1) GENERAL POLICY
We understand that your privacy is important, and we always respect the privacy of all individuals. This policy governs the collection, use and disclosure of personal information. There are a number of ways that you can access, view, participate and interact with us, which include (but are not limited to):- subscribing and becoming a member of the website; online purchasing of products and services; the submission of interactions with product reviews, and on secondary devices; newsletters, promotions and marketing; competitions; through third party login platforms such as Facebook, and Instagram; and through third party affiliate organisations and joint ventures. The services listed above and other activities undertaken by us from time to time are, altogether, DWL’s “Functions and Activities”. When you share information with us, we can make these Functions and Activities even better, and allow third parties and brands who are also involved in our Functions and Activities to improve their products and services. We do not provide your personal information to third parties unless you have agreed for us to do so.
2) COLLECTION OF SOLICITED PERSONAL INFORMATION
We collect personal information where it is reasonably necessary for our Functions and Activities. Where we request personal information in relation to our Functions and Activities, we will state the general purposes for its use and to whom it may be disclosed, and the main consequences, if any, if the information is not provided. Further, we will not solicit personal information about an individual from someone other than the individual, unless it has obtained consent to do so, or it is unreasonable or impractical in the circumstances for us to obtain this consent.
3) ANONYMITY AND PSEUDONYMITY
When providing your personal information to us, you have the option of not identifying yourself, i.e. using a pseudonym. However, where it is impractical for us to provide and perform our Functions and Activities in relation to an individual who has not identified themselves, we may ask for this identifying information and if you do not comply with this request, you may then be prevented from accessing or using our services.
4) COLLECTION OF UNSOLICITED PERSONAL INFORMATION
5) NOTIFICATION OF THE COLLECTION OF PERSONAL INFORMATION
At the time that we collect an individual’s personal information (or as soon as reasonably practical), we will notify an individual that this information has been collected, and the circumstances of that collection (for example, via confirmation of an individual's successful subscription to DWL email marketing, or via confirmation of an individual's successful purchase with DWL).
6) USE OF PERSONAL INFORMATION
We use the personal information that we collect to fulfil our Functions and Activities, to provide opportunities to individuals, and to keep individuals informed of DWL’s business, and the products and services that we provide. We try to ensure, that as far as is practicable, this information is accurate, up to date, and complete. We may use personal information from time to time to send marketing material that we consider will be useful but if we are notified that a person does not wish to receive such information, we will not send it to that person. This does not apply to information that we are legally required to send.
7) DISCLOSURE OF PERSONAL INFORMATION
Generally, we will obtain consent before we disclose any personal information. Consent may be given expressly or it may be implied by conduct. Depending on the product or service, personal information may be disclosed to:-
a) third party clients of us and other promotional partners who participate in DWL’s Functions and Activities;
b) social media companies such as Facebook, and other public forums in which you choose to participate and through which you access DWL’s services; and
c) any other person authorised, implicitly or expressly, when the personal information is provided to or collected by us.
8) TRANS-BORDER DATA FLOWS
We may disclose personal information to overseas recipients. This is likely where our related parties and promotional partners have overseas subsidiaries or an individual uses a third party platform such as Facebook connect to use DWL’s services, and the servers for that platform are not located in Australia. Whilst we use our best endeavours to protect personal information, individuals should be aware that the Australian privacy law or a law providing for similar privacy protections may not apply to an overseas entity’s use of their personal information.
9) SECURITY OF PERSONAL INFORMATION
We take all reasonable steps to protect personal information we hold from loss, unauthorised access, modification, disclosure, interference or other misuse and we will take reasonable steps to destroy or permanently de-identify personal information we hold if it is no longer needed for our Functions and Activities.
10) SENSITIVE PERSONAL INFORMATION
We do not generally collect any sensitive information as that term is used in the privacy legislation (including information relating to racial or ethnic origin, membership of political bodies, religion or trade unions, sexual preferences or activities, criminal record, state of health or medical history). We will only collect sensitive information where required by law or with consent and that information is reasonably necessary for, or related to one of our Functions or Activities. If we hold any sensitive personal information, that information will only be used and disclosed by us for the purpose for which it was provided. If we ask for sensitive information, we will explain this.
11) ACCESS TO PERSONAL INFORMATION
A person may request access to personal information that we hold about them and we will process such requests within a reasonable time and in the manner, if any, requested. If we deny an access request, we will provide reasons for doing so.
12) CORRECTION OF PERSONAL INFORMATION
We will take reasonable steps to ensure the personal information we hold is accurate, complete and up to date. We should be promptly notified if there are any changes to an individual’s personal information. A person may ask us at any time to correct personal information held by us about them. On request, or if we become aware that personal information which we hold is inaccurate, out-of-date, incomplete or irrelevant or misleading, we will take reasonable steps to correct the information, and will also notify any third parties, to which this information has been disclosed, of these corrections. If we do not make changes in response to a request, we will provide reasons for not doing so.
13) CONSENT AND AGREEMENT
14) CHANGES TO THIS POLICY