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1. Respecting your privacy
We are committed to compliance with privacy laws which apply to our businesses and which set out standards for the management of personal information. This policy outlines our personal information management practices applying to the personal information of individuals in respect of their dealings with Hallas or interaction with a Hallas online site or application, specifically:
- the kinds of personal information we collect and hold;
- how we collect and hold it;
- the purposes for which we collect, hold, use and disclose it;
- your right to access and seek correction of it;
- how you may complain about privacy matters; and
- our sharing of your personal information overseas.
There are some matters to which this policy does not apply. These are referred to below.
2. Who are we?
In this policy, ‘we’ and ‘Hallas’ are, individually and collectively, Hallas Trading Co Pty Ltd ACN 001 708 925 and its related bodies corporate, including Hallas Franchising Company Pty Ltd ACN 099 864 865.
Hallas manufactures, markets and distributes beauty, skincare and sunscreen products, skincare regimes and associated products for use and sale. Since circa 1954 it has primarily been engaged in manufacturing and distributing Ella Baché products through Ella Baché salons in Australia and New Zealand, which it does under licence. It also sells Ella Baché products online and through department stores.
3. What kinds of personal information do we collect and hold?
The personal information we collect and hold is what we consider reasonably necessary for our business functions and activities. When we collect and hold personal information, it is generally of the kind we ask for in order to provide our services and what arises from those services. This personal information may include your first name, surname, email address, phone numbers, date of birth, mother’s maiden name and place of birth. We may also ask several optional demographic questions that are used to assist us with anonymous internal research and development purposes. On occasions, we may also receive sensitive information such as health information, including medicines that you currently use or have previously used, and any other information which you consent to give us and to which we are permitted to collect under law. It will also extend to other personal information you make available to us including to create an account with us. We may also collect information including your IP address when visiting our website.
You have the option of not identifying yourself or of using a pseudonym when dealing with us. But not where this is impractical or where the law or a court order provides otherwise. Given our products and services are usually of a personalised nature, and that we may need to arrange delivery of products or facilitate the provision of beauty or skin care services to you, it is sometimes not possible to utilise our service without identifying yourself.
4. How do we collect and hold personal information?
Collection of personal information: When we collect personal information about you, we do so by making a record of it. We do this when:
- you communicate with us online, for example when you create account with us or utilise the service of one of our Ella Baché salons (eg Ella Baché franchisees or distributors);
- you subscribe to our newsletter;
- you take part in any trade promotions, testimonials, surveys or focus groups we are involved in conducting;
- you provide personal details to one of our Ella Baché salons during the course of a transaction with them;
- you deal with us in other ways involving a need for personal information to be provided such as when you make contact with us.
If you are one of our Ella Baché franchisees, similarly, we will collect information about you including name, salon address, telephone number, facsimile number, account details, contract information and confidential business information.
We may also collect information about you from third parties, including department stores or technology service providers (for example Shortcuts Software Australia Pty Ltd), to provide, and continue to provide, our products and services to you. By providing your personal information, and placing an order with us or one of our distributors, you consent to such behaviour by us.
Holding of personal information: Personal information we hold is generally stored in computer systems. These may be operated by us or by our service providers.
5. Why do we collect, hold, use and disclose personal information?
When we collect, hold and use your personal information, we do so primarily to:
- ensure that our services are tailored to your specific beauty and skin care needs;
- maintain our customer records;
- allow you to participate in Hallas activities such as patient consultations, and beauty and skin care services provided online or at our salons;
- respond to any request for products or services;
- fulfil orders placed with Hallas by any means (including through our website)
- provide newsletters; and
- maintain a record of enquiries, complaints and adverse event reports relating to Hallas products and services.
We may use some of your personal information to market to you and to others and for incidental purposes. Not all information collected in respect of you is used for marketing and the majority of information is collected solely for the purpose of providing products, access to the website and any account you may have with us, and our services to you.
If you are an Ella Baché franchisee, we will also use your personal information to:
- facilitate day to day business communications with salons;
- provide salon assistance including arranging meetings and conferences;
- maintain account records; and
- provide salon contact details to members of the public.
We disclose personal information we collect for those purposes, and for incidental purposes. For example, we may disclose your personal information within our group, to service providers who assist us in our day-to-day business operations and as part of buying or selling businesses.
We may collect, hold, use and disclose your personal information for other purposes which are within reasonable expectations or where permitted by law. When marketing to you, your personal information is only ever used or disclosed for our own purposes. You may opt out of our direct marketing to you. Our direct marketing materials will tell you how to do this.
We may de-identify your personal information. We may do this for use and disclosure of the anonymous data for various data analytics purposes.
6. How can you enquire about, access and correct your personal information?
Access: We will provide you with access to any of your personal information we hold (except in limited circumstances recognised by law). If you wish to access your personal information or have an enquiry about privacy, please contact our Privacy Officer at:
Hallas Trading Co Pty Ltd ACN 001 708 925
2 Lambs Road
ARTARMON NSW 2064
Post: Locked Bag 1360, ARTARMON NSW 1570
Telephone: 02 9432 5000
Before we provide you with access to your personal information we may require some proof of identity. We may charge a reasonable fee for giving access to your personal information if your request requires substantial effort on our part.
Correction: If you need to correct personal information we hold, please contact our Privacy Officer at one of the above contact points.
7. How can you complain about our management of personal information?
If you wish to complain about a breach of the privacy rules that bind us, you may contact our Privacy Officer at one of the above contact points. We may ask you to put your complaint in writing and to provide details about it. We may discuss your complaint with our personnel and our service providers and others as appropriate.
Our Privacy Officer will investigate the matter and attempt to resolve it in a timely way. Our Privacy Officer will inform you in writing about the outcome of the investigation. If our Privacy Officer does not resolve your complaint to your satisfaction and no other complaint resolution procedures are agreed or required by law, our Privacy Officer will inform you that your complaint may be referred to the relevant privacy regulator for further investigation and will provide you with the regulator’s contact details.
8. Our sharing of your personal information overseas
We may allow your personal information to be shared with those who are in countries other than your own location. We do this:
- where we have made a business decision to store our data with a trusted service provider who is in the business of providing data storage and processing services. Examples are those who store and process our email and mobile application data. These services commonly involve diverse geographic locations which change from time to time for reasons which include data protection and processing efficiency. Where these services are used by us, it is not practical for us to notify you of which country your personal information may be located in;
- for disclosures between our group companies. Our main business location is in Australia but we do business in a number of countries, including New Zealand, and some of our group companies may be based in other countries from time to time; and
- when our business that collected your personal information is in a different country to your location.
10. Payment information
All pages that require you to enter your personal information or payment details on our site use 128 bit SSL encryption. To ensure that the page you are viewing uses 128 bit SSL encryption, you should look for the padlock icon in your browser.
11. Other privacy terms and limits of this policy
This is a policy only. There may be additional privacy notices and terms relevant to you depending on the nature of your dealings with us. We have separate charters concerning our employees – this policy does not apply to the personal information of our employees in their capacity as such.
Although we offer you access to external websites through the links we have provided, those websites are not subject to our privacy standards, policies and procedures. Likewise, our Ella Baché salons are independent owners and we do not have control over their data handling practices. We recommend that you make your own enquires as to the privacy policies of these third parties. Hallas is in no way responsible for the privacy practices of these third parties.
12. More information
More information about privacy law and privacy principles is available from the privacy regulator. The privacy regulator in Australia is the Privacy Commissioner: www.oaic.gov.au (email: firstname.lastname@example.org).