Application

Last Updated: 12/09/2022

This Privacy Policy explains how Oroton Group Australia Pty Ltd (also referenced as Oroton) collects and handles your personal information, and applies it to our services. This includes this website and the information from which you can be identified directly or indirectly from while you browse www.oroton.com, as well as when you interact with our different platforms, portals and applications using your Personal Information.

We have developed this Privacy Policy to inform you of how your personal information and data is collected, held, and processed by Oroton.

Definitions

In this Privacy Policy, a reference has been made to:

Confidentiality Notice - the notice given to visitors at the time of submitting sign-up forms, including the degree of confidentiality and/or anonymity that the site visitors will have when answering submitting forms;

Oroton, Oroton Group Australia Pty Ltd, we, us, or, our - Oroton Group Australia Pty Ltd A.C.N. (000 704 129) and any of its related bodies corporate;

Services, Product - all internet websites, consumer products listed on the website offered by Oroton;

Visitor - any person who visits our websites;

Website(s) - collectively, www.oroton.com as well as the other websites that Oroton operates and that link to this Privacy Policy;

Customer - the person or entity that has signed up the account with Oroton; and / or purchased any products or services from Oroton. The Person or Company that has a commercial relationship with Oroton; or visited Oroton website generally;

Personal Profile Page - the “My Account” page within the website which is a personal page available to customers;

Business Data - any content or data that you or third parties submit to Oroton using the Marketing Services;

You or your - either an Administrator, Respondent, Individual Feedback User or Visitor, as applicable.

We may update this Privacy Policy from time to time and the most current version will be posted on our website. We will notify you by email if changes are made to the address associated with your account or when you next log in to your account prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. If you have any questions or concerns about our Privacy Policy, or with the handling of your personal information, please contact our Privacy Officer at customercare@oroton.com.

Which Oroton entities collect and manage your personal information?

Oroton collects your Personal Information when you interact with Oroton in Australia.

When interacting with Oroton through www.oroton.com or our different platforms, portals and applications, your Personal Information may be collected and managed on behalf of Oroton by other Oroton Group entities.

What personal information does Oroton collect and hold (categories of personal information)?

The kind of personal information that Oroton collects and holds about you is dependent on the nature of your interaction with us and the circumstances of collection.

Set out below is the kind of information we collect when you interact with us through www.oroton.com or our different platforms, portals, and applications. If you interact with us as a supplier, a contractor or in some other capacity, we may collect your name, contact details and any other information you choose to provide us with. We may also collect details of the interactions we have with you.

Oroton does not generally collect sensitive information and will only collect sensitive information about you with your consent (unless we are otherwise required or are authorised under law to do so). "Sensitive information" is a special category of personal information and includes health information, information about an individual's race or ethnic origin, philosophical beliefs, membership of a professional or trade association, membership of a trade union, religious or philosophical beliefs, sexual orientation or practices, or criminal record.

Listed below are the categories of Personal Information we collect directly or indirectly from you when you browse www.oroton.com or interact with our different platforms, portals and applications using your Personal Information:

Identity information - includes name [first, last, initials], date of birth, e-mail address, Member ID (Member Identification Number), nickname, password, social media identifiers, information passed along to us via your Facebook or Instagram account, your device fingerprint, and gift card codes that are assigned to you. This information is utilised to verify your identity.

Contact information - includes your phone number, shipping and billing address, e-mail address, social media handle, and any other communication channel you have used to contact us for more information. This information is utilised to contact you.

Location information - includes your residential location, current log-in location (IP address), or the specific Oroton store you have visited that might indicate your location. This information is utilised to help you find what you are looking for at your current location.

Style Preferences - includes shoe size, clothes size, height, weight, chest, waist, hip, inseam, body shape, heel-toe measurement. This information is utilised to assist with sizing.

Purchase information - includes your payment information (credit card number), shopping cart (your ordered items), delivery details, shipping and billing address, customer order number, purchase history with Oroton, transaction ID, and any other information related to your purchase. This information is utilised to complete your order on Oroton websites, in Oroton stores, or other selling platforms.

Behavioural and Profile information - includes your shopping history, Wishlist items, your browsing behaviour, your browsing preferences, your shopping preferences, in-store interactions, product reviews, social media interactions with us, and any other intelligence we have about you to help us learn about you as a consumer. including “Community information”. This information is used to know you better as a consumer, and so we can send you marketing messages containing products and services that we think you might be interested in.

Community information - includes information provided by you when you participate in various Oroton events and communities either as a team member, a participant or as a promotor of our events. Examples include pictures, videos, your nickname, interests and preferences, your feedback, event participation and registration details. This information is used to organise events, communities, and to know more about you as a consumer.

Social Media information - includes information obtained through your interaction with us on various social media channels such as Facebook, Instagram, Google, etc This includes any social media information that is publicly available such as your social media handles, social media interactions and public postings, your “Likes” and other reactions, your social media connections, your photos that are publicly available, or those you send to us by mentioning us or following our social media posts by using “handles” or “hashtags”. We obtain this information from the social media network (e.g., Facebook, Snapchat, Instagram, etc.) directly or indirectly through third-party agencies we have agreements with.

Device information - includes information about your device or browser that give us an idea about your browsing behaviour or device usage. Your device and browser information are collected by our cookies, tags, and pixels. This is often required for the purpose of network security. This includes, but is not limited to IP address, date, and time of the visit, how long you remained on our website, the referral URL (if you came to our site via a different site or an advertisement), the pages visited on our website, your browser type, device type, versions and operating system.

Correspondence - includes conversations we have when you contact our customer service, the emails you write to us about our products or services, the complaints you address to us via post, e-mail, fax, chat, messenger, SMS or call, notes we prepare on your feedback, call backs from our Customer Service to you, and any other communication between you and an Oroton personnel. We record all Customer Service calls for quality assurance purposes.

Preference information - includes preferred language, log-in location, Wishlist items, preferred shipping address, browsing preferences, our correspondence with you and your Oroton product reviews. This information is utilised to provide you convenience when you visit and/or shop on our website and app.

How does Oroton collect your personal information?

Oroton generally collects your personal information directly from you, for instance when you visit us or interact with us in writing, electronically or on a call, you communicate with us through www.oroton.com, via customer service or our different platforms, portals and applications, or you participate in one of our promotions or events.

What are the purposes for which Oroton collects, holds, uses, and discloses personal information?

Oroton collects, holds, uses, and discloses Personal Information for a range of purposes, including:

• to respond to enquiries about the products and services we offer;
• to supply our products and services;
• if you enter one of our promotions or events, to administer your participation in that event;
• to manage our relationships with customers, contractors, and suppliers;
• to perform research and analysis;
• to consider job applicants for current and future employment;
• if you sign up for an Oroton account, to allow you to use the same sign in detail anywhere in the world;
• for identification and authentication purposes;
• for our administrative purposes and internal record keeping;
• to provide customer service and technical support, and deal with any complaints or feedback;
• to conduct investigative, fraud and loss prevention activities to protect Oroton’s interests including protection of our stores, staff, customers, suppliers and merchandise (including theft and fraud prevention);
• to send you Oroton news, offers and information about our products, services, and events;
• to improve our products and services;
• to personalise the products and services we offer you;

We may use or disclose your information for purposes required or authorised by or under law (including purposes for which you have provided your consent).

If Oroton is unable to collect Personal Information from or about you, we may not be able to respond to your requests or enquiries, or, engage in managing rights to forget or in other dealings with you.

What do we do with personal information collected through www.oroton.com and our various platforms?

Oroton collects and uses your Personal Information through www.oroton.com and our various platforms, for several purposes not limited to:

1. Website operation
2. Product delivery
3. Electronic delivery tracking
4. Business operational analytics
5. Global credential to all Oroton platforms – user experience
6. Sales of Oroton products – online, outlet (offline) orders
7. Customer service
8. Personalised marketing messages via email and SMS (newsletter sign-up)
9. Personalised marketing messages via email and SMS (via existing contact)
10. Personalised marketing messages via email, SMS and other digital channels. These may include service-related messages updates, alerts, and information (e.g. order updates, account alerts, etc.). Promotional messages may include promotions, specials, and other marketing offers (e.g., cart reminders)
11. Product research and development
12. Legal obligation - cooperation with law enforcement and regulatory authorities (including courts)
13. Collecting your device information on our website using cookies, pixels, tags, and similar technologies (“cookies notice”)
14. User-generated content (UGC) acquisition from social media

Why do we collect information?

When and why do we need your Personal Information (“Purpose”)?

What do we do to your Personal Information for each Purpose (“Handling”)?

Website operation handling

To run the websites that are connected to the Oroton domain, fix bugs to ensure you always see the website the way we intended, and monitor compliance with our terms and conditions, we screen all traffic to our site and analyse data that is received by our servers.

We may collect your personal details for website handling by using technologies such as cookies, pixels, and tags to collect your device information.

Sale of Oroton products - online and offline order handling

We collect your personal information to process your online order, ensure your payment is received, and complies with the requirements under our Terms & Conditions, including invoice processing, delivery, personalisation services, exchanges, refunds and click and collect. Your order cannot be completed if our payment processor’s fraud detection solutions flag your transaction as suspicious and potentially fraudulent.

Product delivery handling

After you have successfully placed an online order, we use your contact details (home and/or shipping address) and other purchase information to deliver the products purchased to you.

Electronic delivery tracking handling

This service is provided on request of the consumer by our Delivery Partners.

You have the option to track your delivery using services provided directly by our delivery partners; however, we will only be able to share your information with our delivery partners with your consent. The service is hosted on the Delivery Partner’s platform. Please read their Privacy Notice for the processing of your Personal Information for this purpose.

Business operational analytics handling

Evaluation of our business performance is in the interest of our shareholders, our board members, our employees, and our partners. We analyse different categories of information to understand how our products are selling in different markets, what are the popular features of our products, what worked and what didn’t in terms of our marketing and advertising campaigns, our product designs and distribution strategy, our website design and overall user experience, so we can establish, implement, and evaluate our business strategy.

This includes analysing data to understand how users browse our site and platform to improve our user experience design to make sure you will continue to purchase our products and interact with us.

To minimise the risk to you as an individual, we only use either the unique consumer identifier or the IP address for this purpose.

You can learn in detail about how our Data Analytics Solution Providers provide analytics services by using your data here:

Google Analytics Data Collection https://support.google.com/analytics/answer/9019185?hl=en#zippy=%2Cin-this-article

Customer service handling

We collect your Personal Information to inform you when the product you like is available upon your request and respond to your queries and concerns through various communications channels we make available to you such as:

• Zendesk https://www.zendesk.com/company/agreements-and-terms/privacy-policy/

Personalised marketing messages via email (newsletter sign-up) handling

We send you marketing messages that we think you would be interested in (“personalised”) to the email address you provide to us when you signed up to our email newsletters. To send you “personalised” messages, we observe your online (and sometimes, where applicable, offline) behaviour, and analyse your behaviour using analytics to best estimate what product lines you might be interested in, and can benefit from. This requires us to collect various categories of Personal Information from you. We use various analytics tools to understand what your behaviour means in terms of your like and dislike of our various product lines, and to understand the impact (success rates) of the messages delivered to you.

We may collect your personal details for this purpose by using technologies such as cookies, pixels, and tags to collect your device information.

How can you unsubscribe from email marketing messages?

You can opt out of receiving marketing messages from Oroton at any time. Click ‘Unsubscribe’ at the bottom of the newsletter or marketing email that you want to unsubscribe from; or update your communication preferences in your account if you have one.

How can you unsubscribe from SMS marketing messages?

Text the single keyword command STOP to +18449964528 or click the unsubscribe link (where available) in any text message to cancel. You'll receive a one-time opt-out confirmation text message. No further messages will be sent to your mobile device, unless initiated by you. If you have subscribed to other Oroton mobile message programs and wish to cancel, except where applicable law requires otherwise, you will need to opt out separately from those programs by following the instructions provided in their respective mobile terms.

For Service assistance please contact our customer service. We may change any short code or telephone number we use to operate the service at any time and will notify you of these changes. You acknowledge that any messages, including any STOP requests, you send to a short code or telephone number we have changed may not be received and we will not be responsible for honouring requests made in such messages.

Note: We will unsubscribe you from the marketing messages, such as email, SMS, calls etc. However, we may still hold your contact information for our records.

Targeted messages on 3rd-party advertising platforms handling

We use third-party advertising platforms, such as Facebook, Google, YouTube, Instagram, etc. to send you messages that are targeted for you, based on your behaviour, and browsing pattern, at specific times and locations of these platforms to increase the efficiency of our advertising campaigns. We use third-party solutions such as Google Audience and Facebook Custom Audience to help us do a better job at targeting our campaigns and messages for our consumers. Your Personal Information is shared with the third-party advertising platforms, and they will attempt to match your profile in their database to determine the optimal time and place (the page you are browsing) to show you an advertisement from Oroton. We also need to analyse necessary information to understand the impact of our campaigns. If you don’t accept that we track you for this purpose, you will still see Oroton advertisements on other platforms at random. You can learn more about how our Advertising Partners help us achieve this purpose by visiting their websites:

Google Personalised Advertising: https://support.google.com/adspolicy/answer/143465?hl=en

Google Advertising Policies: https://support.google.com/adspolicy/answer/6020956

Facebook Lookalike Audiences: https://www.facebook.com/business/help/164749007013531

Facebook Custom Audience Terms: https://www.facebook.com/legal/terms/customaudience

Product research and development handling

We conduct analysis and research to improve our products and services. This includes asking you to take surveys, asking you to share your feedback, asking you to test our products and provide us with a review, asking other service providers to conduct market and product research for us and try new technologies in our product that might collect Personal Information to stay ahead of the competition.

Survey Monkey is used to conduct our consumer surveys. In line is the privacy policy of Survey Monkey for reference.

https://help.surveymonkey.com/categories/Privacy_Legal?l=en

Legal obligation - cooperation with law enforcement and regulatory authorities handling

When we are legally required to provide your Personal Information for national and public security reasons, crime prevention, investigation and prosecution, anti-money laundering, judicial proceedings, protection of other individuals’ rights and freedoms, and enforcement of civil claims. We will provide information as requested by the authorities or parties once we are satisfied that the request is mandated by law. We may not be able to notify you if it is against the law to do so.

How do we protect your information?

We have in place an internal framework of policies and minimum standards across all our businesses to keep your data safe. In addition, we limit access to Personal Information by our employees, business partners, service providers and third-party service providers to a ‘need-to-know’ basis. More specifically and in accordance with the law, we take appropriate technical and organisational measures (policies and procedures, IT security, and others) to ensure the confidentiality and integrity of your personal information and the way it is processed.

You will be notified by email or SMS or when you next log in to your account.

What are your rights?

We will honour your rights under the applicable laws. To the extent provided under your local data protection laws, including Australian privacy law, EU General Data Protection Regulation (“GDPR”), Brazil’s Lei Geral De Proteҫão de Dados (“LGPD”), or the California Consumer Privacy Act (“CCPA”), your rights include the following:

• Right of access (‘an overview of your personal information’): the right to get an overview of your personal information that we process.
• Right to rectification (‘correct your personal information’): the right to ask us to rectify or complete your personal information, if it is inaccurate or incomplete.
• Right to erasure (‘right to be forgotten’): the right to request that we delete your personal information to the extent permitted by applicable law. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if processing is necessary for the performance of a contract. In some cases, your personal information is necessary to provide our Services and if you do not provide such information to us then you may be precluded from accessing and using the Services or using certain Services features.
• Right to data portability (‘transfer your personal information’): the right to ask us to transfer your personal information directly to you. This applies to certain personal information if processed by automated means and with your consent or based on the contract you have with us. On your request, and where technically feasible, we will transfer your personal information to another party of your choice.
• Right to restrict processing: the right to request that we restrict or stop the processing of your Personal Information held by us for a certain period of time, or for an indefinite period. In certain circumstances, it may not be possible for us to accept your request, for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
• Right to object: the right to object to the processing of your personal information. The reasons for objection should relate to your specific situation and be related to a processing based on the legitimate interest condition. We will then no longer process the personal information, unless we can demonstrate compelling reasons otherwise. In certain circumstances you have the unconditional right to object, for instance, in the context of direct marketing activities.
• Withdrawal of Consent: the right to withdraw your consent to the processing of your personal information at any time; for instance, after you have given the consent to keep you informed about our Services, you have the right to withdraw this consent at any time.

Click here for Data erasure request.

How can you access, correct and seek deletion of your personal information? You can help by letting us know about any changes to your Personal Information, such as changes to your address and phone number. If you would like to access or correct the Personal Information Oroton holds about you, please contact the Data Protection Officer or Oroton Group Australia Pty Ltd. https://oroton.com/contact-us/ Oroton Privacy Team and the Data Protection Officer.

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CONTACTS

Office of the Australian Information Commissioner
www.oaic.gov.au
+1300 363 992
enquiries@oaic.gov.au
Level 3, 175 Pitt Street
Sydney, New South Wales, 2000, Australia