Our Privacy Policy complies with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) as amended from time to time (‘Privacy Act’).

When you engage us to provide you with any goods or services, apply or complete an application for commercial credit, communicate with us through email, by telephone, in writing, participate in any of our marketing activities, or use any of our other services, including the our websites, you agree to the use and disclosure of your personal information in the manner described in this policy. This policy is also relevant and applies to other individuals we deal with in connection with commercial credit we provide, such as guarantors and directors.

We may, from time to time, review and update this Privacy Policy so please check our website periodically to stay informed of any updates. All personal information collected and held by us will be governed by the most recently updated Privacy Policy.

Personal information we collect

When you visit the Site, we 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 collect Device Information using the following technologies:

• “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.
• “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.
• “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site. Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, address/s, payment information (including credit card numbers, email address, and phone number. We collect any personal information you provide to us when you participate in a promotion, competition, promotional activity, survey, market research, subscribe to our mailing list; We refer to this information as “Order Information”. Our website may also contain links to or from other websites. We are not responsible for the privacy practices of other websites. This privacy policy applies only to the information we collect on our website. We encourage you to read the privacy policies of other websites you link to from our website.

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

How do we use your personal information?

We use the Order Information that we collect generally to fulfil any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

• Communicate with you;
• 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.

Our general business operations;

• effectively providing you with our goods and services;
• where applicable, assessing and processing an application for commercial credit, and for administrative purposes in relation to the ongoing management of your commercial credit arrangement;
  communicating with you;
• responding to your inquires or complaints;
• meeting our legal and regulatory obligations;
• conducting, improving and developing a relationship with you;
• direct marketing (such as providing you with information about our products and promotional notices and offers);
• and improving our websites.
  Your personal information is only collected by lawful and fair means; and where practicable, only from you or from a person acting or authorised to act on your behalf. Where you have applied for commercial credit account with us, we may also make enquiries in respect of commercial credit with third parties with your consent. This could include persons nominated by you as trade references, credit reporting bodies (“CRBs”) and your bankers.

We will take reasonable steps to ensure that you are aware of:

• the likely use of the information;
• the right of access to the information;
• the identity and contact details of the our employee/representative collecting your personal information;
• any law requiring collection of the information; and
• the main consequences of failure to provide your personal information

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimise our Site (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.

Sharing your personal Information

We share your Personal Information with third parties to help us use your Personal Information, as described above. For example, we use WooCommerce to power our online store – you can read more about how WooCommerce uses your Personal Information here. We also use Google Analytics to help us understand how our customers use the Site – you can read more about how Google uses your Personal Information here.

How we may use and disclose your personal information

We may use your personal information for:

• the primary purposes for which it was collected, such as those described above;
• assessing and processing an application for, or administrative and management of, and commercial credit account with us;
• administering and responding to your enquiry or feedback about our products and/or services;
• conducting, and allowing you to participate in, a promotion, competition, promotional activity, survey, market research or customer behavioural activity;
• promoting and marketing our current and future products and services to you, informing you of upcoming events and special promotions and offers and analysing our products and services so as to improve and develop new products and services (but giving you the opportunity to opt out of such direct marketing)
• improving the operation of our websites.

We may disclose personal information we collect from you:

• to our related companies, suppliers, consultants, contractors, stockists or agents for the primary proposes for which it was collected or for other purposes directly related to the purpose for which the personal information is collected. For example, your name and telephone number may be disclosed to our supplier to enable that supplier to respond to your request for information about a particular product;
• for direct marketing by, but giving you the opportunity to opt out of such direct marketing; We will include our contact details in any direct marketing.
• to relevant Federal, State, Territory medical, health and safety authorities (as required);
• where the law requires or authorises us to do so;
• to others that you have been informed of at the time any personal information is collected from you;
• with your consent (express or implied) to others.
• Where the Privacy Act permits us to do so, we may also disclose your credit related information (in respect of commercial credit) to CRBs such as Veda or Dunn & Bradstreet, if you apply for commercial credit or request to increase in your commercial credit limit with Bright Early Days.

Where Bright Early Days information that we are likely to disclose to a CRBs, please note:

• the CRBs may include that information in reports provided to Bright Early Days to assist it to assess your creditworthiness;
• if you fail to meet payment obligations in relation to commercial credit or commits a serious credit infringement, Bright Early Days may be entitled to disclose this to the CRB;
• if you are an individual you may access information from Bright Early Days in accordance with this privacy policy and may access this information for the purpose of requesting Bright Early Days to correct the information or make a complaint to Bright Early Days.
• Bright Early Days will only disclose personal information to CRBs where Bright Early Days is a member of a recognised External Dispute Resolution Scheme (‘EDR Scheme’). If Bright Early Days disclosing your personal information to CRBs, we will provide you written notice prior to that disclosure, as well as the details of the recognised EDR Scheme.

How your personal information is stored and secured

We take reasonable steps to protect your personal information from loss, misuse or unauthorised access by restricting access to the information in electronic format and by appropriate physical and communications security.

If a substantial data breach has or may have occurred (for example, your personal information was shared with unauthorised persons) we will notify you as soon as is practicable.

We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by law. We will take appropriate measures to destroy or permanently de-identity your personal information if we no longer need to retain it. These measures may vary depending on the type of information concerned, the way it was collected and how it was stored.

Marketing and Opting-Out

We may use your personal information for:

• promoting and marketing of our current and future products and services;
  informing you of upcoming events and special promotions and offers; and
• analysing our products and services so as to improve and develop new products and services.

We may exchange your personal information between our related entities and so they can also assist in the marketing of our products and services to you.

We will only offer you products or services, where we reasonably believe that they could be of interest or benefit to you.

At the point we collect information from you, you may be asked to “opt in” to consent to us using or disclosing your personal information. You will generally be given the opportunity to “opt out” from receiving marketing communications from us. You may “opt out” from receiving these communications by clicking on an unsubscribe link at the end of an email or by contacting us with this request.

Cross boarder disclosure

Your personal information may also be processed by, or disclosed to employees, representatives, or other third parties operating outside of Australia who work for, or are engaged by us in other countries, including USA. For example, we may use a server hosted overseas to store data, which may include your personal information.

We will take reasonable steps, in the circumstances, before your personal information is disclosed to an overseas recipient, to ensure that the overseas recipient does not breach privacy laws in relation to your personal information (‘the reasonable steps’).

The reasonable steps may not apply if you consent to the disclosure of your personal information to an overseas recipient and we reasonably believe that the overseas receipt is subject to laws that are suitability similar to privacy laws in Australia.

If you consent to the disclosure of your personal information to an overseas recipient, the overseas recipient may not be accountable under the Privacy Act, and you will not be able to seek redress for breaches under the Privacy Act.

Collecting sensitive information

Bright Early Days does not collect sensitive information, unless it is specifically relevant and necessary for the purpose of our business activities and functions, and your consent is first obtained. All sensitive information that is collected is used in accordance with this privacy policy.

Data retention

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

Contact us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e‑mail at hello@brightearlydays.com.au.