Privacy Policy

Privacy Commitment

Country Road Group Pty Ltd ACN 006 759 182 and its Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth)) (“we”, “our” or “us”) recognise the trust you are placing in us through your dealings with us. We do everything we can to maintain that trust. Our staff are employed on the basis that they will protect information about you. Your rights to privacy are also protected by the Australian Privacy Principles in force under the Privacy Act 1988 (Cth) and if you are in a country that is a member of the European Economic Area, your rights to privacy are protected under the General Data Protection Regulation (“GDPR”). These privacy laws place strict requirements on us to treat certain information collected as confidential, to store your information securely and to allow you easy access to check and correct your information.

Country Road Group Pty Ltd ACN 006 759 182 and its Related Bodies Corporate (as defined in the Corporations Act 2001 (Cth)) (“we”, “our” or “us”) recognise the trust you are placing in us through your dealings with us. We do everything we can to maintain that trust. Our staff are employed on the basis that they will protect information about you. Your rights to privacy are also protected by the Australian Privacy Principles in force under the Privacy Act 1988 (Cth) and the Privacy Act 2020 (NZ). If you are in a country that is a member of the European Economic Area, your rights to privacy are protected under the General Data Protection Regulation (“GDPR”). These privacy laws place strict requirements on us to treat certain information collected as confidential, to store your information securely and to allow you easy access to check and correct your information.

Scope Of Our Privacy Policy

Our Privacy Policy applies to the personal information we collect, store, maintain and use about you as our customers, visitors to our website, our social media pages, or our mobile apps and other digital services (“Online Services”), or visitors to our stores, or members of the public. Our Privacy Policy applies to all of the brands owned by us from time to time, including, but not limited to, Country Road, Trenery, Witchery, Politix and Mimco (“Our Brands”). Personal information we collect from job applicants as part of our recruitment process is governed by our Privacy Statement.

Our Privacy Policy applies to the personal information we collect, store, maintain and use about you as our customers, visitors to our website, our social media pages and other digital services (“Online Services”), or visitors to our stores, or members of the public. Our Privacy Policy applies to all of the brands owned by us from time to time, including, but not limited to, Country Road, Trenery, Witchery, Politix and Mimco (“Our Brands”). Personal information we collect from job applicants as part of our recruitment process is governed by our Privacy Statement.

Demerging With David Jones

David Jones (ABN 75 000 074 573) is no longer our Related Body Corporate (as defined in the Corporations Act 2001 (Cth)) but, for a transitional period of up to 16 months from 27 March 2023, the two companies will provide each other with transitional services as we work to demerge our systems and processes. During this time, we may continue to collect your personal information from and share your personal information with David Jones in accordance with this policy and any agreement between you and David Jones.

Consent

By using our products and services you agree to this Privacy Policy and consent to the collection and use of information by us in accordance with this Privacy Policy. Please note that we reserve our right to amend, remove or vary this policy from time to time without notice. You should check this page regularly to take notice of any changes we may have made to this policy.

When Do We Collect Information About You?

Collection of your personal information can occur through the following interactions:

• when you sign up to a loyalty program, membership account or newsletter subscription
• when you visit one of our stores;
• when you make a purchase, submit an order, registration, requests or applications for our products or services (by phone, in person or electronically);
• when you use any of our services including when you access and use our website, mobile apps, or interact with us via social media or digital media;
• when you register with us by creating an online account
• when you communicate with us directly (including in person, via telephone and social media channels such as Facebook and Instagram)
• when you interact with us during promotions, competitions, or special events;
• if you are involved in an incident in one of our stores;
• when you post a review or leave a rating on this site or complete our surveys;
• if you attend one of our functions or events;
• any other time where you may supply personal information to us from time to time.
• third party service providers who provide services or functions on our behalf, such as IT service providers, delivery service providers and fulfilment managers, mailing houses, our insurers and brokers, and marketing agencies;
• third party sources and platforms, such as public sources, social networking sites, information service providers and third party analytics providers to whom you have provided your personal information;
• our Brands, and
• David Jones.

Cookies, analytics and remarketing

We also make use of “cookies” within our Online Services such as on our websites and apps. A cookie is a small software message sent to your web browser by our web server. Your browser stores the message in a file and the message is then sent back to our servers each time your browser requests a page from our servers.

Cookies enable us to track and save information about your use of our Online Services. We use cookies to gain statistics on which areas of our sites attract traffic. We also use cookies to improve and customise your experience of our websites and mobile apps. For example, cookies allow us to recognise whether or not you are returning to our websites. We also use cookies to help us understand how our Online Services are being used so that we can improve their performance. For example, when you use our mobile app, we may also collect technical data to enable us to facilitate the provision of software updates and support. In addition, we make use of third parties who use cookies to serve ads based on past visits to our website. This may allow us to alert you to products or offers which we think you might be interested in viewing. We may collect this information in relation to your online account, as well as on an anonymous basis.

Most Internet browsers are set up to accept cookies. If you do not wish to receive cookies, you will need to adjust the settings of your browser to refuse all cookies or to notify you each time a cookie is sent to your computer. Please note that some of our Online Services will not function if your browser does not accept cookies. By using our Online Services, you consent to the use of cookies.

We use third parties including Google Analytics Advertising Features to promote our products and services. Google and other third parties collect data about traffic to this site via advertising cookies and identifiers which are used display ads on other sites that are relevant to you, based on your previous visits to this site. If you would like to prevent your data from being used by Google Analytics, please click here: https://tools.google.com/dlpage/gaoptout.

When you click on links and banners on our sites that take you to third-party websites, you will be subject to that third-party's privacy policies. We are not responsible for the privacy or security practices of those third party websites.

What Information Do We Collect?

We may collect the following information from you:

• your name and contact details, such as your physical address, email address and phone number;
• payment information;
• your purchase history;
• a photograph or video surveillance recording of you if you are physically present in our stores;
• information required to verify your identity;
• your company name (if applicable);
• information about your shopping preferences/selections;
• account preferences, activity details and interactions (including statistics on page views and clicks), transaction details (such as payment method and where you shopped);
• if you are a member of our loyalty program, your membership number and reward redemption history;
• information relating to your participation in, and interaction with our loyalty program;
• statistics about visits to our websites such as domain name and the time and date our website was accessed;
• gender and birth date; and
• any other information you may provide to us from time to time.

Sensitive Information

We will not collect sensitive information about you unless we have your consent and the information is reasonably necessary for one of our functions or activities (unless we are otherwise required or authorised by law to collect that information). Examples of sensitive information include information about your health, race and ethnic origin. For example, if you are involved in an incident in one of our stores, we may also collect sensitive information from you (such as health and medical information).

Why Do We Collect This Information?

We collect your personal information for purposes necessary to sell and promote our products and services to you. In addition, we collect your personal information so that we can carry out the following actions:

• to provide our products and services to you;
• to tailor how we provide and market our products and services to you, based on your purchase history, shopping preferences and personal information you have provided us so that we can provide you with relevant consumer information and notify you of products and special offers that may be of interest to you across Our Brands
• to carry out quality control and research (including via customer satisfaction surveys), analysis and tracking;
• to provide value-added services and marketing and remarketing across Our Brands, our Associated Entities (as defined in the Corporations Act 2001 (Cth)), David Jones, and our promotional partners through our websites, social media channels or other marketing mediums.
• to communicate with you, including about products and services, competition results, special offers, and events which might interest you (including any associated loyalty rewards);
• to operate our loyalty programs;
• to answer your questions and provide you with information or advice;
• to interact with you via social media and digital marketing;
• to create orders, transaction records, agreements for the sale of products or services, accounts, tax invoices or receipts;
• provide your personal information to third parties that assist us in providing products and services you have requested, such as delivery service providers and fulfilment managers;
• to carry out administration, marketing, planning, procurement, product and service development, fraud and loss prevention activities;
• to consider and respond to complaints made by you;
• to comply with laws or regulations or to comply with any directions given by regulators or authorities.

We may also collect data about you on an aggregate and anonymous basis in order to help us improve the functionality of our website and tailor the way we communicate with you.

If we are unable to collect your personal information

If we are unable to collect your personal information, some or all of the following may occur:

• we may be unable to provide products or services to you, to the requested standard or at all;
• we may be unable to communicate with you to provide information about products and services that you have purchased from us, or may intend to purchase in the future;
• we may be unable to tailor the content of our marketing communications to suit your preferences;
• your experience when interacting with us may be delayed or not as efficient as you may expect.

Do We Share Personal Information With Third Parties?

We may disclose information we hold to any of the following:

• our directors, officers, employees and other Associated Entities within our corporate group and our parent company, Woolworths Holdings Limited (incorporated in South Africa).
• David Jones.
• third party service providers or contractors who provide services or functions on our behalf such as internet service providers, IT systems administrators, mailing houses, couriers, payment processes and data entry service providers.
• third party platforms and services who process sales, store and analyse data and information, provide web support, send marketing messages, deliver products or information. These services are hosted and managed by organisations other than ourselves.
• our business advisors, including lawyers, accountants or other professional service providers, to the extent reasonably required;
• if required by law, to any person authorised by such law. This may include the police service, ambulance service, or government departments or regulators within Australia or New Zealand in connection with law enforcement activities; and
• for any other purpose permitted by law.

We will not sell or trade your personal information to third parties for marketing purposes.

Disclosure overseas

We may disclose your personal information to third parties and service providers located outside the country in which you live. These include:

• our related companies in New Zealand and South Africa;
• our related companies in Australia, New Zealand and South Africa;
• our services providers that are located overseas or hold and store data overseas including the United States of America, the Philippines, Singapore, Canada, Japan, Britain and the European Union.

If you are based in New Zealand, please note that some of our related companies and third party service providers who are located outside New Zealand may not be subject to New Zealand privacy laws or to privacy laws that offer equivalent protections and safeguards to those in the NZ Privacy Act.

We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

Promotional Communications

From time to time we may use your personal information to provide you with information about our services or the services of our Associated Entities or promotional partners. We may provide this information in a variety of ways such as via email, post, our mobile apps, SMS and MMS. We want to communicate with you only if you want to hear from us. If you prefer not to receive promotional information from us, please let us know by clicking on the “unsubscribe link”/”update your preferences” at the bottom of any of our communications, following the opt-out instructions on our SMS and MMS, or by clicking into your account to manage the level of communication which you want to receive from us across Our Brands. You may also unsubscribe by making a request to our Privacy Manager (please see contact information below). Once you have told us you no longer wish to receive information about our products and services, we will no longer contact you. We will keep your basic details on our ‘do not contact’ database so that we do not contact you again.

Personal Information Access

You may access your personal information related to your use of our products and services. Where this information is held in your online account, simply sign into your account and click on your name on the top navigational menu - this will take you to "My Profile".

You may also access your personal information held by us by making a request to our Privacy Manager.
Email: privacymanager@countryroadgroup.com.au.

Mail:
Privacy Manager
Country Road Group Pty Ltd
Building 2, 572 Swan Street
Burnley VIC 3121

Normally we will provide a record of your personal information to you via your preferred contact method (phone, email or mail), and we may charge a fee to cover the reasonable costs incurred by us in providing you with the information (the fee does not apply to the making of the request).

If your request is unlawful or may interfere with the privacy of others we may reasonably refuse to provide access to your personal information.

Correction of your personal information

We will try to ensure that all information we collect, use or disclose about you in accordance with this Privacy Policy is accurate, complete and up-to-date. We expect that you will promptly notify us of any changes to your personal information.

If you hold multiple accounts with us through any of Our Brands’ loyalty programs, we may combine your accounts to create one profile only for all brands. Prior to doing this, we will take reasonable measures to ensure we have verified your membership details and that all the accounts belong to you.

If you discover that there is an error or information is missing, you can update your details online by signing in and visiting “My Profile” and editing the relevant details. Alternatively, if you wish to correct any personal information we hold about you, please contact our Privacy Manager.

We may ask you to verify your identity to ensure that personal information we hold is not improperly accessed.

Pseudonyms and Anonymity

You have the option of using a pseudonym or remaining anonymous when dealing with us so as not to identify yourself fully to us. Please bear in mind, however, that we will be unable to provide certain services to you unless you disclose your correct identity.

If you are a candidate for employment you must provide personal information which is in all respects true, accurate and up to date and is not, in any respect, misleading, deceptive or inaccurate or likely to be misleading or deceptive.

Security

We understand the importance of your personal information and have appropriate procedures in place to safeguard and secure the information we collect to prevent unauthorised access or disclosure, maintain data accuracy and ensure the appropriate use of information. We also take measures in respect of destroying or de-identifying personal information that is no longer needed for any lawful purpose. Some of the steps we take to protect your information include:

• utilising security restrictions on access to our systems such as passwords, firewalls and anti-virus software;
• external and internal premises security.

We also have measures in place to detect and prevent online fraud or suspicious activity. In some instances, we may ask you to provide us with information so that we can verify your identity and payment details (for example, if you have never shopped online with us before or if your payment details need to be verified with our payment providers). As part of this process we may ask you to provide redacted (masked) copies of your ID and the credit card used to place your online order.

If information is requested from you in order to verify your identity and payment, there may be a delay with the despatch of your order. You will receive a follow up email once your order has been approved.

There is no obligation for you to provide this information, but if we are unable to verify your identity, we may not be able to finalise your online order.

This information will be used for verification purposes only. Once your details have been verified, the verification information you have provided will be deleted.

How we hold your personal information

We may hold your personal information in either electronic or hard copy form. If you provide information to us electronically we retain this information in our computer systems and databases. This includes computer software programs, internet servers, and hosted internet solutions provided by third parties. If you provide information to us in hard copy (paper) this information is normally retained in our files and a copy is made to our electronic files.

Residents in the European Economic Area

If you are in a country that is a member of the European Economic Area (“EEA”), then you have the following rights under the GDPR.

Erasure of your personal information

You have in certain circumstances the right to request that the personal information that we collect from you is erased. We may need to retain some of your personal information in certain circumstances (for example, we may retain some of your details in our “Do Not Contact” section of our marketing database to ensure that we do not contact you again). If we refuse any request you make in relation to this right, we will provide you with reasons for our refusal.

Your right to object to or restrict processing of your information

You may request that further processing of your personal information is restricted in certain circumstances, including while we investigate your concerns with this information.

Your right to object to data processing and right to data portability

You have in certain circumstances the right to request that the further processing of your information is restricted or to object to its processing and the right to data portability (to receive and have transferred the information you provided).

Individuals under 16 years of age

Individuals over 16 years old can consent to the processing of their personal information, but anyone younger needs the consent of their parent or guardian.

Privacy Complaints

If you believe that we have breached your privacy rights in any way, or you would like to discuss any issues about our Privacy Policy please contact our Privacy Manager on 1800 801 911 or privacymanager@countryroadgroup.com.au.

If you believe that we have breached your privacy rights in any way, or you would like to discuss any issues about our Privacy Policy please contact our Privacy Manager on 1800 801 911 (AU) or 0800 300 034 (NZ) or privacymanager@countryroadgroup.com.au.

All such enquiries or complaints will be taken seriously and handled with impartiality and discretion.

If you wish to submit a complaint, please provide us with all relevant details such as the date and time of the incident or communication, the circumstances surrounding the event and your concerns about what was said or done. You will also receive an acknowledgment from us within 7 days confirming receipt of your complaint.

Once you have submitted your complaint we will assess it to determine whether or not you have complained about a privacy issue which is covered by the relevant privacy laws. If you have complained about something which is not appropriately dealt with under privacy law, we will write to you and explain why our Privacy Manager is unable to address your complaint.

If you have complained about something which the relevant privacy laws cover, we will thoroughly investigate all aspects of your complaint including ascertaining the relevant facts and what your expectations are for any resolution. During our investigation we may need to seek further information from you as to the nature of or factual circumstances surrounding your complaint.

We will endeavour to respond to you at all times promptly and to offer a practical solution which is consistent with our legal obligations.

If you are not satisfied with the result of your complaint to us, you can refer your complaint to the Office of the Australian Information Commissioner

Mail: Office of the Australian Information Commissioner GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Online: www.oaic.gov.au/privacy/making-a-privacy-complaint

If you are not satisfied with the result of your complaint to us, you can refer your complaint to the following:

Australia
Office of the Australian Information Commissioner
Mail: Office of the Australian Information Commissioner GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au
Online: www.oaic.gov.au/privacy/making-a-privacy-complaint

New Zealand
Office of the New Zealand Privacy Commissioner
Mail: PO Box 10 094, Wellington 6143
Telephone: 0800 803 909
Email: enquiries@oaic.gov.au
Online: https://privacy.org.nz/your-rights/making-a-complaint/

Privacy Policy reviewed and updated on 12 May 2023.