Privacy Policy

Pump Haircare Pty Ltd (ABN 86 157 791 467) (“Pump Haircare”, “us”, “we” or “our”) owns and operates the websites www.pumphaircare.com and www.pumphaircareb2b.com (“Websites”).  Pump Haircare is committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) and in accordance with other applicable privacy laws. Our Privacy Policy outlines how Pump Haircare collects and handles your personal information.

If you are located in the European Union (“EU”), you have additional rights under the EU General Data Protection Regulation (“GDPR”).  Details of those additional rights and how we address them are set out at the end of our Privacy Policy.

What is personal information?

“Personal information” means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether that information or opinion is true or not or recorded in a material form or not.

What personal information do we collect?

We collect and hold personal information that is necessary for, or related to, one or more of our services or activities; or because it is required under a relevant law or regulation.

The types of personal information that we will collect from you will depend on the nature of your interaction with us but will ordinarily include:

• if you are a customer, for example, your name, contact details, billing address, shipping address, product preferences and product feedback;
• if you are a stockist, your name, job title, business name and contact details;
• if you comment on our Facebook or Instagram page/account or send us a message there, your social media account name; and
• if you are interested in working with us, we may collect your full name, contact details (including address, phone number and email address), job title, passport details, employment history and education details, as well as names and contact details of referees.

From time to time, you may be able to visit our Websites or deal with us anonymously or by pseudonym. However, please be aware that, if you do not provide us with certain information that we request, we may not be able to provide you with the products or services you require.

How do we collect personal information?

We may collect personal information from you in variety of ways, including when you:

• sign-up for an account on our Websites;
• apply to be a stockist of our products;
• purchase our products or provide feedback about our products;
• update your account;
• contact our Customer Support team;
• engage with us via our official social media pages, such as our Facebook or Instagram account or pages;
• contact us by phone, email, post or via our Website enquiry forms;
• subscribe to receive our newsletters and other promotional materials; and
• participate in surveys and competitions we conduct.

We may also collect certain non-personal information when you visit or use our Websites and use our services, for example, your IP address and details of your operating system or internet browser.

Do we collect personal information from third parties?

We may also collect your personal information from third parties when permitted or required by law. We may collect personal information from:

• someone duly authorised to act on your behalf;
• law enforcement agencies and other government entities;
• third party suppliers and contractors who assist us to operate our business; and
• if you are a job applicant, recruiters or your referees.

Your personal information will only be collected from third parties if it unreasonable or impractical to collect that personal information from you directly.  If and when we do collect personal information from third parties, we will take reasonable steps, in the circumstances, to inform you of this collection.

Why do we collect your personal information and how do we use it?

Pump Haircare may collect and use your personal information for the purposes of providing you with our products and services and for our internal business purposes.  These purposes include (but are not limited to):

• registering, setting up and managing accounts;
• sending order confirmations and fulfilling orders;
• providing our products to our stockists and to consumers.
• sending you notifications about our products;
• responding to your questions, comments and requests and to otherwise provide customer services;
• assessing applications for employment;
• marketing our products and providing you with information and updates such as newsletters or offers of promotional events or opportunities that you may be interested in (such as competitions, surveys or product testing opportunities);
• the prevention of fraud and/or identifying and investigating any suspicious use of our Websites;
• for our internal business and management processes, for example, to conduct research and analysis, improve our products and services and for accounting or auditing purposes;
• for any other purpose to allow us to comply with our obligations under law; and
• for any other purposes that would be reasonably expected by you.

Direct Marketing

Pump Haircare may use your personal information for the purposes of marketing our products or to inform you of new products, promotions or events that we believe you may be interested in.  If you would like to stop receiving any of these marketing communications, you can opt out by writing to us at the contact details listed below (“Contact Details”) and informing us that you no longer wish to receive these materials.   If at any time you would like to stop receiving future electronic marketing messages (such as emails or SMS), you can click the “unsubscribe” link in the electronic marketing messages we send.

Will your personal information be disclosed to third parties?

From time to time, Pump Haircare may disclose your personal information to third parties for the purposes of providing our products and services and conducting our business.  These third parties may include:

• Shopify, a Canadian company which operates the online e-commerce platform on our Websites, which enables us to sell our products to you. If you choose a direct payment gateway to complete your purchase, then Shopify stores your credit card data. Your purchase transaction data is stored only as long as necessary to complete your purchase transaction. Once the transaction is completed, your purchase transaction information is deleted.
• third party service and content providers, contractors, advisors and suppliers who assist us in managing our business or operating our Websites, for example, business support services, webhosting service providers, cloud storage providers, mailing houses, delivery service providers etc;
• our professional advisors including lawyers, accountants, tax advisors and auditors;
• if you are applying for employment with us, recruiters we have engaged and/or your referees;
• law enforcement bodies to assist in their functions, courts of law or as otherwise required or authorised by law; and
• regulatory or government bodies for the purposes of resolving customer complaints or investigations.

If we sell or purchase any business or assets, your personal information may be disclosed to the prospective buyer/seller. If our business (or substantially all of our assets) is acquired by a third party, your personal information held by Pump Haircare may be an asset which is transferred to the buyer.

How do we secure and protect your personal information?

We take such steps as are reasonable in the circumstances to maintain the integrity of your personal information and to store your personal information securely to protect it from interference, misuse and loss and from unauthorised use, access, modification or disclosure. 

Although no method of transmission over the Internet or electronic storage is 100% secure, our Websites implement generally accepted industry standards.

Data is stored on servers in Australia and Canada.

We take reasonable steps to destroy or permanently de-identify your personal information if it is no longer needed for a purpose which it may be used or disclosed under the Australian Privacy Principles and we are not required by law or a court/tribunal order to retain the information.

Cookies

Our Websites use cookies. Cookies collect information that includes the server your computer or device is logged onto, your browser type and how you gained entry to our Websites. Therefore, when you visit our Websites anonymously, details are recorded about your visit, such as time and date, pages accessed and time spent on the Websites, in addition to the matters described above. This information is used in an anonymous form for statistical purposes, for example, to determine how many people access a webpage on the Websites. A cookie cannot retrieve any other information from your hard drive, pass on computer viruses or capture your email address or any other personally identifiable information.

Check the “Help” menu of your browser for more information on how to change your cookie preferences. You may disable cookies or set your browser to alert you when cookies are being sent. If you do disable cookies, we may be unable to optimise your visit to our Websites and you may experience some errors. Refer to your browser instructions or help screens to learn about these functions.

Further information is available in our Cookie Policy.

https://pumphaircareb2b.com/pages/cookie-policy

Our Websites use Google Analytics to help us learn about who visits the Websites and what pages are viewed.

Third Party Links

From time to time, our Websites may contain links to websites operated and maintained by third parties over which we have absolutely no control.  These third party websites are not subject to this Privacy Policy or our privacy standards and procedures. Any information you provide to third party websites will be governed by the terms of the websites’ privacy policies. We have no responsibility or liability whatsoever for the content, actions or policies of third party websites. The inclusion of third party links on our Websites in no way constitutes an endorsement of such websites’ content, actions or policies. 

Accuracy and requests for access and correction of personal information

We will take reasonable steps to ensure that the information we hold about you is relevant, accurate, up-to-date and complete.

You can request that we provide you with access to information we hold about you or ask us to correct any personal information we hold about you that is out-of-date, incorrect, incomplete or misleading. You can update your contact details by logging in to your account. You can also contact us by submitting a request in writing to the address set out below. If we are able to, we will action your request within a reasonable time frame (usually within 30 days) following receipt of your request.

We may decline an access or correction request in circumstances prescribed by the Privacy Act. If complying with your request for access requires considerable time and expense on our part, we may charge you a reasonable fee for providing you with information.

If we do refuse your access or correction request, we will provide you with written reasons 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.

Complaints

You may contact us at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to our Privacy Officer using the contact details set out below.

Our Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint.

Your complaint will then be investigated. 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 a reasonable time, usually 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, you may make a complaint to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

EU GDPR

How we use your personal information

We can only collect and use your personal information if we have a valid lawful reason to do so. Our reasons are:

• Consent – you have consented to our processing of your personal information for a specific purpose
• Contract – we process your personal information to fulfil a contract you have with us or, alternatively, because you have requested us to take specific steps before you enter into a contract with us
• Legitimate interests – we process your personal information for our legitimate interests (or a third party’s legitimate interests) unless the legitimate interests are overridden by a good reason to protect your personal information
• Legal obligations – we process your personal information in order for us to comply with the law (which does not include complying with contractual obligations)

Individual Rights

If you are located in the EU, you have the following additional rights:

• The right to information – you can request confirmation about the following: whether your personal information is being processed by us; the purpose of processing; the categories of personal information which are processed; the recipients (or types of recipients) who may receive the  personal information; the anticipated retention period of the personal information; and your rights to rectification, erasure, to restrict (or object) to processing and to lodge a complaint with a data protection supervisory authority in the EU.
• The right to object to our processing of your personal information for (i) direct marketing purposes; (ii) for scientific, historical research or statistical purposes; or (iii) where our processing is based on legitimate interest grounds or because it is in the public’s interest. We will respond to your objection request within a month. However, there may be some circumstances where we are not required to stop processing your personal information. If this is the case, we will provide you with a written explanation.
• The right to restrict processing – in some circumstances, you can request us to restrict our use of your personal information in which case we will not use or disclose your personal information while it is restricted. We will respond to your restriction request within a month.
• The right to erasure – you can request us to erase your personal information where it is no longer required for a purpose for which it was collected or where, for example, you have exercised successfully your right to object to processing. We will respond to your erasure request within a month.  However, where there are legal or other reasons for us to retain your personal information, we will provide you with a written explanation.
• The right to data portability – you can request us to provide you with a copy of the personal information you have provided to us. We are required to provide it to you in an electronic format that can be reused easily. You can also request us to transfer your personal information in an electronic format to another entity.

You can exercise any of these rights by contacting us using the contact details below.

You also have the right to:

• access your personal information and request the correction of your personal information (see “Accuracy and requests for access and correction of personal information” above); and
• lodge a complaint with a data protection authority if you are unhappy with the outcome of a privacy complaint. The “Complaints” section above explains our complaints handling process.  A list of EU data protection authorities is available at https://ec.europa.eu/.

Changes to our Privacy Policy

Pump Haircare reserves the right to make changes to this Privacy Policy from time to time.  If the changes are material, we will provide you with reasonable notice before the changes take effect by, for example, publishing the changes on our Websites and/or sending email notifications to our customers and stockist. We encourage you to review the Privacy Policy regularly for updates and amendments. 

Contact Details

If you have any questions or comments about this Privacy Policy, please contact us:

            The Privacy Officer

            Pump Haircare Pty Ltd

            5B Gibbes Street CHATSWOOD NSW 2067 Australia

            Australia

Email:     privacy@pumphaircare.com

            Tel:       +61403000000

Last Updated: 18 November 2020