Privacy Policy
SULH – Privacy Policy
This Privacy Policy applies to the activities of SULH ABN 68 584 664 503. SULH takes the privacy of the information about customers of SULH and users of the sulh.co website (the “Site”) very seriously.
By providing your personal information (eg name, address, telephone number, email address, date of birth, gender, credit card details, country/region of residence, nationality, and any other personal information you submit to SULH) (“Personal Information”) to our representatives through our stores (including through telephone calls with in-person Client Advisers), our Customer Department or the Site, you signify your acceptance of this Privacy Policy. If you choose to collect your goods purchased online via our Click & Collect service, you agree that (i) you will produce your identity document (with your photo), your credit card and the receipt for the purchase to our in store staff, and (ii) we will collect and process your personal information contained in such documents, to enable us to conduct authentication or identity checks. Please read the following policy to understand how we will treat your Personal Information.
1. Your Personal Information is important
We recognise that your privacy is very important and SULH is committed to protecting your privacy. We will not collect and use your Personal Information as set out below unless you provide your Personal Information to us voluntarily. We will also comply with the requirements of the Australian privacy legislation.
2. Children Privacy
We do not sell or ship any items ordered through the Site directly to anyone we know to be under the age of 18. If you are under the age of 18, you should use the Site only with the involvement of a parent or guardian and should not submit any Personal Information to us.
3. Collecting Your Personal Information
We request Personal Information from you when you:
register your Personal Information for the purpose of creating an account in our site or requesting our Newsletters;
participate in a promotion or other website feature;
request a catalogue;
request to receive any marketing, promotional or other types of communications;
purchase through our store or site;
make enquiries or comments through our Customer Department;
interact with our sales staff, including through any third party apps such as WhatsApp or WeChat;
collect your goods purchased online via our Click & Collect service;
You have no obligation to provide any information requested by us. However, if you choose to withhold requested information, we may not be able to provide you with any goods and services that depend on the collection of this information (particularly where our collection of this information is required by law).
We also use tools to collect information about your activity on the Site. Please see Clause 9 for details.
4. Using Your Personal Information
SULH does not routinely disclose Personal Information, and except as otherwise set out in this Privacy Policy or as otherwise notified to you from time to time, including any collection statement, will not use or disclose any information about you without your consent, unless it is to be used for the following purposes:
to improve our understanding of your interests, concerns and preferences
to provide you with further information about our new products, events, changes to our website, service updates, special offers and promotions;
to record statistical data for marketing analysis;
to communicate with you about your purchase, account information, or customer service needs; and/or
to better respond to your customer service enquiries or provide you with a service which you have requested.
We may contact you at the email address or any other contact methods which you provide to us for the purposes listed above.
5. Marketing Opt–out
We may contact you from time to time for marketing and promotional purposes by email, mail or phone. Subject to your rights to opt out from receiving such contact, your consent is provided on an ongoing basis. If you would rather not receive any promotional or marketing correspondence from us, you can let us know and we will not contact you further for these purposes. If you wish to opt out of receiving electronic marketing and promotional messages, simply follow the unsubscribe instructions on the message that you have received. Unsubscribe requests originating from electronic messages will be honoured within five (5) working days. We will deal with all other requests as soon as reasonably possible.
Subject to Clause 7, your election not to receive promotional and marketing correspondence from us will not preclude us from: (a) corresponding with you by email or otherwise, regarding your existing or past relationship with us, (b) accessing and viewing your Personal Information in the course of maintaining and improving our database and the Site; or (c) using your Personal Information otherwise in accordance with this Privacy Policy.
6. Sharing Your Personal Information
For the purposes mentioned above and for reporting purposes, your Personal Information may be shared with our group companies either in Australia.. Also, in order to operate the website or deliver a service, your Personal Information may also be shared with service providers, suppliers and other third parties or non-SULH group companies either in Australia or overseas. We will provide our preferred service providers with the information they need to perform their services and work with them to respect and protect your Personal Information. We require our service providers to adhere to strict privacy guidelines and not to keep this information or use it for unauthorised purposes. SULH may share your data (e.g., to monitor for potential fraudulent activity and other security-related purposes) with service providers who incorporate that data into their services provided to SULH and other clients. These service providers are not permitted disclose your data to other clients.
To the extent you interact with us through third party apps such as WhatsApp, the terms of use of such apps will apply in relation to your use of the apps. SULH does not accept any responsibility for use of such apps. To the extent SULH collects personal information from you in the use of such apps, SULHwill use and handle such information in accordance with this Privacy Policy.
We may share your Personal Information with our legally affiliated entities. If SULH is merged, or in the event of a transfer of our assets, Site or operations, SULH may disclose or transfer your Personal Information in connection with such transaction.
SULH may also disclose your Personal Information where we believe it necessary to implement our terms of service or to protect the rights, property or personal safety of another SULH customer, any member of the public or SULH.
Please note also that SULH may use overseas facilities, to process or back up its information. As a result, we may transfer your personal information to these overseas facilities for storage.
By accepting this Privacy Policy, you acknowledge and consent to the disclosure of your Personal Information to overseas recipients as set out in this Clause 6. You acknowledge that if an overseas recipient handles the information in breach of the Australian Privacy Principles, SULH will not be accountable under the Privacy Act and you may not be able to seek redress under the Privacy Act or in the jurisdiction where the overseas recipient is located.
Other than as otherwise set out in this Privacy Policy, SULH will disclose specific information without your permission only when required or authorised by law, or in good faith believe that such action is necessary to investigate or protect against suspected criminal activities to our customers, visitors, associates, or property (including this Site), or to others.
7. Accessing, Modifying or Deleting Your Personal Information
If you wish to access or modify your Personal Information in our database, or update Personal Information that is inaccurate or out of date, please send your request in writing to the attention of the Privacy Officer by contacting [email protected]. We will make reasonable efforts to service your request in a timely manner. If you wish to have your Personal Information deleted, please let us know in the same manner as referred to above and we will take reasonable steps to delete it unless we need to keep it for legal reasons.
8. Protecting Your Personal Information
We will endeavour to take all reasonable steps to ensure your Personal Information is kept confidential and secure, and to take appropriate technical and organisational measures to prevent unlawful or accidental destruction, accidental loss, unauthorised disclosure or access or other unlawful forms of processing are implemented.
For users of the Site, however, please note that due to the open nature of the Internet, we cannot guarantee that any of your Personal Information stored in our servers, or transmitted to or from a user, will be free from unauthorised access, and we cannot be responsible for any theft or loss of, unauthorised access or damage to, or interception of any data or communications. By using the Site, you acknowledge that you understand and agree to assume these risks.
We will not rent, trade, distribute or sell any Personal Information that you give us to any third party unless we receive your prior consent.
9. Cookies
We use digital technologies such as cookies and other tracking tools which collect information about user interaction on the Site. Our vendors and partners may also use these tools.
For users of the Site, please note that SULH may deposit “cookies” in your computer in order to identify you. Cookies are small data text files that are sent from a server computer during a browsing session. Cookies are typically stored on the computer’s hard drive and are used by web-sites to simulate a continuous connection to the site. Security measures have been employed to prevent unauthorised access to visitor data. However, visitors acknowledge that SULH does not control the transfer of data over telecommunication facilities including the Internet. Therefore, SULH will not be responsible for any breach of security or the unauthorised disclosure or use of any such data on the Internet. You may configure your browser to reject cookies. This may mean you may not be able to take full advantage of the services on the website.
We use tracking tools on user interaction across the Site to:
· recognise new or past users;
· improve the Site, products or services;
· observe user behaviour and browsing activities over time across multiple devices;
· better understand the interests of Site visitors;
· improve user web browsing;
· help tailor advertising and promotions to users; and
· monitor for potential fraudulent activity and other security-related purposes.
These tools may collect details such as device and browser type, city geolocation based on IP address, URL, session age and how a user inputs details and user settings.
10. Registration Information
Our Site contains areas where you can submit information to us (such as our registration service), and we also have features (such as cookies and performance tracking technology) that automatically collect information from the visitors to our Site. During the registration process, you must provide us with a password, your name, address and a valid email address. It is your responsibility to keep your password strictly confidential.
11. Employee Information
Employee records are not generally subject to the Privacy Act 1988 and therefore this Privacy Policy does not apply to the handling of information about employees by SULH. For information about our practices relating to employee information please contact us directly.
12. Changes to this Privacy Policy
Our privacy practices will be continuously assessed against new technologies, business practices and our customers’ needs. As we update and diversify our services, our Privacy Policy may evolve. SULH reserves the right to change its Privacy Policy at any time and notify you by posting an updated version of the policy on the website. The amended Privacy Policy will apply between us whether or not we have given you specific notice of any change. Please check this page for updates on our Privacy Policy periodically.
13. Problems, queries or complaints
If you have any queries relating to our Privacy Policy, please send your request in writing to the attention of the Privacy Officer via email at [email protected].
You may also contact us at the details above if you have a complaint about how we have handled your information. We will investigate your complaint and will use reasonable endeavours to respond to you in writing as soon as possible. If we fail to respond to your complaint within a reasonable time or if you are dissatisfied with the response that you receive from us, you may have the right to make a complaint to the Office of the Information Commissioner.