When we use the words we, us and our we are referring to KLP Group Pty Ltd (ACN 151 427 280) trading as Rayell, DWBH and other businesses from time to time
We are committed to protecting your privacy and respecting your rights under the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act).
By accessing and using our website, products and services, you agree to and consent to the collection, use, storage and disclosure of personal information by us as set out in this Policy.
If you have any concerns about the manner in which your personal information has been collected, used or disclosed by us, we have put in place an effective mechanism and procedure for you to contact us so we can attempt to resolve the issue. We can be e-mailed at firstname.lastname@example.org or write to us 1021 Beaudesert Rd, Archerfield QLD 4108 and our Privacy Officer will then attempt to resolve the issue.
We recommend you keep this information for future reference.
What is personal information?
Personal information is information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent or can be reasonably ascertained from the information or an opinion.
What is Sensitive Information?
- Sensitive information is a subset of personal information. It means information or an opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information or biometric information.
- In general, we attempt to limit the collection of sensitive information we may collect from you. However, depending on how you use our website, products and services, this may not always be possible and we may collect sensitive information from you in order to carry out the services provided to you. In any event, we will not collect sensitive information from you without your consent.
Collection of your personal information
We only collect personal information that is necessary for what we do. The type of
information we may collect from you includes (but is not limited to) the following:
if you contact us or make an enquiry through our website, at a trade fair or with our
- your full name (first and last);
- the name of the business you own or work for;
- your email address;
- your phone number (personal and at the business where you work);
- event data, which may include your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information; and
- any other information you offer in the body of your enquiry;
for our stockists:
- your contact information such as first and last name and the e-mail address of the approved contacts in your organisation, current postal address, delivery address (if different to postal address) and phone numbers;
- if you request that we dropship to your end customer, we will also be supplied with the customer’s name, address and email;
- your opinions via surveys and questionnaires, if applicable, including but not limited to your views on the products and services we offer;
- details relating to the products and services you have obtained from us;
- if you are requesting products or services from us, then any relevant payment or billing information (including but not limited to bank account details, credit card details, billing address, payment information and invoice details); and
- credit information: bank account (including bank statements), credit or debit cards, credit worthiness checks and references;
if you are an applicant for employment with us, or engaged by us as an employee:
- details relating to your employment and performance related information (if applicable);
- contact information: such name, e-mail address, current postal and residential address, phone numbers, country of residence, next of kin contact details; and
- CV, resume or application related information: such as the details provided in your resume or CV, your eligibility to work in Australia, your education, previous employment details, professional memberships or trade qualifications;
if you are engaged by us as a contractor:
- the details listed in paragraph 3.1(c), except that references to ‘employment’ may also references to your prior engagements as a contractor, as applicable; and
- tax, superannuation and payroll information, such as your Tax File Number and ATO Declaration, ABN details, Superannuation details and financial institution details.
- if you contact us or make an enquiry through our website, at a trade fair or with our sales team:
- As much as possible or unless provided otherwise under this Policy, we will collect your information directly from you. However, you acknowledge that there may be instances where your personal information is supplied to us by another entity in our corporate group or a third party, including sales agents with whom we have a relationship.
- We may collect personal information from you when you engage in certain activities, including but not limited to when you visit our website, communicate with us, enter a contest or promotion, fill out a survey or online form, or send us feedback. It is completely optional for you to engage in these activities.
- Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. We require individuals to provide us with accurate, up-to-date and complete personal information at the time it is collected. You acknowledge that if you do not provide the mandatory data or any other information we require in order for us to provide our services to you, we may be unable to effectively provide any or all of our products and services to you.
- Due to the nature of the products and services we provide to you, it is impractical and unreasonable for us to deal with you on an anonymous basis or through use of a pseudonym. This is also the case when you make an enquiry with us, as we need to determine if you are a suitable stockist of our products.
- We only collect personal information that is necessary for what we do. The type of information we may collect from you includes (but is not limited to) the following:
Other information we collect
- We may utilise “cookies” or other similar tracking technologies on our website which enable us to monitor traffic patterns, track website usage, remember your preferences and to serve you more efficiently if you revisit the site. Cookies are small files that store information on your computer, TV, mobile phone or other device. A cookie does not identify you personally but it does identify your device to recognise you across different websites, services, devices and/or browsing sessions. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. You can disable cookies through your internet browser but, if you do so, you may not be able to fully experience the interactive features of our website, products and services.
- We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.
How we may use and disclose your personal information
- We will only use or disclose your personal information for the purposes for which it is collected or for a directly related purpose, except as otherwise consented to by you and/or as set out in this Policy.
You consent to us using and disclosing your personal information to facilitate the purpose
for which your personal information was collected, including:
- to provide any or all of our website, product and services to you;
- to administer, protect, improve or optimise our website, products and services (including to perform data analytics, conduct research, and for advertising and marketing purposes);
- to bill you for purchasing or using our website, product and services, as applicable;
- to verify your identity;
- for enquiries you submit to us, to enable us to consider and respond to your enquiry;
for our stockists:
- the creation of an account with us to process invoices;
- the provision of our services and delivery of our products to you;
- the administration and management of our products and services, including charging, billing, credit card authorisation and verification, checks for financial standing, credit-worthiness, fraud and collecting debts;
- the improvement of our services (including to contact you about those improvements and asking you to participate in surveys about the products and services);
- the maintenance and development of our products and services, business systems and infrastructure;
- marketing and promotional activities by us and our related bodies (including by direct mail, telemarketing, email, SMS and MMS messages) such as our stockist loyalty programs and newsletters;
- to ensure our stockists are not in direct competition with one another in relation to particular product ranges;
- to provide customer service functions, including handling stockist enquiries and complaints;
- to offer you updates, or other content or products and services that may be of interest to you;
- to set up your personal or business account with us, including conducting credit checks, references and authorisations (as applicable); and
- to send you or your end customer the products purchased;
for persons that apply for a role with us, employed by us or are engaged by us as
- background checks and verification of your identity;
- (upon carrying out your duties or providing services), payment of amounts due and owing to you;
- administration, performance monitoring and management; and
- to conduct or provide reference checks;
- our compliance with applicable laws;
- the sale, and matters in connection with a potential sale, of our business or company to a third party;
- any other purposes which you have consented to; and
- any other matters reasonably necessary to continue to provide our products and services to you.
We may also use or disclose your personal information for the following purposes and in
doing so we are not required to seek your additional consent:
- when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose;
- if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
- if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
- if it is required or authorised by law (including but not limited to regulatory bodies such as the Australian Securities and Investment Commission).
- In the event we propose to use or disclose such personal information other than for the purposes set out in this Policy, we will first seek your consent prior to such disclosure or use.
- If you have received communications from us and you no longer wish to receive those sorts of communications, you should contact us by e-mail at email@example.com or write to us 1021 Beaudesert Rd, Archerfield QLD 4108 and we will ensure the relevant communication ceases. Any other use or disclosure we make of your personal information will only be as required by law or as permitted by the Privacy Act or by this Policy or otherwise with your consent.
The types of organisations to which we may disclose your personal information
We may disclose your personal information to:
third parties we engage from time to time to perform functions on our behalf,
including (but not limited to):
- service providers based here and overseas, including without limitation our courier companies and service providers that help us manage our customer database, marketing material and shipping labels; and
- our contractors and agents;
- any person or entity to whom you have consented to us disclosing your personal information to;
- our related entities and subsidiaries, including our related bodies corporate (as that term is defined in the Corporations Act 2001 (Cth));
- our external advisors, auditors, lawyers, insurers and financiers; and
- as required or authorised by law, or as otherwise required by regulators or government authorities in connection with compliance procedures and obligations.
- third parties we engage from time to time to perform functions on our behalf, including (but not limited to):
- Your personal information is disclosed to these organisations and/or parties only in relation to the products or services we provide to you or for a purpose permitted by this Policy.
- We take such steps as are reasonable to ensure that these organisations and/or parties are aware of this Policy in relation to the handling of your personal information.
- We may disclose your personal information to:
- You expressly consent to us using or disclosing your personal information, including any email address you give to us, to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) when you are an individual or a business stockist of ours (Direct Marketing Communications) which we consider may be of interest to you.
- Without limiting the above, if it can be reasonably expected that we may send you Direct Marketing Communications in light of the transaction or communication you have had with us, then we may also use your personal information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.
- If at any time you do not wish to receive any further Direct Marketing Communications from us, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the email or by contacting us at firstname.lastname@example.org or write to us 1021 Beaudesert Rd, Archerfield QLD 4108.
Cross Border Disclosure
- Any personal information provided to us may be transferred to, and stored at, a destination outside Australia, including but not limited to the Philippines, United States where we may utilise third party service providers or contractors to assist us with providing our products and services to you. Personal information may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.
- By submitting your personal information to us, you expressly agree and consent to the disclosure, transfer, storing or processing of your personal information outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to personal information. You agree that, to the fullest extent allowed by law and without limiting anything else in this Policy, we exclude all liability to you and anyone else for any breach of law committed by any entity or person other than us.
- The Privacy Act requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information outside of Australia do not breach the privacy principles contained within the Privacy Act. By providing your consent, under the Privacy Act, we are not required to take such steps as may be reasonable in the circumstances.
- If you do not agree to the transfer of your personal information to a location outside of Australia, please do not supply us with your personal information, or contact us by email at email@example.com or write to us 1021 Beaudesert Rd, Archerfield QLD 4108.
Data quality and security
- We will hold your personal information for the purposes listed above, and we have taken steps to ensure the security of any personal information we hold. We primarily hold your information in an internal e-commerce system supplied by a third party, and in paper form ‘pick slips’. You acknowledge, however, that we cannot and do not guarantee the security of all transmissions or personal information. Other than liability that cannot lawfully be excluded, we will not be liable in any way in relation to any breach of security, or any unintended or unauthorised access, modification, loss, misuse or disclosure of your personal information.
Notwithstanding the above, we will take reasonable steps to:
- make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
- protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
- destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.
As the accuracy of personal information depends largely on the information you provide to
us, you agree that you are responsible for:
- notifying us in writing as soon as practicable if there are any errors in your personal information; and
- keeping us up-to-date with changes to your personal information (such as your name or address).
- Under the notifiable data breaches scheme that commenced from 22 February 2018 certain entities are required to provide the Australian Information Commission with a Notifiable Data Breach statement when an eligible data breach occurs. If an eligible data breach occurs in respect of the personal information we hold about you, we will notify you directly or publish a statement on our website.
Access to and correction of your personal information
- You are entitled to have access to any personal information relating to you which we possess, except in some exceptional circumstances provided by law. You are entitled to edit or delete such information unless we are required by law to retain it or permitted to retain it in accordance with this Policy. However, you agree that we may keep track of past transactions for our accounting and audit requirements. While we will take reasonable steps to destroy your personal information or de-identify it at your request, you acknowledge that there may be certain circumstances where it may be impossible to completely delete your information.
- Subject to applicable law, you may request to access, update, delete or correct any records of personal information we have about you, online in your own account by contacting our Privacy Officer at firstname.lastname@example.org or by writing to us 1021 Beaudesert Rd, Archerfield QLD 4108. We reserve the right to charge a reasonable fee to cover our costs in searching for, retrieving and/or providing you access to your information. We do not charge you for making the request.
Complaints and Consent
- If you wish to raise a complaint with us in regard to the way that we have handled your personal information or otherwise have any concerns, please write to us at email@example.com or write to us 1021 Beaudesert Rd, Archerfield QLD 4108. We will take steps to handle and resolve your complaint, including escalating your complaint to a person appropriate to handle it.
- This is a compliance document prescribed by law, rather than a legal contract. However certain contracts may incorporate all of part of this Policy. By using our website or by accepting the terms of one of our terms and conditions which refer to this Policy, you are agreeing to the terms of this Policy.
- If you are taken to a third party website from our website, this Policy no longer applies to your personal information.
- We reserve the right to modify our Policy as our business needs require. We will notify you of such changes (whether by direct communication or by posting a notice on our website), after which, your continued use of our products, services or website or your continued dealings with us shall be deemed to be your agreement to the modified terms.
This Policy was last updated on 11/11/2022.