Which parts of this policy apply to you?
26. However, your actual rights and the available complaints / remedies you may make use of, will change depending on what privacy laws apply to you. This privacy policy aims to comply with the privacy laws of these specific territories and has separate headings on each:
- Australia:
i. Laws: the australian privacy principles (apps) in the privacy act 1988 (cth), and requirements under the spam act 2003 (cth) (altogether the “AU Privacy Law”)
ii. Does this apply: these laws apply to you if you are a person (instead of a company). To clarify, australian privacy laws apply based on who the data collector is (who are certain australian businesses like us), instead of applying based on what the nationality the data subject is.
- Europe:
i. Laws: the general data protection regulation (eu 2016/679) (gdpr or “EU Privacy Law”)
ii. Does this apply: these laws apply if you are a resident of the european economic area (eea), which covers all countries in the european union (eu) and iceland, liechtenstein and norway. Please note switzerland and the united kingdom are not part of the eu or eea.
- United Kingdom:
i. Laws: the UK general data protection regulation (“UK GDPR”) and privacy and electronic communications regulations 2003 (“PECR”) (altogether the “UK Privacy Law”)
ii. Does this apply: these laws apply if you are located in or a citizen of the UK.
- United States of America:
i. Laws: while each state may pass their own privacy laws, we address the requirements for the state of California, which are considered to impose a high standard for privacy protection rights; we do this by complying with the following laws (which we refer to together as the us privacy law)- the California consumer privacy act (CCPA) and the children’s online privacy protection act (COPPA) (altogether the “US Privacy Law”)
ii. Does this apply: these laws apply if you are a resident of the state of California (CA), USA, and if the information is collected all or partly while you are in CA. For clarity, you are still covered if you are a CA resident and temporarily outside of CA.
- New Zealand:
i. Laws: privacy act 2020 no. 31 and the information privacy principles (the “NZ Privacy Law”)
ii. Does this apply: these laws apply if you are located in or a resident of NZ.
- Canada:
i. Laws: personal information protection and electronic documents act S.C. 2000, c. 5 (“PIPEDA” or the “CA Privacy Law”)
ii. Does this apply: these laws apply if you are located in Canada.
- Singapore:
i. Laws: the personal data protection act 2012 and the personal data protection regulation 2012 (together, the “SG Privacy Law”).
ii. Does this apply: these laws apply if you are located in Singapore.
- UAE:
i. Laws: the constitution of the UAE and the federal decree law no. 45 of 2021 concerning the protection of personal data (together, the “UAE Privacy Law:)
ii. Does this apply: these laws apply if you are located in the UAE
27. Regardless which privacy laws may apply to you, you may still contact us to resolve any concerns using the contact details and complaints handling process contained in this policy as-
- Your territory may in fact have privacy laws which we can or must comply with; and
- Even if your territory does not have privacy laws we are required to abide by, we may voluntarily choose (at our sole discretion) to respond to your request, as part of our goals to satisfy customers and be a socially responsible company that respects and protects privacy.
28. In this policy Protected Data refers to either:
- Personal Information, Sensitive Information and Credit Information, under the AU Privacy Law;
- Personal Data, under the EU Privacy Law;
- Personal Data, under the UK Privacy Law;
- Personal Information, under the US Privacy Law, noting that-
i. Personal information is information that identifies, relates to, or could reasonably be linked with you or your household. For example, it could include your name, social security number, email address, records of products purchased, internet browsing history, geolocation data, fingerprints, and inferences from other personal information that could create a profile about your preferences and characteristics. https://oag.ca.gov/privacy/ccpa
- Personal Information, under the NZ Privacy Law;
- Personal Information, under the CA Privacy Law;
- Personal Data under the SG Privacy Law; and
- Personal Data and Sensitive Personal Data under the UAE Privacy Law.
Is this policy a contract?
29. This privacy policy is not a contract itself. It is a compliance document, that is, it is a notice required by law for us to explain certain things to the public. However, there may be other contracts which can include all or part of this policy as relevant to those contracts.
30. Importantly, our website terms require you to have read and understood this policy and provide the following required consents (see at the end of this policy for a link to these terms along with links to other policies).
Types of data collected
31. We use your data to provide and improve the services. By using the services, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this privacy policy, the terms used in this privacy policy have the same meanings as in our terms and conditions (see at the end of this document for links to other documents).
Personal Data
32. While using our services, in particular when creating and registering your account, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("personal data"). Personally identifiable information may include, but is not limited to:
Types of data and their purpose
Names (first and last) -- subscription, purchase
Gender -- Subscription
Physical / postal address (for delivery of purchased goods) -- Purchase
Email Address -- Subscription, purchase
Phone number -- Subscription, purchase
Date of birth -- Subscription
Internet protocol (ip) addresses -- Marketing
Credit card information -- Purchase
Shopping preferences (your settings for product sizes, colours etc from our ecommerce page) -- Marketing, purchase
33. Here is a full description of the purposes mentioned in the above table:
- Subscription: when you subscribe with us (create an account) we will ask for these details.
- Purchase: when you make a purchase with us on our site, we will ask for this additional information to complete your purchase and obtain the delivery address details.
- Marketing: we use this information to help improve and tailor our services and prices.
34. We may use your personal data to contact you with notifications, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by turning off notifications within the app or following the unsubscribe link and the instructions provided in any correspondence we send.
Usage data and feedback (personal / deidentified)
35. We also collect information on how the service is accessed and used ("usage data"). This usage data may include information such as your device’s:
- Internet protocol address (e.g., ip address), or geo-location information;
- Browser type and browser version;
- The screens and interfaces within our service that you visit;
- The time and date of your visit;
- The time spent on those interfaces;
- Unique device identifiers (like any device id);
- Device type;
- Computer and connection information; and
36. We also can collect information provided by you in any feedback or correspondence from time to time with:
- Customer surveys;
- Details of the services we have provided to you or that you have enquired about, including any additional information necessary to deliver the services and respond to your queries; and
- Any other information necessarily required in order to facilitate and improve your dealings with us and the services.
Location data
37. We may use and store information about your location if you give us permission to do so (“location data”). We use this data to provide certain features within our services, as well as to improve and customise the services.
38. You can enable or disable location services when you use our services at any time by way of your device settings.
39. You are not required to provide your location data when using the services and can decline requests for location data. You may choose to either enter an address or postcode or simply view the locations on the map.
Identification, tracking & cookies data
40. We use cookies and similar tracking technologies to track the activity on our service and we hold certain information.
41. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our service.
42. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.
43. Examples of cookies we use are:
- Session cookies. We use session cookies to operate our service.
- Preference cookies. We use preference cookies to remember your preferences and various settings.
- Security cookies. We use security cookies for security purposes.
44. More information on cookies and which ones we use is set out in our cookie policy (see heading below “changes to this document and our other documents” for link to policy).
45. To provide clarification on possible identifiers for you-
- You may be able to browse our website anonymously if you disable any cookies and tracking;
- You may be able to browse our website pseudonymously, only being identified by the cookies and tracking ids from other analytics providers (see section on third parties for this).
- If you create an account with us, you:
i. May use your real name and details in creating an account; and
ii. May create a nickname to operate pseudonymously.
46. In compliance with the ipps we note that we do not attempt to use any identifiers used by other agencies for you, apart from those used for statistical or research purposes (such as via analytics providers)
Age-specific privacy (children and teenagers)
47. Our service does not address anyone under the age of 13 years’ of age ("children" / “child”).
48. We do not knowingly collect personally identifiable information of children.
49. If we become aware that we have collected personal data from children we will take steps to remove that information from our servers.
50. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us.
51. Our service does target and collect data from users, between the ages 13 years’ to 18 years’ of age (“teenager”).
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