depending on the nature of your dealings with us. We have separate charters concerning our employees – this policy does not apply to the personal information of our employees in their capacity as such.
Although we offer you access to external websites through the links we have provided, those websites are not subject to our privacy standards, policies and procedures. We recommend that you make your own enquires as to the privacy policies of these third parties. We are in no way responsible for the privacy practices of these third parties.
MORE INFORMATION
More information about privacy law and privacy principles is available from the privacy regulator. The privacy regulator in Australia is the Privacy Commissioner: www.oaic.gov.au (email: enquiries@oaic.gov.au).
Last updated: August 2018
