Overview
This Privacy Policy (‘the Privacy Policy’) applies to Smileflex ABN 92 406 109 452, (“Smileflex”, “we”, “us” and “our”) and outlines in general terms how we collect, manage, use and disclose Personal Information.
We define “Personal Information” as information that is associated with a specific person and can be used to reasonably identify that person. Personal Information does not include information that has been made anonymous, and cannot reasonably identify a specific person.
We maintain the website and associated features and mobile applications located at smileflex.com.au (collectively the “Website”).
Unless stated otherwise, this policy does not apply to third-party websites, products, or services, even if they link to our Website, and you should consider the privacy practices of those third-parties carefully.
By visiting and continuing to access our Website, you are agreeing to the terms and conditions set out in this policy.
The types of Personal Information that we collect about you will depend on our association with you, and may include the following:
- Your name, gender, date of birth, contact details, photos;
- Your financial information, including your bank account and credit card details;
- Any other information that we may need to identify you as well as any information that you provide to us on our Website.
We may collect Personal Information where you input information into our Website, purchase our goods, sign up to our newsletter, and/or from cookies and traffic data.
Usage of Your Personal Information
We may use your Personal Information in the following ways:
- To provide you with our goods and services;
- To improve our goods and services;
- To send you updates and promotional information relating to our products;
- For research purposes. Some of the data provided may be de-identified (e.g. no name or reference to data from which you are reasonably likely to be re-identified by); and
- To maintain records and comply with our legal obligations.
Disclosure of Your Personal Information
We may disclose your Personal Information to:
- Our employees, contractors and third-party service providers. This includes social network providers, payment providers (e.g. for goods purchased from us with others that may manage our brand or product promotions) and for others that may develop or maintain our systems or technology which will enable us to enhance and better our offering for your continued use;
- Those parties who we are required to provide your Personal Information to by law (eg. to comply with a court order, prevent illegal use or to defend third-party claims);
- Associated businesses that may wish to market products to you; and
- For research purposes. Some of the data provided may be de-identified (e.g. no name or reference to data from which you are reasonably likely to be re-identified by).
Instalment Payment Providers
In some cases, we act as an intermediary for your nominated Instalment Payment Provider (e.g. Afterpay and Paypal) in order to facilitate the processing of your instalment payment in relation to any products you purchase from us, which shall include but is not limited to verifying your identity. To the extent necessary, you explicitly consent to Smileflex disclosing your Personal Information, including any information derived from your credit information, to your payment provider.
Smileflex does not provide any Personal Information to any credit reporting bodies unless required by law. However, your nominated instalment payment provider may perform credit checks and may disclose your credit information to one or more credit reporting bodies. For further information, refer to the payment providers' privacy policies here: Afterpay Privacy Policy and Paypal Privacy Policy.
Direct Marketing (Opt-Out)
From time to time we may use your personal information to provide you with current information about offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company with whom we are associated.
If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting us through privacy@smileflex.com.au. If the direct marketing is by email you may also use the unsubscribe function. We will take all reasonable steps to meet your request at the earliest possible opportunity.
Data Security
We have adopted a number of measures to ensure that the security of your personal information is maintained. Such measures include:
- The adoption of internal practices, procedures and systems — this includes the training of staff with respect to the risks and threats to personal information, providing them with access to our internal policies and procedures on this issue and taking disciplinary action if they are found to have breached our policies;
- Access security — we ensure that access to personal information is provided on a ‘need to know’ basis and is secured with password protection;
- Destruction and de-identification — when we no longer need your personal information for the purposes detailed in this policy or as required by law, we will take reasonable steps to destroy or de-identify the personal information that we have collected.
We may combine personal information we receive about you with other information we hold about you. This includes information received from our partners or third-parties. Secure Sockets Layer (SSL) encrypts the information you send through our Website.
Cookies
Cookies are small files we send through your web browser that are stored on your computer. We use cookies for the following reasons:
- Enhance your online website experience;
- To track and report on website usage; and
- To personalise your experience and make it easier for you to use our services.
At any time, you can change your browser’s cookie settings via your browser's privacy settings.
Third-Party Website Links
From time to time, we may provide hyperlinks to third-party websites that we do not control. We do not accept any responsibility nor make any warranties with respect to the collection, use, disclosure and storage of your personal information when accessing those websites. It is your responsibility to review the privacy policies of the websites that you are accessing.
Our Website currently contains links to the following social media providers: Facebook, Instagram and YouTube via the relevant social media buttons. In order to avoid unwanted transfer of your usage data (e.g., address of the currently visited page) to these services, you will only be able to access them by clicking on the link. The aforementioned social networks may themselves collect usage and possibly user data. We have no control over the data collected and data processing activities, nor are we aware of how much data is collected, the purposes of processing or the storage periods. Nor do we have any information on the erasure of the data collected by the plugin provider.
Your browser may not establish a direct connection to the servers of the aforementioned services until you click on the links. This means that the information that you have visited our website is indirectly (referrer) forwarded to these services. If you are already logged in to the service with your personal user account during your visit to our Website, you can usually click on the social media buttons to "share" the content or leave a comment, etc. If you do not wish any such data transfer, we advise against clicking on the social media buttons.
The purpose and scope of data collection by social media services, as well as the further processing and use of your data there and your rights and options for setting your privacy preferences can be found in the privacy policies for these services.
Access and Correction
You may seek to access, delete (where permitted by law) or correct Personal Information which we hold about you. We will provide that access in accordance with the applicable laws, however there are certain exemptions, which may apply to the provision of that information.
If we have obtained your consent to process certain Personal Information, you may withdraw your consent at any time. If you would like to obtain access to or correct personal information, you can contact us at the following:
Postal Address: PO Box 99, Clifton Hill VIC 3068, Australia.
Email Address: privacy@smileflex.com.au
Complaints or Disputes
If you have any concerns or complaints about your privacy and the Australian Privacy Principles, or you have any queries on how your Personal Information is collected or used please contact us at privacy@smileflex.com.au.
We will respond to your query or complaint within a reasonable time. If you are dissatisfied with our response, you may make a complaint to the Office of the Australian Information Commissioner (OAIC) at either www.oaic.gov.au or 1300 363 992.
Privacy Policy Changes
This policy may change at any time and in this event, we will post a notification on our Website. This privacy policy was last updated in October 2021.
