Privacy Policy - Australia

SEACRET Direct Australia Pty Ltd (SEACRET AU) is dedicated to ensuring that we comply with our obligations under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

As your privacy is important to us, SEACRET AU is committed to taking such steps as are reasonable in the circumstances to protect and maintain your privacy.

By using our services, you consent to our collection and use of your personal information in the manner detailed in our Privacy Policy, including the disclosure of your personal information to overseas recipients as set out in section 7 below.

1. Why do we collect personal information?

SEACRET AU collects personal information from:

• Our valued customers; and
• Our SEACRET AU Agents.

SEACRET AU only collects personal information from you if that information is reasonably necessary for or directly related to, one or more of SEACRET AU’s functions and activities. Where we collect personal information from third parties, such as related companies, we will only do so if it is unreasonable or impracticable to collect the personal information directly from you and we will take reasonable steps to inform you if and when we do.

Our valued customers

SEACRET AU collects personal information from you to provide you with quality products and personalised services.

For example, SEACRET AU may collect personal information to allow us to sign you up to our newsletter, to provide you with occasional news, to process your orders, to provide you with updates and related product or service information and so that we may promptly respond to your queries.

Our SEACRET AU Agents

SEACRET AU collects personal information from you when you apply to become an independent SEACRET AU Agent, and to assist you to operate your SEACRET AU business.

For example, SEACRET AU may collect personal information to allow us to provide you with important updates and new product information, to process your orders, to provide you with reports and to pay your commissions and bonuses.

2. What personal information do we collect?

The types of personal information that we may collect includes your name, e-mail address, postal/mailing address, telephone number, bank account details and credit card information.

SEACRET AU may also collect your login details when you register on our site.

You may, however, visit our site anonymously and, on some occasions, you may be able to deal with SEACRET AU anonymously or by using a pseudonym in relation to a particular matter. However, if you do not provide us with certain personal information, SEACRET AU may not be able to provide you with the relevant products or services that you want or respond to your query.

3. How do we collect personal information?

We collect personal information from you in a variety of ways, including when you:

• Become a SEACRET AU Agent or a Preferred Customer;
• Place an order on our website or with one of our SEACRET AU Agents;
• Subscribe to our newsletter or mailing list;
• Respond to a survey or complete a form or similar; or
• Contact us.

We may also collect your personal information:

• From SEACRET AU Agents who submit your details to us to enable us to, for example, process your orders
• From SEACRET AU Agents who have provided your information to us in order to send you invitations to events organised or hosted by SEACRET AU or the SEACRET AU Agent, for example, SEACRET AU Wow Events;
• From third party companies such as law enforcement agencies and other government entities;
• When you visit our website, Facebook page and any other webpages that we own and manage;
• During phone calls made when you contact SEACRET AU directly, or contact a Secret Agent.

Your personal information will only be collected from third parties if it is unreasonable or impracticable to collect that personal information from you directly. If and when we do collect personal information from third parties, we will take reasonable steps to inform you.

4. How and what do we use your information for?

Information we collect may be used in any of the following ways:

• To process transactions and manage your account – your personal information will allow us (and third party service providers we engage) to process orders, generate invoices and receipts and manage your account with SEACRET AU;
• To protect the security of our website and business – your financial information will only be used to process transactions; conducting internal investigations in relation to crime and fraud prevention, detection or prosecution, and in order to meet our obligations under privacy and fraud legislation;
• To personalise your customer experience – your personal information will help us to better respond to your individual needs;
• To improve our website – we continually strive to improve our website offerings and features based on the information and feedback we receive from you;
• To manage your concerns – we may use your personal information to contact you when dealing with enquiries or complaints and other customer care activities;
• To improve our Agent services – your personal information helps us to more effectively respond to your customer service requests and support needs;
• To administer contests, promotions, surveys and other site features – your personal information will assist us to provide you with the opportunity to participate in various promotional activities and other site features to enhance your experience with SEACRET AU;
• To organise and assist our SEACRET AU Agents in hosting SEACRET AU Events – your personal information (such as your name and your email address) may be used to send you information about, and email invitations to attend, SEACRET AU Events, for example a SEACRET AU Wow Event;
• To improve our marketing and promotion services – your personal information may be used in carrying out anonymous market analysis and product analysis and development to provide you with better products;
• To keep you informed – the email address you provide may be used to send you information and updates relating to your order, occasional news, information about changes to Policies and Procedures and other updates as well as direct marketing communications concerning products or services, etc. You may also receive emails from third party suppliers we have engaged to provide products or services on our behalf; and
• For any other purposes that you would reasonably expect including to allow us to comply with our obligations under the law.

5. Are cookies used?

SEACRET AU uses cookies. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service providers systems to recognise your browser and capture and remember certain information.

Google, as a third party service provider, uses cookies to serve ads on our site. Google's use of the DART cookie enables it to serve ads to our users based on their visit to our site and other sites on the Internet. Users may opt out of the use of the DART cookie by visiting the Google ad and content network privacy policy.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

If you reject all cookies, you will not be able to use SEACRET AU’s services that require you to "log on," and you may not be able to take full advantage of all offerings. However, there may be some SEACRET AU products and services that do not require that you accept cookies.

SEACRET AU uses its own cookies for a number of purposes, including to:

• Access your information when you "log on," so that we can provide you with customised content in certain online areas;
• Conduct research to improve our content and services; and
• Require you to re-enter your login details after a certain period of time has elapsed to help protect you against others accidentally accessing your account contents.

Please note that SEACRET AU does not control the use or contents of third-party cookies.

6. How do I unsubscribe from marketing materials?

If you would like to stop receiving any communications about our latest products and services, company information or promotional activities, such as competitions and surveys, you can opt out. If at any time you would like to stop receiving future emails, we include an unsubscribe link in each direct marketing email we send.

However, please be aware that SEACRET AU will still need your essential personal information to assist in the management of your account and purchases.

7. Do we disclose any personal information to third parties?

SEACRET AU has business relationships with third parties. In some instances, we may disclose your personal information to third parties that we have engaged to provide us with products and services on your behalf such as order fulfilment, SEACRET AU-related merchandise, package delivery, payment processing and the preparation of mailings.

In these circumstances, we will require these third parties to agree to treat personal information they receive from us in a confidential manner.

De-identified information may also be provided to other parties for marketing, advertising, or other uses.

SEACRET AU may also disclose your personal information, both within and outside Australia, if we believe the disclosure is appropriate to:

• Comply with the law;
• Enforce our site policies; or
• Protect ours or other's rights, property, or safety.

This may involve disclosure to:

• Our professional advisors including lawyers, accountants, tax advisors and auditors;
• Law enforcement bodies to assist in their functions, Courts of law or as otherwise required or authorised by the law;
• Debt collection agencies and other parties that assist with debt-recovery functions;
• Regulatory or government bodies for the purposes of resolving customer complaints or disputes both internally and externally or to comply with any investigation by one of these bodies; and
• Other SEACRET Agents within your organisation upline.
• Any other person for any other purposes that would be reasonably expected.

Where we do provide your personal information to third parties, we will take reasonable steps to ensure that the recipient will protect your privacy

Overseas recipients

Occasionally, we may disclose personal information to overseas recipients, for example, to our parent company in the USA. Other recipients may be located in the countries identified in the Appendix to this Privacy Policy. This list of countries is not exhaustive and may change from time to time.

APP8.1 requires SEACRET AU, before it discloses personal information to an overseas recipient, to take such steps as are reasonable, in the circumstances, to ensure that the overseas recipient does not breach the APPs. If you consent to SEACRET AU’s disclosure of your personal information to overseas recipients, APP8.1 will not apply to that disclosure so that, if an overseas recipient handles your personal information in a manner which breaches the APPs, SEACRET AU will not be accountable under the Privacy Act for the breach, nor will you be able to seek redress under the Privacy Act. We also note that the recipient may not be subject to laws or principles which are similar to the APPs.

SEACRET AU has in place contractual arrangements with the overseas recipients, whereby the recipients are also contractually obliged to comply with the APPs.

Third party links

Occasionally, at our discretion, we may provide links to third party websites from our website. These linked sites are for your own convenience. You access any linked sites at your own risk. These third party sites have their own privacy policies, which we strongly recommend you read. We have no responsibility or liability for the content and activities of these third party sites.

Nonetheless, we welcome any feedback about these sites.

8. How do we maintain the accuracy of the personal information we hold about you?

SEACRET AU takes all steps as are reasonable, in the circumstances, to ensure that the personal information that we collect, hold, use and disclose about you is accurate, up to date and complete.

However, in order to maintain the accuracy of the personal information, we rely on the quality of the personal information that you provide to us. To ensure that we always have your most current and accurate personal information, please contact us as soon as possible when your details change. This might include when you change your name, mailing address or use a new email address.

9. How do we secure and protect your personal information?

SEACRET AU is committed to ensuring the security of your personal information. We take such steps as reasonable, in the circumstances, to protect the information from misuse, interference and loss and secure your personal information from unauthorised access, modification or disclosure.

In order to protect your personal information, we implement a variety of security measures to maintain the safety of your personal information when you place an order or enter, submit, or access your personal information.

We offer the use of a secure server. All supplied sensitive/credit information is transmitted, via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorised with special access rights to such systems, and required to keep the information confidential.

After a transaction, your private information (financials, such as credit card and debit card numbers and bank account details required to process the transaction etc.) will not be kept on file for more than 60 days.

SEACRET AU will also hold information about your order and purchase history, your SEACRET AU online account details (for example, usernames and passwords) and, if you are a SEACRET AU Agent, your commission history. This information will be stored securely by SEACRET AU for as long as is reasonably required to comply with our legal requirements.

10. What can you do to protect your account from unauthorised access?

Your SEACRET AU Agent account can be accessed by anyone who knows your login details. You should keep your login details, and any other information you use to remember these details, private and secure.

SEACRET AU accepts no responsibility for information that is disclosed to or obtained by parties who know your login details.

11. Can you access the personal information we hold about you?

You have a right to request access to the personal information we hold about you and we will grant you access to that information unless there is a permitted reason for not doing so. If there is a permitted reason for not doing so, we will provide you with a written explanation of the reasons for the refusal (unless it would be unreasonable to do so) and inform you of the mechanisms to complain about the refusal.

To make a request for access to your personal information, please contact our customer service department or email privacy@seacretdirect.com.au. We will respond to your request within a reasonable period after the request is made and we may charge reasonable costs for actioning the request.

12. What if the personal information we hold about you is incorrect?

If you believe that your personal information may be inaccurate, out of date or incomplete, you can request us to update and correct the information. To make a request for the correction of your personal information, please contact our customer service department or email privacy@seacretdirect.com.au. We will respond to your request within a reasonable period after the request is made and we may charge reasonable costs for actioning the request.

13. How can you report a breach of your privacy?

If you have concerns that your privacy has been compromised, please contact our customer service department or email privacy@seacretdirect.com.au. A member of our Privacy team will contact you within 10 business days to confirm receipt of your email. We will then investigate your complaint and provide you with our response to your complaint within a reasonable time. If, after receiving our response, you still consider that your privacy complaint has not been resolved, you may then, for example, take your complaint to the Office of the Australian Information Commissioner.

Changes to our Privacy Policy

If we decide to change our Privacy Policy, we will post those changes on this page.

Contacting Us

If there are any questions regarding this Privacy Policy, you may contact us. Please contact our customer service department or email privacy@seacretdirect.com.au.

Date: June 2014

Appendix to Privacy Policy

Overseas recipients of personal information are likely to be located in the following countries:

• Canada;
• Mexico;
• South Korea; and
• The USA.