Adairs Limited (ACN 147 375 451), Adairs Retail Group Pty Ltd (ACN 128 287 776) (Adairs or our or we) is in the business of retailing goods including, but not limited to, furnishings and homewares, with stores around Australia and an online/digital presence under brands such as Adairs and Urban Home Republic (Services).
This Policy explains and governs how Adairs will deal with your Personal Information collected in connection with the Services.
This Policy also applies to Personal Information collected by Adairs in connection with its website, social media accounts, applications, and other technological means (Online Platforms), as well as in connection with any direct communication between you and Adairs.
Adairs uses third parties located both locally and overseas in addition to its own resources to provide these Services.
1.2 We are committed to protecting the privacy of everyone who uses our Online Platforms and/or our Services, for them to understand what Personal Information we collect and store, and why we do so, how we receive and/or obtain that information, the rights an individual has with respect to their Personal Information in our possession, and with complying with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
2.1 Personal Information is any information or opinion that can be used to identify an individual.
2.2 The type of information we may collect includes:
2.2.1 Personal Information - We may collect personal details such as an individual’s name, location, date of birth and nationality allowing us to identify who the individual is;
2.2.2 Contact Information - We collect information such as an individual’s email address, telephone, login credentials, third-party usernames (such as social media handles), residential, business and postal address and other information that allows us to contact the individual;
2.2.3 Financial Information - We do not collect financial information such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our Services;
2.2.4 Statistical Information - We collect behavioral and statistical information about an individual and businesses in connection with the Services and/or the Online Platforms this may include your purchase history, preferences and interests regarding our products and the Services;
2.2.5 Other communications – We also collect Personal Information about your dealings with us, including from records of any contact we have had with you.
2.2.6 Other Information – We may collect other information such as your IP address, browser type, date and time of website access, location information and cookies.
3.1 We may collect your Personal information when required by law, but generally we collect your Personal Information so that we can carry out the following actions:
3.1.1 to enable you to use our Online Platforms;
3.1.2 to provide our Services and operate our business;
3.1.3 to communicate with you, including about our Services and offers which might interest you;
3.1.4 to provide you with information or advice;
3.1.5 to process payments by or to you in connection with our Services;
3.1.6 to create accounts, tax invoices or receipts;
3.1.7 to provide your personal information to third parties in order for them to supply the Services to you or as or a function of market research;
3.1.8 to consider and respond to complaints made by you.
3.2 We may disclose additional purposes for collection of your personal information in collection statements at the point of collection.
Your Personal Information is collected in connection with your use of the Services, when you make an enquiry with Adairs or generally when you deal with us directly or via our Online Platforms.
5.1 We will not use any Personal Information other than for the purpose for which it was collected other than with the individual’s permission and subject to clause 5.4.
5.3 Subject to clauses 8 and 14, we will not sell an individual’s Personal Information to unrelated third parties.
5.4 We may disclose your Personal Information:
5.4.1 where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
5.4.2 as required by any law (including the Privacy Act); and/or
5.4.3 in order to sell our business (in that we may need to transfer Personal Information to a new owner).
5.4.4 to third parties who assist us, provide us with services and perform functions on our behalf, including any subsidiary business of Adairs Ltd.
5.5 If personal information is disclosed to a third party, we are required to take reasonable steps to ensure your personal information is treated in accordance with all applicable privacy principles and laws.
6.1 Sensitive information is information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record.
6.2 It is our policy to only collect your sensitive information where it is reasonably necessary for our functions or activities and either you have consented or we are required or authorised under law to do so.
7.2 An individual may opt to not have us collect their Personal Information (for example by unsubscribing to any marketing emails received). This may prevent us from offering them some or all of our services and may terminate their access to some or all of the services they access with or through us.
7.3 When opting out via the unsubscribe link within Adairs promotional emails, you are opting out from email marketing only. When opting out of Adairs SMS communications via the opt out reply function, you are opting out of SMS marketing only. If you elect to opt out, you will still receive service-based communications relating to your Linen Lover membership and account, as well as other information that we are required to send you by law, such as changes to our terms and conditions and notifications relating to your transactions, rewards, and entitlements. To opt out of mail or all other marketing, please send us a message via our contact us form or call 1300 783 005 (free call Australia).
7.4 If an individual believes that they have received information from us that they opted out of receiving, they should contact us on the contact details set out in clause 15.
8.1 We may use your Personal Information in de-identified form (de-identification being a process by which a collection of data or information is altered to remove or obscure personal identifiers and personal information) to assist us in running our business. We may also provide, including by way of sale, de-identified information in aggregated form, to third parties. This information may include (but is not limited to):
8.1.1 age demographics;
8.1.2 purchasing trends;
8.1.3 trends and statistics in relation to our goods and services;
8.1.4 statistics about purchasing patterns of our goods and services;
8.1.5 statistics surrounding our goods and services.
8.2 When your Personal Information is included in de-identified, aggregated data, it is not possible to identify you or anything about you from that data.
We may use temporary (session) cookies or permanent cookies when you access our Online Platforms and/or Services. This allows us to recognise your browser and track the web pages you have visited. You can switch off cookies by adjusting the settings on your web browser..
10.1 We may hold your personal information in either electronic or hard copy form.
10.2 If you provide information to us electronically, we retain this information in our computer systems and databases. 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.
10.3 We have appropriate measures in place to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way and we use industry standard security measures to safeguard and protect your information. You should be aware that there are risks with transmissions and storage of Personal Information via the internet, meaning we cannot guarantee the absolute safety of the information we collect. However, we will always take reasonable steps to maintain the security of your Personal Information.
10.4 We may disclose your Personal Information to third parties and service providers located overseas in connection with any purpose, including to overseas cloud computing hosts. We take reasonable steps to ensure that the overseas recipients of your Personal Information comply with their privacy obligations in respect of your Personal Information.
10.5 We are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s Personal Information to in accordance with this policy or any applicable laws). The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.
10.6 If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.
10.7 Where we become aware of any breach to our security systems that breaches or is likely to result in a breach of your rights or freedoms with respect to your Personal Information, we will notify you and any supervisory authority as required by law.
10.8 To the extent permitted by law, we are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information.
11.1 If you would like us to update or amend your Personal Information, please contact us on the contact details set out in clause 15 and we will make the requested amendments.
11.2 We may ask you to verify your identity to ensure that Personal Information we hold is not improperly accessed.
13.1 We and/or our carefully selected third party business providers may contact you with direct marketing communications and information about the Services or other products and services offered by us via telephone, email, SMS, or regular mail
13.2 If you have indicated a preference for a method of communication, we will endeavor to use that method wherever practical to do so.
13.3 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 on the contact details set out in clause 15. You can unsubscribe from emails by clicking the unsubscribe link on the footer of the email communication you have received.
14.1 If an individual needs to contact us or has a complaint about our handling of their Personal Information, they should address their communication in writing to the details below:
Contact: Privacy Officer
Phone: +61 (0) 3 8888 4500
Mail: 2 International Court, Caribbean Business Park, Scoresby, VIC Australia 3179
14.2 If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.
14.3 If we become aware of any unauthorised access to an individual’s Personal Information we will inform them and any supervisory authority as required, at the earliest practical opportunity once we have established what was accessed and how it was accessed.
15.2 For further information regarding the Privacy Act, visit the Office of the Australian Information Commissioner's website at www.oaic.gov.au.
Version Date: November 2022