1. What we collect and how we collect it
The personal information we collect about you depends on the dealings you have with us. Personal Information includes information about an individual who is reasonably identifiable. You generally have the option of interacting with us anonymously or using a pseudonym, however in some instances this may prevent us from being able to provide you with products and services, for an example where you place an order for products online.
The types of personal information we collect and use information depending on your interaction and transactions with us, including
General: What we collect
Loyalty: What we collect
Collection of personal information by third parties
Information is automatically collected through your use of Routleys websites, Affiliates’ websites and Apps, electronic communications, through cookies. Cookies are small text files that websites or Apps may place on your computer or device. Generally, cookies are used to recognise repeat users of websites and remember user preferences. We may collect this information both anonymously and in relation to user accounts. Cookies are also used to allow the website to gain statistical information about your usage behaviour and aggregate data to allow Routleys to customise a user's experience on their websites. The information is used and disclosed by Routleys for purposes including statistical analysis and to assist Routleys to improve the functionality and usability of the website and our Apps.
2. Why we collect personal information
We collect your personal information to provide, administer, improve and personalise our products and services, and to support our business functions, including:
3. Direct marketing, tech advertising and opting out
By providing your address, email address and contact number to Routleys or its related parties and partners, you consent to Routleys contacting you and your nominated Routeys account representatives related to our loyalty program for the purposes set out above. We may send this information in a variety of ways, including by mail, email, social media, SMS, MMS, telephone and via Routleys Apps. You may prefer to provide to us your personal email address or mobile number rather than, for example, an email address accessible by your work colleagues. If we send you direct marketing or send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, withdraw your consent or opt-out by
4. Sharing your personal information
We work with a number of suppliers that provide us with services to fulfil your request or carry out specific functions on our behalf, including: * Contracted or approved third party service providers or contractors to provide you with products or services requested by you or may be of interest to you, to process your payment, to communicate offers and promotions to you, and for product development and product, service and market research * Our loyalty program partners, suppliers and service providers * Approved technology services including application and systems, cloud computing facilities, development and technical support, processing, storing, hosting, research and to analyse data * Retail brands, suppliers and sellers who provide products and services within our stores, online platforms, Routleys and where products and services are provided on our behalf * Business advisors, including lawyers, accountants, insurance, recruitment advisors and agencies, auditors or other professional service providers to the extent reasonably required * Regulatory, investigative or government bodies to comply with applicable laws or respond to valid legal process such as a search warrant, a court order or a subpoena and fraud management
Some of our trusted service providers such as technology or data storage providers may be located outside of Australia including Japan, Singapore, India, Hong Kong, the Philippines, the United States of America and other countries or jurisdictions depending on the nature of the services those recipients provide to Routleys.
5. Protection of personal information
Personal information we hold can be in electronic or hard copy form, both onsite at a Routleys premises or with our trusted service provider. Any trusted service provider must observe and meet our information security requirements to minimise the risk of unauthorised access to, and loss, misuse or unapproved alteration of, personal information.
In addition we have a number of security controls in place and use a range of resources, process and technology controls to protect your personal information. For an example all Routleys Team Members are required and bound by internal information security policies including limiting and controlling access to systems that hold personal information.
While we endeavour to protect the personal information of users of our website, we cannot guarantee the security of information you disclose online. You disclose that information at your own risk. You should be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. You can also help protect your personal information by keeping your account details confidential, access is limited and encourage you to use a unique and strong password, limit access to your computer and log out after use. If you become aware of unauthorised access, please let us know as soon as practicable.
6. Third party sites
We may display advertisements from third parties and other content that links to third-party websites. Links to third party sites that are not operated or controlled by Routleys are provided for your convenience. If you click on a third-party advertisement or link, you are leaving Routleys and any personal information you provide will not be covered by this Policy and Routleys is not responsible for the privacy or security practices of those sites. Third party websites should have their own privacy and security policies, which we encourage you to read before supplying any personal information to them.
7. Access and Correction
7.1 Access If you would access to personal information we hold about you, please contact our Privacy Officer. We will generally provide you with access to your personal information subject to some exceptions permitted by law. When making an access request, please provide as much detail as you can about the particular information you seek, in order to help us retrieve the information. We may ask you to verify your identity before proceeding with any request you make, this includes providing us satisfactory proof of identity as determined by us. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act or will contact you directly to seek your permission.
We may charge a reasonable fee to cover our reasonable costs of locating the information and providing it to you.
7.2 Correction If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. If we correct personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, we will take reasonable steps to do so, unless this would be impracticable or unlawful. You should ensure that all personal information submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested. A record of the changes made to your personal information may be noted in your account or filing. You acknowledge that there may be circumstances where Routleys is entitled to assume such accuracy and completeness and reserves the right to not correct personal information, where permitted under relevant laws.
We may ask you to submit your complaint in writing. We may discuss and share your complaint with our staff and our service providers and others as required and appropriate.
All complaints received by the Privacy Officer will be dealt with fairly and in a timely manner considering all the circumstances of the complaint. In most cases, we expect that complaints will be investigated and a response generally provided within 30 days of receipt of the complaint. If the matter is more complex and our investigation may take longer, we will contact you and advise you of this.
8. Updates to this Policy
For information about privacy generally, you may visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.