Privacy Policy

PRIVACY POLICY

LOUNGEFACE PTY LTD ACN 637 775 734 (LOUNGEFACE)

Last updated: 6 September 2023

LOUNGEFACE understands the importance of, and is committed to, complying with its obligations under the Privacy Act 1988 (Cth) and the associated Australian Privacy Principles (APPs). This Privacy Policy explains how we manage your personal information, including our obligations and your rights in respect of our dealings with your personal information.

1. Our designated Privacy Officer is:

2. We, through our Privacy Officer, are happy to provide further details as to the extent to which we are required to comply with the APPs should any person wish. Alternatively, further details of the obligations imposed upon organisations under Australia’s privacy laws can be obtained directly from the Office of the Australian Information Commissioner (Commissioner) or by reference to the APPs and the Commissioner’s associated guidelines at oaic.gov.au.

The types of information held by LOUNGEFACE

3. “Personal information” is information or any information or an opinion about an identified individual, or an individual who is reasonably identifiable.
4. The types of personal information held by us includes the following (as well as other information):

• names, dates of birth, email addresses, mobile phone numbers, other contact details, residential and postal addresses, gender information, occupation details, and other personal information provided by individuals to LOUNGEFACE;
• details of the products and services you have purchased from us or put in your shopping cart, or which you have enquired about or subscribed to, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
• any additional information relation to you that you provide to us directly through our website or indirectly through our website or online presence or through our representatives or otherwise;
• information you provide to us through customer surveys, your feedback or other communications with our representatives from time to time;
• financial information such credit reference information and credit card/banking details; and
• data obtained from third parties such as credit reporting agencies, law enforcement agencies and other government entities, recruitment agencies and contractors and business partners.

Ways in which LOUNGEFACE collects personal information

5. LOUNGEFACE collects personal information in several ways, including:

• when you register for, subscribe to or use any of our services, our website or any of our applications;
• when you apply for and/or establish and/or access an account, order products or services, or put products in your shopping cart;
• through our website;
• through publicly available information services (e.g. social media, telephone directories, internet records);
• through referrals from others;
• when we are required to collect the information by virtue of legal or regulatory requirements;
• from our clients when they pass on information in connection with work we are doing or may do for them;
• from third parties passing on information on behalf of their clients;
• when people participate in competitions or surveys conducted by LOUNGEFACE (or third parties, on our behalf) including, but not limited to, surveys relating to the quality of our services provided.

6. If we receive unsolicited information about you that we have not requested, and if we determine that we could not have lawfully collected that information under privacy law if we required it, we will destroy or de-identify the information, if it is lawful and reasonable to do so.

The primary purpose for which LOUNGEFACE holds information

7. The primary purpose for which we collect information is to enable us to perform our business activities and functions and to provide the best possible quality customer service to our customers. In particular:

• we collect information to enable us to provide our products, services and information and to improve and refine our operations and website content and functionality;
• we collect information to provide advice to clients and prospective clients with respect to our products and services;
• we obtain information to assist us with marketing and developing the products and services of LOUNGEFACE;
• we collect information to enable us to advise our clients of additional information or services supplied by us (or by third parties) that may be of interest to them;
• we collect information to assist with our delivery of services via our website including gauging visitor traffic, trends and delivering personalised content to our users;
• we collect information to enable us to screen for potential risk or fraud, and to efficiently manage our business;
• we collect information to assist with our delivery of services via our website including gauging visitor traffic, trends and delivering personalised content to our users;
• we collect information for research and statistical purposes.

8. You have the right to refuse to provide us with personal information. However, if you decide not to do so, we may be unable to provide you with our goods and services or access to all parts of our website or applications.

Disclosure of personal information

9. In general, we do not use or disclose your personal information for a purpose other than:
   • a purpose set out this Privacy Policy;
   • a purpose you would reasonably expect;
   • a purpose required or permitted by law; or
   • a purpose otherwise disclosed to you to which you have consented.
10. We may disclose your personal information to other organisations, for example to our related companies (if any), external service providers such as accountants, lawyers, auditors, consultants and government or regulatory authorities where required or permitted by law.
11. We provide may personal information to our advisers, consultants and contractors, who provide us with services to assist us with conducting our business;
12. We may provide information to consultants, marketing entities (including messaging partners for the purpose of enabling and operating our text messaging program) and contractors to enable us to market, promote our services and conduct our business through the internet;
13. We disclose information for research and statistical purposes;
14. We may store information on data storage facilities provided by third parties; and
15. We may disclose your personal information to overseas recipients. Refer to paragraphs 16 and 17 below.

Disclosure of personal information to overseas recipients

16. It is likely that we will disclose your personal information to overseas recipients (e.g. data storage services and contractors we engage to help us provide the services more cost-effectively) when that disclosure is consistent with the purpose set out above.
17. The location of the overseas recipients may vary from time to time depending on the location of the data storage services and which contractors we use. If you would like a list of the locations of any overseas recipients used at any given time, please contact our Privacy Officer.

Right to gain access to personal information held by LOUNGEFACE

18. Pursuant to the APPs, you may request access to the personal information we hold about you by contacting our Privacy Officer in writing. Subject to the relevant exemptions contained in the APPs and subject to you providing sufficient proof of your identity, LOUNGEFACE will provide you access to information that it holds about you.  LOUNGEFACE reserves the right to charge a fee for the provision of this information based on the administrative cost of supplying the information requested.  Further details as to these costs and the ability to access information held by us can be obtained by contacting our Privacy Officer.
19. We will deal with your request for access within a reasonable time. Should we believe that we are entitled to refuse your request to access information we will provide written reasons for our decision and the relevant provisions of the Privacy Act that we rely on to refuse access.

Accuracy of personal information held by LOUNGEFACE

20. We will take reasonable steps to make sure that the personal information we collect is accurate, up-to-date and complete. We will take reasonable steps to make sure that the personal information we use or disclose is accurate, up-to-date, complete and relevant. Where we believe that the personal information is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information.
21. If you believe that information we hold about you is incorrect you are entitled to request, by contacting our Privacy Officer, that we correct that information. We will take reasonable steps to correct the information to ensure that it is accurate, up-to-date, complete, relevant and not misleading.
22. We will deal with your request to correct personal information within a reasonable time. Should we believe that we are entitled to refuse your request to make corrections we will provide written reasons for our decision.

Security of personal information held by LOUNGEFACE

23. LOUNGEFACE holds your personal information in paper-based and electronic form. We are required to take all reasonable steps to ensure your personal information kept in our files is protected from misuse, interference and loss, unauthorised access, modification or disclosure.
24. When we no longer require your personal information (including when we are no longer required by law to keep records relating to you), we ensure that it is destroyed or de-identified.

Website

25. This section explains how we handle personal information collected from our website. If you have any questions or concerns about transmitting your personal information via the internet, you may contact us using the contact details provided above, as there are other ways for you to provide us with your personal information.

Visiting our website

26. Anytime you access an unsecured part of our website, that is, a public page that does not require you to log on, we will collect information about your visit, such as:
    • the time and date of the visit;
    • any information or documentation that you download and pages viewed while browsing the site;
    • your browser type, version and language and operating system;
    • referring website address; and
    • your server address.

Cookies

27. A "cookie" is a small text file which is placed on your internet browser and which we access each time you visit our website. When you visit the secured pages of our website (i.e. pages that you have to provide login details to access) we use cookies for security and personalisation purposes. When you visit the unsecured pages of our website (i.e. public pages that you can access without providing login details) we use cookies to obtain information about how our website is being used. 
You may change the settings on your browser to reject cookies, however doing so will prevent you from accessing the secured pages of our website. 

28. Our website also uses cookies to help keep track of items that you put into your shopping cart including when you have abandoned your shopping cart. This information is used to determine when to send shopping cart checkout reminder messages via text message or email.

IP Addresses

29. Whenever you use our website, and many other websites, the computer on which the web pages are stored (the web server) needs to know the network address of your computer so that it can send the requested web pages to your internet browser. The unique network address of your computer is called its “IP address” and is sent automatically each time you access any internet site. From a computer’s IP address, it is possible to determine the general geographic location of that computer, but otherwise it is anonymous.
30. We do not keep a record of the IP addresses from which users access its site except where the user has specifically provided it with information about itself, in which case we also record the user’s IP address for security purposes.

Email

31. When we receive emails, we will retain the content of the email and our response to you where we consider it necessary to do so. 
Your email address will only be used or disclosed for the purpose for which it was provided. It will not be added to any mailing lists or used for any other purpose without your consent. 


Security

32. We make reasonable efforts to ensure that the most up-to-date security measures are used on our website to protect your personal information. Any data containing personal information which we transmit via the internet is encrypted. However, we cannot guarantee that any information transmitted via the internet by us, or yourself, is entirely secure. You use our website at your own risk. 


Links on our website

33. Our website may contain links to third party websites. We advise that the terms of this Privacy Policy do not apply to external websites. If you wish to find out how any third parties handle your personal information, you will need to obtain a copy of their privacy policy.

Further information

34. Should any person wish to obtain further information with respect to the type of personal information we hold, the purposes for which we use that information and/or the way in which we manage that information, please contact our Privacy Officer at the contact details set out above.

Direct Marketing by Email and Text Message

35. As part of our functions and business activities and to promote the services we can provide to you, we may use your personal information that you have provided to us for the purposes of direct marketing. Direct marketing includes but is not limited to, sending to you and/or contacting you (including by email and/or text message) in relation to your order (including shopping checkout reminders), marketing offers and promotions, information about our products and services, and requests for reviews.
36. You may opt out at any time if you no longer wish to receive email or text message marketing information. You can opt out of receiving direct email marketing communications by sending an email to our Privacy Officer using the contact details provided above, or by "unsubscribing" from email marketing messages. You can opt out of receiving direct text message marketing communications by replying with ‘STOP’ to any text message received from us or by using the unsubscribe link that we provide to you in any of our text messages. You understand and agree that alternative methods of opting out, such as using alternative words or requests, will not be considered a reasonable means of opting out. We do not charge for the service, but you are responsible for all charges and fees associated with email and text messaging imposed by your mobile phone network and/or internet provider. Message and data rates may apply.
37. LOUNGEFACE has the right to modify any email, telephone number or short code that we use to operate the email or text message marketing service at any time, and we will endeavour to notify you in this circumstance. You agree that any text messages that you send to a telephone number or short code that LOUNGEFACE has changed, including any ‘STOP’ requests, may not be received, and that LOUNGEFACE will not be liable for honouring requests made in such text messages.

Questions and complaints

38. If you have any questions, concerns or complaints about this Privacy Policy, or our use of your personal information, please contact the Privacy Officer using the contact details provided above. You can also contact the Privacy Officer if you believe that the privacy of your personal information has been compromised or is not adequately protected.
39. Once a complaint has been lodged, the Privacy Officer will respond to you as soon as possible.
40. You may also lodge a complaint with the Office of the Australian Information Commissioner by telephone: 1300 363 992 or email: enquiries@oaic.gov.au.

Changes to our Privacy Policy

41. This document sets out our current privacy policy. We review and update our privacy policy from time to time.  A current version of the policy can be found on our website.