Introduction

FashionLine Group Pty Ltd ABN 39 051 967 116 (FashionLine, the Group, we, us, our) is committed to complying with applicable privacy laws in relation to the personal information that we collect in the course of running our business.

FashionLine is an industry peer group for independent window furnishing businesses. Our members (Members) are separate businesses that participate in the Group.

This Privacy Policy applies to everyone whose personal information we handle. In practice, this includes:

• members of the public, most commonly people who enter a competition or trade promotion we run, and anyone who contacts us, visits our Website or otherwise deals with us; and
• Members and their personnel, with whom we have an ongoing relationship in operating the peer group.

If you have entered one of our trade promotions, section 7 sets out specifically how we handle your information, including that we collect it both to run the promotion and on behalf of the Member you are dealing with. Section 6 explains how information is shared with Members and how their own privacy policies apply. The rest of this Privacy Policy applies to you regardless of which of the above describes you.

Please take a moment to read our Privacy Policy as it explains:

• how we collect and handle personal information; and
• your rights in relation to any of your personal information that we hold about you.

We may, in connection with particular activities, events or services we offer or provide to you, make other privacy disclosures to you or seek your authority to use your personal information in ways which are different from or more specific than those stated in this Privacy Policy. In the event of any inconsistency between the provisions of this Privacy Policy and those other disclosures, the other disclosures will apply. Where applicable privacy laws provide for exceptions or exemptions, we may rely on those exceptions or exemptions in our information handling practices.

This Privacy Policy (other than section 13) explains how we manage personal information about individuals other than employees. Section 13 explains the position of employees.

We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you. An up-to-date copy of our Privacy Policy is available on our Website.

Key definitions

In this document:

• “APPs” means the Australian Privacy Principles set out in the Privacy Act;
• “Member” means an independent business that participates in the FashionLine peer group, and includes that business’s owners, personnel and representatives;
• “personal information” has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise;
• “Privacy Act” means the Privacy Act 1988 (Cth); and
• “sensitive information” has the meaning set out in the Privacy Act, and includes certain specific types of personal information such as health information, and information about a person’s racial or ethnic origin, sexual orientation or practices, criminal record, religious beliefs or affiliations, political opinions, membership of a political, professional or trade association, and biometric and genetic information.

1. How we collect your personal information

We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way.

Some of the common ways in which we may receive personal information directly from you include:

• when you enter, or make an enquiry about, a competition or trade promotion we run, including through an entry form on our Website or at an event;
• when you make an inquiry or request in relation to our activities or services, including through our Website;
• from correspondence (whether in writing or electronically) or when you contact us via telephone, e-mail, social media platforms or other means;
• when you complete any registration, online surveys, and other online forms of ours that ask you to provide your name, email address, other contact information, business details, optional demographic information, images, interests, feedback, rating and voting;
• when you upload content to or interact (in an identifiable manner) with our Website or our social media pages;
• when you apply for, or enquire about, membership of FashionLine;
• when you register for, attend or participate in our meetings, sessions, events, workshops or peer group activities;
• when you enter into contracts, agreements or arrangements with us;
• in administering and performing any contracts with service providers;
• when you apply for a role with us;
• while conducting satisfaction and market research surveys;
• if you attend any of our premises or events, we may record certain contact details so that we can comply with applicable laws, and we may also record your image and/or voice if we have surveillance or recording systems operating at those premises or events;
• when administering any of our activities; and
• as otherwise required to manage our business.

Where it is reasonably practical to do so, we will collect your personal information directly from you. However, in certain cases we may collect personal information from publicly available sources and third parties, such as our Members, suppliers, recruitment agencies, your employer, contractors, referees, government bodies (e.g. police checks, if required), academic and professional bodies (e.g. to validate details and currency of qualifications).

If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.

2. Types of personal information we collect

The types of personal information we collect about you depends on the circumstances in which the information is collected. Typically, the types of personal information we may collect can include (but is not limited to) your name, address, email address, phone numbers and IP address. Where you are dealing with us as a Member or in a business capacity, this may also include your business name and role.

If you enter a competition or trade promotion we run, we will typically collect your name, contact details (such as email address, phone number and postal address) and your entry details.

If we enter into contracts with you, or you participate in our activities or have any other commercial dealings with us, we may also collect your signature, credit card and/or banking details, and billing information.

If you are an individual contractor to us or apply for a role with us, we may also collect information relevant to your engagement with us including qualifications, Australian Business Number, details of your insurance policies, length of engagement, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment (e.g. phones, computers and vehicles).

If we need to confirm your identity, we may collect a copy of appropriate identification.

If you access our Website, we may:

• utilise cookies to collect additional information about your use of our Website, such as your internet protocol (IP) address, device information, browser information, and details on your usage. Please see the cookies section below for further details; and
• if you have provided us with permission to access your device location when using our Website, we may collect information about your geographical location.

If you contact us via telephone or other audio/video channels, we may monitor and record those conversations for staff training, quality assurance, and record-keeping purposes.

Where our meetings, sessions or events are held via video or audio conferencing, we may record those sessions for the purposes of quality assurance, member education, minute-taking and record-keeping. Where we intend to record, we will make reasonable efforts to notify participants in advance.

If you do provide sensitive information to us for any reason (for example, if you provide us with information about a health condition, injury or disability you have), you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.

In addition to the types of personal information identified above, we may collect personal information as otherwise permitted or required by law.

Where you do not wish to provide us with your personal information, we may not be able to provide you with membership, or requested services and/or certain functionality of our Website.

3. Our purposes for handling your personal information

As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.

We may use or disclose your personal information:

• for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
• for other purposes to which you have consented; and
• as otherwise authorised or required by law.

In general we collect, use and disclose your personal information so that we can run our activities (including our competitions and trade promotions), operate the peer group, and for purposes connected with our business operations.

Some of the specific purposes for which we collect, hold, use and disclose personal information are as follows:

• To facilitate your entry and participation in a competition or trade promotion, including conducting the draw, notifying winners, awarding prizes and meeting our permit obligations;
• To respond to your request or query made via our Website or other means;
• To operate, monitor, develop and improve our Website and our activities and services;
• To confirm your identity;
• To optimise and customise the user experience for users of the Website;
• To facilitate communications via our Website and our social media platforms;
• To contact you (directly or through our service providers and marketing research agencies) to obtain your feedback and to find out your level of satisfaction with our activities and services;
• To keep you informed of the activities and services we offer;
• To facilitate the sharing of information, insights and support between Members (see section 6);
• To provide you with our services and to receive services from you;
• To consider you for a job (whether as an employee or contractor) or other relationships with us;
• To provide you with tax invoices for membership fees and other charges;
• To protect the security and integrity of our Website and services;
• To comply with our legal and regulatory obligations;
• To protect the security, health and safety of our premises, facilities, personnel and visitors;
• To address any issues or complaints that we or you have regarding our relationship; and
• To contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.

4. Who we disclose your personal information to

We may disclose your personal information in accordance with any consent you give or where disclosure is authorised, compelled or permitted by law.

If we disclose information to a third party who is handling it on our behalf, we generally require that the third party protect your information to the same extent that we do.

If you post information to certain public parts of our Website or to our social media pages, you acknowledge that such information may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.

We may disclose your personal information to third parties in connection with the purposes described in section 3 of this Privacy Policy. This may include disclosing your personal information to the following types of third parties:

• Our Members, in accordance with section 6 of this Privacy Policy;
• Our suppliers, contractors and organisations that provide us with technical and support services or who manage some of our business functions;
• Our accountants, insurers, lawyers, auditors and other professional advisers;
• Any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees);
• In the unlikely event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors; and
• Debt collection agencies.

5. Storage and protection of personal information

We will hold personal information as either secure physical records, electronically on our systems, in cloud storage, and in some cases, records on third party servers.

We take reasonable steps to ensure the security of your personal information and have put in place reasonable security measures to prevent loss, misuse, or unauthorised access and alterations to personal information under our control. We use a range of security measures to protect the personal information we hold, including by implementing IT security tools to protect our electronic databases. However, we cannot and do not guarantee that unauthorised access to your personal information will not occur.

We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law. We may need to retain records containing personal information to comply with record keeping obligations, and for other legitimate business purposes (such as quality assurance).

6. Sharing of Information with our Members

FashionLine is a peer group made up of independent Member businesses. The nature of the Group means that information, including some personal information, is shared between FashionLine and its Members, and between Members, as part of the normal operation of the peer group.

Examples of information sharing that may occur include:

• member contact details and business information circulated within the Group to enable Members to connect and collaborate;
• materials, presentations, benchmarking data, insights and discussion shared during meetings, sessions and events;
• feedback, case studies and examples shared by Members with one another for mutual learning and support; and
• photos, recordings and minutes of meetings, sessions and events circulated to participants and Members.

Each Member’s obligations in relation to privacy and the handling of personal information they receive through their participation in FashionLine, including the treatment of confidential information shared within the Group, are dealt with in the Member Agreement between FashionLine and that Member.

Each Member is a separate business and operates its own website and its own privacy policy. When a Member handles personal information in the course of its own business (rather than as part of FashionLine activities), that information is handled under the Member’s own privacy policy and not this Privacy Policy. Member privacy policies are the responsibility of each Member, are separate from this Privacy Policy, and may be updated by the relevant Member from time to time without notice to you.

Access to a Member’s privacy policy can generally be found via that Member’s own website. 

We make no representations or warranties in relation to the privacy practices of any Member, and we are not responsible for the privacy policies or the content of any Member’s website or business. Each Member is responsible for informing you about its own privacy practices and procedures. We encourage you to review the relevant Member’s privacy policy before providing personal information to that Member.

7. Trade promotions and information collected on behalf of Members

FashionLine does not generally deal directly with members of the public in the ordinary course of running the peer group. The main circumstance in which we collect personal information from a consumer is when they enter a competition or trade promotion that we run.

When you enter one of our trade promotions, the personal information we collect typically includes your name, contact details (such as email address, phone number and postal address) and your entry details.

We collect and use this information for two related purposes:

• To administer the promotion. FashionLine runs the promotion, including conducting the draw, contacting and notifying winners, awarding prizes, and complying with our legal and permit obligations across the relevant states and territories. We handle your information in our own right for these purposes and may retain it for as long as required to meet those obligations.
• On behalf of the relevant Member. We also collect your information on behalf of the Member you are dealing with in connection with the promotion, and we may provide your information to that Member. Once your information is held by that Member, the Member handles it in its own right under the Member’s own privacy policy, which is separate from this Privacy Policy and may be updated by the Member from time to time (see section 6).

Any ongoing relationship you have as a customer, and any further marketing to you following a promotion, is a matter between you and the relevant Member and is governed by that Member’s own privacy policy. If you do not wish to receive marketing from a Member, or you wish to access or correct the information a Member holds about you, you should contact that Member directly.

If you have questions about how FashionLine handles information collected through a trade promotion, please contact our Privacy Officer (see section 17).

8. Our marketing and advertising activities

8.1 Overview

Like most businesses, marketing and advertising is important to our continued success. We therefore like to stay in touch with Members and interested parties and let them know about new offers and opportunities.

We may provide you with information and advertisements about activities, services and promotions either from us, or from third parties which may be of interest to you, where:

• you have asked us to (or have otherwise consented to us doing so); or
• it is otherwise permitted by law.

8.2 Direct marketing

We conduct direct marketing through various channels, including over the phone and by e-mail, SMS and post.

If you would like us to stop sending you direct marketing communications, you can request this by contacting our Privacy Officer (see contact details in section 17 of this Privacy Policy). Alternatively, if we have contacted you by email or SMS, you may use the unsubscribe function in that message to notify us that you do not wish to receive further marketing information from us.

Please note that there are certain types of communications that you may not be able to opt-out from, such as communications that we are required or permitted by law to send you, and communications necessary to administer your membership.

8.3 E-mail analytics

Like many organisations, we use e-mail analytics to track and measure the success of our e-mail newsletters and other e-mail campaigns.

We use various technologies (such as tracking pixels) to collect information such as: which of our emails you have opened, which links you have clicked, which email client you are using, whether you opened our e-mail on a computer or mobile device, and the geolocation of your IP address. We use this data to analyse and improve the performance of our e-mail campaigns.

8.4 Internet advertising

This section applies to visitors to our Website and to our marketing to Members and other businesses interested in the Group. It does not apply to personal information collected from entrants in our trade promotions, which is handled as described in section 7 and is not used by us for the online targeted advertising described below.

We may also collect and use information about you for the purposes of online targeted advertising services that help our ads to reach you (and other people who may be interested in our activities and services) on websites, apps and social media platforms across the Internet. These online targeted advertising services are operated by third party vendors, such as Facebook, Instagram, Google and LinkedIn.

Some of these services work by using non-identifying data about your behaviour and demographics that has been collected through cookies and other tracking technologies (such as pixels and device identifiers) when you use the Internet, including when you move between different websites and apps and use different devices. For example, third-party vendors may use cookies and/or device identifiers to serve ads based on your past visits to our Website. Your browser or device may provide you with the option to disable or opt-out of some of these cookies and other tracking technologies (such as device identifiers).

The data that is collected through these cookies and other tracking technologies may be combined with other data (supplied by our advertising service provider, or third parties) to improve the targeting and serving of ads.

Our online advertising service providers also help us by measuring the effectiveness of our ad campaigns (e.g. conversion tracking) and providing us with analytics data that we use to inform and optimise our ad campaigns. These analytics are based on data that may be collected through cookies and other tracking technologies. The analytics data we receive is generally aggregated and non-identifying.

When we use any advertising service that requires us to use or disclose your personal information, we will only do so if we are permitted to do so by applicable privacy laws. You can notify us at any time if you would like us to stop using your personal information for these targeted advertising purposes. Our contact details are set out in section 17 of this Privacy Policy.

You can also:

• Opt-out of certain online targeted advertising networks directly by visiting the Digital Advertising Alliance’s opt-out portal at http://optout.aboutads.info/; and the Network Advertising Initiative’s opt-out page at http://www.networkadvertising.org/managing/opt_out.asp;
• view the relevant social media platform’s website to learn more about how they collect and use your information and adjust your preferences regarding the types of advertising you are shown.

9. Use of Artificial Intelligence (AI) Tools

We may use artificial intelligence (AI) tools and platforms in the course of operating our business. This includes AI-assisted tools for tasks such as drafting communications, analysing data, improving service delivery, and supporting our internal operations.

Where personal information is processed through AI tools, we take reasonable steps to ensure that:

• the AI tools we use are operated by reputable providers with appropriate data handling and security standards;
• personal information shared with or processed by AI tools is limited to what is reasonably necessary for the relevant purpose;
• personal information is not used to train third-party AI models without your consent, to the extent this is within our control; and
• our use of AI tools complies with applicable privacy laws, including the Australian Privacy Principles.

AI tools may occasionally generate outputs that are inaccurate or incomplete. We do not rely solely on AI-generated outputs for decisions that materially affect individuals. Where AI is used to assist in communications or assessments, a human review step is applied where reasonably practicable.

If you have questions about how we use AI in handling your personal information, please contact our Privacy Officer (see section 17).

10. Cookies

A cookie is a small text file stored in your computer’s memory or on your hard disk for a pre-defined period of time. We use cookies to identify specific machines in order to collect aggregate information on how visitors are experiencing the Website. This information will help to better adapt the Website to suit personal requirements, and diagnose problems with our services or the Website. While cookies allow a computer to be identified, they do not permit any reference to a specific individual. For information on cookie settings of your internet browser, please refer to your browser’s manual.

We may use third party vendors to show our ads on sites on the Internet and serve these ads based on a user’s prior visits to our Website and other internet activity. We may also use analytics data supplied by these vendors to inform and optimise our ad campaigns based on your prior visits to our Website. We do not have access to or control over information collected by outside advertisers on our Website.

If you choose to disable this function, your experience on the Website may be diminished and some features may not work as they were intended.

If you access our Website with your mobile device, we may also collect device-specific information such as device type, operating system, universally unique identifiers (UUID) and device tokens that allow us to diagnose issues and send device-specific notifications. You may also elect to share other information automatically such as geolocation.

11. Accessing and correcting your personal information

We endeavour to ensure that the personal information we hold is accurate and up-to-date. We realise that such information changes frequently with changes of address and other personal circumstances.

You may contact our Privacy Officer (see section 17) to change your contact details, to request access to the personal information that we hold about you and/or to make corrections to that information, at any time.

On the rare occasions when we refuse access (which we will only do in accordance with applicable laws), we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to the personal information we hold about you.

We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.

We will respond to all requests for access to or correction of personal information within a reasonable time.

If you entered a trade promotion and your information has been provided to a Member (see section 7), that Member holds its own copy of your information under its own privacy policy. To access or correct the information a Member holds about you, you will need to contact that Member directly.

12. Overseas transfers of personal information

Some of the third parties to whom we disclose personal information may be located outside Australia. The countries in which such third party recipients are located depend on the circumstances. In the ordinary course of business we commonly disclose personal information to support staff located in India and the Philippines.

From time to time we may also engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider.

Whenever we transfer your personal information outside of Australia, we will do so in accordance with the requirements of applicable privacy and data protection laws. We may disclose your personal information to an overseas recipient without your consent where permitted by the Privacy Act (and, in such circumstances, we will comply with the applicable requirements of the Privacy Act in doing so).

13. Employees

We collect information in relation to employees as part of their job application and during the course of their employment, either from the employee directly or, in some cases, from third parties such as recruitment agencies, referees, government bodies (e.g. police checks, if required) and academic and professional bodies (e.g. to validate details and currency of qualifications).

The information we collect may include contact details, qualifications, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors and training records.

We may also collect details of disabilities, allergies and health issues that may impact the employee’s role, or which arise while on our premises or in the performance of the employee’s duties, so we can accommodate and otherwise assist the employee with any such health requirements or incidents.

We collect camera/video footage of employees while on our premises (via CCTV), recordings of telephone calls and interactions for training and quality assurance purposes, and logs of the employee’s usage of our equipment (e.g. phones, computers and vehicles) on a continuous and ongoing basis using various technologies, including monitoring:

• email, internet and network use; and
• the location of our vehicles and other equipment via GPS.

Under the Privacy Act, personal information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship. We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.

14. Links

Our Website may contain links to other websites and interactive forums such as messaging channels, message boards and chat rooms operated by third parties, including our Members. We make no representations or warranties in relation to privacy practices of any third party forum or website and we are not responsible for the privacy policies or the content of any third party forum or website. Third party forums and websites are responsible for informing you about their own privacy practices and procedures.

15. Social media platforms

We use social media platforms such as Facebook, Google, Instagram and LinkedIn to communicate with the public about our activities and the Group. We may collect the information that you choose to share with us through these platforms, including photos, videos and comments and posts, check-ins and activities on and across our Website. We may use this information to sort and filter information to tailor user experience.

These social media platforms have their own privacy policies, and may handle your information for their own purposes. You can access the privacy policies and set your preferred privacy settings for these platforms by visiting their websites.

16. Resolving personal information concerns

If you have any questions, concerns or complaints about this Privacy Policy or how we handle your personal information, including if you believe we have breached the APPs, please contact our Privacy Officer (see section 17).

When contacting us please provide as much detail as possible in relation to your question, concern or complaint.

We take all complaints seriously and will respond to your complaint in accordance with any applicable timeframes imposed by law and otherwise within a reasonable period. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5288, Sydney NSW 2001

Telephone: 1300 363 992

Email: [email protected]

17. Contact details of Privacy Officer

The contact details for our Privacy Officer are as follows:

Email: [email protected]