Privacy policy

Collection Statement

To assist Secrets Shhh in providing our products and services to you, and otherwise conduction our business functions and activities, we need to collect personal information about you. Generally, this information is used to improve our services and product offerings, and to provide a more tailored and better shopping experience for you.

We take the utmost care to respect your privacy, and strive to handle your personal information responsibly, and to act honestly, fairly and with transparency in all our customer transactions. Should we ask you to provide certain information by which you can be personally identified, then you can be assured that it will only be used in accordance with this Privacy Policy. As a policy, we do not sell, trade or rent your personally identifiable information to third parties, unless you have granted us permission to do so. If you do not agree to the terms outlined in our privacy policy, you must not provide your personal information. This means we may not be able to communicate with you or provide a partial or full range of products and services to you.

The Privacy Policy outlines what personal information we may collect from you, how we use that information, the secure storage of information, how you may access and seek correction of your personal information, how you may complain about a perceived breach of your privacy, and how we deal with that complaint.

Privacy

1. About this Privacy Policy

        • The Company, as defined below, is committed to protecting the privacy of its individuals and is bound by the Australian Privacy Principles (‘APPs’) set out in the Privacy Act 1988 (as amended from time to time) (‘Act’). We will only collect, use or disclose personal information in accordance with the Act and this Privacy Policy.
        • Company (‘the Company’), Secrets, Secrets Shhh, us, or we means “Secrets Shhh Pty” trading as “Secrets Shhh” ABN 36 617 804 332 and its successors and assigns. This Privacy Policy applies to the collection, use, disclosure and handling of personal information (including sensitive information as defined by the Act) by the Company.
        • This Privacy Policy explains, in general terms, how the Company protects the privacy of your personal information and sensitive information under the APPs. The APPs set out in this Privacy Policy will only apply to Personal Information or sensitive information as defined in the Act (where applicable) (the ‘Personal Information’) or opinions you provide to the Company via the Website, any agreement or arrangement with us and any information which we collect about you from other sources as permitted by law.

2. Personal Information

2.1 The Act defines "Personal Information" to mean information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

3. Personal Information collected and held by Secrets Shhh

3.1    The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with them. Personal Information that we collect may include (but is not limited to) the following:

 

  • name
  • date of birth
  • contact details including telephone numbers (landline and/or mobile)
  • current address (including postal address and country of residence)
  • email address
  • gender
  • life-event information which may include your date of birth and other anniversaries (wedding, birthday, partner’s birthday etc)
  • transactional details such as product purchases and order details, financial institution details, payment card type, number expiry date, CVV number and proof of identification
  • digital device information, such as IP addresses, geographical location, device type and connection information
  • security data such as photographs and/or images of you from CCTV footage or information used to secure online transactions
  • consumption habits and preference information from customer service call recordings, marketing activities and services, social media accounts and profiles, events attended or participated in, or reviews provided by you
  • human resources data such as occupation and employment details including employment status and any previous work experience, tax, superannuation, and payroll information
  • employment candidacy related information from or in connection with your resume or job application such as background information checks, birth certificate, passport or citizenship certification, criminal history, social media activity and medical and health information
  • any personal information volunteered through general use of our Website (including via cookies) or in dealings with store staff
  • Where lawful and practicable, individuals have the option of not identifying themselves (remaining anonymous or using a pseudonym) when dealing with Secrets Shhh.
4. How and when Secrets Shhh collects Personal Information

4.1    Secrets Shhh collects your Personal Information to allow us to conduct our business functions and activities. These functions or activities include, but are not limited to, the sale, promotion and distribution of its services by direct to customer marketing as well as on-line advertising and marketing and for the specified purposes set out below. In some circumstances the collection of Personal Information may be required by law.

4.2    How we collect Personal Information will depend upon the nature of our interaction with a person. Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect Personal Information directly from the relevant individual where reasonable and practicable. How we collect information may include (but is not limited to) the following:

  • when you use or buy our products or services
  • when you provide us, or you offer or apply to supply us, with goods or services;
  • when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card);
  • when you request information about us, our products or our services
  • when you attend or register for an event, workshop, webinar, special offers or similar;
  • when you provide feedback or provide a product review to us
  • when you visit or fill in a form on our Website (see Section 5);
  • when you register for or use an account on our Website, including passive collection which is information automatically collected without your knowledge whilst using our Website and includes information on your device or computer such as cookies (see Section 5);
  • when you visit premises from which we operate;
  • when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations;
  • when you submit a job application to us;
  • when you otherwise contact us by telephone, fax, email, social media, post or in person, or live chat;
  • where we are otherwise required or authorised by law to do so.

4.3 Secrets Shhh may also collect Personal Information about you from other third parties or sources. We will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you, or if we are otherwise permitted or lawfully able to do so. These sources may include (but are not limited to) the following:

  • your nominated representatives (eg spouse, accountant, power of attorney, brokers and other professional advisors);
  • a known person to you, such as someone who buys a gift for you and your personal information is provided to us in connection with the purchase of that gift;
  • trade promotions, competitions and games (whether in-store or online), including those run by us or run by third parties who participate with us;
  • referees provided on an employment application made with us;
  • credit reporting bodies or an agent for a third-party credit provider;
  • publicly available sources of information;
  • related law enforcement agencies, bankruptcy and court judgements;
  • government entities such as Australia Post;
  • identity verification providers;
  • social media platforms.

4.4 The Personal Information we collect may include sensitive information, including health information. We will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent.

4.5 Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you choose not to provide mandatory or voluntary Personal Information to us for the purposes set out in this Privacy Policy, we may be unable to provide you with requested information, products or services to effectively conduct our relationship with you.

5. Personal information collected from you via our Website

5.1  The sole purpose of collecting your Personal Information is to improve your experience when using our website and web services.

5.2 Any person may access or use the Website via the internet without registering with or disclosing any Personal Information to us.

5.3 Personal Information may be collected by us and by our third-party service providers who assist us in operating our Website including its subdomains and any other website we operate from time to time (collectively the ‘Website’).

5.4 Personal Information may be collected by us on our Website when you:

  • purchase a product, or engage with a service offered online;
  • use or generally navigate around our Website;
  • fill in a form;
  • register for or use an account;
  • register for an event, workshop, webinar, special offers or similar;
  • when you provide online feedback or provide an online product review to us
  • volunteer Personal Information to us via the Website.

5.5 We may use various technological methods from time to time to track the visiting patterns of individuals accessing our Website, including but not limited to the methods set out in this Section 5.

5.6 Cookies: Our Website may use 'cookies' from time to time. A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie enables us to monitor web traffic, trends and some system information such as:

  • device type (unique device identifiers) and browser information;
  • your device's Internet Protocol (IP) address (collected and stored in an anonymized format);
  • device screen size;
  • geographic location (country only);
  • preferred language used to display the webpage.

Cookies help tailor your web operations to your needs, likes and dislikes by gathering and remembering information about your preferences. In some cases, cookies can help us to aggregate certain information with other Personal Information we hold about you. This helps us to enhance the content and services delivered to you, by providing a more tailored experience via our Website.

  • Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information. However, they do allow third parties such as Google and Facebook to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and whenyou choose to provide the Site with personal information, this information may be linked to the data stored in the cookie.

You can set your web browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. This will provide you an opportunity to decide what information is shared through cookies. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

If you disable cookies or remove or reject specific cookies from our Website or linked sites, then you may not be able to access all of the content on our Website or take advantage of the tailored experience that cookies can facilitate.

5.7 Web analytics: We use a range of analytic service providers such as Google Analytics to generate statistical and general usage information. These tools do not use any Personal Information you have provided us

If you do not want your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit the Google Analytics opt-out page here

5.8 Retargeting: Retargeted services are used by us to display content specific advertisements to previous visitors of our website when those visitors go to other websites, including social media applications.

You can opt out of retargeting advertising by visiting the Network Advertising Initiative opt out page here.

5.9 Click Stream Data- When you read, browse or download information from our Website, we or our internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, and any information downloaded.

5.10 Web Beacons - Web beacons are images that originate from a third-party site to track visitor activities. We use web beacons to track the visiting patterns of individuals accessing our Website.

5.11 Third party content (eg social media links)- Some of the content on our Website includes applications made available by third parties. We use these third-party applications to provide a more connected and better online experience. They enable activities such as sharing social media content or links to our Website through the relevant third-party platforms amongst other functionality. The third-party applications themselves may facilitate collection of information, through your direct, or even indirect interaction, with the applications. Please visit the relevant third-party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information. We are not responsible for the technical operation of these applications, or the data collection and usage of Personal Information by these third parties.


6. Disclosure of your Personal Information

6.1    We may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in paragraph 5.3.

6.2 Depending upon the nature of our interaction with a person, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application submitted to us).

6.3 We may also disclose your Personal Information to:

  • any of Secrets Shhh internal divisions, business units or departments;
  • your nominated representatives (eg spouse, accountant, power of attorney, brokers and other professional advisors);
  • other organisations or individuals who assist us in providing products and services to you;
  • professional service providers and advisors who perform functions on our behalf, such as lawyers;
  • representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development);
  • bankers, mortgage insurers, lenders, valuers, real estate agents, insurers, brokers, auditors, business consultants and IT service providers;
  • external service providers; and
  • Government, regulatory authorities, law enforcement agencies and other organisations as required or authorised by law;
  • credit reporting agencies and courts, tribunals and regulatory authorities where you fail to pay for goods or services provided to you;
  • third parties to collect and process data such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia.

 

6.4 We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

6.5 You acknowledge that any information which you choose to make public within our Event, Workshop & Webinar Registrations, Special Offer Registrations, Product reviews and other public sections, including your Personal Information will be publicly available within that area.

6.6 We may also disclose your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of Secrets Shhh, our business or any of our assets, including in insolvency, in circumstances which require the purchaser or potential purchaser to use such Personal Information consistently with this Privacy Policy.

6.7 Trans-border disclosures

The Company may transfer (and you are deemed to consent to the Company transferring) your Personal Information outside of Australia in the following circumstances:

  • where the Company has taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your Personal Information;
  • where the Company reasonably believes that the person who will receive your Personal Information is subject to effective data protection obligations;
  • where the transfer is necessary for the performance or conclusion of any contract between you and the Company or for the implementation of pre-contractual measures;
  • where the transfer is for your benefit and it is impractical for the Company to obtain your consent, but if it were practical you would be likely to consent;
  • as required or authorised by or under law;
  • where you subsequently consent from time to time;
  • our offices or related entities are overseas;
  • we outsource certain activities overseas;
  • transactions, information, services or products have an overseas connection; or
  • our computer systems including IT servers are located overseas.

6.8 Other uses and disclosures

We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will take reasonable steps to make it known to you at the time we collect or use your Personal Information.

6.9 Where we disclose your personal information to third parties for these purposes, we will request that the third party follow this Privacy Policy regarding handling of your personal information.

7. Storage and Security of your Personal Information

7.1 The Personal Information is collected and held only to the extent reasonably necessary for one or more of the Company’s functions or activities.

7.2 We are committed to ensuring that your personal information is protected from misuse, loss, unwarranted modification, unauthorised access or disclosure both physically and through computer encryption and security.

7.3 We are committed to ensuring that your information is secure. We use the most secure SSL encryption (the industry standard method for computers to communicate securely without risk of manipulation or recipient impersonation), passwords, anti-virus software and email filters act to protect all our electronic information.

7.4 In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

7.5 We do not collect sensitive or financial information about our users via our Website.

7.6 If we find we have no further need for your Personal Information we may de-identify it or remove it from our systems and destroy all record of it.

7.7 No information transmitted over the Internet can be guaranteed to be secure. We cannot guarantee the security of any information that you transmit to us, or receive from us. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

8. Access to, and Correction of, your Personal Information

 8.1 The accuracy of your Personal Information is largely dependent on the information you have provided to us. Any errors or changes to your Personal Information can be communicated with us via the contact form on our Website, or instore. We will use all reasonable efforts to correct the Personal Information.

8.2 If you have a Secrets Shhh online account, you can access and correct some of your Personal Information by logging on and updating your profile at any time.

8.3 If you would like access to our records of your Personal Information, please contact us in writing through the contact form on our Website.

8.4 We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date.

9. Consent

9.1 By using our Website, purchasing a product or service from us (whether in store or online), interacting with us through third party applications (such as social media), registered or attended an event, workshop and webinar, special offer or provided a product review or engaged in other public sections, where you have been provided with a copy of our Privacy Policy or had a copy of our Privacy Policy reasonably available to you, you are acknowledging and agreeing:

  • to provide the consents given by you in this Privacy Policy; and
  • that you have been informed of all of the matters in this Privacy Policy

9.2 You consent to the collection, use, storage, and processing of your Personal Information outside of Australia as set out in this Privacy Policy.

9.3  You may opt out of Website collection of data by the means prescribed in section 5.6, 5.7 and 5.8.

9.4 You may opt of marketing activities by:

  • Clicking unsubscribe in a direct marketing email received from us;
  • Responding with STOP to SMS messages sent by us;
  • Unfollowing our social media accounts; and
  • Emailing us via the contact formon our website

9.5  The website uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS.

9.6 The above excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.

10. Privacy Complaints or Inquiries

10.1 If you have:

  • a query or concern about this Privacy Policy or our Personal Information handling processes;
  • wish to make a complaint in relation to a perceived breach of your privacy;
  • would like to access your Personal Information held by us;
  • would like to update or correct your Personal Information held by us; or
  • would like to opt out of direct marketing

Please contact us by:

  • Telephone: 07 3569 6515; or
  • Email: onlineassist@secrets-shhh.com or contact us via the contact formon our website

10.2 We will promptly investigate your complaint and respond to you in writing setting out the outcome of our investigation, what steps we propose to take to remedy the breach and any other action we will take to deal with your complaint.

Last update: March 2023