Northside Brands Pty Ltd Privacy Policy

1. Northside Brands Privacy Policy

This is the Privacy Policy of Northside Brands Pty Limited ACN 648 673 769 (‘Northside Brands’, ‘us’, ‘we’, ‘our’).  Northside Brands is a subsidiary of Adore Beauty Group Limited ACN 636 138 988 (‘Adore Beauty’). This Privacy Policy applies to all of our businesses (unless any of our businesses have adopted a separate policy) including, but not limited, to Viviology. This Privacy Policy also sets out Northside Brand’s obligations in line with the Australian Privacy Principles (‘APP’) in the Privacy Act 1988 (Cth) (‘Privacy Act’) and the Privacy Act 1993 (NZ) (the ‘NZ Act’) in New Zealand. Where the terms ‘information’ or ‘personal information’ are used in this policy this is a reference to ‘personal information’ defined in the Privacy Act or the NZ Act (as applicable). This Privacy Policy sets out the different types of information we collect, why we collect it and what you can do if you would like to remove yourself from our mailing list or change any details we may hold about you. If you need to contact us to discuss this policy, our contact details can be found here.

What information does Northside Brands collect and when does it collect this information?

Northside Brands will collect information from you when you visit our website or when you otherwise transact with us. The types of information that Northside Brands collects from you and the situations in which we collect personal information are outlined below.

If you sign up as a subscriber: we will collect your name, and email address and may provide such information to Adore Beauty and other subsidiaries of Adore Beauty Group Limited. You will not be put on the mailing lists of any third parties.

If you do not sign up as a subscriber: we may collect general site traffic data (see the paragraph on General site traffic data below).

Currently, it is not possible to place an order on Northside Brands’ websites. Rather, when placing an order you will be directed to Adore Beauty’s website. When you place an order: Adore Beauty will collect your name, billing address, delivery address, email address and telephone number. This information must be provided to allow Adore Beauty to effect delivery of the products that you order, and to contact you if necessary. These details are retained in Adore Beauty’s database for record keeping purposes. 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. The collection, storage and use of any personal information by Adore Beauty will be managed by Adore Beauty in accordance with its own privacy practices and policies and not this Privacy Policy. 

When you use our website: 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. 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 Northside Brands will only be used for the purpose of hiring new employees. Your employment application will be stored by us on file for the duration that they are relevant to hiring new employees and then destroyed. This information will not be disclosed to third parties

When you engage in business with us: Northside Brands 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.

What happens if you do not provide personal information?

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 goods, services or information to you, or be able to provide them to the same standard as if we had the information requested.

Why does Northside Brands collect personal information?

Northside Brands collects personal information to:

  1. provide you with information that you have requested;

  2. process orders you make through Adore Beauty’s websites;

  3. add you to Northside Brands mailing list and the mailing lists of the other businesses conducted by Adore Beauty Group and its other subsidiaries;

  4. send you marketing materials about Northside Brands and the other businesses conducted by Adore Beauty and its other subsidiaries;

  5. promote our goods and services;

  6. deliver to you the goods that you have ordered and provide you with customer service following these orders;

  7. improve the website experience of our visitors;

  8. provide services to you;

  9. contract with you; and

  10. comply with our legal obligations.

We also use personal information for our own internal business purposes including:

  1. for data analysis to improve our products and services among our subsidiaries and businesses;

  2. auditing our internal processes to ensure they function as intended and that we comply with regulatory requirements;

  3. for fraud and security monitoring;

  4. developing new products and services;

  5. identifying usage trends so we can understand which part of our services are of most interest to our customers;

  6. determining the effectiveness of marketing campaigns so that we can adapt to the needs and interests of our customers; and

  7. operating and expanding our business activities such as understanding which of our services are of most interest to our customers, so we can focus on our customers’ needs.

Do you collect my sensitive information?

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). We generally do not collect sensitive information about individuals. 

If you provide sensitive information to us for any reason (for example if you provide us information about skin conditions in feedback to a product) 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.

Do we engage in direct marketing?

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, please click on the “unsubscribe” link at the bottom of any email we send you and you will be removed from any future communications. 

Who do we disclose your personal information to?

In the course of conducting our business we may provide your personal information to:

  1. third parties: in the course of providing products and services to you including, without limitation, through your use of our website.  These third parties may include fraud prevention providers, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers and electronic network administrators

We may disclose your personal information to third parties:

  1. to enable our website (and your shopping experience) to function in the manner it is intended;

  2. to prevent payment fraud;

  3. as part of our business processes and for the purposes described above in ‘Why does Northside Brands collect personal information’;

  4. to meet the purpose for which your personal information was submitted;

  5. if we have your consent to do so or otherwise when we are authorised by law;

  6. if we are required by law to disclose the information

 

We may also use and share your personal information: 

  1. 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, as a minimum, agreed to comply with all privacy laws applicable to it and adhere to terms similar to this Privacy Policy;

  2. to share among our related entities, or business units or brands within, Adore Beauty; and affiliates to deliver our goods and services to you or receive goods and services from you; and

  3. with any other persons and entities permitted under the Privacy Act and NZ Act.

Does Northside Brands store personal information outside of Australia or New Zealand?

Some of the third party service providers to whom we send data are located outside of Australia or may store your data outside of Australia, including in these countries:

  1. Australia;

  2. New Zealand;

  3. Ireland;

  4. United States;

  5. Israel; and

  6. Singapore.

When we disclose personal information outside of Australia and/or New Zealand we will comply with this Privacy Policy and other requirements of the Privacy Act and NZ Act. 

If you do not agree to the transfer of your personal information outside of Australia and/or New Zealand, please contact us before you agree to this Privacy Policy. In these circumstances, we may be prevented from providing products or services to you.How do we hold your information?

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:

  1. make sure that the personal information we collect, use or disclose is accurate, complete and up to date;

  2. protect the information from misuse, interference, loss or unauthorised access, modification or disclosure both physically and through security methods; and

  3. destroy or permanently de-identify the information if it is no longer needed for any purpose.

  4. 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.

For how long do we keep information?

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:

  1. the length of time we have an ongoing relationship with you and provide services to you;

  2. legal obligations we may have to keep (or destroy) your data; or

  3. legal advice we receive (such as in regard to litigation, regulatory investigations or applicable statutes of limitation).

When your information is no longer required it is destroyed in a secure manner.

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.

How can I access my information?

You are entitled to request access to personal information we hold about you and to request any information we hold about you be corrected or deleted. If you would like to request to review, correct, update, suppress, restrict or delete personal information that you have previously provided to us, 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), you may contact us by emailing privacy@northsidebrands.com.au and we will provide this information to you consistent with applicable law.

In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information deleted from our database or otherwise let us know what limitations you would like to put on our use of your personal information. 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 reserve the right to charge a fee for providing access to your information when permitted by law. If we delete your information we may not be able to provide goods, services or information to you, or be able to provide them to the same standard as if we had your information.

What about links to other websites?

This Privacy Policy is strictly limited to the collection, storage and use of personally identifiable information collected by Northside Brands 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, and assume no liability for the privacy practices of those websites. We urge users to take time to examine individual privacy policies and guidelines on other websites.

Minors

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 using the details below.

Information that is not personal information (De-Identified Data)

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.

Contacting Us

You can contact us by email at privacy@northsidebrands.com.au  or in writing to:

Privacy Officer

Northside Brands

Level 1, 421 High Street

NORTHCOTE VIC 3070

Australia

How can I complain?

If you would like to complain about a breach of the Privacy Act or NZ Act you can contact us using the details below.  We will look into your complaint and respond promptly in writing notifying you of what we will do in response. If you are in Australia and unsatisfied with our response you can contact the Office of the Australian Information Commissioner (‘OAIC’).  Contact details are on the OAIC website at https://www.oaic.gov.au.If you are in New Zealand and not satisfied with our handling of your complaint, you may refer the issue to the Privacy Commissioner (at www.privacy.org.nz).

Changes to this Policy

This policy is subject to change over time without prior notice.  We may amend this policy by updating it and posting it on our website.We recommend that you visit our website regularly to keep up to date with any changes.

Copies of this policy

You can ask us to provide you with a copy of this policy, including a hard copy, by contacting us using the details above.

Last Published: June 2022