Privacy Policy
Privacy Policy
Struddys Apparel Co - Privacy Policy and Credit Management Policy
1 Privacy Policy
Struddys Apparel Co Pty Ltd (ABN 97 010 396 513), trading as Struddys
Apparel Co, is committed to protecting the privacy of your personal
information. This Privacy Policy explains how Struddys Apparel Co
manages personal information that it collects, holds, uses and discloses
to ensure that your personal information and privacy are protected.
Struddys Apparel Co complies with the Australian Privacy Principles
(APPs) and, to the extent applicable, the credit provider provisions in
the Privacy Act 1988 and the registered Credit Reporting Code.
1.1 Collection of personal information
When collecting your personal information, Struddys Apparel Co takes
reasonable steps to make you aware of the purposes for which the
information is being collected, the organisations to which Struddys
Apparel Co will usually disclose your information (and, if they are
located overseas, the countries they are located in), legal obligations
(if any) requiring Struddys Apparel Co to collect the information, and
the main consequences (if any) if you fail to provide any information
that is requested.
Struddys Apparel Co limits the personal information collected to that
which is reasonably necessary for Struddys Apparel Co's functions or
activities. When reasonable and practicable, Struddys Apparel Co only
collects your personal information directly from you. If you do not
provide the personal information requested, we may be unable to assist
you (for example, we may not be able to complete a sale or approve any
application you make for credit).
Struddys Apparel Co may collect personal information from you in a
number of circumstances, including if you (or a business you operate or
represent):
• contact Struddys Apparel Co, for example, to enquire about Struddys Apparel Co’s products;
• place an order for Struddys Apparel Co products;
• apply for credit terms with Struddys Apparel Co.
The types of personal information that Struddys Apparel Co collects and
holds may include your name, email address, residential and/or postal
address, telephone number and/or date of birth. We may also collect and
hold identity verification documents which may include a copy of your
driver’s licence or birth certificate.
Struddys Apparel Co may also collect and hold other personal
information, such as credit information or credit eligibility
information obtained from a credit reporting body, in connection with a
credit application or the ongoing management of credit and processing of
payment. For more information on how Struddys Apparel Co manages credit
information please see Struddys Apparel Co’s Credit Management Policy
below.
This information may be collected from you via our website, over the
telephone, via email or mail, or in person and may be held in electronic
or paper form.
Struddys Apparel Co collects and holds personal information in order to
conduct its business, to provide its products and services and to meet
legislative and regulatory requirements. This generally involves, but is
not limited to, collecting and holding personal information to:
• provide further information about Struddys Apparel Co's products;
• assess an applicant's eligibility for credit terms;
• process payment for products ordered;
• arrange for delivery of ordered products;
• provide customer support; and
• respond to customer enquiries and resolve any complaints.
1.2 Use of personal information
Struddys Apparel Co will use personal information for various purposes, depending on the circumstances.
Struddys Apparel Co will generally only use your personal information
for the purpose for which it was collected, and for related purposes
that are within your reasonable expectations. Struddys Apparel Co will
seek your consent prior to using or disclosing your personal information
for another purpose, unless we are required or authorised by the APPs
or by law to do so without seeking your consent.
If you or a business you operate or represent apply to Struddys Apparel
Co for credit, we may use your personal information to determine
eligibility for credit, and to set credit limits from time to time.
Your personal information may also be used to enable Struddys Apparel Co
to offer you other products or services that are related to products or
services Struddys Apparel Co has previously provided to you, and you
consent to us doing so. However, if you do not wish to receive
marketing or promotional communications from us, please notify Struddys
Apparel Co (using the contact details set out below), or use the opt out
function provided for in those communications. Unless you opt out, you
will be taken to have consented to receiving such communications.
There are no consequences of opting out of receiving our marketing and
promotional communications except that you will no longer receive them,
and you may elect to rejoin our marketing list at a later stage if you
wish.
1.3 Disclosure of personal information
Struddys Apparel Co may disclose your personal information to other
organisations to enable it to provide and administer its products. These
organisations include the following:
• credit reporting bodies, for the purpose of obtaining your credit
report (for more information see Struddys Apparel Co’s Credit Management
Policy below);
• electronic identification verification service providers;
• fraud prevention service providers; and
• other organisations, where you have provided your consent.
When Struddys Apparel Co engages contractors and third party service
providers to provide specialised services such as bulk mailing and
market research services, these contractors and service providers are
obliged to only use personal information disclosed to them by Struddys
Apparel Co for the specific purposes for which it was provided. It is
unlikely that Struddys Apparel Co will disclose your personal
information to overseas recipients.
1.4 Access to personal information
You may request access to your personal information held by Struddys
Apparel Co by writing to us. Struddys Apparel Co will respond to your
request within a reasonable period after your request is made. APP 12
outlines your rights to access personal information in greater detail.
If you lodge a request for access, we may provide you with access to
your personal information in any of a number of ways (including, for
example, supplying you with a copy or providing you with the opportunity
to inspect it).
1.5 Correction
Struddys Apparel Co takes reasonable steps to ensure that the personal
information it collects, uses or discloses is accurate, up-to-date and
complete.
If you believe any of your personal information held by Struddys Apparel
Co is incorrect or out-of-date you may make a written request to
Struddys Apparel Co seeking a correction. Struddys Apparel Co will
respond within a reasonable period after your request is made.
1.6 Storage of personal information
Struddys Apparel Co takes reasonable steps to store your personal
information securely, and has policies and procedures intended to ensure
that your personal information is not misplaced or misused, and that
unauthorised access to, or modification or disclosure of, your personal
information does not occur.
1.7 Privacy online
When you visit Struddys Apparel Co’s web site, our web server collects
the following information for statistical and customer service purposes:
• the number of users who have visited our web site;
• the date and time that visitors have visited our web site;
• the number of pages viewed and documents downloaded;
• the type of browser software that you are using; and
• the type of operating system that you currently use.
Struddys Apparel Co makes no attempt to identify you or to track or
monitor your browsing activities from the above information. We only use
this information to improve the performance of Struddys Apparel Co's
web site and Struddys Apparel Co's service to its customers.
You acknowledge that, if you provide any personal information to
Struddys Apparel Co via online services (including email) or if we
provide such information to you by such means, the privacy, security and
integrity of this information cannot be guaranteed during its
transmission.
1.8 Amendment
Struddys Apparel Co undertakes periodic reviews of its policies and
procedures with guidance by Struddys Apparel Co’s legal advisers to
ensure that the personal information held is managed appropriately.
Struddys Apparel Co therefore reserves the right to amend this Privacy
Policy at any time. You may obtain a copy of the current version of this
Privacy Policy by
contacting Struddys Apparel Co, or by accessing Struddys Apparel Co’s web site.
1.9 Complaints
If you believe that a breach of your privacy has occurred, we encourage you to contact Struddys Apparel Co to discuss your
concerns.
Your complaint will be considered and dealt with by our Privacy
Officer. If the breach is considered to be serious, the Privacy Officer
may escalate the complaint internally within Struddys Apparel Co.
Please allow us a reasonable time to respond to your compliant.
1.10 Contact information
Struddys Apparel Co Pty Ltd
Attn: Privacy Officer
82 Bryants Road, Loganholme, QLD 4129, Australia
Phone: (07) 3209 6100
Email: wholesale@struddys.com.au
2 Credit Management Policy
Struddys Apparel Co is committed to protecting the privacy
of your credit information and credit eligibility information
(collectively referred to as “credit data” in this Credit Management
Policy).
This Credit Management Policy explains how Struddys Apparel Co handles such credit data.
Struddys Apparel Co does not provide consumer credit, but it provides
commercial credit to some of its wholesale customers. In the course of
assessing applications for commercial credit, credit data on individuals
may be collected (for example, this may occur if a customer carries on
business as a sole trader, or if a personal guarantee is provided in
support of a credit application).
Generally speaking, credit data is information used to assess an
individual's eligibility to be provided with credit. It may include
details of credit provided to you, repayment history information, and
certain details regarding overdue payments or defaults.
Credit data is a specific kind of “personal information” (which is
essentially information or an opinion about you as an identified or
reasonably identifiable individual). Struddys Apparel Co’s Privacy
Policy set out above applies to Struddys Apparel Co’s handling of
personal information generally. Unless otherwise stated, this Credit
Management Policy applies instead of Struddys Apparel Co’s Privacy
Policy where Struddys Apparel Co handles credit data.
2.1 Collection of credit data
The kinds of credit data that Struddys Apparel Co collects and holds may include:
• identification information (which may include your full name,
previous name, alias, date of birth, gender, current and last known
address and two previous addresses, the name of your current or last
known employer, and driver’s licence number);
• a copy of documents that include such identification information
(such as your driver’s licence, birth certificate or passport);
• consumer credit liability information (which may include information
about existing credit provided to you such as the name of the credit
provider, the type of credit, when it was provided, the terms and
conditions that apply, the maximum amount of credit available, and the
day on which the credit was terminated);
• repayment history information (which may include whether or not you
have made a payment on time, when it was due and when it was paid);
• details of previous applications for credit made by you;
• default information (which relates to certain overdue payments);
• payment information (which relates to when such overdue payments were made);
• court proceedings information (which relates to court judgements about credit provided to
you);
• personal insolvency information (for example, if you are declared bankrupt);
• publicly available information relating to your credit worthiness; and
• any opinion of a credit provider that you have committed a serious credit infringement.
Credit information may be collected by Struddys Apparel Co:
• directly from you;
• from a credit reporting body (such as Veda Advantage); and/or;
• from other parties (for example, other credit providers) where permitted by the Privacy Act.
If you do not provide or agree to the collection of the credit data
requested, we may be unable to assist any business you operate or
represent (for example, we may not be able to approve any application
such a business makes for credit facilities).
Struddys Apparel Co usually derives, from credit data disclosed to
Struddys Apparel Co by a credit reporting body (such as Veda Advantage),
information including internal assessments and calculations based on
such credit data for the purpose of assessing credit applications
received by Struddys Apparel Co.
2.2 Purposes
Struddys Apparel Co collects, holds, uses and discloses credit data in
order to conduct its business, to provide its products and services and
to meet legislative and regulatory requirements. This generally
involves, but is not limited to, collecting, holding, using and
disclosing credit data to:
• assess a customer's eligibility for credit and credit worthiness. In particular, Struddys Apparel Co may use
your credit data to determine the eligibility for credit of a business you operate or represent;
• monitor and adjust credit limits for customers or revoke the provision of credit;
• administer customers’ orders and accounts;
• facilitate collection of overdue accounts; and
• resolve complaints.
Struddys Apparel Co will not sell your credit data to any third parties.
It is unlikely that Struddys Apparel Co will disclose your credit data to overseas recipients.
2.3 Credit reporting bodies
Personal information provided by us to credit reporting bodies such as
Veda Advantage may be included in reports provided by credit reporting
bodies to other credit providers, to assist them to assess your credit
worthiness.
If a customer fails to meet its payment obligations or commits a serious
credit infringement, we may be entitled to disclose this information to
credit reporting bodies. A serious credit infringement includes:
• fraudulently obtaining a loan;
• fraudulently evading (or attempting to evade) obligations in relation to a loan; or
• an act that a reasonable person would consider indicates an intention
to no longer comply with obligations in relation to a loan.
You may contact a credit reporting body to request that it does not:
• use credit reporting information about you for the purpose of pre-screening of direct marketing by a credit provider; or
• use or disclose credit reporting information about you if you believe
on reasonable grounds that you have been or are likely to be a victim
of fraud.
You may obtain a credit reporting body's credit management policy by
requesting a copy from them, or it may be available on their website.
2.4 Access to credit information
You may request access to your credit data held by Struddys Apparel Co
by writing to us. Struddys Apparel Co will respond to your request
within a reasonable period after your request is made. The section of
our Privacy Policy available above, outlining the process that will
apply should you request access to your personal information, also
applies to access to your credit data. Section 21T of the Privacy Act
also outlines your rights to access your credit data in greater detail.
2.5 Correction
Struddys Apparel Co takes reasonable steps to ensure that the credit
data it collects, uses or discloses is accurate, up-to-date and
complete.
If you believe any of your credit data held by Struddys Apparel Co is
incorrect or out-of-date you may make a written request to Struddys
Apparel Co seeking a correction. Struddys Apparel Co will respond within
a reasonable period after your request is made.
The section of our Privacy Policy available above outlining the process
that will apply should you request correction of your personal
information also applies to the correction of your credit data.
Sections 21U to 21W of the Privacy Act also outline your rights to
correct your credit data in greater detail.
2.6 Storage of credit data
Struddys Apparel Co takes reasonable steps to store your credit data
securely, and has policies and procedures intended to ensure that your
credit data is not misplaced or misused, and that unauthorised access
to, or modification or disclosure of, your credit data does not occur.
Credit data may be held by us electronically or in hard copy form, and
we employ security protections appropriate for the form in which that
information is held (eg, passwords linked with authorised user access
and physical document security).
2.7 Amendment
Struddys Apparel Co undertakes periodic reviews of its policies and
procedures with guidance by Struddys Apparel Co’s legal advisers to
ensure that the credit data held is managed appropriately. Struddys
Apparel Co therefore reserves the right to amend this
Credit Management Policy at any time. You may obtain a copy of the current version of this Credit
Management Policy by contacting Struddys Apparel Co, or by accessing Struddys Apparel Co’s web site.
2.8 Complaints
If you believe that a breach of your privacy has occurred, we encourage
you to contact Struddys Apparel Co to discuss your concerns. Your
complaint will be considered and dealt with by our Privacy Officer. If
the breach is considered to be serious, the Privacy Officer may escalate
the complaint internally within Struddys Apparel Co. Please allow us a
reasonable time to respond to your compliant.
2.9 Contact information
Struddys Apparel Co Pty Ltd
Attn: Privacy Officer
82 Bryants Road, Loganholme 4129, Australia
Phone: (07) 3209 6100
Email: ross@struddys.com.au