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Privacy Policy – Australia

LAST UPDATED: January 2021

This privacy policy (Policy) applies to AirRobe Pty Ltd (ACN 628 335 713) and their affiliates and related companies, (together, AirRobe, we, us or our), and details how we collect, manage and use Personal Information, including but not limited to Personal Information collected on our websites, online marketplace, mobile applications, via email, cloud-based services, or controlled widgets embedded in communication platforms with a link to this Policy (Websites). By Personal Information we mean information that is associated with a specific person and can be used to reasonably identify that person. Personal information does not include information that has been made anonymous, and cannot reasonably identify a specific person. It covers how we collect, use, and share that Personal Information as of the date that this Policy is posted.

AirRobe is committed to respecting the privacy of your Personal Information. We appreciate the importance of Personal Information being secure and we are committed to protecting any Personal Information that comes into our custody or control. AirRobe is subject to the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).

AirRobe’s retailers (which may include online market places), third party suppliers and commercial partners (together, our Partners) are independent of AirRobe and may have privacy policies which differ from ours. Our Partners are responsible for their own privacy policies and privacy practices. Please contact our Partners directly for further information on their privacy policies.

The Websites may contain links to third party websites. These linked sites are not under our control and we are not responsible for content on these sites, nor are these sites subject to this Policy. Before disclosing your personal information on any third party website we recommend that you examine any terms and conditions and privacy policy relating to that particular site.

This Policy applies when you sign up for, access, or use our marketplace, services, features, technologies, functions or purchase goods and services offered on our Websites (collectively, AirRobe Services) and in relation to Personal Information we may otherwise collect during the course of our business as set out in this Policy.

AirRobe may amend this Policy at any time. The updated version will be available by following the ‘Privacy’ link on the Websites. The updated Policy will be effective on and from the time we post it on the Websites. AirRobe may highlight any material changes to the Policy that may impact you by notifying you by email or otherwise.

Collecting Personal Information

AirRobe strives to be fair and open about the way we collect information about you and what we intend to do with such information.

We receive and store certain types of information from you when you interact with our Websites to deliver the products and services you request from us, and help improve your overall online experience. For example, like many other websites, we store cookies and other web-based files on user-devices to get certain types of information when your web browser, mobile phone, or other device accesses our Websites. The information sent to us may include data on the pages you access, your computer IP address, device identifiers, the type of operating system you are using, your location, mobile network information, standard web log data and other information. Web log data includes the browser type you are using and traffic to and from our site. When you visit our Websites or use AirRobe Services, we may also collect information about your transactions and your activities. Details on our collection of Personal Information using cookies and analytical services is set out below.

In addition, if you open an AirRobe account with us or use AirRobe Services, we may collect the following types of information:

• Contact information, such as your name, address (including your geolocation), phone number and email.
• Financial information, such as the full bank account numbers and/or credit or debit card numbers that you link to your AirRobe account or give us when you use AirRobe Services.
• Detailed Personal Information such as your date of birth, driver license number, or other identification information or documents.

We may also obtain information about you from third parties including our Partners and related companies.

You may choose to provide us with access to certain Personal Information stored by third parties such as social media sites (e.g., Instagram and Twitter). The information we may receive varies by site and is in each case controlled by that site. By associating an account managed by a third party with your AirRobe account and authorising AirRobe to have access to this information, you agree that AirRobe may collect, store and use this information in accordance with this Policy.

We may also collect your Personal Information if you enter a competition or promotion we run (either directly or through our marketing agents or our Partners), or if you apply for employment with us either directly or through a recruitment or employment agency.

We may collect Personal Information about our Partners’ staff directly from those staff or from our Partners. The information we collect about our Partners’ staff may include your name, position, contact details and training records.

We may also collect the Personal Information of our suppliers and service providers’ staff during the course of our business activities. This information may include your name, contact details and position. We will collect this information directly from you, or from the applicable supplier or service provider.

In order to help protect you from fraud and misuse of your Personal Information, we may collect information about your use and interaction with our Websites or AirRobe Services. For example, we may evaluate your computer, mobile phone or other device to identify any malicious software or activity.

We may also collect additional information from or about you in other ways, such as through contact with our customer support team, suppliers or service providers (whether via mail, email or through telephone enquiries), your responses to a market survey, and from interactions with our Partners or as otherwise notified to you at the time.

Use of Personal Information

AirRobe only collects, holds and handles information about you that is necessary for us to perform the services you request from us, that is otherwise reasonably necessary for our business activities or if required by law, court, or tribunal order.

We may use Personal Information we collect about you for a number of purposes including:

• providing (or assessing whether to provide) AirRobe Services;
• processing transactions for the delivery of third party goods or services available through our Websites;
• customer support;
• processing transactions and sending notifications about your transactions;
• resolving disputes, collecting fees and troubleshooting problems;
• investigating and preventing potentially prohibited or illegal activities;
• enforcing our Terms of Use Agreement with you;
• learn more about your level of satisfaction, your expectations of us and our Partners, and how we can meet them;
• customise, measure, and improve AirRobe Services and the content, layout, and operation of our Websites;
• deliver targeted marketing, service update notices, and promotional offers based on your communication preferences;
• contact you via telephone, SMS or email messaging, including as authorised by our Terms of Use Agreement;
• compare information for accuracy and verify it with third parties;
• confirm your identity for the purposes of anti-money laundering and counter-terrorism laws and assess applications and your suitability for AirRobe Services;
• to consider you for a position at AirRobe for which you have applied;
• to acquire goods or services from you or from your employer;
• for the purpose of performing data analytics including to improve our and our Partners’ services;
• for other purposes to which you have consented; and
• as required or permitted by relevant laws and regulations.

You agree that we may use your Personal Information for the purposes for which we collect it and for related purposes which would be reasonably expected by you.

If all or some of your Personal Information is not collected or cannot be verified, we may be unable to provide you with AirRobe Services or a customised experience, engage with you, or do business with you.

How we share Personal Information

We may share your Personal Information with:

• our affiliates and related companies;
• our Partners and the suppliers and service providers who help with our business operations including in relation to fraud prevention, identity verification, payment collection, marketing, customer service, and technology services;
• our retailers and third party suppliers, so that they can provide goods or services to you (or the recipient of third party goods or services) or respond to a complaint by you, or to help them improve the quality and standard of service they provide to you. If you transact with a retailer in another country, we will disclose personal information to such locations.
• financial institutions that we may partner with to jointly create and offer a product;
• companies that we plan to merge with or be acquired by or who may invest in us;
• law enforcement, government agencies or officials, or other third parties pursuant to a subpoena, court order, or other legal process or requirement applicable to AirRobe; when we need to do so to comply with law; or when we believe, in our sole discretion, that the disclosure of Personal Information is necessary to prevent physical harm or financial loss or to report suspected illegal activity;
• your nominated referees so that we may check your references if you are applying for a position with AirRobe; and
• other third parties with your consent or direction to do so.

Please note that these third parties may be in other countries where the laws on processing Personal Information may be less rigorous than in your jurisdiction. When we disclose your Personal Information overseas, we will take all reasonable measures to ensure that your information is held, managed and accessed in accordance with appropriate standards for the handling of Personal Information.

We will only share your Personal Information with third parties as described in this Policy or as otherwise notified to you at the time of collection or with your consent.

If you open an AirRobe account directly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on AirRobe’s Websites) will be shared with the owner of the third party website or application. These sites are governed by their own privacy policies and you are encouraged to review their privacy policies before providing them with Personal Information. AirRobe is not responsible for the content or information practices of such third parties.

Consent

We may require your consent to use and/or disclose your Personal Information if we need to use your information for a purpose that is not related to the purpose for which it was collected.

If you do not consent to AirRobe collecting, using and/or disclosing your Personal Information for such other purposes, this may affect AirRobe’s ability to deliver and improve our products and services, or to engage or do business with you.

Marketing and privacy

AirRobe may send marketing materials from time to time to those who have provided AirRobe with Personal Information about products and services offered by AirRobe and our Partners.

If you signed up to receive newsletters or other marketing communications from us, you can opt-out any time by clicking the unsubscribe link at the bottom of the message. You can also log-in to your account to opt-out and update your preferences at any time.

Even after you opt-out or update your marketing preferences, please allow us sufficient time to process your marketing preferences. Unless otherwise required to process your requests earlier by law, it may take up to 5 days to process your opt out requests in relation to receipt of electronic marketing materials such as emails and SMS, and up to 30 days for all other marketing-related requests.

Even after you opt-out of receiving marketing communications from us, we may still contact you for transactional or informational purposes. These include, for example, customer service issues, returns or product-related inquiries, outstanding payment inquiries, surveys or recalls, or any questions regarding a specific order.

You may also contact us on:

Email: hello@airrobe.com Mail: 710 Collins Street, Docklands, VIC 3008, Australia

Controlling Our Tracking Tools

Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie. Certain browsers can be set to reject all browser cookies. If you configure your computer to block all cookies, you may disrupt certain web page features, and limit the functionality we can provide when you visit or use our Websites. If you block or delete cookies, not all of the tracking that we have described in this policy will stop. If you continue without changing your settings, we will assume that you are happy to receive all cookies on this Website. You can change your cookie settings at any time.

Cookies and third party analytical services

We use cookies and track IP addresses via our Websites so we can improve our services provided by our Websites and enhance your user experience. When you access our Websites or use AirRobe Services, we (including our Partners and companies we work with) may place small data files on your computer or other device. These data files may be cookies, pixel tags, “Flash cookies,” or other local storage provided by your browser or associated applications (collectively, Cookies). We use Cookies to ascertain which web pages are visited and how often, to make our Websites more user friendly, to give you a better experience when you return to a website and to target advertising to you that we think you may be interested in. For example, Cookies allow us to save your password so you do not have to re-enter it every time you visit our site. Most web browsers automatically accept Cookies. You are free to decline our Cookies if your browser or browser add-on permits, unless our Cookies are required to prevent fraud or ensure the security of websites we control. However, declining our Cookies may interfere with your use of our Websites and AirRobe Services.

Controlling Online Interest-Based Ads

We sometimes work with online advertising vendors to provide you with relevant and useful ads. This may include ads served on or through our Websites. This may also include ads served on other companies’ websites. These ads may be based on information collected by us or third parties. For example, your postal code may be used to target an ad for people in your area. These ads may also be based on your activities on our Websites or on third party websites.

Our Websites also use Google Analytics, a web analysis service of Google Inc. (Google). Google Analytics uses Cookies to monitor traffic to, and use of, the Websites. Information about the use of the Websites generated by these Cookies is generally transferred to a Google server in the USA and stored there. Google uses this information on our behalf to evaluate your Website usage, to compile reports on the Websites activities, and to provide additional services connected with the Websites. We will not identify you to Google, and will not merge personal and non-personal information collected through this service. You can prevent the use of Google Analytics Cookies by adjusting the settings on your browser software, however, you may not be able to fully use all of the functions of the Websites if you do so.

We may also use other third-party analytics tools to monitor, analyse and collect information about your use of the Websites. Users may prevent Google’s collection of data generated by your use of the Websites (including your IP address) by downloading and installing a Browser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

Protecting Personal Information

AirRobe will keep your Personal Information secure by taking reasonable steps to protect it from misuse, loss, and unauthorised access, use, modification, and disclosure. We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. We also review our security procedures periodically to consider appropriate new technology and updated methods. Only properly authorised people who have a need to access Personal Information to perform their job will be able to see or use that information. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable.

Accessing and requesting correction of Personal Information

We will strive to ensure that information about you is accurate when we collect or use it. Subject to some exceptions under privacy law, we will let you see the information we hold about you and correct it if it is inaccurate, incomplete or out-of-date. If we do not grant you access to your Personal Information or do not agree to correct your Personal Information we will tell you why.

If you wish to obtain access to and/or correct your Personal Information held by AirRobe, please contact AirRobe on:

Email: hello@airrobe.com Mail: 710 Collins Street, Docklands, VIC 3008, Australia

For California residents: California Civil Code (section 1798.83) gives AirRobe customers who are California residents the right to request certain information about our disclosure of Personal Information to third parties for their own direct marketing purposes. If you wish to make this request, please e-mail or write to us at the address provided above.

Unless we do not agree to your request for access to Personal Information, in most cases AirRobe will provide you with access as soon as reasonably possible following receipt of your request. If you request corrections to your Personal Information and AirRobe agrees with your request, these changes will be made as soon as practicable. If AirRobe does not agree to your request for correction, it will notify you of the reasons it does not agree and will note your request on the records it holds about you. If you are dissatisfied with our refusal to provide you with access to, or correct, your Personal Information you may also complain to the applicable regulator in your jurisdiction.

Subject to the terms set out in the AirRobe Terms of Use Agreement, you can also close your AirRobe account through our Websites. If you close your AirRobe account, we may retain information from your account for a period of time to resolve disputes, troubleshoot problems, assist with any investigations, prevent fraud or risk, enforce our Terms of Use Agreement, or take other actions as required or permitted by law.

Resolving your concerns

If you have a complaint regarding AirRobe’s management of your Personal Information, please prepare your complaint in writing and email it to us at hello@airrobe.com.