Privacy policy

 CGBV1 Pty Ltd (trading as Swaggle) Privacy Policy

 

1. General

This Privacy Policy sets out how CGBV1 Pty Ltd trading as Swaggle (‘We’/ Swaggle) collects, uses, discloses and protects Your Personal Information, including where You give Us that information when You access any of our websites, mobile sites and downloadable applications.

Swaggle is committed to managing Personal Information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) (‘Privacy Act’) and in accordance with other applicable privacy laws.

We understand the significance of being transparent with You in the way in which We collect, store, use and disclose Your Personal Information. If You have any questions about this Privacy Policy, please contact Us using the relevant contact details set out in section 14.

 

2. Definitions

For the purposes of this Privacy Policy, the following definitions shall apply: 

‘Account’ means a unique account created for You to access Services or parts of Our Services.

‘Australian Privacy Principles’ means the Australian Privacy Principles under the Privacy Act, that govern standard rights and obligations around the collection, use and disclosure of Personal Information; integrity and correction of Personal Information; an organisation or agency’s governance and accountability; and the rights of individuals to access their Personal Information.

‘Device’ means any device that can access the Website such as a computer, a cell phone or a digital tablet. 

‘Internet Protocol Address’ and ‘IP Address’ means an identifying number that is associated with a specific computer, device or computer network.

‘Personal Information’ means information or an opinion about an identified individual or an individual who is reasonably identifiable: (I) whether the information or opinion is true or not; and (ii) whether the information or opinion is recorded in a material form or not.

‘Service’ means one or more services provided by Swaggle.

‘Service Provider’ means a third party that provides Services on Our behalf. 

‘CGBV1 Pty Ltd’, ‘We’ and ‘Us’ means Swaggle, a company registered in Australia and the owner of this Website and Services.

‘User’ means any individual or company which enters the Website.

‘Website’ means the website controlled by Us located at www.swaggle.com.au or any other satellite websites or subdomains controlled by Us that link to this Privacy Policy.

‘You’ means the individual accessing or using Our Website and/or Services, or whose Personal Information We are processing.

 

3. Why do We collect and handle Personal Information?

We collect, store, use and disclose Your Personal Information for purposes arising from your use of our website and services and for running our business effectively. Those purposes include to:

• Provide our products and Services, including to monitor the usage of our services.
• Register and manage Your Account, including to identify and communicate with You.
• Enter into or carry out obligations arising from any contracts entered between You and Us.
• Collect and process payments.
• Manage and improve Our Services and operational processes, including conducting research for the purposes of better understanding Your requirements and preferences.
• Respond to and deal with an application that You submit to Us.
• Notify You about any changes of Our Services.
• Assist with business-related purposes, including maintenance and back-up purposes.
• Investigate, review and mitigate risks associated with a security or data breach and contact You if necessary.
• Store, verify and update Your Personal Information.
• Request feedback through surveys and research so that We can improve our products and services.
• Manage Our supply chain, procuring products and materials, and working with Our Service Providers
• Conduct safety, security, investigative, fraud, and loss prevention activities.
• Facilitate corporate transactions like mergers and acquisitions, e.g. to assess those transactions and manage the transition of the business.
• Comply with Our legal obligations and protect and defend Our legal rights and interests.
• Interact with regulators and relevant government entities.
• Engage in other activities as required or permitted by law.
• Provide your personal and pet information to our Vet partners when You contact them via our channels;
• Personalise your experience with our services;
• Undertake direct marketing (detailed in the section below ‘Direct Marketing’).

• Subscription and Repeat Delivery Services: We use third-party service providers to manage subscription-based purchases, including our provider, Ordergroove. This means that customer data related to subscriptions will be processed through Ordergroove.

• Payment Processing: Payment transactions related to repeat delivery and subscriptions will be processed in compliance with Australian financial regulations.

• Cross-Border Data Storage: Some of our third-party service providers, including Ordergroove, may store data in offshore locations. We ensure that any such transfers comply with Australian Privacy Principles and have appropriate safeguards in place

Please note that We may not be able to some of the above activities without your personal information. For example, We may not be able to deliver items ordered online without Your delivery address.

To the extent permitted by applicable law (including with your consent where required), We may use your personal information to tell You about products or services We think You may be interested by sending You marketing communications, including e-mail and digital marketing. Such communications may be ongoing but if at any time You decide to withdraw your consent and do not wish to be contacted for marketing purposes, You can opt out of receiving future direct marketing communications by clicking on the unsubscribe button in any marketing communications We send to You. You can also send a request to opt out using relevant contact details set out in section 14.

Where you provide us with personal information about someone else, you must have their consent to provide their personal information to us based on this Privacy Policy. 

 

4. What Personal Information We collect from You and how do We collect it?

The types of Personal Information that We collect and how We collect it depend on Our interactions with You.

The Personal Information may include but is not limited to:

• Your identity and contact details: this includes Your name, delivery/billing address, telephone number, email address, IP address, date of birth and Account details;
• Information about Your pet(s): including name, age, breed and health conditions;
• Financial and transaction information: this includes payment card details and transaction history;
• Order History and Preferences: Information about past and ongoing order and subscription purchases;
• Subscription Data: Name, email, shipping and billing addresses, and payment details for customers opting into repeat delivery services;
• Loyalty program information: information about your participation in the Flybuys loyalty program; 
• Your preferences and user data: information about You as Our customer and how You engage with Our products and Services. For example, product preferences, transactional data, order history, interests and feedback You provide on Your shopping experience;
• Usage and interaction data: details of how You interact with Our products and Services including Your device’s Internet Protocol address, browser type, browser version, the pages of Our Website that You visit, the time and date of Your visit, unique device identifiers and similar diagnostic data);
• Contact history: details of Your contact and interactions with Us, including customer support contact messages and responses (by chat, email, SMS or social media); and,
• Marketing and communications data: this includes Your marketing preferences, channel preferences, and Your interaction with Our Digital Services and marketing.

4. How personal information is collected and held

We may collect Your Personal Information when You:

• Use Our Services. (Usage and interaction data is collected automatically when using Our Digital Services).
• Create an Account with Us.
• Subscribe to Our Services and promotional and marketing communications.
• Join a membership program or loyalty program provided by Us, such as Flybuys. 
• Make a purchase or subscribe to Repeat Delivery.
• Use your Flybuys and payment cards (i.e. credit card or debit card).
• Interact with Us in various ways, such as via e-mail, phone, online (through Our Digital Services.
• Participate in a promotion, competition or survey.
• Post a review, rating or other content about Us, including online.
• Apply for a position with Us.

If You provide Us with Personal Information which relates to another person (for example, a joint pet owner), You agree that You have received permission from that individual for Us to collect, use, store and disclose it in accordance with this Privacy Policy. We advise You to let them know about this Privacy Policy. 

We may also collect Personal Information from third parties including from:

• Public sources (for example, in public registers or social media);
• Information service providers;
• The parties described in section 7;
• Anyone authorised to act on Your behalf.

We may also generate new Personal Information from time to time – e.g. reports or analysis based on other information We hold about You.

 

6. Direct marketing

Swaggle may use and disclose your personal information in order to inform You of promotions, competitions, giveaways, events, goods or services that may be of interest to You. This may include Swaggle disclosing the information to related companies of Swaggle or other entities with which Swaggle has a commercial relationship or arrangement for the purpose of the other entity contacting You for such direct marketing purposes.

 

7. Do We share Your Personal Information with third parties?

We may share Your Personal Information with third parties who provide services to Us or on Our behalf, including payment handling, marketing, customer service, technology services, data processing, data storage, market research, security, investigations, and professional advice (including legal and accounting).

We often work co-operatively within the Coles Group and may share Personal Information with other members of the Group. Visit coles.com.au to find the Coles Group Privacy Policy.

We are a participating partner in the Flybuys program (Loyalty Pacific Pty Ltd) and share Personal Information with Flybuys. Members of the Flybuys program should ensure they are familiar with the Flybuys privacy policy which can be found on the Flybuys website at http://www.flybuys.com.au/about/#/privacy-policy.

Other third parties We share personal information with include:

• your representatives;
• police, courts, government agencies and lawyers, e.g. in in connection with regulatory and legal investigations and processes; and
• parties involved in business transfer transactions (and prospective transactions).

 

8. Do We share Your Personal Information overseas?

We use systems, customer service teams and service providers located in Australia; and in overseas locations that include EU Member States, Singapore, India, United Kingdom and United States. We may share Personal Information with third parties in these countries. From time to time, this list of countries may change.

 

9. How We protect Your Personal Information?

We understand the importance of safeguarding Your Personal Information. We put in place physical, electronic and governance measures to protect Personal Information from any kind of misuse, interference or loss, and from unauthorised access, modification or disclosure.

Depending on the data and circumstances, the measures We adopt include encryption of data, use of secure servers and networks, security audits, strict access controls and data protection training and awareness for Our employees, affiliates, partners and third parties working on Our behalf.

Please keep in mind that the transmission of information via the Internet is not completely secure. Even though We will take all reasonable steps to safeguard Your Personal Information, We cannot guarantee the security of data transmitted via Our Digital Services.

 

10. Our Digital Services

We operate a range of websites, mobile apps, email services, online advertisements and social media profiles, which are collectively known as ‘Our Digital Services’. We want You to be confident that Your Personal Information is being used to offer You a better and more personalised experience with Us.

Our Website may use cookies. Cookies are small files placed on Your computer or device through your browser.  We and Our Service Providers (including Meta, Google, Algolia, Shopify, Klaviyo, Ordergroove, Microsoft, HotJar, and Amazon Web Services) use cookies and similar technologies such as web beacons, tags and pixels help Us improve the functionality and performance of Our Digital Services, maintain the continuity of Your browsing session, remember Your details and preferences when You return, deliver online advertising that We think is more relevant to You and measure the effectiveness of Our communications. Cookies and similar technologies may also help Us to detect fraudulent activity or prevent security breaches and so We may collect information about Your device from within the cookie.

You may configure Your browser or device to reject and delete cookies, block JavaScript, disable location services and anonymise Your usage patterns. However, in that case some parts of Our Digital Services may not have full functionality. For example, You may not be able to add items to

Your shopping basket, proceed to checkout, or use Our products and Services that require You to sign in.

We use Google Analytics to help analyse how You use Our Digital Services. Google Analytics functions as a cookie and generates statistical information from Your computer or device. The information is used to create reports about the use of Our Website and is retained by Google. Further information on how Google collects and uses data can be found at  https://www.google.com/policies/privacy/partners/. You can choose to prevent Google’s collection and usage of data gathered by cookie files to provide information regarding Your usage of Our Digital Services (including Your IP address) by downloading and installing the browser plugin available. 

 

11. How can You access or correct Your Personal Information?

If You have an Account with Us, You can access and update Your personal information any time by accessing your Account. You also have the right to request access to any other Personal Information that We have about You. To make such a request, please contact Us using relevant contact details set out in section 14.

If You consider any Personal Information We have about You is out-of-date, inaccurate, incomplete, misleading or irrelevant, You have the right to request correction of the Personal Information. To make such a request, please contact Us using relevant contact details set out in section 14.

We may decline Your request to access or correct Your Personal Information in particular circumstances in accordance with applicable law. If We decline Your request, We will generally provide You with a reason for Our decision.

Please include as much detail as possible about the subject of Your request. We will generally provide access, correction or Our reason for refusal within 30 (thirty) days from when We receive Your request.

 

12. How can You make a complaint?

If You have any questions or complaints about how We have handled Your Personal Information or about this Privacy Policy, You may contact Us using the relevant contact details set out in section 14.

Please include as much detail as You can about the subject of Your complaint. We will generally respond to Your complaint within 30 days from when We receive Your complaint.

If You are not satisfied with Our response to Your complaint, You have the right to make a complaint to the Office of the Australian Information Commissioner. The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992 or You can fill out this Privacy Complaint Form to make a complaint.

More information about the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.

 

13. Amendments to Privacy Policy

Any amendments We may make to Our Privacy Policy will be posted on this Website. We recommend that You check this Privacy Policy from time to time for any changes. 

 

14. How can You contact Us?

You can contact Us using the details below:

E-mail: support@swaggle.com.au

Postal Address: 800 Toorak Road, Hawthorn East, VIC 3123