1. What is "Personal Information"? 

2.1 GAZMAN may collect and hold Personal Information about you for various reasons. The types of Personal Information we collect about you will depend on the purpose for which the Personal Information is collected. This can include: 

a) in the case of customers procuring our products, including through our Website – your name, billing or shipping address, email address, telephone number(s), payment information (including credit card information or alternative payment method account information) and your order details; 

b) if you have requested to receive news about exclusive offers, promotions, or events from us – your name, date of birth, mailing or street address, email address, and telephone number(s);  

c) if you have contacted us to make a complaint, provide feedback, submit an enquiry, request a call-back or request a product replacement – your name, mailing or street address, email address, and telephone number(s); 

d) in the case of our brand ambassadors, representatives or supporters – your name, mailing or street address, email address, date of birth, occupation, and social media information; 

e) in the case of our stores where we have CCTV technology installed, CCTV footage and recordings, including footfall detectors, and which may include CCTV technology that uses artificial intelligence; 

f) in the case of prospective employees or contractors – information contained in your application or résumé, recorded during any interview, or obtained through any pre-employment checks, and government-issued identifiers such as tax file numbers;  

g) in the case of wholesale customers who apply for credit – information required to assess your credit worthiness, including your credit or business history and any trade referees; and  

h) in the case of our suppliers and distributors – your name, mailing or street address, email address, and telephone number(s). 

2.2 Your Personal Information may be processed in accordance with, and we suggest you familiarise yourself with Afterpay’s and PayPal’s privacy policies here www.afterpay.com/en-AU/privacy-policy and here www.paypal.com/au/legalhub/paypal/privacy-full. 

2.3 Generally, we will not collect Sensitive Information about you. However, in certain circumstances such as when you become an employee of GAZMAN, we may need to collect limited Sensitive Information about you. For instance, if you disclose details of medical conditions, including pre-existing injuries or specific dietary or allergy requirements to us as part of your employment. 

3. Can you choose not to disclose your Personal Information? 

3.1 You have the option to deal with us anonymously or by using a pseudonym. However, you acknowledge that where this is impractical (for example when you contract with us) or where the law or a court order provides otherwise, we are not required to provide these options to you. 

3.2 If you choose not to provide your Personal Information to GAZMAN, or if you use a pseudonym, we may not be able to undertake certain activities for you such as providing you with requested information, products or services. For example, we will not be able to send you information you have requested if you have not provided us with a valid email address or telephone number. 

4. When and how do we collect Personal Information?

4.1 GAZMAN collects Personal Information directly from you, including when you: 

a) visit our Website or stores; 

b) supply or buy products or services; 

c) request information about us or our products or services; 

d) sign up to receive news and exclusive offers, promotions, or events, including through our GAZCLUB membership program; 

e) provide feedback; 

f) respond to a survey, or enter our competitions or promotions;  

g) change your marketing content or email preferences;  

h) contract with us, apply to work with us or are engaged by us as a contractor; or 

i) fill in a form on our Website or communicate with us via the Website, by telephone, facsimile, email, post, in person or otherwise. 

4.2 Where it is reasonable and practicable to do so, we will only collect Personal Information about you from you directly and not from third parties.   

4.3 In limited circumstances, GAZMAN may also collect Personal Information about you from publicly available sources (such as the Internet) and via third parties such as: 

a) mutual contacts; 

b) if someone makes a purchase on your behalf; 

c) from your referees during the recruitment process if you apply for a job with us; 

d) our service providers, suppliers and merchants; or 

e) through promotional and marketing activities.  

4.4 Whilst we will always maintain robust privacy practices, we are not responsible for the privacy practices of third parties, so you should review their relevant privacy policy to satisfy yourself as to how they protect and handle your Personal Information. For example, we engage Experian for data analytics purposes, whose privacy policy can be found here www.experian.com.au/privacy-policy-terms-conditions.  

4.5 In some circumstances we may receive Personal Information that we have not requested. If this occurs, we will comply with our obligations under the Privacy Act. You acknowledge that we may, in accordance with the Privacy Act, de-identify or destroy this information unless we are required to keep it by law. 

5. Information collected via our Website 

5.1 GAZMAN will generally not collect any Personal Information about users of our Website except when you knowingly provide it or as otherwise described below. For example, GAZMAN may collect Personal Information from users of the Website when you: 

a) complete an online form; and/or 

b) otherwise correspond with GAZMAN through the Website.  

5.2 When you visit and browse our Website, our Website host may collect information, including Personal Information, for statistical, reporting and maintenance purposes. Generally, the Personal Information collected by our Website host will not be used to identify you. The information may include technical information and general analytics (which may be collected automatically) such as: 

a) web browser type and browsing preferences;  

b) Internet service provider information; 

c) the number of users visiting our Website and the number of pages viewed; 

d) the date, time and duration of a visit; 

e) the IP address of your device;  

f) time zone and geolocation data (if applicable) and 

g) the path taken through our Website. 

5.3 GAZMAN's Website host uses this information to administer and improve the performance of our Website and our products and services.  This information may also be used for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are using our Website. 

5.4 Cookies are small text files that are transferred to a user's computer hard drive or web browser by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns.  

5.5 If you access our Website, a cookie is downloaded onto your computer's hard drive or browser when you first log on to our Website. You can adjust your internet browser to disable cookies, however GAZMAN may not be able to provide you with all the service or functionality you require on our Website if you choose to do so. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org. 

5.6 Web beacons are images that originate from a third party site to track visitor activities. GAZMAN may use web beacons to collect aggregate data and provides this information to our Website host to administer and improve the performance of our Website.  

5.7 We use Google and/or other third-party service providers to serve ads on our behalf across the Internet and sometimes on our Website. They may collect anonymous information about your visits to our Website (not including your name, address, email address or telephone number), and your interaction with our products and services. They may also use information about your visits to the Website and other websites to target advertisements for goods and services in order to provide more relevant advertisements about goods and services of interest to you. 

5.8 You may opt out of targeted advertising by using the links below:  

a) Facebook; 

b) Google; and 

c) Bing. 

5.9 Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal.  

6. How GAZMAN uses the Personal Information it collects about you 

6.1 GAZMAN uses the Personal Information it collects about you for our business functions and activities, which may include the following: 

a) to provide you with information, products or services you have requested, or to receive products and services from third parties; 

b) to enable the proper operation and functionality of our products and services; 

c) to promote and market our products and services to you; 

d) to personalise and customise your experiences on our Website; 

e) to gain insights about you to help GAZMAN research the needs and preferences of its customers; 

f) to conduct research, including for the purposes of improving existing products or services or creating new products or services; 

g) to provide you with ongoing information about GAZMAN and its activities; 

h) to verify your identity (for example, if you request access to the Personal Information we hold about you);  

i) to comply with regulatory or other legal requirements, such as notifying you of matters where required to do so by law; 

j) to prevent, detect and investigate suspicious, fraudulent, criminal or other activity that may cause you, us or others harm, including in relation to our products and services; 

k) to communicate with you, and to address any issues or complaints that we or you may have regarding our relationship and our products and/or services; 

l) for direct marketing (see clause 6.4 below);  

m) to consider you for a job at GAZMAN (whether as an employee or contractor) or other relationships with us, and for other purposes related to the engagement of our personnel and providing internal services to our staff;  

n) for any other purpose communicated to you at the time that the Personal Information was collected or for which you provided your consent; and 

o) to contact you regarding any of the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner. 

6.2 We may also use or disclose your personal information for our administrative, planning, product or service development, quality control and survey purposes or as otherwise permitted or required by law. 

6.3 GAZMAN may use your Personal Information for a secondary purpose if that secondary purpose is related to those purposes listed above, if we have your consent or if otherwise permitted under the Privacy Act. 

6.4 GAZMAN may use your Personal Information to provide you with direct marketing materials, including any news, exclusive offers, promotions or events, where you have consented to receive direct marketing materials. Direct marketing material may include promotional material about GAZMAN, the GAZCLUB membership program (including details about your progress for loyalty rewards) or the products or services offered by GAZMAN. 

6.5 You may opt out of receiving direct marketing material by contacting us in any of the ways specified in the direct marketing materials or as set out in clause 13. 

7. Who do we disclose your Personal Information to? 

7.1 Depending on the nature of your relationship with GAZMAN, we may disclose your Personal Information to third parties in connection with the purposes described above (see clause 6 above). This may include disclosing your Personal Information to the following types of third parties:  

a) shareholders, officers, employees and contractors of GAZMAN;  

b) other businesses within our group of companies;  

c) service providers who assist us in our business operations e.g. payment systems operators and financial institutions, cloud service providers, data storage providers, shipping companies, telecommunications providers and IT support services providers;  

d) parties involved in the purchase or sale of any of our businesses;  

e) our professional advisers (such as lawyers, accountants or auditors) and insurers; 

f) organisations authorised by us to conduct promotional, research or marketing activities; 

g) third parties to whom you have authorised us to disclose your information; and 

h) other third parties as required or permitted by law. 

7.2 GAZMAN may also disclose your Personal Information to our Website host or service providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.  

7.3 In some circumstances, we may also share de-identified and aggregated information for research or promotional purposes. We will not sell your Personal Information to third parties for marketing purposes. 

7.4 If we disclose your Personal Information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your Personal Information as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws, for example (where commercially practical) by including suitable privacy and confidentiality clauses in our agreement with a third party service provider to which we disclose your Personal Information. 

8. Disclosure of your Personal Information overseas 

8.1 Your Personal Information may be disclosed outside of Australia to an entity in a foreign country, including entities in which GAZMAN has an ownership interest. These countries include Vietnam and the United Kingdom, and such other countries as necessary from time to time.  

8.2 If your Personal Information is sent to a recipient in a country with data protection laws which are at least substantially similar to the Privacy Act and the Australian Privacy Principles, and where there are mechanisms available to you to enforce protection of your Personal Information under that overseas law, we will not be liable for a breach of the Privacy Act and the Australian Privacy Principles if your Personal Information is mishandled in that jurisdiction. If your Personal Information is transferred to a jurisdiction which does not have data protection laws as comprehensive as Australia's, we will take commercially reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the Privacy Act and the Australian Privacy Principles. 

9. Storage and security of Personal Information held by GAZMAN 

9.1 GAZMAN will take reasonable steps to protect your Personal Information from misuse, interference, theft and loss and from unauthorised access, modification or disclosure. 

9.2 GAZMAN aims to keep your Personal Information secure and up to date. We will comply with our obligations under the Privacy Act in relation to any Personal Information that we handle, including information which is held on GAZMAN's computer systems. 

9.3 GAZMAN aims to keep Personal Information that is held by GAZMAN in hard copy secure. We also 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 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. 

9.4 However, particularly for electronic data stores and due to the fact that the Internet is inherently insecure, we cannot guarantee the security of transmission of Personal Information disclosed to us online.  Accordingly, you transmit your Personal Information to us online at your own risk and are encouraged to exercise care in sending Personal Information via the internet.  Please notify us immediately if you know or reasonably suspect that your Personal Information has been subject to any data breach, breach of security or other unauthorised activity. 

10. Updating and correcting your Personal Information 

10.1 We will take reasonable steps to ensure that the Personal Information that we hold is accurate, up-to-date and complete. If you believe that Personal Information we hold about you is incorrect, incomplete or inaccurate, then you can request us to update your Personal Information at any time by contacting GAZMAN in any of the ways specified in clause 13.  

10.2 Where we agree that the information needs to be corrected, we will update it. If we do not agree, you can request that we make a record of your correction request with the relevant information.  

11. How long will GAZMAN keep your Personal Information? 

11.1 Generally, we will keep your Personal Information only for as long as required for our business purposes (as outlined in this Privacy Policy) unless otherwise required by Australian law or if it is reasonably necessary for us to comply with our legal obligations, resolve a dispute or maintain security. 

11.2 Where we no longer need to keep your Personal Information in accordance with clause 11.1, we will take reasonable steps to destroy or de-identify your Personal Information. 

11.3 If you wish to have your Personal Information destroyed or de-identified, please let us know by contacting us in any of the ways specified in clause 13 and we will take reasonable steps to do so (unless we need to keep it for legal, auditing or internal risk management reasons, or as otherwise permitted or required by law). 

12. Finding out what Personal Information GAZMAN holds about you and how to correct it 

12.1 You are entitled request to access Personal Information that GAZMAN holds about you. If you request access to your Personal Information, we will grant your request unless providing you with access would unreasonably impact upon the privacy of others or another exemption under the Privacy Act applies. If we provide access to your Personal Information, we may charge an administration fee in limited circumstances, but we will let you know in advance if that is the case. If we refuse your request to access your Personal Information, we will provide you with written reasons for the refusal.  

12.2 You are entitled to request correction of Personal Information that GAZMAN holds about you if you believe that it is incorrect, incomplete or inaccurate. If you request correction of your Personal Information, and we are satisfied that the information needs to be corrected, we will update it. If we refuse to correct your Personal Information, you can request that we make a record of your correction request with the relevant information. 

12.3 A request for access or correction can be made by contacting GAZMAN in any of the ways specified in clause 13. 

13. How to contact us and more information 

13.1 If you feel that your privacy has not been respected or that GAZMAN has conducted itself inconsistently with this Privacy Policy, the Australian Privacy Principles, a registered APP Code and/or the Privacy Act in respect of your Personal Information, or for any other queries, problems, complaints or communication in relation to this Privacy Policy, please contact us in any of the following ways:  

13.2 You can find out more information about the Privacy Act and the Australian Privacy Principles from the Office of the Australian Information Commissioner. If you have raised a complaint with us and you are unsatisfied with the outcome or have further concerns about the way we handle your personal information, under the Privacy Act, you may complain to the Information Commissioner at the Office of the Australian Information Commissioner, whose contact details are set out below: