Escape to Paradise Privacy Policy

Introduction
Escape to Paradise Pty Ltd and its related bodies corporate (“ETP”) are committed to managing your personal information openly and transparently and to keeping your personal information safe. We want our customers to visit our site with confidence that their personal information is safe and that they know how we gather, manage, and use their information.

We will take all necessary measures to fulfil this commitment, including to:
• comply with the Australian Privacy Principles ("APPs");
• ensure that we manage your personal information openly and transparently;
• only collect personal information from you that we need in order to offer you the best possible service and customer experience;
• tell you how we might use your personal information;
• let you know if we need to disclose your personal information to anyone else (including anyone overseas) and if so, in what circumstances this might occur;
• keep your personal information secure;
• promptly respond to any request by you not to receive direct marketing material from us;
• make sure your personal information is kept accurate and up to date and to properly dispose of any personal information which is no longer required by us; and
• ensure that, where appropriate, you can access and correct your personal information.

The Purpose of this Policy
This privacy policy (“Privacy Policy”) is intended to explain clearly and in plain language some of the key processes and procedures that we have implemented to manage your personal information, to protect your privacy and to comply with the Privacy Act 1988, the Privacy Amendment (Enhancing Privacy Protection) Act 2012 ("Act") and the Australian Privacy Principles.
References to "our", "us" and "we" in this policy are references to ETP. ETP operates from locations in Australia and internationally. Our Australian website, www.escapetoparadise.com.au (the "Website"), is owned and administered by Escape to Paradise Pty Ltd.

Your Consent to this Policy
You must read the Privacy Policy before providing us with any personal information or using the Website. By providing us with your personal information or by using the Website, you are confirming your consent and agreement to the policies and procedures described in this Privacy Policy and the Terms of Use of the Website.

What types of personal information do we collect?
We will only collect from you information that is necessary and relevant to our relationship with you, including to enable us to provide to you the best possible service and customer experience.

Depending on the exact nature of our relationship with you, we may request that you provide, or we may collect through your activity on the Website, some or all of the following information:
• information that we may require to initially identify you, including your name, home address and your date of birth;
• information that we can use to contact you, including your telephone number, mobile number, email address, work address, mailing or delivery address;
• information we may require to confirm your identity, including your driver's licence number, passport details, or business name;
• information that may assist us to confirm your financial position or credit history when you are considering a finance or credit arrangement, including your credit card details, bank details, purchase history or transaction details and loan and credit information where finance arrangements apply;
• your location details through your smart phone or device;
• details of your communications and interactions with us, including log information such as your IP address, access dates and times, browser type and pages visited when you interact with the Website;
• transaction details, including the products you have ordered, the date and time of your order and the amount charged;
• usage and preference information we collect information about how you interact with the Website, including the pages you visit, your preferences and settings that you choose, which we may do this through the use of cookies and other similar technologies that uniquely identify you.
We may not need to collect all the above information from you, and the information we will require will depend on the specific goods or services that we are providing to you. We will only collect personal information from you that we reasonably require for the purposes of satisfactorily performing the services that you require.

The Act places restrictions on us collecting sensitive information about you (including information about your religion, political views, ethnicity, biometric data, criminal records and sexual preferences). Generally we will not collect this type of information. However, we may need to collect some sensitive information if you are applying for a job with us, and you have provided us with your consent to collect such information.

We may also collect from (and share with) third parties deidentified data for data analysis purposes, and inferred information and characteristics as a result of undertaking data analysis.

Why do we require your personal information?
There are various reasons why we might need to collect, hold, use or disclose your personal information and this will depend upon the specific services that we are providing to you. At the time that we collect your personal information, we will make it clear to you why we are collecting your information, including through this Privacy Policy where appropriate. We will not use your personal information for any other purpose without your consent or where we do use your information for another purpose, it will either be for a purpose which we believe is related to the purpose for which you first provided us with the information or for a purpose which you would expect.

Usually, the primary purpose that we will need to collect your personal information will be relating to a service or goods that we are providing to you or are about to provide to you and for contacting you in relation to those services. Our main services include the sale and delivery of goods; providing a forum for product and service reviews and feedback; providing information and responding to queries, support requests and warranty claims in relation to our goods and services.

We may also use your personal information for other business reasons, including:
• to contact you in relation to an event, special offer or product that you might be interested in;
• preventing fraud and other criminal activities;
• to assist us to run our business and to improve our services and performance, including staff training, accounting, risk management, record keeping, archiving, systems development, developing new products and services and undertaking planning, research and statistical analysis; and
• to comply with our legal obligations.

Do you have to provide us with your personal information?
There is no obligation for you to provide us with any of your personal information but if you choose not to provide us with your personal information, we may not be able to provide the information, goods or services that you require.
How do we collect your personal information?
The means by which we collect your personal information will depend on the nature of the service that we are providing to you.
We may collect your personal information:
• directly from you, either in person or over the phone;
• when you place an order via the Website;
• when you interact with the Website; or
• from other sources.

We will always collect your personal information directly from you unless it is impracticable to do so. This would usually be done through the Website when you elect to disclose your personal information to us for a particular purpose.

Your personal information will not be collected if you are only browsing the Website, but we do use cookies to better tailor our information and our services to meet your needs. A cookie is a small piece of text that is placed within the memory of a computer and can be later retrieved by web page servers. Cookies are used to enhance your interaction and convenience in using the Website and we do not use cookies to record any of your personal information. Cookies may record information about your visit, including the type of browser and operating system you use, the previous site you visited, your server’s IP address, the pages you access and the information downloaded by you. While this anonymous statistical data may be aggregated and used in broader statistical analysis by us and our web monitoring service provider to improve our services, at no time can we personally identify you as the source of that data.

Where we are collecting your personal information, we will remind you of the following regarding the collection your personal information:
• our details, including our contact details and how you may contact us regarding privacy matters;
• that we are collecting your information and the reasons why we are collecting your information;
• if the collection is required or authorised by law, the details of the law, court or tribunal order;
• what happens if we cannot collect your personal information;
• any third parties to whom we may disclose the personal information;
• how you can access and correct your personal information;
• how you can complain about any breach of the APPs and how we will handle any such complaints; and
• whether your personal information is likely to be disclosed to anyone overseas and if practicable, the countries in which those recipients are located.

Collecting and disclosing personal information about others
Wherever possible, we will collect personal information directly from the relevant individual to whom that information relates.

You represent and warrant to us that where you provide personal information to us about another person:
(a) you are authorised to provide that information to us;
(b) you have obtained the express consent of the individual to disclose their personal information to us for its relevant use, including for use in our business and to provide our goods or services;
(c) you have complied with the APPs in collecting that personal information, including by making all relevant notifications required under APP 5; and
(d) you have informed that person about the contents of this Privacy Policy including who we are, how we use and disclose personal information, and that they can gain access to, and correct, that information.

Unsolicited personal information
Occasionally we may receive personal information about you that we have not requested or taken steps to acquire. In these circumstances, we will only hold onto such information where the information is necessary in our dealings with you. If we determine that the information received is not necessary to our relationship with you, then we will take steps to de-identify or destroy the information as soon as is practicable. Any determination as to whether or not we are required to retain any such unsolicited information will be made within a reasonable period after we receive the information. Any information that has not been requested by us, but is subsequently retained by us will be subject to the procedures and requirements set out in this Privacy Policy.

Children
Personal information will not be collected by any person who is known by us to be under the age of eighteen (18) without the consent of a parent or legal guardian. Persons under age eighteen (18) may only provide personal information with the involvement and consent of a parent or legal guardian.
How do we use or disclose your personal information?
We may use and disclose your personal information for the purposes for which it was collected or for a related purpose such as:
• to set up and activate your account with ETP;
• to consider your request for a product or service;
• to enable us to provide a product or a service to you;
• to coordinate delivery of your goods;
• to facilitate and process your orders and payments;
• to carry out or respond to your queries or requests;
• to provide information to you that you have requested;
• to provide additional information to you as requested by you and to respond to your queries about our products;
• to facilitate your entry into competitions, contests or promotions run through the Website;
• to facilitate online chat;
• to any third party suppliers of our goods or services, including third party application owners or licensors;
• to any third party credit provider to facilitate the provision of credit to you as required;
• to our third party service providers to assist us in providing and improving our services to you, and to analyse trends in sales and better understand your needs or to develop, improve and market our products and services to you;
• for regulatory reporting and compliance with our legal obligations;
• to relevant third parties to undertake fraud prevention efforts;
• to various regulatory bodies and law enforcement officials and agencies to protect against fraud and for related security purposes;
• to perform administrative and operational tasks (including risk management, systems development and testing, staff training and collecting debts);
• to facilitate product reviews and to seek your feedback in relation to particular products, customer satisfaction and our relationship with you and to manage any customer complaints;
• for use in direct marketing of promotions, products and services that we think might be of interest to you, including to add to a database compiled by us for this purpose;
• to our third party service providers, for use in direct marketing of promotions, products and services that our third party service providers think may be of interest to you, including to add to a database complied for this purpose;
• to Escape to Paradise Pty Ltd, and other ETP parents, subsidiaries or related entities ("ETP Related Parties") for the direct marketing by those ETP Related

Parties of promotions, products and services offered by those ETP Related Parties;
• to monitor or improve the quality and standard of service that we provide to you;
• to consider any concerns or complaints you may raise against us;
• to our agents, successors and/or assigns;
• to notify you of offers that may be of interest to you; and
• to better understand your preferences.

By agreeing to accept the terms of this Privacy Policy or by providing your personal information to us, or both, you are taken to have consented to the use and disclosure of your personal information for the above purposes.

We may also provide your personal information to third parties as outlined in this Privacy Policy. Other than as outlined in this Privacy Policy or in any notice provided to you at the time of collecting your personal information, we will not disclose your personal information without your consent unless disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate any suspected unlawful activity.

Do we share your personal information with others?
We may share your personal information with ETP Related Parties or with other companies that are third-party service providers to ETP Related Parties. By agreeing to accept the terms of this Privacy Policy or by providing your personal information to us, or both, you consent to your personal information being shared with our related entities and with any one or more of the ETP Related Parties or their service providers.

We deal with third party service providers who may assist us with a variety of functions including with research, mail and delivery, security, insurance, professional advisory (including legal, accounting and auditing advice), banking, payment processing, facilitating credit arrangements, credit reporting, fraud checks, data storage, information processing, order tracking, marketing, analytics, marketing, product reviews, online competitions, responding to customer queries and complaints or technology services. By agreeing to accept the terms of this Privacy Policy or by providing your personal information to us, or both, you are deemed to have consented to us disclosing your personal information to our third-party service providers. Where we engage third party service providers to perform services for us, those third parties may be required to handle or deal with your personal information. Under these circumstances, those third parties must safeguard this information and must only use it for the purposes for which it was supplied and we will make all reasonable enquiries to try to ensure that this is the case.

Wherever possible, we will limit the information provided to independent third parties to that information required for those third parties to properly perform their functions. Further, our contracts with these third parties will always require the third parties to comply with the APPs (or equivalent standards).
If we or a ETP Related Party merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this privacy policy.

How may we use your personal information for marketing purposes?
As part of the services that we provide to you, we may:
• use personal information that we have collected to identify a product or service that may benefit you;
• contact you from time to time to let you know about a product or service that we believe you might be interested in; and
• disclose your personal information to the ETP Related Parties or to our third party business partners to enable them to tell you about a product or service that you might be interested in.

By providing your personal information to us or by agreeing to accept the terms of this Privacy Policy, or both, you consent to your personal information being included in our database to be used for direct marketing purposes, including those described above. However, you can opt-out, unsubscribe or make a request to not receive direct marketing communications from us, by writing to us by email at:

admin@escapetoparadise.com.au
ATTN: OPT-OUT REQUEST

You may make a request that we do not disclose your personal information to facilitate direct marketing by another company and you may request that we provide you with the source of any personal information we use for direct marketing purposes. Any such requests will be actioned within a reasonable period and there will be no charges to you for making such requests.
Additionally, each direct marketing communication, including all emails and SMS, will include an opt-out or "unsubscribe" option which will immediately indicate to us that you no longer wish to receive materials of this kind. If you make a request not to receive direct marketing communications from us, we will stop sending you these materials.

How do we store your personal information?
We have implemented appropriate processes and techniques (including physical security such as locks and security systems and computer and network security, including firewalls and passwords) to protect personal information from loss, misuse and interference and from unauthorised access, modification or disclosure. In addition, access to your personal information is limited to those who specifically need it to conduct their responsibilities.
We and our third-party service providers take all necessary steps to destroy or permanently de-identify your personal information where it is no longer required and to protect your personal information from loss, misuse and interference and from unauthorised access, modification or disclosure.
While care is taken to protect your personal information on the Website, unfortunately no data transmission over the Internet is guaranteed as 100% secure. Therefore, we cannot guarantee, ensure or warrant the security of any information you send to us or receive from us online. This is particularly true for information you send to us via email, which may be unencrypted and for which we have no way of protecting that information until it reaches us. Once we receive your personal information, we are required to protect it in accordance with the Act.

Maintaining your personal information
We take reasonable steps to ensure that:
• the information that we collect about you is accurate, complete and up-to-date at the time of collection;
• when we use your personal information, it is accurate, up-to-date, complete and accurate at the time of use; and
• if we disclose your personal information, it is accurate, up-to-date, complete and accurate at the time of disclosure.

Will we disclose your personal information to anyone overseas?
There may be circumstances where we need to disclose personal information that we hold about you to international ETP Related Parties, or a third party overseas ("Overseas Recipients"). This may occur, for example, where we, or one of our service providers, have a database or server hosted outside Australia or where you are interacting with an application which is based overseas.

Prior to us disclosing your personal information to a ETP Related Party or an Overseas Recipient, we have an obligation under APP 8.1 to take reasonable steps to ensure that the ETP Related Party or the Overseas
Recipient does not breach the APPs in relation to your personal information, as well as an obligation under APP 6 to only disclose your personal information to an Overseas Recipient for the primary purpose for which that personal information was collected (unless an exception applies under APP 6) (the "Overseas Disclosure Obligations").

We will take all reasonable steps to satisfy our Overseas Disclosure Obligations.

How can you access your personal information?
We are committed to and take all reasonable steps to maintain accurate, timely, relevant, complete and appropriate information about our customers and Website users. You may request access to personal information about you held by us. Requests for access to your personal information should be made to:

admin@escapetoparadise.com.au
ATTN: PRIVACY DATA REQUEST

Verification of identity is required with a request to access (or update) personal information so that we can ensure your personal information is disclosed only to you. Inaccurate information will be corrected upon receiving appropriate correcting from you. Where you request access to your personal information, we will respond to any such request within a reasonable period after the request is made and if possible, we will provide you with access to your information in the manner requested by you, if specified. If we refuse to provide you with access to or correct the personal information held about you by us, then we will provide reasons for such refusal as well as a procedure to complain about the refusal. In any event, we will take all reasonable steps to give you access to your information in a way that meets your needs.

We are not responsible for removing your personal information from the lists or databases of any third party who has previously been provided your information in accordance with this Privacy Policy.

There are some limited circumstances in which we may not be able to provide you with access to your personal information when requested. Such circumstances might include where access would pose a serious threat to the life, health or safety of another person or where such access would unreasonably impact on the privacy of others.

We may recover from you our reasonable costs of supplying you with access to your personal information, but we will not charge you for any request you might make to access your information.

How can you seek to correct your personal information?
We take efforts to ensure that the information we hold about you is accurate, complete, up-to-date, relevant and not misleading. To assist us to do this, please ensure that you provide us with correct information at the time you provide it to us and immediately inform us if your details change at any time. If we are concerned that any of your information is inaccurate, incomplete, out-of-date, irrelevant or misleading, or if you request that we correct any of your information, then we will take all reasonable steps to correct the information to ensure that it is accurate, complete, up-to-date, relevant and not misleading in the context of the purpose for which it is held.

If we correct any of your personal information and that information has previously been disclosed to another entity that is required to comply with the APPs, then, upon your request to do so, we will take reasonable steps to notify that other entity of the correction unless such notification is impracticable or unlawful.
If we refuse to correct your personal information following a request by you to do so, then we will provide you with the reason for such refusal and information regarding the procedure to complain about the refusal.

If we refuse to correct your personal information following a request by you to do so and you request that we associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading then we will take reasonable steps to associate the statement with the information so that the statement is apparent to users of the information.

We will respond to any requests regarding the correction of your personal information within a reasonable period after the request is made.

We will not charge you for any request to correct your personal information, nor will we pass on to you any costs incurred by us in correcting your personal information or for associating a statement with your personal information.
Complaints or Questions about our Privacy Policy

We are committed to maintaining and protecting your privacy. If you are concerned with the way your personal information has been handled then you are entitled to make a complaint or ask us about our Privacy Policy. Please contact us through our Privacy Compliance Officer, by email at:

admin@escapetoparadise.com.au
ATTN: PRIVACY COMPLIANCE

If your personal information has not been handled in an appropriate way, we will do our best to remedy your concerns as quickly as possible, including by acknowledging receipt of your complaint and trying to resolve the complaint within a reasonable time. Where this is not possible, we will contact you within this period to let you know an anticipated time frame within which your complaint will be resolved.

If your complaint is not satisfactorily resolved, you may approach an external dispute resolution service or apply to the Office of the Australian Information Commissioner ("OAIC") to have the complaint heard and determined.
For information about privacy generally, you may visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.

Protecting your identity
Wherever it is practicable, we will always provide you with the option not to identify yourself when dealing with us. Alternatively, you may elect to use a pseudonym to protect your identity.

Links to other websites
This Website may contain links to websites which are owned or operated by other parties. You should make your own enquiries as to the privacy policies of these parties. We are not responsible for information on, or the privacy practices of, such websites.

Changes to this policy
From time-to-time it may be necessary for us to review and revise this Privacy Policy. We reserve the right to change our Privacy Policy at any time.

How can you contact us?
Please find below our contact details. Please do not hesitate to contact us in relation to any privacy-related concerns and we will address any such concerns thoroughly and in a timely manner.

If it is practical to do so, you can contact us without identifying yourself. However, if you choose not to identify yourself, it may be more difficult for us to assist you with your enquiry. This will depend on the nature of your enquiry.

admin@escapetoparadise.com.au
ATTN: PRIVACY COMPLIANCE

Please note that the Act contains certain exemptions which may permit us to use your personal information in a particular way if specific circumstances arise. Any such exemptions under the Act will take priority over this Privacy Policy to the extent of any inconsistency.

Your express consent to collection, storage, use and disclosure of your Personal Information

In addition to the other consents provided by you above, by agreeing to accept the terms of this Privacy Policy, or by providing your personal information to us, or both, you are deemed to have expressly consented to the collection, storage, use and disclosure of your personal information for each of the purposes and to all of the parties outlined in this Privacy Policy.

Text message/SMS program terms
We occassionally offer our customers mobile alerts about order and shipping updates and other marketing messages about events, new products, and other offers by SMS message (the "SMS Service"). By participating in the SMS Service, you are agreeing to these Terms and to the Privacy Policy.

Signing Up and Opting-In to the SMS Service
Enrolment in the SMS Service requires you to provide your mobile phone number and to agree to these terms and conditions. You may not enrol if you are under 18 years old. Before the SMS Service will start, you will need to verify the mobile phone number you provided by responding to a text message to your mobile phone that affirms your choice to opt-in to this SMS Service and your agreement to these Terms. We reserve the right to stop offering the SMS Service at any time with or without notice.

By opting into the SMS Service, you:
Authorise Us to use autodialer or non-autodialer technology to send text messages to the mobile phone number associated with your opt-in (i.e., the number listed on the opt-in form or, if none, the number from which you send the opt-in, or, if none, the number on file for the account associated with your opt-in);
Acknowledge that you do not have to agree to receive messages as a condition of purchase;
Confirm that you are the subscriber to the relevant phone number or that you are the customary user of that number on a family or business plan and that you are authorised to opt in; and
Consent to the use of an electronic record to document your opt-in.

To request a free paper or email copy of the opt-in or to update our records with your contact information, please email us at admin@escapetoparadise.com.au. To view and retain an electronic copy of these Terms or the rest of your opt-in, you will need (i) a device (such as a computer or mobile phone) with Internet access, and (ii) and either a printer or storage space on such device. For an email copy, you'll also need an email account you can access from the device, along with a browser or other software that can display the emails.

Messages You May Receive
Once you affirm your choice to opt into the SMS Service, your message frequency may vary. You may receive an alert when:
You are welcomed into the SMS Service;
An order has been placed;
An order has been delivered;
An item or items has shipped;
An item or items are ready for an in-store pick up; and
There are general marketing or promotions.

Charges and Carriers
Message and data rates may apply. Please consult your SMS Service agreement with your wireless carrier or contact your wireless carrier to determine your phone's pricing plan and the charges for sending and receiving text messages. You acknowledge that you are responsible for any message, data or other charges incurred (usage, subscription, etc.) as a result of using the SMS Service.
The SMS Service may not be available on all wireless carriers. We may add or remove any wireless carrier from the SMS Service at any time without notice. We and mobile carriers are not responsible for any undue delays, failure of delivery, or errors in messages.

To Stop the SMS Service
To stop receiving text messages from Us, click the UNSUBSCRIBE link in any of the text messages you have received from Us. Your opt-out request may generate either a confirmation text or a texted request to clarify the text message program to which it applies (if you have more than one). To complete your opt-out, please provide the requested clarification. You acknowledge that the text message platform may not recognise and respond to unsubscribe requests that aren’t actioned through the provided UNSUBSCRIBE link and agree that We and our SMS Service providers will have no liability for failing to honour such requests. If you unsubscribe from one of our text message programs, you may continue to receive text messages from Us through any other programs you have joined until you separately unsubscribe from those programs. These Terms still will apply if you withdraw the consent mentioned above or opt out of the SMS Service.

Questions About the SMS Service
You can email SMS HELP to admin@escapetoparadise.com.au for help at any time. This will provide you a link to the terms and conditions along with a phone number to call for assistance.

Mobile Phone Number Change
In the event that you change or deactivate your mobile phone number, you agree to notify us by emailing admin@escapetoparadise.com.au