LENOXX ELECTRONICS PRIVACY POLICY
This Privacy Policy sets out the approach which Lenoxx
Electronics will take in relation to the treatment of
Personal Information. It includes information on how
Lenoxx Electronics collects, uses, discloses and keeps
secure, individuals' Personal Information. It also covers
how Lenoxx Electronics makes the Personal Information
it holds available for access to and correction by the
individual.
This policy has been drafted having regard to Lenoxx
Electronics’ obligations under the Privacy Act
1988 (including the new National Privacy Principles)
(the Privacy Act).
This Policy is a public document and has been prepared
in light of National Privacy Principle 5, Openness.
1. COLLECTION
1.1 Lenoxx Electronics will only collect Personal Information
where the information is necessary for Lenoxx Electronics
to perform one or more of its functions or activities.
In this context, "collect" means gather,
acquire or obtain by any means, information in circumstances
where the individual is identifiable or identified.
1.2 Lenoxx Electronics collects Personal Information
primarily to supply customers with the products and services
ordered from it and its related companies. Lenoxx Electronics
also collects and uses Personal Information for secondary
purposes including:
billing and account management
business planning and product development; and
to provide individuals with information about promotions,
as well as the products and services of Lenoxx Electronics
affiliated companies and other organizations.
to enhance the online shopping experience by displaying
products and/or services that match the personal preferences
of individuals based on their previous website browsing
history and/or buying activity.
1.3 Lenoxx Electronics will not collect Sensitive Information
from individuals except with consent and only where it
is necessary for Lenoxx Electronics to collect such information
for an activity or function.
1.4 Lenoxx Electronics will not collect Personal Information
secretly or in an underhanded way.
1.5 Lenoxx Electronics will take steps to ensure that
individuals on purchased lists are or have been notified
of the information as outlined at 1.3.
2. USE
2.1 Lenoxx Electronics will obtain an individual's consent
for Use of non-sensitive Personal Information for Secondary
Purposes at the time of collection, unless the Use
is a related Secondary Purpose that would be within
the relevant individual's Reasonable Expectations.
2.2 Lenoxx Electronics Uses Personal Information primarily
for the purposes listed in 1.2 above.
2.3 If Lenoxx Electronics relies on the Direct Marketing
exception to Direct Market to individuals it will ensure
that:
the individual is clearly notified of their right to
Opt Out from further Direct Marketing;
there is only one Use of the information before the Opt
Out right is given and this Use applies across all Lenoxx
Electronics Related Bodies Corporate (if the information
is shared between those Related Bodies Corporate);
the individual is given an Opt Out in all further instances
of Direct Marketing if they have not previously chosen
to Opt Out; and
if the individual Opts Out of all Direct Marketing the
Opt Out will be respected by Lenoxx Electronics and all
its Related Bodies Corporate.
2.4 Lenoxx Electronics will not use Sensitive Information
for Direct Marketing.
2.5 Lenoxx Electronics may use Personal Information to
avoid an imminent threat to a person's life or to public
safety. It may also use Personal Information for reasons
related to law enforcement or internal investigations
into unlawful activities.
2.6 Lenoxx Electronics will not use Personal Information
without taking reasonable steps to ensure that the information
is accurate, complete and up to date.
3. DISCLOSURE
3.1 Lenoxx Electronics may Disclose Personal Information
to related or unrelated third parties if consent has
been obtained from the individual. This will include
obtaining the individual's consent for Disclosures
made under the credit reporting requirements of the
Privacy Act.
3.2 Lenoxx Electronics may Disclose Personal Information
between Related Bodies Corporate. Where information is
Disclosed to such a Related Body Corporate, that Related
Body Corporate is bound by the original Primary Purpose
for which the information was collected.
3.3 Lenoxx Electronics may Disclose Personal Information
to unrelated third parties to enable outsourcing of functions
(such as billing, customer relations management and order
fulfilment), where that is Disclosure or Use for a related
Secondary Purpose and has been notified to individuals
or where such Disclosure is within the individual's Reasonable
Expectations.
3.4 Lenoxx Electronics will take reasonable steps to
ensure that its contracts with third parties include
requirements for third parties to comply with the Use
and Disclosure requirements of the Privacy Act.
3.5 Lenoxx Electronics may Disclose Personal Information
to law enforcement agencies, government agencies, courts
or external advisers where permitted or required by law.
3.6 Lenoxx Electronics may Disclose Personal Information
to avoid an imminent threat to a person's life or to
public safety.
3.7 If a Disclosure is not for a Primary Purpose; is
not for a related Secondary Purpose; or upfront consent
has not been obtained, Lenoxx Electronics will not Disclose
Personal Information otherwise than in accordance with
the exceptions set out at 3.1 to 3.6 above.
3.8 Lenoxx Electronics does not generally sell or share
its customer lists on a commercial basis with third parties
but if it did, it would only do so if we had the appropriate
consent of the individual involved. If the consent provided
is conditional, Lenoxx Electronics will take steps to
ensure (by contract) that the use of its customer list
by third parties does not exceed the scope of the consent.
4. INFORMATION QUALITY
4.1 Lenoxx Electronics will review, on a regular and
ongoing basis, its collection and storage practices
to ascertain how improvements to accuracy can be achieved.
4.2 Lenoxx Electronics will take steps to destroy or
de-identify Personal Information after as short a time
as possible and after a maximum of seven years from the
date of the last customer interaction, unless the law
requires otherwise.
5. USE OF COOKIES
5.1 A cookie is a small message given to your web browser
by our web server. The browser stores the message in
a text file, and the message is then sent back to the
server each time the browser requests a page from the
server.
5.2 We make limited use of cookies on this website. We
only use cookies to improve the functionality of our
website, not to store any of your personal information.
For example, if we provide a notice or update regarding
a significant change to the law, we may use cookies to
ensure that you do not receive this notice each time
you access our website.
5.3 When cookies are used on this site, they are used
to store information relating to your visit such as a
unique identifier, or a value to indicate whether you
have seen a web page. They are used to distinguish your
Internet Browser from the thousands of other browsers.
This site will not store personal information such as
email addresses or other details in a cookie.
5.4 Most Internet browsers are set up to accept cookies.
If you do not wish to receive cookies, you may be able
to change the settings of your browser to refuse all
cookies or to notify you each time a cookie is sent to
your computer, giving you the choice whether to accept
it or not.
6. INFORMATION SECURITY
6.1 Lenoxx Electronics requires employees and contractors
to perform their duties in a manner that is consistent
with Lenoxx Electronics 's legal responsibilities in
relation to privacy.
6.2 Lenoxx Electronics will take all reasonable steps
to ensure that paper and electronic records containing
Personal Information are stored in facilities that are
only accessible by people within Lenoxx Electronics who
have a genuine "need to know" as well as "right
to know".
6.3 Lenoxx Electronics will review, on a regular and
ongoing basis, its information security practices to
ascertain how ongoing responsibilities can be achieved
and maintained.
7. ACCESS AND CORRECTION
7.1 Lenoxx Electronics will allow its records containing
Personal Information to be accessed by the individual
concerned in accordance with the Privacy Act.
7.2 Lenoxx Electronics will correct its records containing
Personal Information as soon as practically possible,
at the request of the individual concerned in accordance
with the Privacy Act.
7.3 Individuals wishing to lodge a request to access
and/or correct their Personal Information should do so
by contacting Lenoxx Electronics Customer Service, as
per the details on the website.
7.4 Lenoxx Electronics can charge a fee for processing
an access request but will generally not do so unless
the request is complex or is resource intensive.
8. OPENNESS
8.1 Lenoxx Electronics Customer Service representatives
will be the first point of contact for inquiries about
privacy issues. Individuals wishing to make an inquiry
or complaint regarding privacy, should do so by contacting
Lenoxx Electronics Customer Service, as per the details
on the Lenoxx Electronics website.
7.3 Lenoxx Electronics websites will contain a prominently
displayed privacy statement and will include a copy of
this Lenoxx Electronics Privacy Policy.
9. ANONYMOUS TRANSACTIONS
9.1 Lenoxx Electronics will not make it mandatory for
visitors to its web sites to provide Personal Information
unless such Personal Information is required to answer
an inquiry or provide a service. Lenoxx Electronics
may however request visitors to provide Personal Information
voluntarily to Lenoxx Electronics (for example, as
part of a competition or questionnaire).
10. TRANSFERRING PERSONAL INFORMATION OVERSEAS
10.1 Lenoxx Electronics will take reasonable steps to
limit the amount of Personal Information it sends to
unrelated organizations overseas.
10.2 If Personal Information must be sent by Lenoxx Electronics
overseas for sound business reasons, Lenoxx Electronics
will require the overseas organization receiving the
information to provide a binding undertaking that it
will handle that information in accordance with the National
Privacy Principles, preferably as part of the services
contract.
11. GLOSSARY
Collection Information means the information outlined
in 1.3 notified to individuals prior to, or as soon
as practical after, the collection of their Personal
Information.
Direct Marketing means the marketing of goods or services
through means of communication including written, verbal
or electronic means. The goods or services which are
marketed may be those of Lenoxx Electronics or a Related
Body Corporate or those of an independent third party
organization.
Disclosure generally means the release of information
outside Lenoxx Electronics, including under a contract
to carry out an "outsourced function".
Health Information means:
information or an opinion about:
the health or a disability (at any time) of an individual;
or
an individual's expressed wishes about the future provision
of health services to him or her; or
a health service provided or to be provided to an individual;
that is also personal information; or
other personal information collected to provide or in
providing a health service; or
other personal information about an individual collected
in connection with the donation; or intended donation
by the individual of his or her body parts or body substances.
Opt Out means an individual's expressed request not to
receive further Direct Marketing.
Lenoxx Electronics means all companies in the Lenoxx
Electronics group.
Personal Information means 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 reasonably be ascertained
from the information or opinion.
Primary Purpose is the dominant or fundamental reason
for information being collected in a particular transaction.
Reasonable Expectation means a reasonable individual's
expectation that their personal information might be
Used or Disclosed for the particular purpose.
Related Body Corporate means that where a body corporate
is:
a holding company of another body corporate;
a subsidiary of another body corporate; or
a subsidiary of a holding company of another body corporate,
the first mentioned body corporate and the other body
corporate are deemed to be related to each other.
Sensitive Information means:
information or an opinion about an individual's:
racial or ethnic origin; or
political opinions; or
membership of a political association; or
religious beliefs or affiliations; or
philosophical beliefs; or
membership of a professional or trade association; or
membership of a trade union; or
sexual preferences or practices; or
criminal record;
that is also personal information or
Health Information about an individual.
Use means the handling of Personal Information within
Lenoxx Electronics.
Contacting Lenoxx Electronics
If you require further information regarding Lenoxx Electronics
's Privacy Policy, you can contact Lenoxx Electronics
Customer Service Centre: Telephone: (03) 9311 9848
or International +61 3 9311 9848, or by emailing Lenoxx
Electronics at privacy@lenoxx.com.au
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