Privacy Policy
This Privacy Policy sets out the principles that LJEG Holdings Pty Ltd ACN 664 345 288 including each of its subsidiaries, brands and divisions from time to time, such as Dante Pierre Pty Ltd, Purascrew Pty Ltd, Visual Ascent Pty Ltd, Revenue Vault Pty Ltd and Revenue Vault Holdings Pty Ltd (collectively referred to as the ‘us’, ‘we’, ‘our’ or the ‘LJEG Group’), will follow in the management of your personal information. In this Privacy Policy, ‘you’ refers to any individual about whom we collect personal information in Australia.
The LJEG Group is committed to managing personal information in accordance with the Australian Privacy Principles (‘APP’) in the Privacy Act 1988 (Cth) (‘Privacy Act’). The LJEG Group will only collect, use or disclose personal information in accordance with the Privacy Act and this Privacy Policy.
This Privacy Policy sets out our policies for managing your personal information, specifically:
- the kinds of personal information we collect and hold,
- how we collect and hold it;
- the purpose for which we collect, hold, use and disclose it
- how you can seek access to and correct it;
- how you can contact us to make a complaint and how such complaints will be dealt with; and
- how, and to whom your personal information will be disclosed to overseas, and why.
- If you need to contact us to discuss this policy, our contact details can be found below.
In Australia, ‘personal information’ is any information or an opinion about an identified individual, or an individual who is reasonably identifiable.
The LJEG Group will, from time to time, collect personal information in the course of its business.
When you use our services or interact with us, either electronically (e.g. via websites, apps, social media, chats, telephone, emails and/or SMS), telephone or as otherwise permitted by law, we may collect and hold personal information about you. We may also collect personal information about you from third parties where you have agreed with them that your information may be disclosed to us, and with whom we have business relationships.
Some examples of the types of information that the LJEG Group collects about you and how we collect this personal information are outlined below.
If you sign up as a customer on our website: we will collect your name, date of birth, gender, delivery address, country of origin, billing address and email address. We will not disclose your details for inclusion in the mailing lists of any parties that are not members of the LJEG Group. We may also collect login information (including registration passwords and usernames) and other user IDs (including for systems and third party services integrated with our service offering).
If you do not sign up as a customer: we may collect general site traffic data (see the paragraphs on “When you use our websites” and “When you use our apps” below).
When you place an order or browse our sites or apps: we collect your name, billing address, delivery address, email address, telephone number, information about your orders and purchases, including what, how, and when you buy from us, information about your browsing behaviour on our internet sites and apps, including promotions you activated, as well as items you have added to your carts, information collected and held via our secure financial systems about the payment method you use for your purchases from us (including payment card and transaction details), website and app browsing data (see below “When you use our websites” and “When you use our apps”), comments, feedback or survey responses. This information must be provided to allow us to effect delivery of the products that you order, and to contact you if necessary. Your email address may also be used to contact you in the event that you discontinue a shopping session. We or our service providers may contact you by email to see if there were any problems and if we can help you to complete your transaction. Other information you provide at the checkout, such as comments or survey responses is stored by us and is used to better plan future items to add and developments for our websites or apps.
If you elect to pay online using your credit card: your credit card details are not stored by us. They are encrypted and passed directly to the Bank through our security provider.
When you use our websites: General site traffic data is collected for the purpose of site maintenance and improvement and provides information about which and how often certain pages are viewed. This helps us to understand what sorts of products our customers are interested in and alerts us to any areas of the site that may be difficult to navigate. The data we collect may include your IP address, your approximate geographic location, and data sent to us by your web browser, such as your operating system, browser type and version, computer type, MAC address and screen resolution. We may also collect metadata including social media content (including tags, handles and other social media profile information). This information may be collected directly and/or via cookies. Cookies and other tracking technologies are used by us and our third-party partners, such as our advertising and analytics partners and our fraud prevention service provides, to provide functionality and to recognise you across different services and devices. You may opt out of sending us cookie data but this may adversely affect your experience using our services.
When you apply for a job with us: Personal information collected from employment applications by post or by email to the LJEG Group will only be used for the purpose of assessing a person’s suitability for available employment positions. Your employment application will be stored by us on file for the duration that it is relevant to the role you have applied for and then destroyed. This information will be disclosed to third parties as required for the purpose of assessing your application. The range of personal information that may be collected about applicants for employment include name, contact information (including email address, telephone number and postal address,) employment and training history and other information included as part of an application, resume or curriculum vitae. Information may also be obtained from psychological or aptitude tests and from referees.
When you engage in business with us: the LJEG Group may collect personal information from you when you provide it to us in the ordinary course of business, for example when you contract with us or otherwise engage with our business.
Enquiries: when you make an enquiry of us online or by phone, we may collect your name and contact details in order to respond to your enquiry.
In each case, by giving us access to this information, you are consenting to our ability to collect, store, use and disclose such information strictly in line with our Privacy Policy.
The main consequence for you, if some or all of the above personal information is not collected by us is that we may not be able to provide products, services or information to you, or be able to provide them to the same standard as if we had the information requested.
The personal information that we collect about you may be used by us for a number of purposes connected with our business including to:
- provide you with information that you have requested;
- verify your identity;
- contact you;
- process orders you make through our websites;
- add you to our mailing list;
- send you marketing materials;
- promote our products and services;
- deliver to you the products that you have ordered and provide you with customer service following these orders;
- improve the website experience of our visitors;
- provide a personalised experienced and personalised recommendations;
- provide goods or services to you or to receive goods or services from you;
- address any issues, problems or complaints that we or you have regarding our relationship;
- contract with you; and
- comply with our legal obligations.
We also use personal information for our own internal business purposes including:
- for data analysis to improve our products, services and business;
- auditing our internal processes to ensure they function as intended and that we comply with regulatory requirements;
- for fraud and security monitoring;
- developing new products and services;
- identifying usage trends so we can understand which part of our services are of most interest to our customers;
- determining the effectiveness of marketing campaigns so that we can adapt to the needs and interests of our customers; and
- operating and expanding our business activities such as understanding which of our products and services are of most interest to our customers, so we can focus on our customers’ needs.
The Privacy Act defines some types of personal information as “sensitive information”. Sensitive information is personal information which is information or opinion about a person’s racial or ethnic origin, political opinions or memberships, religious or philosophical beliefs or religious affiliations, professional or trade association or union memberships, sexual orientation or practices, criminal record or health (including genetic and biometric information or templates). The LJEG Group does not generally collect sensitive information about individuals.
If you provide sensitive information to us for any reason you consent to us collecting, using and disclosing that information for the purpose for which you disclosed it and as permitted by the Privacy Act.
As part of our promotional, educational and remarketing campaigns, we may contact you using the email address you have provided. If you prefer not to hear from us, you can opt-out at any time. To do so please click on the “unsubscribe” link at the bottom of any email we send you and you will be removed from any future communications.
If you opt-out of receiving marketing material from us, the LJEG Group may still contact you in relation to any ongoing relationship with you.
We do not provide any personal information provided by you to any third parties other than to our related entities and affiliates, where required by law or as set out in this privacy policy. However, we may disclose your personal data listed below or as otherwise permitted by the Privacy Act.
In the course of conducting our business we may provide your personal information to third parties, such as fraud prevention providers, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers and electronic network administrators, professional advisers, such as lawyers, auditors, accountants, insurers, credit reporting agencies and other financial institutions including our own bankers, other persons that we need to deal with in connection with the engagement of staff, any other commercial partner, supplier or service provider.
We may disclose your personal information to third parties:
- to enable our websites to function in the manner it is intended;
- for fraud detection and security detection or to prevent payment fraud;
- as part of our business processes and for the purposes described above in ‘Why does the LJEG Group collect personal information’;
- to meet the purpose for which your personal information was submitted;
- if we have your consent to do so or otherwise when we are authorised by law;
- to comply with any applicable law, regulation, court order or other legal requirements, including supplying such information to third parties such as lawyers, regulators or law enforcement where applicable law compels us to do so;
- conduct promotional activities, provide special offers, and send you marketing communications from us and our related companies in the LJEG Group (subject to your right to opt out of these at any time);
- to process product returns; and
- as generally required when we need their assistance in our day-to-day business operations or so can work with them to provide goods or services to you.
We may disclose personal information to Shopify to power the online store on our websites. You can read more about how Shopify uses your personal data here: https://www.shopify.com/legal/privacy.
We may also use and share your personal information:
- to transfer your information to a third party as a result of a sale, merger or consolidation of us, insofar as the third party has agreed to comply with all privacy laws applicable to it and adhere to terms similar to this Privacy Policy;
- among our related entities or business units or brands within the LJEG Group; and
- with any other persons and entities permitted under the Privacy Act.
We will not supply, sell or in any other knowing way, make available your personal information to other parties other than in the circumstances outlined above, unless you authorise us to do so.
Some personal information may be transferred to countries outside of Australia in the course of our business. We may share personal information overseas for reasons including:
- where we have engaged a service provider to assist us with certain technology or data storage functions; and
- for disclosures between our related entities. Our main business location is in Australia, but some of our related entities may be based or operating in other countries from time to time.
Your personal information may be subject to the laws of the countries in which it is stored or used. By providing us with any personal information, you understand that your information may be transferred, processed, or stored outside of your country of residence, which may have a different data protection regime from the country in which you reside. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.
When the LJEG Group discloses personal information outside of Australia we will comply with this Privacy Policy and other requirements of the Privacy Act.
If you do not agree to the transfer of your personal information outside of Australia, please contact us via the details set out below under the heading ‘Contacting Us’. In these circumstances, we may be prevented from providing products or services to you.
The LJEG Group will provide individuals with the opportunity of remaining anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not practicable for the LJEG Group to deal with individuals anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, you may be unable to utilise our services.
Any personal information we hold is generally stored in paper-based files or electronically in computers or cloud systems operated by us or our service providers (either in Australia or overseas).
All personal information held by us will be handled and stored in accordance with our obligations under the Privacy Act. We will take reasonable steps to:
- implement practices, procedures and systems in our business that will ensure compliance with our legal obligations and to deal with inquiries or complaints about compliance with our legal obligations;
- make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
- protect the information from misuse, interference, loss or unauthorised access, modification or disclosure both physically and through security methods; and
- destroy or permanently de-identify the information if it is no longer needed for any purpose.
The LJEG Group maintains physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems. We use encryption to ensure the secure transmission of information via the internet. However, users of our websites are encouraged to exercise care in sending personal information via the internet.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others, and to the extent permitted by law, exclude all liability (including in negligence) for the consequences of any unauthorised access to your personal information.
Please notify us promptly if you become aware of any breach of security. We will comply with all mandatory notification requirements in respect of security breaches as required by the Privacy Act.
We will retain your personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained. The criteria used to determine our retention periods include:
- the length of time we have an ongoing relationship with you and provide services to you;
- legal obligations we may have to keep (or destroy) your personal information; or
- legal advice we receive (such as in regard to litigation, regulatory investigations or applicable statutes of limitation).
When your personal information is no longer required it is destroyed in a secure manner.
You are entitled to request access to personal information we hold about you.
If you would like to request access to your personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right of data portability is provided to you by applicable law), please contact us via the details set out below under the heading ‘Contacting Us’. You will not be charged for making a request to access your personal information, but to the extent permitted by law, you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
For your protection we may need to verify your identity before implementing your request. We will comply with your request within a reasonable period after you make your request.
We may decline your request to access personal information in certain circumstances in accordance with applicable law. If we do refuse your request, we will provide you with a reason for our decision.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up to date. You can help us to do this by letting us know if you notice errors or discrepancies in personal information we hold about you and letting us know if your personal details change.
However, if you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.
In your request, please make clear what personal information you would like to have changed. For your protection we may need to verify your identity before implementing your request. We will comply with your request within a reasonable period after you make your request.
We may decline your request to correct your personal information in certain circumstances in accordance with applicable law. If we do refuse your request, we will provide you with a reason for our decision and, we will include a statement with your personal information about the requested correction.
This Privacy Policy is strictly limited to the collection, storage and use personal information collected by the LJEG Group in the course of our business. It does not apply to any third parties. We have no control over the privacy practices or the content of any third party websites linked to our websites, and assume no liability for the privacy practices of those websites. We urge you to take time to examine individual privacy policies and guidelines on other websites.
Our products and services are not directed to individuals under the age of sixteen, and we do not knowingly collect personal information from individuals under 16. If we become aware that a person under 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us via the details set out below under the heading ‘Contacting Us’.
You acknowledge that we may use or modify data and information (including your personal information) that you provide us or we collect from you, including by aggregation and other de-identifying techniques, to produce or derive a compilation of data which has personal information removed from it such that the identity of any individual person cannot be reasonably ascertained from the data (‘De-Identified Data’). You agree that we own all rights, title and interest in and to the De-Identified Data and consequently we may use such De-Identified Data for our own commercial purposes. De-Identified Data is not personal information because the De-Identified Data does not directly or indirectly reveal the identity of a person. However, if we combine or connect De-Identified Data with other data so that the identity of a person can be reasonably ascertained, we will treat the combined or connected data as personal information which may only be used, disclosed, stored and transmitted in accordance with this Privacy Policy.
You may contact the LJEG Group at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information is being handled. You would like to complain about a breach of the Privacy Act you can contact us using the details below in ‘Contacting Us’. You may be asked to put your complaint in writing and to provide relevant details. We may need to discuss your complaint with our personnel, service providers and others as appropriate.
We will investigate and respond to a complaint within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.
If you are in Australia and not satisfied with our handling of your complaint, you may refer the issue to the Office of the Australian Information Commissioner (at enquiries@oaic.gov.au).
There may be additional privacy notices and terms relevant to you depending on the nature of your dealings with us. This policy does not apply to the personal information of our team members (employees) in their capacity as such.
This Privacy Policy is subject to change over time without prior notice. We may amend this Privacy Policy by updating it and posting it on our website or within our apps. We recommend that you visit our website regularly to keep up to date with any changes.
You can contact us by email at sales@purascrew.com.au, or in writing to:
Privacy Officer LJEG Group, 74 Sydney St, Glenunga, SA, 5064.
You can ask us to provide you with a copy of this Privacy Policy, including a hard copy, by contacting us using the details above.
Last Published: 28 MAR 2023