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NAPOLEON PERDIS APP PRIVACY POLICY
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1.      Our APP Privacy Policy statement

1.1    This is the APP Privacy Policy (APP Privacy Policy) of Napoleon Perdis Cosmetics Pty Limited ACN 098 111 776 and its subsidiaries and related companies (we, us, our etc.).

1.2    Our functions and activities include developing and selling our cosmetics and makeup products, developing and selling our fashion, homeware and lifestyle products, providing the services of our makeup artists and training in makeup artistry.

1.3    This APP Privacy Policy was last updated as at 11 March 2014 having regard to our functions and activities and the Australian Privacy Principles contained in the Privacy Act 1988 as amended or replaced from time to time (Act).

1.4    We acknowledge the importance of protecting the privacy of our customers and the other third parties who provide their personal information to us. We are committed to implementing practices, procedures and systems that will ensure that we comply with the Australian Privacy Principles and that will enable us to deal with inquiries or complaints from individuals about our compliance with the Australian Privacy Principles.

1.5    For the purposes of this APP Privacy Policy our customers include, without limitation, visitors to our web site, visitors to our stores and purchasers of our goods and services. This APP Privacy Policy is not intended to apply to our distributors or stockists or to our employees or job applicants, although we acknowledge that we still have legal obligations to protect the personal information of such people.

2.      Types of information we collect

2.1    When used in this APP Privacy Policy, the term “personal information” has the meaning given to it in the Act.  Personal information generally includes any information that can be used to personally identify a person. If you are one of our customers, the types of personal information we collect from or about you may include, but will not be limited to, your name, residential or business address, email address, post code, gender, age and date of birth, signature, telephone number, proof of identity (such as your drivers licence or passport details), financial information, and your image or likeness if you visit our stores. We do not collect your passwords other than in relation to our own online services.

2.2    If you communicate or connect with us through a social media service the information we collect from or about you may also include the user ID or user name associated with that social media service, any information or content you have permitted the social media service to share with us (such as your profile picture, email address, friends list or contacts list) and any information you have disclosed in connection with that social media service.   If you communicate or connect with us through a social media service, we may share your user name, picture, likeness and comments with other users of our services and with your friends or your contacts associated with your social media service. We may also share the same information with the social media service provider. By communicating or connecting with us through a social media service, you are authorising us to collect, store and share information in this way and you acknowledge that the social media service’s use of the shared information will be governed by the social media service’s APP privacy policy, over which we have no control. 

2.3    We may also collect information from or about you that may not be personal information for the purposes of the Act. This other information may be retained with your personal information and may include, without limitation, your shopping preferences, a list of goods and services you have purchased or may wish to purchase from us, your marketing preferences (including the type of marketing materials you wish to receive and the method of delivery e.g. email, SMS, direct mail, or other). This other information may also include device identification information obtained when you use a computer, mobile phone, smart phone, tablet, or other device to access our WiFi service or interact with us through our website or online store. Device identification information may include your device IMEI number, IP address, Mac address or other information identifying your Internet browser, the type of operating system you use, your IP address and the domain name of your Internet service provider.

2.4 We will not collect sensitive information about you unless you give us your consent and the information is reasonably necessary for one or more of our functions or activities.

3.      How and when we collect your personal information

3.1    We will only collect personal information by lawful and fair means.

3.2    When we collect personal information from you we will notify you of our identity and contact details and the main consequence (if any) for you if all or some of the personal information is not collected by us. If you don't provide your personal information to us we may not be able to provide our goods or services to you or communicate to you information about goods and services that you have purchased from us, or may intend to purchase in the future.  We may be unable to tailor the content of our marketing communications to suit your preferences and you may experience delays in your communications or other dealings with us.

3.3    We may collect personal information from you directly when we provide our goods or services to you.  We will usually tell you why we are collecting information, and how we propose to use it, when we collect the information although this will often be obvious in the circumstances. 

3.4    If it is unreasonable or impracticable to collect your personal information from you directly we may use agents or service providers to collect personal information for us.  In such circumstances we may also acquire lists from other sources, both from other companies and from other public documents. 

3.5    We may collect your personal information when you visit our website, use our WiFi services or any devices in our stores, have a conversation with us, complete purchase orders, registrations, requests or applications for our goods or services, communicate with us by any means, participate in any of our promotions, competitions or events, or apply to us for credit. We are not responsible for the collection or use of your personal information by the owners or operators of department stores, pharmacists, stockists or other third parties whose premises you may visit in order to purchase our goods and services.

3.6    We may hold your personal information in either electronic or hard copy form. If you provide information to us electronically we retain this information in our computer systems and databases.  These include computer software programs, Internet servers, hosted Internet solutions and cloud computing systems provided by third parties. If you provide information to us in hard copy (paper) this information is normally retained in our files and a copy is made to our electronic files.

3.7    If we receive personal information that we did not solicit, and would not have been entitled to solicit, we will destroy or de-identify the information unless it is contained in a Commonwealth record.

4.      Online privacy

4.1    Any information you voluntarily disclose online can be collected and used by others.  If you post personal information in publicly accessible online forums you may receive unsolicited messages from other parties in return.  We cannot prevent this. Any information posted on bulletin boards or communicated in chat areas becomes public information.  While we strive to protect and respect your privacy, we cannot guarantee the security of any information you disclose in a chat room or on a bulletin board. 

4.2    You are solely responsible for maintaining the secrecy of your own usernames and passwords and your account information. 

4.3    We may use temporary (session) cookies or permanent cookies when you access our web site.  Cookies are data that a web site transfers to an individual's hard drive for record-keeping purposes. Cookies can facilitate a user's ongoing access to and use of a site. They allow us to recognise your browser and track the web pages you have visited.  They also allow us to track usage patterns and to compile data that can help us improve our goods and services and target our advertising. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. 

4.4    We are not responsible for the content or practices of sites operated by any third parties that are linked to our sites.  These links are meant for the user's convenience only.  Links to third party sites do not constitute sponsorship, endorsement or approval by us of the content, policies or practices of those third party sites.  Once you have left our site via such a link, you should check the applicable APP privacy policy of the third party site.

4.5    You should always close your browser when you have finished your user session.  This is to ensure that others cannot access your personal information and correspondence if you share a computer with someone else or are using a computer in a public place like a library or Internet café. 

5.      Why we collect your personal information

5.1    We consider the collection of your personal information for the purposes described below to be reasonably necessary for one or more of our functions or activities.

5.2    The purposes for which we collect and use your personal information include without limitation, to provide you with goods and services that you have requested from us, to communicate with you (including communications about our goods and services, competition results, special offers, and events), to provide personalised content and advertising, to answer your questions and provide you with information or advice, to create orders, transaction records, agreements for the sale of goods or services, accounts, tax invoices or receipts, to carry out administration, marketing, planning, fraud and loss prevention activities, procurement, goods and services development, and quality control and research, to consider and respond to complaints made by you, to comply with laws or regulations or to comply with any directions given by regulators or authorities.

5.3    We will not use or disclose personal information for the purposes of direct marketing unless entitled to do so under the exceptions contained in the Act. Unless you request us not to, we may send you direct marketing communications and information about goods and services offered by us via email, SMS, or regular mail. You may opt out of receiving marketing communications at any time by responding via the channel in which you received the marketing communication, or by contacting us (see contact information below). You can unsubscribe from unsolicited marketing emails by clicking the unsubscribe link on the footer of the email communication you have received.  You may also update your personal information by editing any online profile you have with a service operated by us.

5.4    We may aggregate, compile and analyse personal information to improve our goods and services and make them more responsive to the needs of our customers.  Information dealt with in this way may also be used by us or provided to others as a summary report for marketing, advertising, business development or research purposes.

5.5    For purposes of the kind mentioned above we may provide your personal information to our employees and contractors and to third parties that assist us in providing goods and services you have requested, such as department stores, pharmacists and stockists that carry our goods or services, mail houses, couriers, delivery service providers and fulfilment managers, internet service providers, IT systems administrators, technical infrastructure providers, data entry service providers and payment processors.

5.6    We may also provide your personal information to our business advisors, including lawyers, accountants, debt collectors or other professional service providers, to the extent reasonably required or permitted by the Act.

5.7    We may sometimes provide your personal information to our foreign affiliates, including without limitation our subsidiaries or affiliates in the United States and New Zealand, for the purposes of the management of our corporate group, database management, processing of online orders or the fulfilment of orders delivered from or to a foreign country. In those circumstances 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.

5.8    Generally, we will seek your consent to the collection, use or disclosure of your personal information unless it is unreasonable or impracticable to do so in the circumstances. Generally, we will take such steps as are reasonable in the circumstances to protect your personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure.

6.      Access to, corrections of and complaints about personal information

6.1    We will take such steps (if any) as are reasonable in the circumstances to ensure that the personal information we collect is accurate, up-to-date and complete.

6.2    We may correct your personal information without asking you if we are satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out of date, incomplete, irrelevant or misleading.

6.3    You have the right to complain to us about a breach by us of the Australian Privacy Principles. You have a right to access most personal information we hold about you and if we deny access we will tell you why in writing.  To request access or corrections or make a complaint please contact our privacy officer whose contact details are set out below.

6.4    Whenever you contact us we may ask you to verify your identity to ensure that personal information we hold is not improperly accessed. You have the option of remaining anonymous or using a pseudonym when dealing with us in relation to your personal information unless it is impracticable for us to deal with you when you deal with us in that way.

6.5    We will endeavour to acknowledge receipt of your requests or complaints in relation to your personal information within two working days of our receiving them, and will normally respond within five working days of our receiving them.  If your request or complaint is complicated or requires further investigation our response may take longer. We will respond to you by your preferred contact method if you have indicated one. We will not charge you for responding.

7.      Contacting us about your personal information

If you would like to contact us in relation to this APP Privacy Policy or your personal information please make contact with the person whose title and details appear below:

Privacy Officer

Telephone number:     +61 2 8595 0911

Email address:             napoleon@napoleonperdis.com

Postal address:            PO Box 7198, Alexandria, 7198, Australia

Please do not contact our Privacy Officer about recruitment or employment matters.



More information about Privacy law and the National Privacy Principles is available from the Federal Privacy Commissioner’s website www.privacy.gov.au
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