OUR COMMITMENT TO PRIVACY
Niskala Pty Limited ACN 098 517 401 (Niskala), its subsidiaries, affiliates and associated entities in Australia (collectively referred to in this document as Camper) are committed to managing personal information in accordance with the Australian Privacy Principles (collectively, the APPs) under the Australian Privacy Act 1988 (Cth) and other applicable Australian privacy laws (collectively, the Australian Privacy Laws).
Camper is one of the companies managed and controlled by RURALMED, S.L.U. (the Group). Details of Group’s current composition is set out in our .
Niskala manages the Group’s business in the Asia Pacific region and is a subsidiary of the Group.
Camper sells contemporary footwear and accessories in the Asia Pacific region.
1 WHAT INFORMATION DOES CAMPER COLLECT ABOUT YOU?
Customers and prospective customers
When you enquire about our services or when you become a customer of ours, a record is made which includes your personal information.
The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us, but will typically include:
· identifying information such as your name, email address, postal address and other contact details;
· information about your employer or an organisation who you represent;
· information about any products you have bought through one of our stores or online;
· your professional details; and
· any additional personal information you provide to us, or authorise us to collect, as part of your interaction with us.
We also collect personal information when recruiting personnel, such as your name, contact details, qualifications and work history. Generally, we will collect this information directly from you.
We may also collect personal information from third parties (for instance, through a recruitment agencies or from referees you have nominated). Before offering you a position, we may collect additional details such as your tax file number and superannuation information and other information necessary to conduct background checks to determine your suitability for certain positions (eg, positions which involve working with children).
We may collect personal information about other individuals who are not our customers. This includes:
· customers and members of the public who participate in events we are involved in;
· our service providers and contractors; and
· other individuals who interact with us on a commercial basis.
The kinds of personal information we collect will depend on the capacity in which you are dealing with us. Generally, it would include your name, contact details, and information regarding our interactions and transactions with you.
If you are participating in an event we are managing or delivering, we may take images or audio-visual recordings that may identify you.
In limited circumstances, we may collect information that is considered sensitive information. For example, if you are injured at an event promoted or delivered by us then we may collect health information about you in an emergency or otherwise with your consent.
We may collect personal information about children (eg, when children participate in events we are involved in). Where children do not have sufficient maturity and understanding to make decisions about their personal information, we will require their parents or guardians to make decisions on their behalf.
You can always decline to give us any personal information we request, but that may mean we cannot provide you with some or all of the services you may have requested. For instance we cannot send you details of sales and new product promotions if you decline to provide us with personal contact details. If you have any concerns about personal information we have requested, please let us know.
Visitors to our websites
The way in which we handle the personal information of visitors to our websites is discussed below.
2 HOW AND WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?
We collect personal information reasonably necessary to carry out our business, to assess and manage our customers' needs, and provide services including contemporary footwear and accessories.
We may also collect information to fulfil administrative functions associated with these services, for example billing, product deliveries, refunds and returns, entering into contracts with you and/or third parties and managing customer relationships.
The purposes for which we usually collect and use personal information will depend on the nature of your interaction with us, but may include:
· sending you an e-receipt;
· processing the item guarantee;
· keeping you up-to-date with activities of the Group;
· maintaining your registration on our website;
· providing you with order tracking details;
· delivering your order;
· responding to requests for information and other general inquiries;
· managing, planning, advertising and administering programs, events, competitions and performances;
· researching, developing and expanding our facilities and services;
· informing you of our activities, events, facilities and services;
· recruitment processes (including for volunteers, internships and work experience);
· online and other customer surveying and market research techniques;
· handling refunds and returns; and
· responding to customer enquires and complaints.
We generally collect personal information directly from you. We may collect and update your personal information over the phone, by email, over the internet, on social media, or in person. We may also collect personal information about you from other sources, including:
· our affiliated and related companies; and
· third-party suppliers and contractors who assist us to operate our business.
We also collect and use personal information for market research purposes and to innovate our delivery of products and services.
3 HOW DO WE INTERACT WITH YOU VIA THE INTERNET?
You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.
Group's websites may contain links to third-party websites. Camper and/or Group are not responsible for the content or privacy practices of websites that are linked to our website.
4 CAN YOU DEAL WITH US ANONYMOUSLY?
We 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 us 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 or participate in our events, programs or activities we manage or deliver.
5 HOW DO WE HOLD INFORMATION?
We store information in paper-based files or other electronic record keeping methods in secure databases (including trusted third-party storage providers based in Australia and overseas).
Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed).
We take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
We maintain 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 instance 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.
Users of our websites are encouraged to exercise care in sending personal information via the internet.
We take steps to destroy or de-identify information that we no longer require.
6 DO WE USE OR DISCLOSE YOUR PERSONAL INFORMATION FOR DIRECT MARKETING?
We may use or disclose your personal information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications by email, SMS or any other similar means of communication, you can opt-out at any time at the following or by contacting us using the contact details below.
If you opt-out of receiving marketing material from us, we may still contact you in relation to our ongoing relationship with you and conserve your details.
7 HOW DO WE USE AND DISCLOSE PERSONAL INFORMATION?
The purposes for which we may use and disclose your personal information will depend on the services and/or products we are providing you.
For example, if you are a customer or participant in an event, we may disclose your personal information to our customers and venues where this is reasonably necessary for, and relevant to, the delivery of the event. We may use images or audio-visual recordings that identify you for promotional purposes where you would reasonably expect this to occur.
Disclosure to contractors and other service providers
We may disclose information to third parties we engage in order to provide our services, including contractors and service providers used for data processing, data analysis, customer satisfaction surveys, information technology services and support, website maintenance or development, printing, archiving, mail-outs, market research and delivery of products.
Personal information may also be shared amongst companies within the Group.
Third parties to whom we have disclosed your personal information may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.
Use and disclosure for administration and management
We may also use and disclose personal information for a range of administrative, management and operational purposes. This includes:
· administering billing and payments and debt recovery;
· planning, managing, monitoring and evaluating our services;
· quality improvement activities;
· statistical analysis and reporting;
· training staff, contractors and other workers;
· risk management and management of legal liabilities and claims (eg, liaising with insurers and legal representatives);
· responding to enquiries and complaints regarding our services;
· obtaining advice from consultants and other professional advisers; and
· responding to subpoenas and other legal orders and obligations.
Other uses and disclosures
8 DO WE DISCLOSE YOUR PERSONAL INFORMATION OVERSEAS?
Group is a global organisation and works with customers, service providers, sponsors and commercial interests across the globe. It is likely that your personal information will be disclosed to overseas recipients.
Unless we have your consent, or an exception under the APPs applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information.
In circumstances where your information is disclosed to overseas recipients, those recipients are likely to be located in countries in the regions in which Group and its related entities and affiliates operate.
We also have offices around the world and some of the administrative, marketing and other functions of the business are handled in Group offices located outside Australia. It is possible that some personal information may be disclosed to other offices within the Group for such purposes.
9 HOW CAN YOU ACCESS OR SEEK CORRECTION OF YOUR PERSONAL INFORMATION?
You are entitled to access your personal information held by us on request. To request access to your personal information please contact our Privacy Officer using the contact details set out below.
You will not be charged for making a request to access your personal information but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
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 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.
We may decline your request to access or correct your personal information in certain circumstances in accordance with the APPs. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.
10 WHAT SHOULD YOU DO IF YOU HAVE A COMPLAINT ABOUT OUR HANDLING OF YOUR PERSONAL INFORMATION?
You may make a complaint about privacy to the Privacy Officer at the contact details set out below.
The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps that can be taken to resolve the complaint. We will generally respond to your complaint within a week (but this will depend on the nature of the complaint and any redress sought)
If your complaint requires more detailed consideration or investigation, we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.
In most cases, 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 not satisfied with our response to your complaint, or you consider that Camper may have breached the APPs or the Australian Privacy Laws, a complaint may be made to the Office of the Australian Information Commissioner (the OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the OAIC website.
We recommend that you visit our website regularly to keep up to date with any changes.
12 HOW CAN YOU CONTACT US?
Our contact details are as follows:
Camper Privacy Officer
Postal Address - Ruralmed SLU
C/ Cuartel 91, 07300 Inca, Majorca, Balearic Islands, Spain
Email Address -
Phone Number - 02 9663 1161
© Niskala Pty Limited ACN 098 517 401