Privacy Policy

Struddys Apparel Co - Privacy Policy and Credit Management Policy

1  Privacy Policy 
Struddys Apparel Co Pty Ltd (ABN 97 010 396 513), trading as Struddys Apparel Co, is committed to protecting the privacy of your personal information. This Privacy Policy explains how Struddys Apparel Co manages personal information that it collects, holds, uses and discloses to ensure that your personal information and privacy are protected.
Struddys Apparel Co complies with the Australian Privacy Principles (APPs) and, to the extent applicable, the credit provider provisions in the Privacy Act 1988 and the registered Credit Reporting Code. 

1.1  Collection of personal information 

When collecting your personal information, Struddys Apparel Co takes reasonable steps to make you aware of the purposes for which the information is being collected, the organisations to which Struddys Apparel Co will usually disclose your information (and, if they are located overseas, the countries they are located in), legal obligations (if any) requiring Struddys Apparel Co to collect the information, and the main consequences (if any) if you fail to provide any information that is requested.

Struddys Apparel Co limits the personal information collected to that which is reasonably necessary for Struddys Apparel Co's functions or activities. When reasonable and practicable, Struddys Apparel Co only collects your personal information directly from you. If you do not provide the personal information requested, we may be unable to assist you (for example, we may not be able to complete a sale or approve any application you make for credit).

Struddys Apparel Co may collect personal information from you in a number of circumstances, including if you (or a business you operate or represent):
•  contact Struddys Apparel Co, for example, to enquire about Struddys Apparel Co’s products;
•  place an order for Struddys Apparel Co products;
•  apply for credit terms with Struddys Apparel Co. 

The types of personal information that Struddys Apparel Co collects and holds may include your name, email address, residential and/or postal address, telephone number and/or date of birth. We may also collect and hold identity verification documents which may include a copy of your driver’s licence or birth certificate.

Struddys Apparel Co may also collect and hold other personal information, such as credit information or credit eligibility information obtained from a credit reporting body, in connection with a credit application or the ongoing management of credit and processing of payment. For more information on how Struddys Apparel Co manages credit information please see Struddys Apparel Co’s Credit Management Policy below. 

This information may be collected from you via our website, over the telephone, via email or mail, or in person and may be held in electronic or paper form.
Struddys Apparel Co collects and holds personal information in order to conduct its business, to provide its products and services and to meet legislative and regulatory requirements. This generally involves, but is not limited to, collecting and holding personal information to:
•  provide further information about Struddys Apparel Co's products;
•  assess an applicant's eligibility for credit terms;
•  process payment for products ordered;
•  arrange for delivery of ordered products;
•  provide customer support; and
•  respond to customer enquiries and resolve any complaints.   

1.2  Use of personal information 

Struddys Apparel Co will use personal information for various purposes, depending on the circumstances. 

Struddys Apparel Co will generally only use your personal information for the purpose for which it was collected, and for related purposes that are within your reasonable expectations. Struddys Apparel Co will seek your consent prior to using or disclosing your personal information for another purpose, unless we are required or authorised by the APPs or by law to do so without seeking your consent. 

If you or a business you operate or represent apply to Struddys Apparel Co for credit, we may use your personal information to determine eligibility for credit, and to set credit limits from time to time.

Your personal information may also be used to enable Struddys Apparel Co to offer you other products or services that are related to products or services Struddys Apparel Co has previously provided to you, and you consent to us doing so.  However, if you do not wish to receive marketing or promotional communications from us, please notify Struddys Apparel Co (using the contact details set out below), or use the opt out function provided for in those communications.  Unless you opt out, you will be taken to have consented to receiving such communications.  There are no consequences of opting out of receiving our marketing and promotional communications except that you will no longer receive them, and you may elect to rejoin our marketing list at a later stage if you wish.

1.3  Disclosure of personal information 

Struddys Apparel Co may disclose your personal information to other organisations to enable it to provide and administer its products. These organisations include the following:
•  credit reporting bodies, for the purpose of obtaining your credit report (for more information see Struddys Apparel Co’s Credit Management Policy below);
•  electronic identification verification service providers;
•  fraud prevention service providers; and 
•  other organisations, where you have provided your consent.

When Struddys Apparel Co engages contractors and third party service providers to provide specialised services such as bulk mailing and market research services, these contractors and service providers are obliged to only use personal information disclosed to them by Struddys Apparel Co for the specific purposes for which it was provided. It is unlikely that Struddys Apparel Co will disclose your personal information to overseas recipients.  

1.4  Access to personal information 

You may request access to your personal information held by Struddys Apparel Co by writing to us. Struddys Apparel Co will respond to your request within a reasonable period after your request is made.  APP 12 outlines your rights to access personal information in greater detail.
If you lodge a request for access, we may provide you with access to your personal information in any of a number of ways (including, for example, supplying you with a copy or providing you with the opportunity to inspect it). 

1.5  Correction 

Struddys Apparel Co takes reasonable steps to ensure that the personal information it collects, uses or discloses is accurate, up-to-date and complete.
If you believe any of your personal information held by Struddys Apparel Co is incorrect or out-of-date you may make a written request to Struddys Apparel Co seeking a correction. Struddys Apparel Co will respond within a reasonable period after your request is made. 

1.6  Storage of personal information 

Struddys Apparel Co takes reasonable steps to store your personal information securely, and has policies and procedures intended to ensure that your personal information is not misplaced or misused, and that unauthorised access to, or modification or disclosure of, your personal information does not occur.

1.7  Privacy online 

When you visit Struddys Apparel Co’s web site, our web server collects the following information for statistical and customer service purposes:
•  the number of users who have visited our web site;
•  the date and time that visitors have visited our web site;
•  the number of pages viewed and documents downloaded;
•  the type of browser software that you are using; and
•  the type of operating system that you currently use.
Struddys Apparel Co makes no attempt to identify you or to track or monitor your browsing activities from the above information. We only use this information to improve the performance of Struddys Apparel Co's web site and Struddys Apparel Co's service to its customers.

You acknowledge that, if you provide any personal information to Struddys Apparel Co via online services (including email) or if we provide such information to you by such means, the privacy, security and integrity of this information cannot be guaranteed during its transmission.

1.8  Amendment 

Struddys Apparel Co undertakes periodic reviews of its policies and procedures with guidance by Struddys Apparel Co’s legal advisers to ensure that the personal information held is managed appropriately. Struddys Apparel Co therefore reserves the right to amend this Privacy Policy at any time. You may obtain a copy of the current version of this Privacy Policy by
contacting Struddys Apparel Co, or by accessing Struddys Apparel Co’s web site.

1.9  Complaints 

If you believe that a breach of your privacy has occurred, we encourage you to contact Struddys Apparel Co to discuss your
concerns.

Your complaint will be considered and dealt with by our Privacy Officer.  If the breach is considered to be serious, the Privacy Officer may escalate the complaint internally within Struddys Apparel Co. Please allow us a reasonable time to respond to your compliant. 

1.10  Contact information 

Struddys Apparel Co Pty Ltd
Attn: Privacy Officer
82 Bryants Road, Loganholme, QLD 4129, Australia
Phone: (07) 3209 6100
Email: wholesale@struddys.com.au 

2  Credit Management Policy 

Doublebrook (Struddys Apparel Co) is committed to protecting the privacy of your credit information and credit eligibility information (collectively referred to as “credit data” in this Credit Management Policy). 
This Credit Management Policy explains how Struddys Apparel Co handles such credit data.

Struddys Apparel Co does not provide consumer credit, but it provides commercial credit to some of its wholesale customers. In the course of assessing applications for commercial credit, credit data on individuals may be collected (for example, this may occur if a customer carries on business as a sole trader, or if a personal guarantee is provided in support of a credit application).

Generally speaking, credit data is information used to assess an individual's eligibility to be provided with credit.  It may include details of credit provided to you, repayment history information, and certain details regarding overdue payments or defaults.

Credit data is a specific kind of “personal information” (which is essentially information or an opinion about you as an identified or reasonably identifiable individual).  Struddys Apparel Co’s Privacy Policy set out above applies to Struddys Apparel Co’s handling of personal information generally.  Unless otherwise stated, this Credit Management Policy applies instead of Struddys Apparel Co’s Privacy Policy where Struddys Apparel Co handles credit data. 

2.1  Collection of credit data 

The kinds of credit data that Struddys Apparel Co collects and holds may include:
•  identification information (which may include your full name, previous name, alias, date of birth, gender, current and last known address and two previous addresses, the name of your current or last known employer, and driver’s licence number);
•  a copy of documents that include such identification information (such as your driver’s licence, birth certificate or passport);
•  consumer credit liability information (which may include information about existing credit provided to you such as the name of the credit provider, the type of credit, when it was provided, the terms and conditions that apply, the maximum amount of credit available, and the day on which the credit was terminated);
•  repayment history information (which may include whether or not you have made a payment on time, when it was due and when it was paid);
•  details of previous applications for credit made by you;
•  default information (which relates to certain overdue payments);
•  payment information (which relates to when such overdue payments were made);
•  court proceedings information (which relates to court judgements about credit provided to
you);
•  personal insolvency information (for example, if you are declared bankrupt);
•  publicly available information relating to your credit worthiness; and 
•  any opinion of a credit provider that you have committed a serious credit infringement. 

Credit information may be collected by Struddys Apparel Co:
•  directly from you;
•  from a credit reporting body (such as Veda Advantage); and/or;
•  from other parties (for example, other credit providers) where permitted by the Privacy Act.   
If you do not provide or agree to the collection of the credit data requested, we may be unable to assist any business you operate or represent (for example, we may not be able to approve any application such a business makes for credit facilities).

Struddys Apparel Co usually derives, from credit data disclosed to Struddys Apparel Co by a credit reporting body (such as Veda Advantage), information including internal assessments and calculations based on such credit data for the purpose of assessing credit applications received by Struddys Apparel Co.

2.2  Purposes 

Struddys Apparel Co collects, holds, uses and discloses credit data in order to conduct its business, to provide its products and services and to meet legislative and regulatory requirements. This generally involves, but is not limited to, collecting, holding, using and disclosing credit data to:
•  assess a customer's eligibility for credit and credit worthiness.  In particular, Struddys Apparel Co may use
your credit data to determine the eligibility for credit of a business you operate or represent;
•  monitor and adjust credit limits for customers or revoke the provision of credit;  
•  administer customers’ orders and accounts; 
•  facilitate collection of overdue accounts; and
•  resolve complaints.

Struddys Apparel Co will not sell your credit data to any third parties.

It is unlikely that Struddys Apparel Co will disclose your credit data to overseas recipients.

2.3  Credit reporting bodies 

Personal information provided by us to credit reporting bodies such as Veda Advantage may be included in reports provided by credit reporting bodies to other credit providers, to assist them to assess your credit worthiness.

If a customer fails to meet its payment obligations or commits a serious credit infringement, we may be entitled to disclose this information to credit reporting bodies.  A serious credit infringement includes:
•  fraudulently obtaining a loan;
•  fraudulently evading (or attempting to evade) obligations in relation to a loan; or
•  an act that a reasonable person would consider indicates an intention to no longer comply with obligations in relation to a loan.

You may contact a credit reporting body to request that it does not:
•  use credit reporting information about you for the purpose of pre-screening of direct marketing by a credit provider; or
•  use or disclose credit reporting information about you if you believe on reasonable grounds that you have been or are likely to be a victim of fraud.

You may obtain a credit reporting body's credit management policy by requesting a copy from them, or it may be available on their website.

2.4  Access to credit information 

You may request access to your credit data held by Struddys Apparel Co by writing to us. Struddys Apparel Co will respond to your request within a reasonable period after your request is made.  The section of our Privacy Policy available above, outlining the process that will apply should you request access to your personal information, also applies to access to your credit data.  Section 21T of the Privacy Act also outlines your rights to access your credit data in greater detail.

2.5  Correction 

Struddys Apparel Co takes reasonable steps to ensure that the credit data it collects, uses or discloses is accurate, up-to-date and complete.

If you believe any of your credit data held by Struddys Apparel Co is incorrect or out-of-date you may make a written request to Struddys Apparel Co seeking a correction. Struddys Apparel Co will respond within a reasonable period after your request is made. 

The section of our Privacy Policy available above outlining the process that will apply should you request correction of your personal information also applies to the correction of your credit data.  Sections 21U to 21W of the Privacy Act also outline your rights to correct your credit data in greater detail.

2.6  Storage of credit data 

Struddys Apparel Co takes reasonable steps to store your credit data securely, and has policies and procedures intended to ensure that your credit data is not misplaced or misused, and that unauthorised access to, or modification or disclosure of, your credit data does not occur.  Credit data may be held by us electronically or in hard copy form, and we employ security protections appropriate for the form in which that information is held (eg, passwords linked with authorised user access and physical document security).

2.7  Amendment 

Struddys Apparel Co undertakes periodic reviews of its policies and procedures with guidance by Struddys Apparel Co’s legal advisers to ensure that the credit data held is managed appropriately. Struddys Apparel Co therefore reserves the right to amend this
Credit Management Policy at any time. You may obtain a copy of the current version of this Credit
Management Policy by contacting Struddys Apparel Co, or by accessing Struddys Apparel Co’s web site.

2.8  Complaints 

If you believe that a breach of your privacy has occurred, we encourage you to contact Struddys Apparel Co to discuss your concerns. Your complaint will be considered and dealt with by our Privacy Officer.  If the breach is considered to be serious, the Privacy Officer may escalate the complaint internally within Struddys Apparel Co. Please allow us a reasonable time to respond to your compliant. 

2.9  Contact information 

Struddys Apparel Co Pty Ltd
Attn: Privacy Officer
82 Bryants Road, Loganholme 4129, Australia
Phone: (07) 3209 6100
Email: ross@struddys.com.au