Privacy policy

Light on Light Privacy Policy

Light on Light respects the privacy of individuals and is committed to protecting personal information that individuals provide. Light on Light is further committed to complying with the obligations of the Australian Privacy Principles (APP) as set out in the Privacy Act 1988 (Cth) (the Act). This document sets out when and how LIGHT ON LIGHT will collect, hold, use and disclose an individual’s personal information, as well as how an individual may contact Light on Light in relation to their personal information or in order to make a complaint about a breach of privacy.

By using Our Services (as defined below), you agree to this Privacy Policy and consent to the collection and use of information by us in accordance with this Privacy Policy. Please note that we reserve our right to amend or vary this policy from time to time without notice. You should check this page regularly to take notice of any changes we may have made to this policy.

  1. What personal information may be collected

1.1     Personal information is defined by the Act as information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Examples of personal information might include an individual’s name, address, phone number, email address, family details or any other information from which an individual could reasonably be identified.

1.2     Light on Light may collect a variety of personal information relating to the provision of its products and services. Examples of personal information which Light on Light regularly collects include an individual’s:

  • your name and contact details, such as your physical address, email address and phone number;
  • your gender, birth date and occupation;
  • your purchase history;
  • your company name (if applicable);
  • the name of the domain from which you access the internet;
  • the date and time you access our sites;
  • the internet address of the website from which you linked directly to our sites;
  • information about your shopping preferences/selections; and
  • Any other information you may provide to us from time to time.
  • financial details for the purposes of providing products;
  • opinion about Light on Light’s products; or
  • Other personal information particular to a specific individual to allow Light on Light to tailor its products or services to that individual.

2        Collection of Personal Information

2.1     Light on Light websites automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”. Device information is collected 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 Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  3. “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

2.2     We collect personal information in the normal course of providing services for our customers. This applies to our services wherever provided including:

  1. Signing up to a loyalty program, membership account or newsletter subscription
  2. Processing lay-by purchases
  3. Accepting customer orders
  4. Processing online purchases and payments
  5. Registering an online account
  6. Maintaining client books
  7. Customer Service lines (including social media channels such as Facebook and Instagram)
  8. Processing payments
  9. Providing tailoring instructions
  10. Processing refunds/replacements
  11. Maintaining detailed information on our websites
  12. Third-party independent reviews provider (Trust Pilot)
  13. Any other time where you may supply personal information to us from time to time.

2.3     If an individual is required to register in order to use Light on Light’s website or to otherwise complete an online application form (e.g. to obtain e-mail updates) then Light on Light will collect personally identifiable information about the individual, such as their name, e-mail address, country of residence and other information which they voluntarily submit.

2.4     While an individual may choose not to provide personal information to Light on Light, failure to do so may hamper the provision of products. In some case failure to provide personal information may result in Light on Light being incapable of providing products to a particular individual at all.

2.5     Light on Light’s website may also collect Internet Protocol (IP) addresses. IP addresses are assigned to computers on the internet to uniquely identify them within the global network. Light on Light collects and manages IP addresses for security purposes. Light on Light may also collect and use web log, computer and connection information to help prevent and detect any misuse of, or fraudulent activities involving, its website.

  1. Use and Disclosure of Personal information.

3.1     Light on Light uses personal information for the purpose of, or in relation to, providing our products and services to individuals. Examples of uses may include, but are not limited to:

  • assessing an individual’s potential requirements for Light on Light’s products;
  • corresponding with an individual regarding the products being provided, including regarding the individual’s satisfaction with the products;
  • providing relevant consumer information and notifying you of products and special offers that may interest you
  • process any purchases of products that you may make through this site, including charging, billing and collecting debts and shipment of products to you;
  • tailoring Light on Light’s products to an individual’s needs.

3.2     Light on Light may also use or disclose personal information in the following circumstances:

(a)  where an individual has given consent;

(b)  where required in order to provide an individual with the products and/or services they requested (for example to a courier company); or

(c)  where use or disclosure is required or authorised by law.

3.2     Further to the uses above Light on Light may use or disclose personal information in relation to applying for appropriate government subsidies or grants available to it.  Wherever reasonable and practicable Light on Light will either limit the personal information disclosed to that which is absolutely necessary or will undertake to de-identify the information prior to its disclosure.

3.4     From time to time Light on Light may disclose personal information to a variety of third parties in relation to the provision of products to individuals. Potential third party recipients may include:

  • Light on Light’s legal and financial advisers;
  • Light on Light’s Insurers;
  • Light on Light’s employees and staff for business purposes such as marketing
  • Light on Light services providers. 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 our websites -- 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.
  • Government agencies, including as outlined in point 3.2;
  • Any third party with a lawful entitlement to the information. Whenever Light on Light discloses personal information to a third party it will take steps that are reasonable and practicable in the circumstances to either:
    1. limit the disclosed personal information to the minimum required to fulfil the purpose of the disclosure; or
    2. De-identify the personal information prior to disclosing it to a third party.

3.5     An individual may agree to provide their personal information directly to third parties in connection with Light on Light offerings, in order to access and/or use the third party’s products and/or services. If an individual agrees to provide such information to these third parties, then their personal information will be subject to the third party’s privacy policies.

3.6      We also collect Personal information so that we may provide value-added services and marketing and remarketing across Our Brands, our Associated Entities (as defined in the Corporations Act 2001 (Cth)), including our promotional partners through our websites, social media channels or other marketing mediums.

  1. Promotional Communications
    • From time to time we may use your personal information to provide you with information about our services or the services of our Associated Entities or promotional partners. We want to communicate with you only if you want to hear from us. If you prefer not to receive promotional information from us, please let us know by clicking on the “unsubscribe link”/”update your preferences” at the bottom of any of our communications, or by clicking into your account to manage the level of communication which you want to receive from us across Our Brands. Once you have told us you no longer wish to receive information about Our Services, we will no longer contact you. We will keep your basic details on our ‘do not contact’ database so that we do not contact you again.
  2. Overseas Recipients
    • It may be necessary for Light on Light to provide personal information to its suppliers, for supply and warranty purposes. In such cases the provisions of clause 5.2 will apply.
    • Prior to disclosing personal information to an overseas recipient Light on Light will generally either seek your consent or ensure that the recipient abides by the APP or ensure that the entity is bounds by restrictions on the use of personal information that are substantially similar to the APP. In addition wherever reasonable and practicable Light on Light will either limit the personal information disclosed to that which is absolutely necessary or will undertake to de-identify the information prior to its disclosure.
  3. Direct Marketing
    • Light on Light does not sell, trade or transfer personal information to third parties for the purposes of direct marketing.
    • Light on Light may from time to time use personal information to notify individuals of changes to products provided to that individual, or to bring to that individual’s attention new or additional products which may be beneficial to them. All such communications will include an option for the recipient to opt out of receiving any future direct marketing.
  1. Security

7.1     Light on Light is concerned with the security of your Personal Information and is committed to taking reasonable steps to protect it from unauthorized access and use. To that end, Light on Light has put in place appropriate physical, electronic and managerial policies and procedures to secure personal information. These policies and procedures include, but are not limited to:

  • storing any electronic information on password protected and secure servers;
  • ensuring any physical copies of personal information are kept in a secure area which is not open to unauthorised access;
  • ensuring that any access to personal information by Light on Light employees is limited to those employees with a need to know that information for the provision of products to the relevant individual;

7.2     Personal information may be retained for 7 years or such other period as required by taxation or other laws.

  1. Accuracy of Personal Information

          Light on Light is committed to ensuring that all personal information held is accurate, complete and up-to-date. To that end Light on Light may from time to time contact individuals directly for the purposes of verifying their information.

  1. Access to and Correction of Personal information

9.1     Individuals have a right to know what of their personal information Light on Light holds. Individuals may request this by contacting Light on Light’s Privacy Officer by the following methods:

Phone: +61 480 105 775

Email: Info@lightonlight.com.au

         

9.2     When requesting access or correction of personal information Light on Light will require an individual to verify their identity by reference to their personal information. In some circumstances it may be necessary for an individual to visit Light on Light’s location to properly verify their identity before access to personal information can be granted.

9.3     While Light on Light will attempt to respond to a request for access to personal information in a timely manner, given the wide array of Light on Light’s products provided, it may take some time to collect an individual’s personal information and make it available. Individuals can help to minimise delays by providing details of what information they require access to, how and when they have provided information to Light on Light in the past and the general nature of any dealings between them.

9.4     When a request for information is received, Light on Light will endeavour to provide an accurate estimate of the time it may take to comply with the request, however, compliance with this timeframe is not guaranteed.

9.5     Generally Light on Light will not charge a fee to grant an individual access to their personal information, however in the case of requests for old or particularly voluminous information it may be necessary for Light on Light to charge a reasonable fee, commensurate with the work required to comply with the request. However, there will be no fee charged in relation to the making of the request for access itself.

9.6     While Light on Light will generally comply with an individual’s request for access to personal information about them, Light on Light does have the right under the APP to refuse access in certain circumstances. In the event that access is refused Light on Light will, where reasonable, provide reasons for the refusal, along with alternative methods which may allow access.

9.7     In addition to requesting access to personal information individuals may request that Light on Light correct any personal information held about the individual. Once the individual’s identity has been verified Light on Light will take reasonable steps to correct their personal information.

  • Complaints

10.1    If an individual wishes to make a complaint about Light on Light’s collection, use or disclosure of any personal information, or about any potential breach of an APP, the individual may contact the Privacy Officer by use of the contact details at the end of this document.

10.2    When making a complaint an individual should include as many details as possible, including the nature of the personal information concerned, how it is believed to have been misused, which APP is believed to have been breached (if relevant), the details of any Light on Light employee or representative involved and any other information which may be relevant. The Privacy Officer may request additional information to enable the Privacy Officer to properly investigate the complaint and take such reparatory action as necessary.

10.3    Once a complaint is received the Privacy Officer will investigate the circumstances of the complaint and determine whether a misuse of personal information has occurred and if so how it may be rectified and whether/what action should be taken in relation to any Light on Light employee or representative involved. Light on Light will endeavour to keep the individual informed regarding the process of their complaint and any action taken.

10.4    Should an individual not be satisfied with Light on Light’s handling of their complaint then Light on Light will generally agree to the complaint being referred to mediation and/or arbitration. Should the matter remain unresolved then an individual is entitled to refer their matter to the Office of the Australian Information Commissioner. 

  1. Use of Cookies

Cookies are small files which are sent to an individual’s web browser and stored on their computer's hard disk. If an individual uses Light on Light’s website, then cookies will be created and transferred to their hard disk upon first registration. Cookies are subsequently used to identify the individual’s computer and allow repeated access to the website without having to re-register each time. The cookie is used purely to speed up an individual’s access to the website and the information they wish to see. The majority of web browsers accept cookies, but individuals can usually change the browser settings to prevent the transfer, though some functionality may be lost.

  1. Third party websites

13.1    Website users may click-through to third party websites from this site, in which case we recommend that users refer to the privacy statement of the websites visited. This Privacy Policy applies to this site only and Light on Light assumes no responsibility for the content of any third party websites.

13.2    In particular, when users submit an order to us, they may be automatically redirected to a payment facilitator in order to complete the required payment. The payment page that is provided by the third party is not part of this site. As noted above, Light on Light is not privy to any of the bank account, credit card or other personal information that may be provided to the payment facilitator, other than information that is required in order to process a user’s order and deliver purchased items to them (eg, name, email address and billing/postal address). Light on Light recommends that users refer to the payment facilitator’s privacy statement if they would like more information about the collection and use of personal information.

13.3    Light on Light may use the Google AdWords and/or Facebook re-marketing services to advertise on third party websites to previous visitors to this site based upon their activity on this site. This allows Light on Light to tailor its marketing to better suit user’s needs and to only display relevant advertisements. Such advertising may be displayed on a Google search results page or a website in the Google Display Network or inside Facebook. Google and Facebook may use cookies and/or pixel tags to achieve this. Any data so collected by Google and/or Facebook will be used in accordance with their own respective privacy policies. None of a user’s personal Google and/or Facebook information is reported to us.

Users can set preferences for how Google advertises to them using the Google Ads Settings page (https://www.google.com/settings/ads). Facebook has enabled an AdChoices link that enables users to opt out of targeted advertising.

  1. GDPR

14.1    Light on Light welcomes the General Data Protection Regulation (“GDPR”) of the European Union (“EU”) as an important step forward in streamlining data protection globally.  Light on Light intends to comply with the data handling regime laid out in the GDPR in respect of any personal information of data subjects in the EU that Light on Light may obtain.

14.2    The requirements of the GDRP are broadly similar to those set out in the Privacy Act and include the following rights:

  • individuals are entitled to request details of the information that Light on Light hold about them and how Light on Light processes it. For EU residents, Light on Light will provide this information for no fee;
  • Individuals may also have a right to:

-       have that information rectified or deleted;

-       restrict Light on Light’s processing of that information;

-       stop unauthorised transfers of that individual’s personal information to a third party;

-       in some circumstances, have that information transferred to another organisation; and

-       lodge a complaint in relation to Light on Light’s processing of personal information with a local supervisory authority; and

  • where we rely upon an individual’s consent as our legal basis for collecting and processing their data, the individual may withdraw that consent at any time.

If an individual objects to the processing of their personal information, or if they have provided consent to processing and later choose to withdraw it, Light on Light will respect that choice in accordance with its legal obligations.  However, please be aware that:

  • such objection or withdrawal of consent could mean that Light on Light is unable to provide its services to the individual; and
  • even after an individual have chosen to withdraw their consent, Light on Light may be able to continue to keep and process their personal information to the extent required or otherwise permitted by law, in particular:

-       to pursue Light on Light’s legitimate interests in a way that might reasonably be expected as part of running its business and which does not materially impact on the individual’s rights, freedoms or interests; and

-       in exercising and defending Light on Light’s legal rights and meeting its legal and regulatory obligations.

14.3    Storage and processing by third parties

Data that Light on Light collects about an individual may be stored or otherwise processed by third party services with data centres based outside the EU, such as Google Analytics, Microsoft Azure, Amazon Web Services, Apple, etc and online relationship management tools.  Light on Light considers that the collection and such processing of this information is necessary to pursue its legitimate interests in a way that might reasonably be expected (eg, to analyse how its customers use its services, develop services and grow its business) and which does not materially impact the individual’s rights, freedom or interests.

Light on Light requires that all third parties that act as “data processors” provide sufficient guarantees and implement appropriate technical and organisational measures to secure data, only process personal data for specified purposes and have committed themselves to confidentiality.

14.4    Duration of retention of data

Light on Light will only keep individual’s data for as long as is necessary for the purpose for which it was collected, subject to satisfying any legal, accounting or reporting requirements.  At the end of any retention period, individual’s data will either be deleted completely or anonymised (for example, by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning).  In some circumstances, an individual can ask Light on Light to delete the individual’s data.

14.5    Keeping your information up-to-date

To ensure that an individual’s personal information is accurate and up to date, Light on Light requests individuals to please promptly advise Light on Light of any changes to their information by contacting Light on Light’s data protection officer at LightonLightwoodcandles@gmail.com or by post.

 

General.

If you have questions regarding this Privacy Policy, please contact Light on Light’s Privacy Officer by the following methods:

Phone: +61 429 788 332

Email: info@lightonlight.com.au

         

Policy issued September 2020