SFG PRIVACY POLICY

Specialty Fashion Group Ltd (SFG, us or we) is one of the largest retailers of women’s fashion in Australia, making women everywhere look good and feel great through six diverse brands that offer style and value. The company’s brands include Autograph, City Chic, Crossroads, Katies, Millers and Rivers.

Some of the information you provide us as part of your dealings with us is “personal information” under the Privacy Act 1998 (Cth) (the Act). This Privacy Policy sets out how we collect, handle, use, transmit and disclose your personal information and applies to you unless you give us explicit consent to act otherwise. If you would like to know more about data protection generally, there is information available from the Australian Information Commissioner at the following website – www.oaic.gov.au.

We generally collect personal information at our stores, corporate premises and online, both electronically and in hard copy.

At SFG we use your personal information primarily for the purposes of: marketing and promotion (by email, text messaging, social networking, conventional post and other means), internal accounting and auditing, recording proof of purchase, validating cheque transactions, receiving, processing and delivering product orders, processing payment, managing our websites (which may include registering you to use our websites), regulatory reporting and compliance, recruitment, servicing our relationship with you and to provide you with information, products and services you may request from time to time. We may communicate additional purposes for use and disclosure of personal information at the point of collection

SFG may engage or deal with other persons or organisations (for example, loyalty program administrators and partners, data analysis specialists, statement producers, data mail houses, data processing organisations, marketing researchers, specialist call centres and service providers, promotional services providers, data hosting service providers, SFG agents, SFG contractors, SFG suppliers, SFG joint venture partners) (all Third Party Providers) to assist SFG in carrying out the above purposes. Your personal information may be disclosed to such persons or organisations for these purposes and, in providing a service, they may contact you directly. In some circumstances, they may disclose personal information they collected from you to SFG for one or more of the purposes already mentioned.

The nature of the information collected will vary depending on the purpose for which the information was collected. However, the information we usually collect includes name, address, credit and debit card details, phone number, email address, work history, SFG website passwords and usernames, clothing size information etc. This information allows us to provide products and services to you or otherwise interact with you. If you do not provide us with the personal information requested, we may not be able to provide the services or interact with you.

If you provide your email address or mobile telephone number to SFG, you consent to us using your email address to email you and/or your mobile telephone number to SMS you for any of the purposes listed above.

SOCIAL MEDIA

We may also collect personal information when you submit content on our social media pages. By submitting content, you agree we may use this content including your name and any other personal information submitted by you, either temporarily or permanently, for testimonial, marketing or other purposes in any media without any compensation to you.

USE AND DISCLOSURE

If we will be using or disclosing your personal information for a purpose other than the primary purposes described above, we will obtain your consent unless the use or disclosure is otherwise permitted under the Act. SFG does not sell personal information to direct marketing organisations.

If you do not wish to be contacted by SFG about our products, simply write, email or call us using the contact information provided below and we will remove you from any mail, telephone or electronic lists used by us for marketing purposes. Please be sure to include your name and other relevant details.

The Privacy Officer, Specialty Fashion Group, 151-163 Wyndham St. Alexandria NSW 2015

Email: privacyofficer@specialtyfashiongroup.com.au

Phone: (02) 8303 9800

From time to time we may sell or disclose information you provide us that is not personal information or does not disclose your identity to any person for any purpose at our sole discretion, including to people or companies located outside of Australia. We may also modify your personal information (through encryption or other de-identifying techniques) so that it is in a form from which you cannot be identified and sell or disclose such modified information to any person for any purpose, including to people or companies located outside of Australia.

ACCURACY OF AND ACCESS TO PERSONAL INFORMATION

We endeavour to take all reasonable steps to ensure the personal information we hold is up-to-date, complete and accurate.

At any time, you may request a copy of your personal information held by us by contacting us using the contact information provided above. If you believe any of your personal information held by us is incomplete or inaccurate, please notify us in writing so that we may update that information. Every reasonable effort will be made to provide or update personal information on request, unless an exemption under the Act applies. In these circumstances we will provide written notification as to why your request has been refused.

We may withhold or refuse you access to your personal information if we are legally authorised to do so or where its disclosure to you is restricted by law, is the subject of legal action, or may compromise the privacy of another person.

DATA SECURITY

SFG will endeavour to take reasonable steps to protect the personal information we hold from misuse, loss and unauthorised access, modification, destruction or disclosure. We adopt practices to prevent unauthorised access to our premises, systems or physical storage locations. Personal information that is no longer required will be destroyed or de-identified, as appropriate.

ONLINE TRANSACTION

SFG takes online transaction security seriously. We process online transactions using at least a 128 bit SSL encryption to a secure eWay credit card payment gateway system.

SFG collects but does not store your credit card details on its databases or servers. You will need to enter those details each time you make a purchase on our websites. However, we do maintain records of your transaction history. As mentioned above, SFG adopts practices which seek to prevent unauthorised access to such records.

The Internet is not a secure method of transmitting information. Accordingly, we cannot accept responsibility for the security of information you send to or receive from us over the Internet or for any unauthorised access, use or modification of that information.

Our websites may provide links or references to other 3rd party websites and resources. These websites and resources are not subject to this Privacy Policy. You should review the privacy policy of each 3rd party website and resource accessed via links from our websites, and assess whether the policy of each website and resource is satisfactory to you before you use the website or resource. You acknowledge and agree that we are not responsible for any personal information you choose to disclose to a 3rd party through a 3rd party website referred to by or linked to any of our websites and that such 3rd parties may store your personal information in any location in accordance with their own security standards.

IDENTIFIERS AND ANONYMITY

Where personal information is collected, it will usually be identified by a common identifier such as the name of the individual, address or transaction details. SFG will not use identifiers assigned by a government agency, such as tax file numbers, to identify your personal information.

Wherever it is lawful and practical, SFG will give you the option of not identifying yourself when interacting with us.

WHERE INFORMATION IS STORED

Subject to the below, personal information we collect from you is stored securely at our offices and on servers in Australia. SFG may also store your personal information at our offices and on servers located in New Zealand, South Africa, the United Kingdom and the USA. We may also engage or deal with Third Party Providers to assist with carrying out the purposes discussed in this Privacy Policy above, which may include the provision of data storage and hosting services in relation to your information. We will disclose your personal information to our Third Party Providers to the extent necessary for them to provide such assistance (including storage and data hosting services) and as otherwise required for you to use our websites and to obtain products or services we offer from time to time. In addition to Australia, our Third Party Providers may also store your personal information in New Zealand, South Africa, the United Kingdom and the USA. If our Third Party Providers store your personal information outside Australia, the Act requires us to ensure that they comply with applicable Australian privacy laws unless you agree otherwise. By providing us with information (including personal information), using our websites or obtaining any products or services provided by us from time to time, you: (i) consent to us disclosing and transferring your information (including personal information) to our Third Party Providers located outside of Australia, particularly in New Zealand, South Africa, the United Kingdom and the USA; (ii) consent to us and our Third Party Providers storing your information (including personal information) in locations and on servers located outside of Australia, particularly in New Zealand, South Africa, the United Kingdom and the USA; and (iii) agree that the requirement under the Act for us to ensure that our Third Party Providers comply with applicable Australian privacy laws in respect of your information (including personal information) does not apply if our Third Party Providers store personal information outside of Australia, including in New Zealand, South Africa, the United Kingdom and the USA (as applicable). We may in the future store your personal information in other locations outside of Australia or engage other providers that may store your personal information in or outside of Australia and will update this Privacy Policy if either is the case. We suggest that you visit our websites regularly to keep up to date with any changes.

SENSITIVE INFORMATION

Where SFG collects personal information that is also sensitive information, such as health details, we will only do so if the individual has consented or the collection is required or permitted by law, including where necessary for the establishment, exercise or defence of a legal or equitable claim.

FEEDBACK

If at any time you believe we have not followed our privacy policy, or if you have some query or comment about our privacy policy, please contact our privacy officer, at the address set out above. We will make every reasonable effort to resolve the problem to the satisfaction of all parties and/or provide you with a response to your query or comment. If you are not satisfied with our response, you can lodge a complaint with the Australian Information Commissioner through its website located at www.oaic.gov.au/privacy/privacy-complaints.

UPDATING THIS PRIVACY POLICY

We may update this privacy policy from time to time by posting a revised version on our website

 

PRIVACY POLICY & COLLECTION STATEMENT

NONI B Group Ltd, crossroads parent company (”crossroads” or “We”) is totally committed to protecting the privacy of our site visitors and customers. crossroads team members are customers themselves of other Internet sites and fully appreciate and respect the importance of privacy on the Internet.

crossroads will only collect and use your personal information as outlined below. From time to time we are required to collect, hold, use and/or disclose personal information relating to customers in the performance of its business activities. The below sets out our policy in relation to the protection of personal information, as under the Privacy Act 1998 (Cth) (the Act) and the Australian Privacy Principles (APP). The APPs regulate the handling of personal information.

The Privacy Policy applies to the services offered on the crossroads website (www.crossroads.com.au) operated by crossroads of the NONI B Group Ltd.

COLLECTION OF PERSONAL INFORMATION

From you

We may collect and process personal data relating to you by you providing such personal data by filling in forms on our site or by you contacting us. This includes, but is not limited to, information provided at the time of registering to use (or become a member of) our site, subscribing to any services (e.g. newsletters), purchasing products or requesting further services.

By using cookies

A cookie is a small information file that is sent to your computer, mobile or other device when you visit a website and it will recognise your device on future visits. These types of files do a number of different jobs such as:

  • enabling the site to provide services you have asked for such as remembering your shopping bag items.

  • anonymously collecting information on how you and other users use the site. Together with information from other users we can identify ways to make the site easier for you to use. The data stored by these cookies never shows personal details from which your individual identity can be established.

  • remembering choices you make which we can then use to provide you with an experience more appropriate with your selections and make the visits more tailored and pleasant. For example, our wish list feature utilises a cookie to remember the products which you have expressed a wish to save whilst browsing our website. The information is also merged with other users on an anonymous basis to enable us to improve how the site operates.

  • anonymously collecting information about your browsing habits in order to make advertising relevant to you and your interests. The cookies remember the websites you have visited and that information is shared with other parties such as advertisers. For example we may use a 3rd party company to provide you with more personalised adverts when visiting other websites.

You can change the settings on your browser to prevent cookies being stored on your computer or mobile device without your explicit consent. Your browser “help” section will normally provide details on how to manage the cookie settings. Please note that if you select such settings you may be unable to access certain parts of our site.

WHAT IS PERSONAL INFORMATION

Personal information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

KINDS OF INFORMATION THAT CROSSROADS COLLECTS AND HOLDS

We collect personal information that is reasonably necessary for one or more of its functions or activities as set out below.

crossroads is principally a retailer, and carries out number of facilities and functions including shops (off the street and in shopping centers), the internet, promotional material (using various forms including paper and electronic mail outs), credit and other card systems, Lay-By arrangements and reward schemes.

The type of information that we collect and hold includes your name, address, email address, contact telephone number, gender, age and your product preferences.

Sensitive information: we will only collect sensitive information where you consent to the collection of the information and the information is reasonably necessary for one or more of our company’s functions or activities. Sensitive information includes, but is not limited to, information or an opinion about racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, membership of a trade union, sexual preferences, criminal record, health information or genetic information.

HOW CROSSROADS COLLECTS AND HOLDS PERSONAL INFORMATION

crossroads must collect personal information only by lawful and fair means. We will collect personal information directly from you if it is reasonable or practicable to do so.

We may collect personal information in a number of ways, including without limitation:

a)            in stores;
b)            through our website;
c)             through application forms;
d)            by email or other written mechanisms;
e)            over a telephone call;
f)             in person;
g)            through transactions;
h)            through our website;
i)              through surveillance cameras;
j)              by technology that is used to support communications between us;
k)             from third parties, including but not limited to:
l)               from past and present employers and referees when conducting reference checks, candidates after completing an interview, clients of crossroads and contract management services in relation to assignments;
m)            through publically available information sources (which may include telephone directories, the internet and social media sites); and
n)             direct marketing database providers.

When we collect personal information about you through third parties, it will manage such information in accordance with the APPs.

Much of the personal information that we hold is stored in our database. Our database comprises of hard copy files and/or electronic files in our ordinary IT systems. These may include cloud servers or servers of third parties.

Unsolicited personal information is personal information that we receive which it did not solicit. Unless we determine that it could have collected the personal information in line with the APPs or the information is contained within a Commonwealth record, it must destroy the information to ensure it is de-identified.

 

PURPOSES FOR WHICH CROSSROADS COLLECTS, HOLDS, USES AND/OR DISCLOSES PERSONAL INFORMATION

We will collect personal information if it is reasonably necessary for one or more of its functions or activities.

The main purposes for which we may collect, hold, use and/or disclose personal information may include but are not limited to providing you with:

a)             product information;
b)            a better website experience;
c)             special offers; and / or
d)            competition entry information.

You authorise that we are to retain your personal information for the purposes outlined in clause 6.2 until such time that you direct us, using the contact details contained within clause 13 herein, that you wish for this personal information to be discarded.

We may also collect, hold, use and/or disclose personal information if you consent or if required or authorised under law.

If you do not allow us to collect all or some of the personal information we request, crossroads may not be able to achieve its purposes.

 

DIRECT MARKETING

crossroads will not send you information without your prior consent. If you agree to receive information, crossroads may contact you via email, post or other forms of direct contact.

crossroads may use or disclose personal information (other than sensitive information) about you for the purpose of direct marketing (for example, advising you of new goods and/or services being offered by crossroads).

crossroads may use or disclose sensitive information about you for the purpose of direct marketing if you have consented to the use or disclosure of the information for that purpose.

You can opt out of receiving direct marketing communications from crossroads by contacting the Privacy Officer in writing or by following the directions contained within emails from crossroads and unsubscribing appropriately.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose your personal information for any of the purposes for which it is was collected, as indicated under clause 6 of this policy, or where it is under a legal duty to do so.

Disclosure will usually be internally, to related entities, candidates, referees, potential and actual employers and clients of crossroads.

crossroads may disclose personal information to third parties such as contracted service suppliers (CSP). Examples of CSPs include, but are not limited to, financial institutions for payment processing, information technology service providers, marketing and communications agencies, printers and distributers of direct marketing material and external business advisors.

Before we disclose personal information about you to a third party, we will take steps as are reasonable in the circumstances to ensure that the third party does not breach the APPs in relation to the information.

CROSS-BORDER DISCLOSURE OF PERSONAL INFORMATION

crossroads utilises the services of overseas servers, your personal information may be to overseas recipients for the purposes of cloud storage.

ACCESS TO PERSONAL INFORMATION

If crossroads holds personal information about you, you may request access to that information by putting the request in writing and sending it to the Privacy Officer. We will respond to any request within a reasonable period, and a charge may apply for giving access to the personal information.

There are certain circumstances in which crossroads may refuse to grant you access to the personal information. In such situations we will give you written notice that sets out:

a) the reasons for the refusal; and

 

b) the mechanisms available to you to make a complaint.

CORRECTION OF PERSONAL INFORMATION

If crossroads holds personal information that is inaccurate, out-of-date, incomplete, irrelevant or misleading, it must take steps as are reasonable to correct the information.

If crossroads holds personal information and you make a request in writing addressed to the Privacy Officer to correct the information, we must take steps as are reasonable to correct the information and will respond to any request within a reasonable period.

There are certain circumstances in which crossroads may refuse to correct the personal information. In such situations we will give you written notice that sets out:

a)  the reasons for the refusal; and

b) the mechanisms available to you to make a complaint.

 

If crossroads corrects personal information that it has previously supplied to a third party and you request us to notify the third party of the correction, we will take such steps as are reasonable to give that notification unless impracticable or unlawful to do so.

INTEGRITY AND SECURITY OF PERSONAL INFORMATION

 

crossroads will take such steps (if any) as are reasonable in the circumstances to ensure that the personal information that it:

a)  collects is accurate, up-to-date and complete; and

b) uses or discloses is, having regard to the purpose of the use or disclose, accurate, up-to-date and complete.

crossroads will take steps as are reasonable in the circumstances to protect the personal information from misuse, interference, loss and from unauthorised access, modification or disclosure.

If crossroads holds personal information, it no longer needs the information for any purpose for which the information may be used or disclosed, the information is not contained in any Commonwealth record and the crossroads is not required by law to retain the information, it will take such steps as are reasonable in the circumstances to destroy the information or to ensure it is de-identified.

ANONYMITY AND PSEUDONYMITY

You have the option of not identifying yourself, or using a pseudonym, when dealing with crossroads in relation to a particular matter. This does not apply:

a)  where crossroads is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves; or

b) where it is impracticable for crossroads to deal with individuals who have not identified themselves or who have used a pseudonym.

However, in some cases if you do not provide crossroads with your personal information when requested, we may not be able to respond to your request or provide you with the goods or services that you are requesting.

COMPLAINTS

You have a right to complain about crossroads handling of your personal information if you believe we have breached the APPs.
If you wish to make such a complaint to crossroads, you should first contact the Privacy Officer in writing. Your complaint will be dealt with in accordance with our complaints procedure and we will provide a response within a reasonable period.
If you are unhappy with crossroads response to your complaint, you may refer your complaint to the Office of the Australian Information Commissioner.

CROSSROADS VIP PROGRAM PRIVACY POLICY

Member privacy is important to crossroads. All data collection will be handled sensitively, securely and with proper regard for privacy. crossroads will at all times collect personal information in a lawful and fair manner. Members may be contacted at any time using the information provided for the purposes of advertising, market research and to ensure proper functioning of the VIP Program. In order to operate the crossroads VIP Program we may sometimes share your personal information with a service partner or a company connected with crossroads (by, for example a common shareholder of some common commercial interest). We will not otherwise disclose your personal information to other companies without your explicit consent, unless required by law.

COMPANY AND PRIVACY OFFICER CONTACT DETAILS

crossroads can be contacted in the following ways:
 
Telephone number:  1800 151 110
Email address:  customercare@crossroads.com.au
Postal address:  NONI B Group LtD, PO Box 27, Liverpool NSW 1871
 
The crossroads Privacy Officer can be contacted in the following ways:
 
Telephone number:  (02) 8303 9800
Email address:  privacy@nonib.com.au
Postal address:  NONI B Group Ltd, PO Box 27, Liverpool NSW 1871