Privacy policy
1 Your rights in relation to privacy
Make My Shave Pty Ltd ACN 654547181 trading as Make My Shave (Make My Shave) understands the importance of protecting the privacy of an individual’s personal information. This policy sets out how Make My Shave aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Make My Shave and the way Make My Shave collects, holds, uses and discloses your personal information.
In handling your personal information, Make My Shave complies with the Privacy Act 1988 (Cth) (Privacy Act), the 13 Australian Privacy Principles in the Privacy Act and all relevant Australian privacy laws.
This policy may be updated from time to time.
2 What kinds of personal information does Make My Shave collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its products and/or subscription services, Make My Shave may collect your personal information.
Generally, the kinds of personal information Make My Shave collects are:
(a) contact and identification information such as your name, address, telephone number and email address;
(b) where you are acting on behalf of another entity (whether as an employee, director or other representative), details of that entity and your relationship with it;
(c) banking details and financial information as required for Make My Shave’s functions and activities, for example, to facilitate payments through our online subscription services and in respect of third party payment providers engaged by Make My Shave;
(d) other information required for Make My Shave’s functions and activities.
In some circumstances Make My Shave may also hold other personal information provided by you.
3 How does Make My Shave collect personal information?
Generally, Make My Shave collects your personal information directly from you, through the completion of an online form or product ordering process through our website. We may also collect your personal information through an interaction or exchange in person or by way of telephone, email, or post.
There may be occasions when Make My Shave collects your personal information from other sources such as from:
(a) an entity you represent (including but not limited to your employer or a company of which you are a director), where necessary for Make My Shave to provide its products or subscription services to that entity through you or where necessary for that entity to supply products or services to Make My Shave;
(b) organisations that facilitate payment or identity verification services in connection with your use of our subscription services and website;
(c) an information services provider;
(d) a publicly maintained record or other publicly available sources of information including social media and similar websites, such as Facebook;
(e) a government agency.
Generally, Make My Shave will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.
4 Why does Make My Shave need your personal information?
Make My Shave collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:
(a) providing the subscription services and shaving products you have requested, ordered or purchased from Make My Shave including:
(i) to enable us to process your subscription and deliver you the razor and shaving products we may agree to supply you from time to time;
(ii) to enable access to our website, and provide associated services;
(iii) to process transactions you may enter with us via our website from time to time;
(iv) for invoicing purposes;
(v) to respond to any inquiries, feedback or complaints made by you;
(b) enabling Make My Shave to promote its products and services to you;
(c) assisting Make My Shave to improve its products and services, including through Make My Shave undertaking environmental and carbon offset initiatives from time to time;
(d) processing and assessing employment applications for current and future positions;
(e) accounting, billing and other internal administrative purposes;
(f) understanding a supplier’s capacity to service Make My Shave’s needs, including manufacturing razor and shaving products for supply to consumers; and
(g) emailing newsletter registration.
Make My Shave may also use your personal information for purposes related to the above purposes and for which you would reasonably expect Make My Shave to do so in the circumstances, or where you have consented, or the use is otherwise in accordance with law.
The principal legal grounds for Make My Shave’s use and disclosure of your personal information are as follows:
■ Consent: where you have consented to Make My Shave’s use or disclosure of your personal information.
■ Contract performance: where Make My Shave is required to collect and handle your personal information in order to provide you (or the organisation you represent) with the products and services that Make My Shave has contractually agreed to provide to you (including through subscription services for razor and shaving products we may supply you from time to time);
■ Legal obligation: where Make My Shave needs to use or disclose your personal information to comply with its legal obligations.
Where personal information is used or disclosed, Make My Shave takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Make My Shave. However, without certain information from you, Make My Shave may not be able to provide its products and/or services to you.
5 To whom does Make My Shave disclose your personal information?
Make My Shave discloses your personal information for the purpose for which Make My Shave collects it. That is, generally, Make My Shave will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to:
(a) third parties engaged to perform administrative or other business management functions, including debtor management, delivery and courier companies, shipping agents, call centres, mailing houses, financial institutions, and web-hosting organisations;
(b) Make My Shave’s professional advisors, agents, contractors, consultants and related bodies corporate;
(c) Third party service providers (including Shopify) and applications relevant to the functionality and operation of the website located at www.makemyshave.com.au;
(d) insurance providers;
(e) recruitment and labour hire agencies (as required).
Make My Shave’s disclosures of your personal information to third parties are on a confidential basis and/or otherwise in accordance with law. Make My Shave may also disclose your personal information with your consent or if disclosure is required or authorised by law.
6 Direct marketing
Make My Shave may use and disclose your personal information to inform you of products and services that may be of interest to you. From time to time we will run ads or promotions that may require you to provide your details. In the event you do not wish to receive such communications, you can opt-out by contacting Make My Shave via the contact details or through any opt-out mechanism contained in a marketing communication to you.
7 Security of your personal information
Make My Shave takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference, and loss and from unauthorised access, modification, or disclosure. Make My Shave holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.
Make My Shave will destroy or de-identify personal information in circumstances where it is no longer required, unless Make My Shave is otherwise required or authorised by law to retain the information.
8 Can you access and correct the personal information that Make My Shave holds about you?
Make My Shave takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by Make My Shave. If at any time you would like to access or correct the personal information that Make My Shave holds about you, or you would like more information on Make My Shave’s approach to privacy, please contact Make My Shave’s Privacy Compliance Officer on the details set out in paragraph 11 below.
Make My Shave will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
(a) you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
(b) Make My Shave requests that you be reasonably specific about the information you require; and
(c) Make My Shave may charge you a reasonable administration fee, which reflects the cost to Make My Shave for providing access in accordance with your request.
Make My Shave will endeavour to respond to your request to access or correct your personal information within 30 days from your request.
9 Links
Make My Shave’s website may, from time to time, contain links to the websites of other organisations which may be of interest to you. Such links are provided as a convenience to you and should not in any way be interpreted as an endorsement of any company, content or product that may be linked. Any access to a third party website that is linked to Make My Shave’s website is at your own risk and Make My Shave has no control over and is not responsible for the accuracy, validity or ownership of any content of a linked site and the privacy practices of those linked websites. You should check those websites for their respective Privacy Policies.
10 Cookies
Make My Shave’s website uses ‘cookies’ which are small pieces of information sent from the website and stored by your browser on your computer’s hard drive. Cookies that Make My Shave uses enable its systems to provide features of its services and allow you to visit its website without re-entering your username and/or password, personalise and improve your experience, and to improve the functionality and user-friendliness of its services and monitor how its website is used through your computer.
This information is used by Make My Shave to improve and tailor its website functionality and better understand how you interact with Make My Shave’s services and to monitor aggregate usage and web traffic routing on its website. You can modify your browser setting by editing your browser options to reject Make My Shave’s cookies or to prompt you before accepting a cookie. However, if a browser does not accept cookies or if you reject a cookie, some portions of Make My Shave’s online services may not function properly.
11 How to contact us
For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications, please contact Make My Shave’s Privacy Compliance Officer at:
hello@makemyshave.com.au
Make My Shave Pty Ltd
P.O. BOX 364 MIAMI, QLD 4220, AUSTRALIA
12 Privacy complaints
Please direct all privacy complaints to Make My Shave’s Privacy Compliance Officer. At all times, privacy complaints:
(a) will be treated seriously;
(b) will be dealt with promptly;
(c) will be dealt with in a confidential manner; and
(d) will not affect your existing obligations or affect the commercial arrangements between you and Make My Shave.
Make My Shave’s Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.