Privacy Notice
Abelini Pty Ltd (“we”, “us” or “our”) are committed to respecting your privacy. This Privacy Notice sets out how we collect, use, store, share and disclose your personal information.
1. Openness and transparency
We are committed to protecting your privacy and respecting and upholding your rights under the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act). We ensure that we will take all necessary and reasonable steps to comply with the APPs and to deal with inquiries or complaints from individuals about compliance with the APPs.
By accessing and using our website, products and services, you agree to and consent to the collection, use, storage and disclosure of personal information by us as set out in this Privacy Notice.
2. Personal information
Personal information is information or an opinion about an individual whose identity is apparent, or can be reasonably ascertained, from that information or opinion (whether true or not, and whether recorded in a material form or not).
The type of personal information we collect from you includes, without limitation, the following:
- your full name;
- address;
- email address;
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- membership information, including your Diamond Club membership number, membership tier, the benefits you use and your membership preferences, and any date of birth you provide to us for a membership benefit;
- any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
- information you provide to us through customer surveys;
- billing information (including credit and bank details); or
- any other personal information that may be required in order to facilitate your dealings with us.
3. Collection
We may collect personal information from you when you fill in an application form, communicate with us, visit our website, provide us with feedback, complete online surveys or participate in competitions. We may collect personal information about you from our business partners or from third parties.
If you use a pseudonym when dealing with us or you do not provide identifiable information to us, we may not be able to provide you with any or all of our services as requested. If you wish to remain anonymous when you use our website do not sign into it or provide any information that might identify you.
We require individuals to provide accurate, up-to-date and complete personal information at the time it is collected.
4. What do we do with your personal information?
Please read this Privacy Notice carefully. If you provide personal data to us, you understand we will collect, hold, use and disclose your personal data in accordance with this Privacy Notice. You do not have to provide personal data to us, however, if you do not, it may affect our ability to provide our services to you and your use of our services. We use and disclose your personal information for the purposes for which the information is collected, or for a directly related purpose, including (but not limited to):
- providing our website, products and services to you;
- administering, protecting, improving or optimising our website, products and services (including performing data analytics, conducting research and for advertising and marketing purposes);
- administering the Diamond Club, providing member benefits and sending you communications about your membership;
- billing you for purchasing or using our website, products and services;
- informing you about our website, products, services, rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
- responding to any inquiries or comments that you submit to us;
- verifying your identity;
- any other purpose you have consented to; and
- any use which is required or authorised by law.
Where we use automated tools to personalise offers or content, we do not use them to make decisions that could reasonably be expected to significantly affect your rights or interests. If this changes, we will update this Privacy Notice to explain how those automated decisions are made, consistent with our obligations under the Privacy Act.
5. Disclosure of personal information
We may disclose your personal information to:
- our employees, contractors and/or related entities (to manage internal operations and provide our services to you);
- IT service providers and analytics providers, such as Microsoft and Hotjar (for secure data storage and business systems, and to understand how visitors use our website so we can improve it);
- our e-commerce platform provider, Shopify International Limited and its group companies (“Shopify”) (to host and operate our online store, manage customer accounts, process orders and transactions, prevent fraud, and provide us with related analytics about the use of our store);
- our live chat and customer support system, Zendesk (to manage online enquiries, provide customer support, and improve the user experience on our website);
- marketing or advertising providers such as Mailchimp and Sendgrid and affiliate link provider Paid on Results Limited (to deliver marketing communications, promotional content, and manage affiliate marketing activities);
- any third-party provider we engage to operate or administer the Diamond Club or our loyalty programme (to manage your membership, benefits and member communications);
- our review platforms, Trust Shop Reviews, Trustpilot and Google Reviews (to collect customer feedback and reviews, which help us improve our services and build trust with potential customers);
- professional advisors, bankers, auditors, our insurers and insurance brokers (to obtain professional advice, manage financial transactions, audit our accounts, and comply with insurance requirements);
- payment systems operators such as Shopify, PayPal, Klarna, Afterpay and ZipPay (to process payments, manage financial transactions, and prevent fraud);
- our delivery provider, Australia Post, and dispatch label provider, Click and Drop (to deliver products to you and manage delivery logistics);
- our existing or potential agents or business partners (to facilitate business operations, partnerships, and strategic collaborations);
- sponsors or promoters of any promotion or competition we run (to administer promotions, contests, or competitions and distribute prizes to winners);
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred (to enable the sale, merger, or restructuring of our business, including due diligence activities);
- courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
- any other third parties as required or permitted by law, such as where we receive a subpoena.
6. Access and management
Subject to some exceptions provided by law, you may request access to your personal information in our customer account database, or seek correction of it, by contacting us. See section 11: Contact information. Should we decline you access to your personal information, we will provide a written explanation setting out our reasons for doing so.
We may charge a reasonable fee that is not excessive to cover the charges of retrieving your personal information from our customer account database. We will not charge you for making the request.
If you believe that we hold personal information about you that is not accurate, complete or up-to-date then you may request that your personal information be amended. We will respond to your request to correct your personal information within a reasonable timeframe and you will not be charged a fee for correcting your personal information.
If we no longer need your personal information for any of the purposes set out in this Privacy Notice, or as otherwise required by law, we will take such steps as are reasonable in the circumstances to destroy your personal information or to de-identify it.
7. Direct marketing
Joining the Diamond Club does not, by itself, sign you up to receive marketing communications. We seek your consent to marketing separately and specifically, and we do not treat enrolment in the Diamond Club as that consent. Communications we send you about your membership (such as confirmations and benefit updates) are service communications, not marketing.
Where we have your express or implied consent, or where we are otherwise permitted by law, we may use your personal information to send you information about products and services we believe are suited to you and your interests or we may invite you to attend special events.
At any time you may opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your personal information as detailed above, will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us in writing at sales@abelini.com.au. We handle electronic marketing in accordance with the Spam Act 2003 (Cth).
8. Cross-border disclosure
We may disclose your personal information to third party recipients located in or outside of Australia in order to provide our website, products and services to you. The overseas recipients are likely to be located in the United Kingdom and in other countries in which our service providers operate.
When entering into a transaction with us you consent to your personal information being disclosed or transferred to overseas recipients Before disclosing your personal information overseas, we take steps that are reasonable in the circumstances to ensure that the overseas recipient handles it in a way that is consistent with the APPs, except to the extent that you have consented to the disclosure or it is otherwise permitted or required by law.
9. Cookies and the Abelini website
When transmitting personal information from your computer to the Abelini website, you must keep in mind that the transmission of information over the Internet is not always completely secure or error-free. Other than liability that cannot lawfully be excluded, we will not be liable in any way in relation to any breach of security or any unintended loss or disclosure of that information.
The Abelini website may use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but if you do so, you may not be able to fully experience the interactive features of the Abelini website.
We use the following categories of cookies and similar technologies: (a) strictly necessary cookies, which are required for the website and checkout to function; (b) analytics cookies, which help us understand how the website is used; and (c) advertising and retargeting cookies, including third-party pixels, which support our marketing. Some of these technologies collect personal information and may share it with third parties, including overseas.
You can manage your choices for analytics and advertising cookies at any time through the cookie preferences tool on our website and through your browser settings. Where required, we will seek your consent before using advertising or retargeting cookies. For more detail about the cookies we use, their purposes, the third parties involved and how to manage them, please see our Cookie Policy, available on our website.
10. Security
We may hold your personal information in either electronic or hard copy. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information.
However, we cannot guarantee the security of any personal information transmitted over the internet and therefore you disclose information to us at your own risk. We will not be liable for any unauthorised access, modification or disclosure, or misuse of your personal information.
11. Contact information
If you require further information regarding this Privacy Notice or wish to make a privacy complaint, please contact us at [config_email] or call us on [config_telephone] or send mail to KSR Partners Pty Ltd, Ground Floor, 1 Oxley Road, Hawthorn VIC 3122. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
12. Miscellaneous
We reserve the right to modify this Privacy Notice in whole or in part from time to time and amendments will be effective immediately upon posting of the amended Privacy Notice on the Abelini website. We will take reasonable steps to notify you of any material changes.