Privacy Policy - Sunnylife Group Pty Ltd (all countries)

This is a Privacy Policy of Sunnylife Group Pty Ltd (ABN 15 093 345 496), (“Sunnylife”,“Us”, “Our”, “We”).

1. Your privacy is important to us

Protecting your privacy and the confidentiality of your personal information is important to Us. Your rights to privacy are protected by the law, and this policy does not limit those rights. This Privacy Policy explains why We collect personal information and how We collect, use, disclose, store and protect your personal information.

We comply with the Australian Privacy Principles (“APPs”) and the EU General Data Protection Regulation, as well as other applicable privacy statutes, which regulate how We use, disclose, store and protect your information.

1. Collecting Personal Information

What personal information do We collect?

The personal information We collect is most likely supplied by you when you purchase from Us in one of Our retail stores or place an order and register your details on Our website to receive direct marketing materials or provide feedback to Us.

The personal information collected will likely include:

• Full Name
• Contact Details including phone number, email address and delivery address
• Date of birth
• Transaction information (your credit or debit card details)
• Network and device data such as IP address and device
• Advertising identifiers and information We obtain using cookies or other tracking technologies. 
• We may also collect information about you from third-party sources and platforms (including data validation services, authentication service providers, social networking sites, online marketing and segmentation providers and ad targeting companies) to supplement the information We collect directly from you.  

Other forms of information We may collect

At times, We may also collect information from you that does not identify you personally. This information is normally retained with your personal information, including:

• Customer shopping preferences, including shopping history, attributes of products and services which We have provided to you or may provide you in the future.
• Marketing preferences, marketing materials which you wish to receive and the method of its delivery (EDM, SMS or other).
   

1. How do We collect and hold your personal information?

There are many different ways that We collect your personal information, these include:

• You purchase a product from Us;
• You register an account on Our website;
• You provide Us with the information via telephone;
• You accept Our cookies and other tracking software when browsing Our website;
• You interact with Our customer service team, on social media or join the Sunnylovers Club;
• We partner with Rakuten Advertising, who may collect personal information when you interact with our site. The collection and use of this information is subject to the privacy policy located here: https://rakutenadvertising.com/legal-notices/services-privacy-policy/

How long do We hold your personal information?

We will not retain your data for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of data, however the longest We will normally hold any personal information is 3 years.

How do We protect your personal information?

Sunnylife is committed to keeping your personal information safe and secure.

Our security measures include:

• encryption of data;
• where possible, the deidentification of data;
• regular cyber security assessments of all service providers who may handle your personal information;
• security controls which protect the entire Sunnylife IT infrastructure from external attack and unauthorised access; and
• internal policies setting out Our data security approach and training for employees.

1. Why do We collect your personal information?

Any personal information provided to Us will only be used for the purpose which it was initially provided:

• To provide goods and services to you.
• To make tailored website & email content available to you.
• To complete transactions and administer Our relationship with you as a customer, this includes refunds.
• To communicate and notify you of new products, offers and competitions that may be of interest of you.
• To investigate and respond to your questions, comments or feedback related to Our services and products.
• To comply with laws and regulations, or to comply with any directions given by regulators or authorities.
• Compile Our customer database to enable Us to market to you more accurately.
• Help Us gain a clearer understanding of what your likes and dislikes are, how to improve Our marketing, Our digital platforms and the overall services in which We provide.
• To enable Sunnylife to manage customer service interactions with you.

How We disclose your personal information

Receiving information from and about Our customers is an important part of Our business. We will not share/sell this information to third parties for profit. We may disclose personal information to other subsidiary companies within Our group but only to be used for the same purposes you agreed to when signing up.

In order to make certain services available to you, We may need to share your personal information with some of Our service partners, which are based in Australia and the United States. These include IT, delivery and marketing service providers. Sunnylife only allows its service providers to handle your personal information when We have confirmed that they apply appropriate data protection and security controls.

Aside from Our service providers, Sunnylife will not disclose your personal information to any third party, except as set out below. We do not sell or rent Our customer data to other organisations for marketing purposes.

We may share your data with:

• credit reference agencies where necessary for card payments;
• governmental bodies, regulators, law enforcement agencies, courts/tribunals and insurers where We are required by law to do so:
• to comply with Our legal obligations;
• to exercise Our legal rights (for example in court cases);
• for the prevention, detection, investigation of crime or prosecution of offenders; and
• for the protection of Our employees and customers

Web Banner Advertising

If you visit Our websites, you may receive banner advertisements promoting Sunnylife and its business whilst browsing other websites. Any banner advertisements you see will relate to products you have viewed whilst browsing Our websites on your computer or other electronic devices.

These advertisements are provided by Sunnylife via market leading specialist providers using ‘cookies’ placed on your computer or other devices (see further information on the use of cookies in the Cookies section of this document). You can remove or disable cookies at any time (see below for further information).

2. What if you don’t want to provide Us with your information?

We will ask you to provide your personal information and you will have a choice to do so. If you do not wish to provide this information, We will not be able to provide you with the requested products or services.

We will only record your email address or other contact details if you provide them to Us. We will only use your email or other contact information to send you information which you have requested or signed up to receive.

Promotional Communications

By providing Us with your email address or other contact details, you will have provided consent to send direct marketing materials. If you do not wish to consent or receive direct marketing from Us, you can unsubscribe at any time to receive any communication from Us. You have the right to opt out of receiving promotional communications at any time, by:

• making use of the simple “unsubscribe” link in emails or other electronic communications; or
• contacting Sunnylife via the contact channels set out in this Policy.

At all relevant times when contacting you, Sunnylife will comply with its obligations pursuant to the Spam Act 2003 (Cth).

Do Not Track requests

Outside of Australia, We note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, We do not alter Our practices when We receive a “Do Not Track” signal from your browser.

2. Updating or correcting your personal information

You have the right to access, update or amend your personal information. If you need to access, update or amend your personal information, please contact Us with your requests through the details provided below. We may ask for verification of your identity to ensure that all personal information held by Us is not improperly accessed.

Your rights

Additionally, you have the following rights in respect of your personal information:

• the right to ask for a copy of personal information that We hold about you (the right of access);
• the right (in certain circumstances) to request that We delete personal information held on you; where We no longer have any legal reason to retain it (the right of erasure or to be forgotten);
• the right to ask Us to update and correct any out-of-date or incorrect personal information that We hold about you (the right of rectification);
• the right to opt out of any marketing communications that We may send you and to object to Us using / holding your personal information if We have no legitimate reasons to do so (the right to object);
• the right (in certain circumstances) to ask Us to ‘restrict processing of data’; which means that We would need to secure and retain the data for your benefit but not otherwise use it (the right to restrict processing); and
• the right (in certain circumstances) to ask Us to supply you with some of the personal information We hold about you in a structured machine-readable format and/or to provide a copy of the data in such a format to another organisation (the right to data portability).

If you wish to exercise any of the above rights, please contact Us by emailing privacy@sunnylife.com.

2. Sunnylife’s legal basis for processing your personal information

Sunnylife collects and uses customers’ personal information because is it may be necessary for:

• the pursuit of Our legitimate interests (as set out below);
• the purposes of complying with Our duties and exercising Our rights under a contract for the sale of goods to a customer; or
• complying with Our legal obligations.

In general, We only rely on direct consent as a legal basis for processing personal information in relation to sending direct marketing communications to customers via email or text message.

Customers have the right to withdraw consent at any time. Where consent is the only legal basis for processing, We will cease to process data after consent is withdrawn.

Sunnylife’s legitimate interests

The normal legal basis for processing customer data, is that it is necessary for the legitimate interests of Sunnylife, including:

• selling and supplying goods and services to Our customers;
• protecting customers, employees and other individuals and maintaining their safety, health and welfare;
• promoting, marketing and advertising Our products and services;
• understanding Our customers’ behaviour, activities, preferences, and needs;
• improving existing products and services and developing new products and services;
• complying with Our legal and regulatory obligations;
• preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
• handling customer contacts, queries, complaints or disputes;
• managing claims made by customers, including but not limited to insurance claims;
• protecting Sunnylife, its employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to Sunnylife;
• effectively handling any legal claims or regulatory enforcement actions taken against Sunnylife; and
• fulfilling Our duties to Our customers, colleagues, shareholders and other stakeholders.

Rakuten Advertising 

Rakuten Advertising may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage, and how you interact with our properties and ads for a variety of purposes, such as personalization of offers or advertisements, analytics about how you engage with websites or ads and other commercial purposes. For more information about the collection, use, and sale of your personal data and your rights, please use the below links.

• The services privacy policy URL: https://rakutenadvertising.com/legal-notices/services-privacy-policy/
• The user rights/opt-out URL: https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/ 

Updating or correcting your personal information
If you need to update or amend your personal information, please contact us with your requests. We may ask for verification of your identity to ensure that all personal information held by Us is not improperly accessed.

1. Cookies policy

What are cookies?

Like most websites, Sunnylife websites use cookies to collect information. Cookies are small data files which are placed on your computer or other devices (such as smart ‘phones’ or ‘tablets’) as you browse this website. They are used to ‘remember’ when your computer or device accesses Our websites. Cookies are essential for the effective operation of Our websites and to help you shop with Us online. They are also used to tailor the products and services offered and advertised to you, both on Our websites and elsewhere.

Information collected

Some cookies collect information about browsing and purchasing behaviour when you access this website via the same computer or device. This includes information about pages viewed, products purchased and your journey around a website. We do not use cookies to collect or record information on your name, address or other contact details. Sunnylife can use cookies to monitor your browsing and purchasing behaviour.

How are cookies managed?

The cookies stored on your computer or other device when you access Our websites are designed by:

• Sunnylife, or on behalf of Sunnylife;
• third parties who participate with Us in marketing programmes; and
• third parties who broadcast web banner advertisements on behalf of Sunnylife.

What are cookies used for?

The main purposes for which cookies are used are: -

• For technical purposes essential to effective operation of Our websites, particularly in relation to on-line transactions and site navigation;
• For Sunnylife to market to you, particularly web banner advertisements and targeted updates;
• To enable Sunnylife to collect information about your browsing and shopping patterns, including to monitor the success of campaigns, competitions etc; and
• To enable Sunnylife meet its contractual obligations to make payments to third parties when a product is purchased by someone who has visited Our website from a site operated by those parties.

How do I disable cookies?

If you want to disable cookies you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use. Further information on disabling cookies can be found on the website of the browser you use.

What happens if I disable cookies?

This depends on which cookies you disable, but in general the website may not operate properly if cookies are switched off. If you only disable third party cookies, you will not be prevented from making purchases on Our sites. If you disable all cookies, you may be unable to complete a purchase on Our sites.

1. Questions or Concerns

If you have any questions regarding Our Privacy Policy or wish to complain about a potential breach by Us of the Australian Privacy Principles or similar legislation, please contact Us through the details provided below and We will endeavour to respond to your request as quickly as possible.

Sunnylife Group Pty Ltd
ABN 15 093 345 496
B1, 85 Dunning Avenue, Rosebery NSW 2018 Australia
Phone: 1300 760 186
Fax: 1300 760 143
Email: hello@sunnylife.com.au

Sunnylife’s has appointed a Data Protection Officer to ensure We protect the personal information of Our customers (and others) and to comply with privacy and data protection legislation. Our Data Protection Officer is Lisa Anderson.

You have the right to lodge a complaint with the relevant region’s Information Commissioner’s Office. Further information, including contact details, is available at https://ico.org.uk.

Go-live date: 17.03.2022