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Gazal Corporation’s Privacy Policy

Respecting your privacy

What kind of personal information does Gazal Corporation collect and hold?

How and why does Gazal Corporation collect and hold your personal information?

How does Gazal Corporation use your personal information?

In what circumstances will Gazal Corporation disclose your personal information?

Who may we disclose your personal information to?

Direct marketing

Does Gazal Corporation disclose your personal information to overseas recipients?

Use of Government Identifiers

Information security and website usage

How you can access or correct your personal information

How you can notify us of a privacy concern or contact our Privacy Officer/Data Protection Officer

Respecting your privacy

Gazal Corporation is committed to handling your personal information/ data in an open and transparent way.

This Privacy Policy applies to Gazal Corporation Limited (ACN 004 623 474) and its related bodies corporate (collectively referred to as “Gazal Corporation”, “we”, “our” and “us” and severally referred to as a “Gazal Corporation entity”).

Gazal Corporation is bound by the Privacy Act 1988 (Cth) and Privacy Act 1993 (NZ). We will only collect and use personal information in accordance with our legal obligations and this Policy. ‘Personal information’ means information which identifies you as an individual or from which you can reasonably be identified.

Gazal Corporation may also be subject to the requirements of the European Union General Data Protection Regulation (the GDPR), as it may (from time to time) collect personal data of EU residents or offer goods and services to individuals in the EU. As part of our Privacy compliance framework we have appointed a ‘data protection officer’ to monitor and advise on compliance with the GDPR and with internal privacy policies and procedures, and their contact details can be found in this Policy.

This Policy outlines our personal information management practices. It relates to the personal information that we collect from customers, suppliers, employees, contractors, visitors to our website, any apps we may use, social media and any other digital services or collection methods that we may employ. By providing your personal information to Gazal Corporation, you consent to and acknowledge our personal information handling practices as outlined in this Privacy Policy, unless you tell us to the contrary by contacting our Privacy Contact Officer/ Data Protection Officer.

There may be additional privacy notices and terms that are relevant to you depending on the nature of your dealings with us (e.g. use of our online sites, membership of loyalty programs, entry into competitions etc).

Where we can, we will allow you to deal with us anonymously or by using a pseudonym. However, in some circumstances, this may not allow us to be able to provide you with a service (such as deliveries etc). We will inform you if it is possible for an interaction to occur on an anonymous basis and, where it is, it will be optional for you to provide personal information. If you have any questions regarding Gazal Corporation’s Privacy Policy, please call our Privacy Officer/ Data Protection Officer in Australia on 02 93162800 or email us at privacy@gazal.com.au. If you would like Gazal Corporation to send you a copy of this policy, please contact us and we will do so.

What kind of personal information does Gazal Corporation collect and hold?

Gazal Corporation collects the personal information of its customers, members of the public, staff and other individuals who have dealings with Gazal Corporation for administrative needs, to conduct its business, for legislative compliance or for market/research purposes. Any personal information that you provide via our websites or directly is collected and managed by Gazal Corporation. The personal information that we collect and hold is what is reasonably necessary for our business functions and activities. The nature and amount of information we collect will depend on the purpose for which it is being collected.

The types of personal information Gazal Corporation may collect includes (but is not limited to):

  • name;
  • date of birth;
  • gender;
  • marital status and family details;
  • residential address;
  • email address;
  • contact telephone numbers;
  • identification details;
  • testimonials or opinions;
  • photos of individuals (possibly including recordings on video and audio surveillance devices in our premises);
  • financial/ purchase information;
  • records of written or verbal contact with Gazal Corporation, including voice recordings of telephone conversations you have had with us;
  • CV details and work experience if you have applied for an employment position;
  • details about your activities, including but not limited to sporting and other lifestyle interests; and/or
  • information related to use of our online services such as device identifiers (IP address), location data, dates, times, file metadata, referring website, data entered and user activity (such as links clicked).

The nature and amount of information collected will depend on the purpose for which it is being collected.

Online purchases

When you make a purchase via one of our online stores or apps we will collect information such as your name, shipping and billing address and contact details such as telephone and email address, ordered and returned products, delivery information and invoice information. We also collect data on your usage vouchers and/or gift cards.

You will be given the option to create a personal account with the brand. If you choose to do so, we will ask you to consent to receiving newsletters and other (electronic) communications via post, email and/or SMS. If you logon to your account through Facebook, Google+, Instagram or other social media accounts, we collect profile information from your social media account including name and email address. Please note that when accessing your account through a social media platform, the social media provider will be notified of your access to the account. Please refer to the privacy notice of the respective social media provider(s) for more information on how your personal information is stored.

Loyalty programs

You may be offered the option to join one of our loyalty programs. On enrolment we will collect your profile information and your purchase history and the contents of your online wish list. We do not collect information related to the payment instrument that you use such as credit card information.

When you visit a store

In our store, depending on whether you are a consumer or small business, we collect your company name, personal name, address and other relevant personal details if this is needed to comply by local fiscal and legal requirements such as to provide a tax receipt.

Third Party Websites

If you provide your personal information to a third party via a link from the Gazal Corporation website (such as when you enter a competition or register for another type of promotion), that information is collected and managed by those third parties. You should familiarise yourself with their Privacy Policy prior to deciding whether you wish to provide them with your information.

Personal information to make automated decisions

If you interact with chatbots (automated messengers) we will record what you respond to these chatbots, how you interact with them and we will store data related to the device that you use. Depending on the platform for the chatbot and your permission, your device data may include: IP address, social medical handle, time zone, country and GPS location. The platform that provides the chatbot may also collect some of this data. For example, if the chatbot is provided on Facebook, this platform will collect your user data as well.

Information that we automatically collect

We, along with our third party service partners, may automatically collect information about you when you use the site to help us measure and determine how visitors use the site. The information automatically collected may include: device ID, device type, browser type and version, geo-location information, computer and connection information, statistics on page views, traffic to and from the site, ad data, IP address, referring website address and standard web log information.

How and why does Gazal Corporation collect and hold your personal information?

Gazal Corporation will only collect personal information about you by lawful and fair means, and not in an unreasonably intrusive manner. Gazal Corporation only collects personal information for purposes that are directly related to our business activities, and only when it is necessary for or directly related to such purposes.

It is our usual practice to collect personal information about you (and possibly about your family) directly from you. This is done when we make a record of the personal information that is provided to us when you:

  • visit one of our websites;
  • fill out a hard copy or digital form;
  • give information to our sales representatives;
  • provide a testimonial, survey response or are part of a focus group;
  • apply for membership to any of our loyalty and marketing programs;
  • subscribe to marketing and sales materials or communications;
  • order or purchase goods or services from us;
  • request delivery or return of products;
  • make a purchase where we request to verify your identity;
  • complete and return to us a wholesale account application form;
  • post a review or comment on one of our websites or social media pages or post a rating or review or other user generated content on one of our websites or apps;
  • enter one of our competitions (or competitions run by our partners or associates);
  • provide services to us;
  • participate in promotional activities;
  • click on one of our advertisements or offers (by using technology such as ‘cookies’);
  • interact with us in relation to employment services, human resource management, and other corporate service functions;
  • communicate with us (including e-mail and telephone) for security, dispute resolution and training purposes and if we operate video and audio surveillance devices in our premises;
  • make a complaint or legal/ liability claims against us; and/or
  • contact us by telephone, mail, email, online or by any digital form or social media.
  • Most of the personal information that we hold about you will be from your direct dealings with us, But we may also collect your personal information from a publicly available source. We will only do this if you have consented to the collection of your personal information, or if you would reasonably expect us to collect your personal information in that way.

    We may collect personal information from our business or related entities and affiliates which collected your information in a different country.

    We may also collect information about you by accessing data from other sources and then analysing that data with the information that we already hold about you in order to learn more about your preferences and interests.

    If we receive information about you from a third party and it is not information we need in respect of our business activities, we will destroy or de-identify that information (provided it is lawful to do so).

    Minors are not allowed to provide any personal information to Gazal Corporation without the consent of a parent or guardian.

How does Gazal Corporation use your personal information?

Your personal information can be accessed by our employees to the extent that this access is required to enable them to perform their work for us.

We use your personal information for a variety of reasons including to:

  • manage your requests for products and services including delivery, processing payments, providing refunds, discounts and incentives;
  • answer your inquiries and deliver customer service to you;
  • to tell you about other products that we think may be of interest to you;
  • to enable us to undertake a credit assessment;
  • maintain and improve customer services, including conducting product and market research and analysis;
  • to improve our operational processes, enhance your customer experience and to monitor and review our compliance with relevant regulations and codes of conduct in our dealings with you;
  • to monitor the quality, safety and efficacy of our products;
  • administer programs or events that are sponsored by Gazal Corporation or our affiliates;
  • generate customer lists for the purposes of market research;
  • facilitate your interaction with us on our website;
  • consider any application for employment made by you;
  • meet our legal obligations and to notify you of matters that we are required to do so by law (such as product recalls);
  • interact with Regulators or other Government agencies;
  • manage and resolve any legal or commercial complaints and issues;
  • investigate fraud and to carry out loss prevention activities;
  • as part of buying or selling our businesses; and/or
  • carry out internal functions including training.

Whilst you may opt not to provide us with your personal information, you should be aware that without this personal information, we may not be able to provide you with some of the services and/or products you are seeking.

In what circumstances will Gazal Corporation disclose your personal information?

In the course of conducting our business and providing our products and services to you, we may disclose your personal information.

We only disclose personal information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or activities. We do not give it to anyone else unless one of the following applies:

  • you have consented to the disclosure;
  • you would reasonably expect, or have been told (for example, by means of this Privacy Policy), that your information will be passes on to those individuals/ entities/Gazal Corporation affiliates bodies or agencies; and/or
  • it is otherwise required or authorised by law.

If we engage third party agents or contractors, we will take all reasonable steps to ensure that they do not breach privacy requirements in relation to the information, before we share your personal information with them.

Who may we disclose your personal information to?

We may disclose your personal information to:

  • our business affiliates or related entities;
  • overseas Gazal Corporation affiliates and other organisations engaged to assist Gazal Corporation in human resource administration or to provide employee benefits;
  • professional advisers (such as lawyers, accountants or auditors) to the extent that is reasonably required;
  • payment systems operators and financial institutions;
  • third party service providers that provide us with communication (e-mail) or data storage services;
  • technology services including application, development and technical support, processing, storing, hosting and data analysis;
  • travel agents and other travel/ event related service providers involved in the organisation of conferences and similar events;
  • administrative services, including mailing services, printing, archival and contact management services;
  • third party agents or contractors with whom we contract in the ordinary course of business;
  • organisations authorised by Gazal Corporation to conduct promotional, research or marketing activities;
  • upon lawful request from law enforcement agencies or government authorities; and/or
  • any persons acting on your behalf including those persons nominated by you, executors, trustees and legal representatives.

In all circumstances where your personal information is disclosed, we will take all steps reasonable to ensure that those third parties undertake to protect your privacy.

Direct marketing

We are committed to compliance with all laws and requirements relating to the use of your personal information for direct marketing.

When you provide your personal details, you may consent to us using your personal information for direct marketing purposes (for an indefinite period). From time to time, we may contact you with information about products and services offered by us and our related entities and our business partners or affiliates, which we think may be of interest to you. When we contact you it may be by mail, telephone, email, SMS or via social media. These communications may relate to products and services that we and our affiliates provide, and other products that may be of interest to you.

Gazal Corporation also hopes to deliver to you advertising for products and services that you need or want. For example, Gazal Corporation partners with websites with whom you have shared your interests and asks that they serve our ads to users who have expressed an interest in Gazal Corporation products. We may also partner with advertising companies to serve you ads based on your web browsing activity, purchases and/or interests. Some techniques for delivering content based on your interests are referred to as online behavioural advertising.

If you do not wish to be contacted by Gazal Corporation, please call our Privacy Officer/ Data Protection Officer in Australia on 02 93162800 or email us at privacy@gazal.com.au. If you would like Gazal Corporation to send you a copy of this policy, please contact us and we will do so.

Does Gazal Corporation disclose your personal information to overseas recipients?

In some circumstances, Gazal Corporation may disclose your personal information to overseas recipients. If this occurs, we take steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the relevant privacy laws in relation to that information.

Your personal information may be disclosed to other Gazal Corporation entities, business partners and service providers in Australia and overseas.

Our service providers are mainly located in Australia, New Zealand and the United States of America. However, from time to time we may need to engage a service provider in another country. We may also be required to report to regulatory authorities, within or outside of Australia, as required by law.

Your personal information may be stored in a secure and/or encrypted form overseas (e.g. in data storage and cloud computing facilities operated by us or by third parties on Gazal Corporation’s behalf). By providing us with your personal information, you are agreeing to the disclosure of your personal information to third parties operating outside of Australia. Gazal Corporation will take all reasonable steps to ensure that any personal information we disclose overseas is handled in accordance with the law.

Sometimes we make the business decision to use third party platforms and services to process sales, provide web support, send marketing messages, deliver products or otherwise provide data storage and processing services. These services are hosted and managed by organisations other than ourselves, and some of these services are hosted overseas. These services may also involve geographic locations which change from time to time which include data protection and processing efficiency. Where these services are used by us, it may not be practicable for us to notify you of which country your personal information may be located in.

Use of Government Identifiers

Gazal Corporation will not use Government Identifiers, such as Medicare numbers, or a driver's licence number as its own identifier of individuals.

Information security and website usage

We hold personal information electronically and in hard copy form, both at our own premises in Australia and with the assistance of our service providers. We have a number of security controls in place and we take all reasonable steps to ensure that your personal information is stored securely and is protected from misuse and loss and from unauthorised access, modification or disclosure.

Our computer systems may be operated by us or by our service providers. In all cases, we have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, the personal information that we handle. Examples of these measures include:

  • control of access to personal information through access and identity management systems (such as passwords); and
  • Gazal Corporation personnel are bound by and trained on internal information security policies and are required to keep personal information secure at all times.

Gazal Corporation also has policies in place for data retention across all key areas. We keep your personal information for as long as it is required to provide you with the products you requested from us and to comply with legal requirements. If we no longer require your personal information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or de-identify your personal information.

Our websites are professionally hosted and operate in a secure environment. You should however be aware that there is always an inherent risk in transmitting your personal information via the Internet.

Cookies are pieces of information that a website transfers to your computer for record-keeping purposes. Cookies help provide additional functionality to the web site or to help us analyse site usage more accurately. We use information collected from cookies to better understand, customise and improve user experience with our websites, services and offerings, as well as to manage our advertising. For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to one of our sites. Also, we may use web analytics services that leverage cookies to help us to understand how visitors engage with and navigate our site (e.g. how and when pages in a site are visited and by how many visitors).

We are also able to offer our visitors a more customised, relevant experience on our sites using cookies by delivering content and functionality based on your preferences and interests. If you have provided us with personal information (e.g. through a registration or a request for certain materials), we may associate this personal information with information gathered through cookies. This allows us to offer increased personalisation and functionality.

In all cases in which cookies are used, the cookie will not collect personal information except with your explicit permission. Your web browser can be set to allow you to control whether you will accept cookies, reject cookies or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognise you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to precent your browser from accepting cookies.

Whilst links to third party websites are provided on our website, we are not responsible for the content or practices of these third party websites. These links are provided for your convenience and do not represent Gazal Corporation's endorsement of any linked third party website. We recommend that you check the privacy policies of these third parties prior to providing them with your personal information.

How you can access or correct your personal information

You can request access to the personal information we hold about you at any time, and we will provide you with that information unless we are prevented by law from giving it to you. If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.

You will not be charged for accessing your information, although we might have to charge the reasonable cost of processing your request, including photocopying, administration and postage. We will advise you of any fee payable before we process your request.

If you believe that your personal information is not accurate, complete or up to date or you wish to request that we delete (or refrain from processing) any of your personal information that we handle, please call our Privacy Officer/ Data Protection Officer in Australia on 02 93162800 or email us at privacy@gazal.com.au. If you would like Gazal Corporation to send you a copy of this policy, please contact us and we will do so.

How you can notify us of a privacy concern or contact our Privacy Officer/ Data Protection Officer

If you:

  • have queries, concerns or complaints about the manner in which your personal information has been collected or handled by Gazal Corporation; or
  • would like to request access to, correction or deletion of the personal information we hold about you;

please call our Privacy Officer/ Data Protection Officer in Australia on 02 93162800 or email us at privacy@gazal.com.au

We may ask you to put your request or complaint in writing, and to provide further details about it. Our Privacy Officer/ Data Protection Officer will investigate the matter and attempt to resolve it in a timely way.

If you consider your privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, you can contact:

Australia

The Office of the Australian Information Commissioner on 1300 363 992 or visit their website at www.oaic.gov.au.

New Zealand

Privacy Commissioner (New Zealand) on 0800 803 909 or visit their website at www.privacy.org.nz.

This privacy policy is effective from July 2018. From time to time, our privacy policies and procedures will be reviewed and, if appropriate, updated. If any changes are made to this policy, these will be posted on our website. We are constantly developing and enhancing our use of online technologies and make reasonable efforts to ensure that we keep this Policy and related documents up to date in this regard. Please check back on a regular basis to ensure you are familiar with our current practices.

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