Respecting your privacy and the law – our commitment to you
We recognise that your personal information is important to you and we share your concerns about how and what personal information is collected, used and shared. Your rights to privacy are protected by law, and this policy does not limit those rights.
We are committed to safeguarding your personal information and will always handle your personal information securely and carefully. We comply with all applicable data protection and privacy legislation and codes affecting your personal information.
From time to time and in line with customer expectations and legislative changes, our Privacy Policies and procedures will be reviewed and, if appropriate, updated. This policy was last updated in March 2017.
What personal information do we collect?
The personal information we collect is in most cases supplied by you when you place an order, register on our website to receive direct marketing materials, open an account with us or to provide feedback to us. Personal information may include:
- name and contact details (eg. delivery address, phone number, email address);
- date of birth;
- other information you may supply us; or
- transaction information (eg. your credit or debit card details).
Although you have the option to use a pseudonym when dealing with us, we will be unable to provide all our services unless you use identifiable information (eg. if you wish to complete any online transaction with us, use our lay-by service, participate in our loyalty programs or enter a promotion or competition). You can choose not to provide us with certain information, for example, you can choose to use our website without creating an account. However, this may restrict our ability to provide you with our services or access to certain features on our websites.
We also collect information from you automatically. Please see “Information collected automatically – Cookies etc.” below for more information about how we collect your information in this way.
Why do we collect your personal information?
In addition to any purpose notified to you at the time of collection, we collect, hold, use and disclose your personal information so we can:
- complete transactions and administer our relationship with you (including refunds and our lay-by service);
- investigate and respond to your questions, comments or feedback in relation to our products or services;
- better understand your requirements and preferences and improve our service to you;
- provide you with information about our products or services;
- identify and inform you about other products, services or offers that may be of interest to you;
- facilitate the running of, and your participation in, loyalty programs;
- facilitate the running of, and your participation in promotions and competitions;
- monitor activity on our website (for the purpose of maintaining the security of the website);
- compile customer databases to enable us to market the Just Group’s brands more accurately;
- comply with our legal obligations (including in relation to health and safety matters or matters relating to our employees or applicants for employment); and
- help us gain a better understanding of your likes and dislikes, so as to improve our website, marketing strategies and the products and services generally offered by us.
Your email address
We will only record your email address if you provide it to us. We will only use it to send you information you have requested about any of the services or products we provide through our website, or for another use for which you have provided it. It will not be used for any unauthorised purpose or disclosed without your consent (unless permitted by law). By providing us with your email address, you will have given your consent to receive direct marketing materials from us together with other Just Group brands or carefully selected third parties. If you do not wish to consent or receive any communication from us, you can select the ‘unsubscribe’ link at the bottom of any email we send you, or you can notify firstname.lastname@example.org.
As part of our commitment to maintaining your privacy, the Just Group does not condone unsolicited commercial electronic messages or ‘spam’. We will only send commercial electronic messages (ie. emails) with the addressee’s express or inferred consent to receive it.
When you enter a competition through our website, social media channels or in our stores, you may be required to provide information to satisfy the entry conditions. Entry constitutes entrants' consent to their personal information to be used by the Just Group’s brands for compiling its customer database and for marketing purposes. The Just Group may provide you with joint promotional offers in conjunction with other third parties. These promotional offers are developed in line with your needs, but should you not wish to receive this information, you can select the ‘unsubscribe’ link at the bottom of any email we send you, or you can notify email@example.com.
Information collected automatically – Cookies etc.
Whenever you visit our website, our servers automatically record information about your usage of our website through ‘cookies’ and clickstream data.
Cookies are small pieces of information stored by your browser on your computer or mobile device. Cookies and clickstream data are used to maintain session information between your browser and our website and identify things related to your use of the website such as the time, date and URL of the pages you visit, your IP address, your location and browser software. Some computers and mobile devices also permit your location to be shared with us (often referred to as geo-location data). Most browsers can notify you when a new cookie is received, or let you turn off cookies or geo-location services altogether. Turning off these services may mean some features on our website are not available to you.
We use information obtained this way in order to learn about your preferences so that we may improve our website and the service offered through it.
We use both first party and third party cookies. First party cookies are those which we use. Third party cookies originate from one of our partners or service providers.
Cookies let you log in and out of your account.
Cookies are just one way we protect you from security risks. For example, we use them to detect when someone might be trying to hack your account.
We use the following third party cookies:
When do we disclose your personal information to third parties
We will often need to pass your personal information to companies who perform part of our service delivery. The relevant organisations include those:
- involved in providing, managing or administering your product or service such as third party suppliers, other Just Group organisations, loyalty and affinity program partners, printers, posting services and call centres;
- which are Just Group brands or carefully selected third parties who wish to tell you about their products or services that might better serve your online and lifestyle needs, promotions or other opportunities, where you have opted to receive these;
- involved in maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems;
- involved in a transfer of all or part of the assets or business of a Just Group organisation;
- involved in the payments system including financial institutions, merchants and payment organisations;
- as required or authorised by law, for example, to government or regulatory bodies for purposes related to public health or safety, the prevention or detection of unlawful activities or to protect public revenue; or
- where you have given your consent.
Your personal information may be disclosed by us for a secondary purpose:
- where you have consented to the use or disclosure; and
- if you would reasonably expect us to use or disclose the information for a secondary purpose which is directly related to the primary purpose of collection; or
- if required or permitted by law or by a court/tribunal;
- if we reasonably believe it is necessary for law enforcement related activities.
Because we operate throughout Australia and New Zealand (and, in the case of Smiggle, Singapore, Hong Kong, Malaysia, Ireland and the United Kingdom), and as noted above because we use third parties to administer some of our service delivery, some of these uses and disclosures may occur outside of your country of residence. The countries where these service providers are located vary, but include Australia, New Zealand, Singapore, the United Kingdom, Ireland, Hong Kong, Malaysia and the USA. We will take reasonable steps to ensure that any overseas recipient does not breach relevant privacy laws or principles.
Keeping your personal information accurate and up-to-date
We aim to make sure that the personal information we collect, use or disclose is accurate, complete, up-to-date and relevant, having regard to the purpose of use or disclosure. We will take reasonable steps to make sure this is the case. This way, we can provide you with better service.
If you believe your personal information is inaccurate, incomplete, not up to date, not relevant or misleading, please log in to your registered account to correct your personal information. If you do not have a registered account or are having trouble updating your personal information, let us know (see Contact Us). We will take such steps as are reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date , relevant and not misleading.
Your privacy on the Internet
We take care to ensure that the personal information you give us on our website is protected from misuse, interference and loss, unauthorised access, modification or disclosure. For example, our website has electronic security systems in place, including the use of firewalls and data encryption. User identifiers, passwords or other access codes may also be used to control access to your personal information.
Links to Other Sites
You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to ascertain their privacy standards, policies and procedures.
How can I access my personal information?
You have a right to gain access to your personal information that we hold. This is subject to some exceptions allowed by applicable law. Factors affecting a right to access include:
- access would pose a serious threat to the life or health or safety of any individual or to public health or safety;
- access would have an unreasonable impact on the privacy of others;
- a frivolous or vexatious request;
- access would reveal evaluative information generated by us in connection with a commercially sensitive decision making process;
- access would be unlawful;
- access would prejudice enforcement activities conducted by an enforcement body;
- legal dispute resolution proceedings with you where the information would not be accessible in the process of discovery in those proceedings ;
- denying access as required or authorised by or under law or court/tribunal order.
We will give you reasons if we deny access (except to the extent that having regard to the grounds for the refusal, it would be unreasonable to do so).
Requests regarding your personal data must be made in writing. Please contact us if you require a form requesting access (see Contact Us).
We take all reasonable steps to protect all personal or company information from misuse, loss, interference, unauthorised access, modification or disclosure.
Your information is stored securely whether in an electronic or physical form. For example, only personnel requiring access to the information are allowed access. All personal, company or confidential information is stored in secured premises or in electronic databases requiring logins and passwords.
Some information is kept for a number of years to comply with applicable legal requirements. Any personal information that is no longer needed is destroyed or de-identified.
Contacting us or making a complaint