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742x175 - Winter 2012 - Privacy

Freedom Privacy Policy


Steinhoff Asia Pacific Limited trading as Freedom and its Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth)) (collectively “Freedom”), recognises the importance of protecting the privacy and rights of individuals in relation to their personal information. This is our privacy policy and it tells you how we collect and manage your personal information.

We respect your rights to privacy under the Privacy Act 1988 (Cth) and we comply with all of the Act’s requirements in relation to the collection, management and disclosure of your personal information. For more information, visit www.oaic.gov.au.

What is your personal information?


When used in this privacy policy, the term “Personal Information” has the meaning given to it in the Act.  Generally, it includes any information that can be used to personally identify you.  This may include your name, address, telephone number, email address and occupation.  If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What personal information do we collect and hold?


We may collect the following types of Personal Information:
(i)    name, residential, mailing and email addresses;
(ii)    date of birth, gender, age, purchase history, income, occupation, hobbies and interests;
(iii)    details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
(iv)    any additional information relating to you that you provide to us directly through our website or indirectly through use of our websites or online presence, through our representatives or otherwise; and
(v)    information you provide us through our service centre, customer surveys or visits by our representatives from time to time.

Other information we may collect


We collect anonymous information on website activity. We use this data to evaluate our website’s performance and to improve the content we display to you.  To evaluate the effectiveness of our online advertising, we may use third parties to collect statistical data. No personal information is collected on these occasions. We may log IP addresses (the electronic address of a computer connected to the internet) to analyse trends, administer our website, track users’ movements, and gather broad demographic information.
Our website uses Google AdWords, Google Analytics, and the Google Display Network together to serve ads to you on other websites after you have visited our website. This practice is known as remarketing and is a tool that Google offers to businesses. If you would like to know more about the program, you can find out more here.  If you would like to opt-out of receiving advertising like this from Google, you can manage these settings by visiting the Google Ads Preferences Manager.

Use of cookies


Freedom uses tracking technologies such as cookies to recognise your browser each time it visits our site, and to track which pages you visit whilst on our site. We use this information to optimize our site and create a better online experience for you.  Cookies are pieces of information that a website transfers to a computer's hard disk for record keeping purposes. Most web browsers are set to accept tracking technologies such as cookies. These tracking technologies do not themselves personally identify users, although they do identify a user's browser. However, if you do not wish to receive any cookies, you may set your browser to refuse them.

How do we collect your personal information?


We collect your Personal Information directly from you unless it is unreasonable or impracticable to do so. When collecting Personal Information from you, we may collect in ways including:

•    through your access and use of our website;
•    during conversations between you and our representatives;
•    when you complete an application or purchase order or ask for a quote to be prepared;
•    when you apply for finance;
•    when you contact us for further information or register your details on our website;
•    your participation in surveys and other types of research;
•    when you enter a promotion, sweepstake, or contest hosted by Freedom;
•    when you subscribe to our mailing list;
•    when you apply for a franchise;
•    when you express interest in a particular Freedom service; or
•    when you submit a job application or résumé.

We may also collect information from third parties such as credit reporting agencies, law enforcement agencies, and other government agencies.

What happens if we can’t collect your Personal Information?


If you do not provide us with the personal information described above, some or all of the following may happen:
•    we may not be able to provide the requested products or services to you, either to the same standard or at all;
•    we may not be able to provide you with information about our products and services that you may want, including information about discounts, sales or special promotions; or
•    we may be unable to tailor the content of our website to your preferences and your experiences of our website may not be as enjoyable or useful.

For what purposes do we collect, hold, use and disclose your personal information?


Freedom uses, collects and holds your information to better understand your needs and provide you with better service. Freedom may share your Personal Information amongst Related Bodies Corporate of Freedom. Freedom also uses, collects, holds and discloses your Personal Information to:
•    to complete a transaction in store or online via our website;
•    to deal with your queries or customer service issues promptly whether by email, telephone or mail. We may also keep information on your communications with our customer service representatives;
•    to keep you up-to-date with products, services, events or promotions we think would be of particular interest through a variety of channels. You are able to "opt-out" from this activity at any time;
•    to enhance your customer experience in store and online and help us complete your transactions faster.
•    for planning, marketing or research purposes;
•    to provide you with access to protected areas of our website;
•    to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties.

Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

Disclosure of personal information


We may disclose your Personal Information to:
•    our employees, related bodies corporate, contractors or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
•    suppliers and other third parties with whom we have commercial relationships for business, marketing, and related purposes;
•    any organisation for any authorised purpose with your express consent; and,
•    to comply with any relevant law.

We may disclose Personal Information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.  We may disclose your personal information to entities located outside of Australia, including the following: our related bodies corporate, located in Europe, Asia and South Africa; and, our data hosting and other IT service providers, located in the United States and Asia.


Direct marketing materials


We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth).  If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.  

At Freedom we only want to communicate with you if you want to hear from us. If you would like to unsubscribe from receiving email Newsletters you can do so at freedom.com.au/unsubscribe at any time and for any reason.
Should you wish to be removed from all our mailing lists you can do so at freedom.com.au/opt-out.

We do not provide your personal information to other organisations for the purposes of direct marketing.

Access and correction


You may request access to any personal information we hold about you at any time by contacting us (see details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you and, if so, the fees will be $25.00.  We will not charge for simply making the request and will not charge for making any corrections to your Personal Information.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it.  We will consider if the information requires amendment.  If we do not agree that there are grounds for amendment then we will add a note to the personal information stating you disagree with it.  

Breach of privacy

If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.   Our procedure for investigating and dealing with privacy breach may involve: making an assessment; taking immediate steps to contain the breach; designating a person/team to coordinate a response; consider what Personal Information is involved; determine whether the context of the information is important; establish the cause and extent of the breach; identify what is the risk of harm (if any); conduct a risk analysis on a case-by-case basis, and consider whether notification is required.
Third-party web sites

Links to third party web sites on www.freedom.com.au are provided solely as a convenience to you. If you use these links, you will leave Freedom's site. Freedom is not responsible for any of these sites, their content or their usage of your personal information.

Security

Freedom is committed to ensuring the security of your personal information and we will take all reasonable precautions to protect this information from loss, misuse or alteration.

Changes to this statement
Freedom may make changes to this Privacy Policy from time to time for any reason. We will publish those changes on our website on this page.  This policy was last updated on 11 March 2014.

Contacting us


If you have any questions about this policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.

We will treat your requests or complaints confidentially.  Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved.  We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

Please contact our Privacy Officer at:

Privacy Officer
Steinhoff Asia Pacific Limited trading as Freedom
1 Epping Road
North Ryde NSW 2113
Phone: 1300 135 588
Email: privacy@steinhoff.com.au