Page 1
PRIVACY POLICY
General Klein Imports Pty Ltd ACN 643 404 077 (trading as Polar Breezy) and its
related entities (referred to in this document as ‘we’, ‘us’ or ‘our’) operate
the polarbreezy.com.au website (‘Site’).
We are committed to protecting the Personal Information we collect from
you when you use our Site. The Privacy Act 1988 (Cth) (‘Privacy Act’), and
the Australian Privacy Principles (‘APP’) govern the way in which we
manage your Personal Information and this Policy sets out how we collect,
use, disclose and otherwise manage Personal Information about you.
We will not share or use your Personal Information, except as described in
this Policy or unless you have otherwise provided us with your consent to
do so.
Collection and
Notice
Types of information collected
We may collect and hold Personal Information about you, that is,
information that can identify you, and is relevant to providing you with the
services you are seeking. This can include but is not limited to:
• your name
• contact details (including address, email address, phone number)
• financial information (such as credit card or bank account numbers)
and information about how you use our products and services.
(collectively, ‘Personal Information’)
This is not an exhaustive list. We may need to collect additional information
about you from time to time to provide products or services to you.
You might also need to provide us with Personal Information about other
individuals (e.g. your authorised representatives). If so, we rely on you to
inform those individuals that you are providing their Personal Information
to us and to advise them about this policy.
Purpose of collection
The type of Personal Information that we collect and hold about you
depends on your interaction with us. Generally, we will collect, use and hold
your Personal Information for the purposes of:
• providing products or services to you or someone else you know;
• issuing tax invoices for the products or services we may provide to
you from time to time;
• providing you with information about other services that we, our
related entities and other organisations that we have affiliations with,
offer that may be of interest to you;
• facilitating our internal business operations, including the fulfilment of
any legal requirements; and
• analysing our services and customer needs with a view to developing
new or improved services.
Method of collection
Personal Information will generally be collected directly from you through
the use of any of our standard forms (such as when you enter into an
Page 2
agreement with us, contact us with a query or request, submit your details
through our Site or by email). We may also collect information other than
directly from you where it is unreasonable or impractical to not do so, for
example:
• from third parties such as our related entities, business partners, or
your representatives;
• from publicly available sources of information;
• from our records of how you use our services; and
• from the third parties we list in the section of this policy with the
heading ‘Use and disclosure’.
We will usually notify you in advance when we indirectly collect information,
or where that is not possible, as soon as reasonably practicable after the
information has been collected.
If you choose not to provide certain information about you, we may not be
able to provide you with the products or services you require, or the level
of service on which we pride ourselves.
If the Personal Information you provide to us is incomplete or inaccurate,
we may be unable to provide you, or someone else you know, with the
products or services you, or they, are seeking.
Internet users
If you access our Site, we may collect additional Personal Information
about you in the form of your IP address and domain name.
Our Site uses cookies. The main purpose of cookies is to identify users and
to prepare customised web pages for them. Cookies do not identify you
personally, but they may link back to a database record about you. We use
cookies to monitor usage of our Site and to create a personal record of
when you visit our Site and what pages you view so that we may serve you
more effectively.
Our Site may contain links to other websites. We are not responsible for
the privacy practices of linked websites and linked websites are not subject
to our privacy policies and procedures.
Google Analytics
We also use third party services such as Google Analytics that collect,
monitor and analyse this type of information in order to increase our Site’s
functionality. These third-party service providers have their own privacy
policies addressing how they use such information. See additional
information below.
Google Analytics is a service which transmits website traffic data to Google
servers in the United States. Google Analytics does not identify individual
users or associate your IP address with any other data held by Google. We
use reports provided by Google Analytics to help us understand website
traffic and webpage usage. By using this Site, you expressly consent to the
processing of data about you by Google in the manner described in
Google's Privacy Policy
and for the purposes set out above. You can opt out of Google Analytics if
you disable or refuse the cookie, disable JavaScript, or use the opt-out
service provided by Google .
Social Media
Page 3
We also use interfaces with social media sites such as Facebook, LinkedIn,
Twitter and other social media channels.
We cannot maintain your privacy if you decide to contact us through public
forums such as Facebook, LinkedIn, Twitter or other social media channels
or if you choose to "like" or "share" information from or in relation to this
Site through these channels. You should review the privacy policy of these
channels if you choose to contact us or like or share information via these
channels. Please be aware if you are a member of a social media site, the
interfaces with social media sites we use may allow the social media site
to connect your visits to this Site with other personal information.
External Links
Our Site may contain links to other websites or social media. These linked
sites are not under our control and we accept no responsibility for the
conduct of those that operate linked websites or social media platforms.
Before disclosing your Personal Information on any other website or social
media platforms, we recommend you examine the terms and conditions of
using that website or platform and its privacy statement.
Use and Disclosure Generally, we only use or disclose Personal Information about you for the
purposes for which it was collected (as set out above) or for purposes which
are directly related to one or more of our functions and activities. We may
disclose Personal Information about you from time to time:
• third party product or service providers, who assist us in operating our
business (including to assist us in providing you with the products and
or services that you have requested or have expressed an interest),
and these service providers may not be required to comply with our
privacy policy;
• our related entities and other organisations with whom we have
affiliations so that those organisations may provide you with
information about services and various promotions
• a purchaser of the assets and operations of our business, if those
assets and operations are purchased as a going concern; and
• government agencies and departments when required to do so by law.
We are not likely to disclose your Personal Information overseas, except
as permitted by the Privacy Act, unless we otherwise advise you in writing.
Disclosure to
overseas recipients We are not likely to disclose your Personal Information to overseas
recipients, except as noted below or as otherwise permitted by the Privacy
Act, unless we otherwise advise you in writing.
The types of overseas companies we share information with, in order to
deliver our service to you are as follows;
1. Companies that do things to assist us in delivering our service such
as ecommerce providers like Shopify, see below for more information;
2. Payment service providers like Stripe and Paypal, see below for more
information; and
3. Marketing service providers such as SMS Bump, MailChimp and
Google Analytics see above for more information;
Page 4
4. Companies that assist us with delivery of our products such as Shippit
and Australia Post.
How we use your
information for
Direct Marketing
We may also use your information so that we, our related entities, and other
business partners can promote and market products, services and special
offers that we think will be of interest to you (which may include products,
services and offers provided by a third party). This marketing may be
carried out in a variety of ways (including by email, SMS/MMS, or social
media) and may continue after you cease acquiring any products or
services from us until you opt-out by contacting us using the contact details
set out in the Contact section of this policy.
How we hold your
Personal
Information
The security of your Personal Information is of paramount importance to
us.
The Personal Information we collect from you may be:
1. transferred to, and stored at a destination outside of Australia; and
2. processed by staff operating outside of Australia who work for us or
one of our affiliates.
We agree to take all reasonable steps to ensure these overseas entities
handle your Personal Information in accordance with the Act and the APPs,
When you provide, or otherwise allow us to collect, your Personal
Information, you expressly consent to your Personal Information being
disclosed to certain overseas recipients, as set out below under ‘Where we
store your personal data: Shopify’. Where we disclose your Personal
Information to an overseas recipient, you agree that we will not be required
to ensure the recipient’s compliance with Australian privacy laws or
otherwise be liable or accountable for how the recipient handles your
Personal Information.
If you have any objections to your Personal Information being disclosed to
an overseas recipient, please let us know by contacting us via the contact
details noted below prior to disclosing any of your Personal Information to
us.
We have also taken measures to enhance the safety and security of your
e-commerce transactions. When you place an order or access your
personal account information, you’re utilising a secure server software
SSL, which encrypts your Personal Information before it’s sent over the
Internet. SSL is one of the safest encryption technologies available.
If we no longer need your Personal Information for the purposes for which
it was collected or for purposes which are directly related to one or more of
our services or other functions and activities, we will take reasonable steps
to securely destroy it or permanently remove all identifying features from
that information. This obligation is subject to any legal requirement or court
order to retain the information.
Where we store your
personal data:
Shopify
Our Site is hosted on Shopify Inc. Shopify provides us with the online e￾commerce platform that allows us to sell our products and deliver our
services to you. Your data is stored through Shopify’s data storage
databases and the general Shopify application.
Shopify Inc. collects, uses and processes your information in accordance
with their privacy policies. You can access their privacy policy here:
Commented [CH1]: Client note: Please advise us what you
use the company ‘Honeycomb’ for.
Page 5
Shopify Inc. is a Canadian company but works with and processes data
about individuals across the world. To operate their business, they may
send your Personal Information outside of your location including to the
United States. This data may be subject to the laws of the countries they
send it to. If you would like more information about where your information
might be sent, please contact Shopify directly. More information can be
found here: .
Information on how Shopify Inc. deals with any bank or credit card details
can be found here: .
Our policies for
Minors
Our Services are not directed at persons under the age of 18 (‘Minor’).
We do not knowingly collect Personal Information from Minors. If you are a
parent or guardian and become aware that a Minor under your care has
provided us with Personal Information, please contact us. If we become
aware that we have collected Personal Information from a minor without
verification of parental consent, we will take steps to remove and destroy
that information from our system.
How we handle data
from international
visitors
As noted above, your Personal Information may be collected used and
processed to overseas recipients. We are an Australian company that
operates entirely in Australia and is subject to Australian law.
We currently only offer our Services to customers located in Australia,
however if you are accessing our Site from a location outside of Australia,
you acknowledge and understand that your Personal Information will be
transferred, processed and stored in Australia in accordance with this
privacy policy. Australian privacy laws may not be as protective as those in
your jurisdiction.
When we disclose Personal Information in accordance with this privacy
policy, it may be accessed from, transferred to, and/or stored outside the
country in which you are located. The privacy laws in that country may be
of a lower standard than those in your own country. We will use our best
endeavours to safeguard your Personal Information in accordance with this
privacy policy.
Data breach
notification
We accept our obligation to keep Personal Information safe. Should
personal data systems be breached or data is misused or lost, then we will
take all reasonable and practicable means to contact individuals whose
Personal Information is involved. We will advise such individuals of the
extent of the data breach (if known) and advise individuals of the most
appropriate means of regaining control of their Personal Information. If
appropriate, we will also report any eligible data breach to the Office of the
Australian Information Commissioner in accordance with the Privacy Act.
How you can access
your Personal
Information
You may access the Personal Information Shopify hold about you, upon
making a written request to us. We will then make a request to Shopify on
your behalf. We will respond to your request within a reasonable period.
We take all reasonable steps to ensure that the Personal Information
Shopify hold, use and disclose is accurate, complete and up to date.
We may decline a request for access to Personal Information in
circumstances prescribed by the Privacy Act, and if we do, we will give you
a written notice that sets out the reasons for the refusal (unless it would be
unreasonable to provide those reasons).
If, upon receiving access to your Personal Information or at any other time,
you believe the Personal Information we hold about you is inaccurate,
incomplete or out of date, please notify us immediately. We will take
Page 6
reasonable steps to correct the information so that it is accurate, complete
and up to date.
If we refuse to correct your Personal Information, we will give you a written
notice that sets out our reasons for our refusal (unless it would be
unreasonable to provide those reasons), including details of the
mechanisms available to you to make a complaint.
If you wish to access any of your Personal Information that we hold or would
like to correct any errors in that information, please contact us using the
contact details set out in the Contact section of this policy, so that we can
consider and respond to your request. We may apply an administrative
charge for providing access to your Personal Information in response to a
request.
Transfer of Personal
Information
If you are located outside of Australia, you acknowledge and understand
that your Personal Information will be transferred, processed and stored in
Australia in accordance with this privacy policy.
When we disclose Personal Information in accordance with this privacy
policy, it may be accessed from, transferred to, and/or stored outside the
country in which you are located. The privacy laws in that country may be
of a lower standard than those in your own country. We will use our best
endeavours to safeguard your Personal Information in accordance with this
privacy policy.
Complaints You may use the contact details below to notify us of any privacy complaint
you have against us, including if you think that we have failed to comply
with the APP or any binding APP code that has been registered under the
Privacy Act. We are committed to acknowledging your complaint in a
prompt manner and will give you an estimated timeframe for when we will
respond to your complaint. We will take reasonable steps to investigate the
complaint and respond to you.
If you are unhappy with the way that we handle your complaint you may
make your complaint to the Office of the Australian Information
Commissioner or, if you are located outside of Australia, the body
responsible for administering the privacy laws in your country.
Contact If you have any queries or concerns about our privacy policy or the way we
handle your Personal Information, please contact our privacy officer at:
Email address: support@polarbreezy.com.au
Street address: 4 Dorset Street, Milton QLD 4046
Changes to our
privacy and
information
handling practices
This privacy policy is subject to change at any time. Please check our
privacy policy on our Site, [please insert] regularly for any changes.
More information For more information about privacy in general, you can visit the Office of
the Australian Information Commissioner website at www.oaic.gov.au.