Privacy Policy

Introduction
1. We are not subject to the Australian Privacy Principles (APPs), however, notwithstanding this have prepared this Policy to set out how we collect, handle and use Personal Information.
2. We reserve the right to update this Policy at any time without notice.
3. In certain circumstances we may also be subject to the EU General Data Protection Regulation (Regulation 2016/679) as it applies to residents in the European Economic Area.
Purpose
1. The purpose of this Policy is to:
  1. set out the types of information that we may collect; and
  2. how that information will be used, handled, stored and disclosed.
Application
1. This policy applies to information that we may collect about you, being the Personal Information.
2. This policy does not apply to information that may be collected by a third party or how that third party may use, handle, store or disclose your information.
Definitions
1. "Organisation" means a natural person, a body corporate, a partnership, any other unincorporated association, or a trust, that is not a small business operator, a registered political party, an agency, a state, territory or national authority or a prescribed instrumentality of a state, territory or nation.
2. "Personal Information" means:
  1. information or an opinion about an identified natural person, or a natural person who is reasonably identifiable;
  2. Order Information;
  3. Third Party Information; and
  4. Device Information.
3. "Villin, we, us, our" means Villin Limited Pty Ltd (ABN 70681808319) and its ‘related bodies corporate’ (as that term is defined and used in the Corporations Act 2001 (Cth)).
4. "Store" means our online e-commerce store at https://villin.co
Legislative Framework
1. In Australia - Privacy Act 1988 (Cth) which includes the Australian Privacy Principles set out therein, as substituted, amended, replaced or varied from time to time.
2. In the European Economic Area – for residents in the European Economic Area only, EU General Data Protection Regulation (Regulation 2016/679).

Policy

How, what and why we collect your information

We collect information about you (including, but not limited to, that information set out in the table below) that:
1. you give us directly (for example when you make a purchase or attempt to make a purchase through the Store, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers and Apple Pay, Paypal, AfterPay and zipPay details), email address, and phone number or when you communicate with us by email or through social media. We refer to this information as “Order Information”);
2. we receive from other sources (for example information we receive from business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers, search information providers, third party applications that plug into the Shopify platform and payment providers/merchants (including Apple Pay, Paypal, AfterPay and zipPay). We refer to this information as “Third Party Information”); and
3. we collect about you and your device (for example technical information, including the IP address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, cookies, operating system and platform, type of device. Additionally, as you browse the Store, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Store, and information about how you interact with the Store. We refer to this automatically collected information as “Device Information”).
4. We collect Device Information using the following technologies:
  1. “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org ;
  2. “Log files” track actions occurring on the Store, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps; and
  3. “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Store.

What information we collect	Why we might collect this information
1. Order Information	To fulfil Orders placed through our Store (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations); Provide such information to third party logistics entities to transport your Order; To communicate with you; To screen our orders for potential risk or fraud; and When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
2. Third Party Information	To process (or facilitate in the processing) of any order or purchase you make via our Store; To fulfil Orders placed through our Store (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations);
3. Device Information	To help us screen for potential risk and fraud; Improve and optimise our Store (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns); To provide you with local information and alerts about our products and services; To improve our website, goods, services and Store; To comply with local legal restrictions; To gather anonymous statistics; For analytical purposes; To ensure proper function of the website and online software; or Any other reason allowed at law.
4. Your full name, sex, date of birth, age, residential address, postal address, email address, telephone number, facsimile number and proof of identity information	To identify you and conduct appropriate identity checks; To create an account with us in order for you to make a purchase of product on our Store; To send you updates about your account; To communicate about and provide you with our current and future products and services; To send you relevant news, promotion and marketing materials, either initiated by us or a third party; To respond to your requests, questions, comments and complaints; or Any other reason allowed at law.
5. Information or opinions about your racial or ethnic origin, political opinions, or memberships, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation, or criminal record	To the extent that we consider it is necessary to provide our products and services to you or to improve the products, services and business activities that we undertake; To publish your reviews, forum posts or other content on our Store (or other website operated by us); or Any other reason allowed at law.
6. Information, communication or opinions about any of our products, services, transactions, payment history and business activities	To improve the products, services and business activities that we or an Institution undertake; or Any other reason allowed at law.
7. Identifiers (such as business number), citizenship and residency details, details regarding and information provided by your referees, details regarding and information provided by your guarantor(s) and business partner(s), financials/credit/criminal history checks, employment history, education history, identity documents	To organise credit for you with third parties such as Afterpay and zipPay; To identify you; To identify any guarantor(s); To conduct identity and criminal checks; To conduct credit checks; To assess your suitability for credit; To act as your agent; To process your application on behalf of Institutions; Any other reason allowed at law.
8. Other information	To provide you with products, services and undertake business activities; As described to you at the point of collection; or Any other reason allowed at law.

In some situations you will have the option to deal with us anonymously or through a pseudonym, however, where you are requesting products or services from us, it may become impracticable to provide those products or services to you without verifying your identity. Where you fail to provide us information or where the information provided is incomplete and/or inaccurate, or you choose not to provide us with the information that we have requested, it may affect our ability to provide you with our products and services.
In the event that we receive identifiable information from a third party, we will take reasonable steps to ensure that you have given express or implied consent to the collection of that information. If it is determined that we are unable to have possession of the information under a relevant law, we will destroy the information or ensure that the information is de-identified.

Do Not Track settings
1. Please note that we do not alter our Store’s data collection and use practices when we see a Do Not Track signal from your browser.
Sharing your personal information
1. We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use Shopify to power our online store--you can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. We also use Google Analytics to help us understand how our customers use the Store -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
2. Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.
Behavioural Advertising
1. As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work .
2. You can opt out of targeted advertising by using the links below:
3. Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.
Storing your information
1. We are a growing online business. In order to offer a consistent service to you we may store and manage data electronically or in paper form. Where data is stored electronically, it is done so by a third party cloud service provider that may store your information or a backup of your information in Australia or such other locations that the third party cloud service provider determines from time to time. The data that we collect from you may be transferred to, and be stored to these servers or processed by staff operating in these other jurisdictions.
2. The Store is hosted on the Shopify platform. Where you make a purchase from us via the Store, you are submitting your Personal Information to us via Shopify and all Personal Information will be stored and processed by Shopify. Shopify has servers in Canada and the United States of America. The data that we collect from you as a result of making a purchase with us via the Store will be transferred to, and be stored to these servers or processed by staff operating in these other jurisdictions.
3. We will take all steps reasonably necessary to ensure that your information is secured from misuse, interference, loss, unauthorised access, unauthorised modification or unauthorised disclosure. Any information will be handled in accordance with this Policy and applicable privacy laws. Despite using all steps reasonably necessary, the transmission of information through the internet is not completely secure.
4. Submission of any information to us is an acknowledgement that you agree to such use, storage and disclosure.
5. For more information on Shopify’s Privacy Policy, see https://www.shopify.com/legal/privacy .
Disclosing your information
1. We may share your information with:
  1. Shopify and its affiliated entities;
  2. third party applications to the Shopify platform;
  3. any of our ‘associates’ (as that term is defined in section 50AAA of the Corporations Act 2001 (Cth));
  4. third parties including logistic providers, business partners, suppliers and subcontractors;
  5. any prospective buyer of any part of our business or assets; or
  6. where we are required to disclose your information in order to comply with any legal obligation, or in order to enforce any agreements; or to protect the rights, property, or safety of us and our customers, or others. This includes, where relevant, exchanging information with Organisations for the purposes of fraud protection and credit risk reduction.
Accessing and correcting your information
1. You may request access to Personal Information that we hold about you at any time by contacting our Privacy Officer using the details set out in this Policy. We will respond to any such request for access to Personal Information within a reasonable time frame and will provide you access to the Personal Information that we hold pertaining to you, unless we are authorised not to do so by law.
2. We may charge you a reasonable fee for processing your request to access your Personal Information and should we decline you access to your Personal Information, a written explanation will be provided setting out the legal reasoning for doing so.
3. If upon receiving your Personal Information, or at any other time, you believe the Personal Information that we hold about you is incorrect, out of date, incomplete, irrelevant or misleading, please notify our Privacy Officer using the details set out in this Policy.
4. If we decline to correct your Personal Information as requested by you, a reason for refusal will be provided except to the extent that it is unreasonable to do so. In the event that we decline the request to correct Personal Information, you may request to associate a statement with the information.
Complaints
1. Should you believe that we have not fulfilled our obligations under any relevant law or have not complied with the terms of this Policy or would like to appeal a decision made by us in relation to your Personal Information, you can make a complaint in writing to our Privacy Officer using the contact details set out in this Policy.
2. We will respond to you within a reasonable period of time (or where a period is specified by any law, that period) to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
3. In Australia if after getting our response you are still not satisfied that your complaint has been resolved or adequately dealt with, you may direct your complaint to the Australian Information Commissioner (AIC). The contact details of the AIC are listed on their website: oaic.gov.au

General Data Protection Regulation
1. Application
  1. This clause applies to residents in the European Economic Area (EEA) only.
2. Your rights
  1. If you are a European resident, you have the right to access personal information we hold about you and to ask that your Personal Information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
  2. Additionally, if you are a European resident we note that we are processing your information in order to fulfil contracts we might have with you (for example if you make an order through the Store), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States.
3. Data retention
  1. When you place an order through the Store, we will maintain your Order Information for our records unless and until you ask us to delete this information.
4. Minors
  1. Our Store is not intended for individuals under the age of 16.
Contact
1. If you have any comments, concerns or questions regarding this Policy or Personal Information that we hold about you, please contact our Privacy Officer by email to info@villin.co or by post at: Privacy Officer, Villin,10 Nicklaus Crt, Merrimac Qld 4226, Australia