1. DATA WE COLLECT
We always seek to improve our Services to you, and that requires that we collect, hold and use information about you and your usage preferences. As we do so, we are absolutely committed to protecting your privacy and the security of your “personal information” in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (collectively, “Australian Privacy Law”). We will not collect “sensitive information” from you or any third-party, as that term is defined Australian Privacy Law.
- name, address(es), telephone number(s) and other contact details;
- payment information (such as credit card or bank details);
- transaction details relating to your use of our goods, services or benefits;
- information relating to an individual's access of our website (including social media accounts or apps), including IP address, device type, browser information, time and date of access, location data, webpages visited, and other website related information including through the use of internet cookies;
- any other personal information an individual provides, or authorise us to collect, as part of the individual's interaction with us;
- other personal information required to provide our goods, services or benefits.
We collect personal information in the following circumstances:
- Creating an account. You are not required to create an account to purchase our products. If you decide to create an account however, you will provide us with certain information, such as your name, email address, username, and password. If your account is created while placing an order, we will also request your shipping address and phone number.
- Purchasing a product from our website. When you make a purchase, you are given the option of logging into an account or checking out as a guest. In either case, when you purchase a product, you will provide us with information, such as your name, email address, phone number, and shipping address.
- Making a payment. When you make a payment to Solo Brands in connection with a product purchase, you may need to provide personal information to our third-party payment processors. Such personal information may include your name, address, phone number, and payment information, including your credit card number.
- Information provided to Solo Brands. We collect personal information you provide to us when you communicate with us via email, call our customer service department, participate in a survey, or join our rewards program. We also collect your information when you post a product review, refer a friend, or post comments on social media. If you post content on public facing areas of the website or other social media you will not be subject to the privacy protections identified in this Policy.
- Automatic collection. We (via third parties) use automatic data collection technologies to collect certain information about you, your equipment, browsing actions or patterns. This information may include your Internet protocol (IP) address, location data, cookie identifier, browser type, Internet Service Provider (ISP), referring/exit pages, the files viewed on our website, operating system, date/time stamp, and/or clickstream data. We use this data to analyse trends in the aggregate and to tailor our website to make a better customer experience.
- Third-party collection. Solo Brands uses third parties to help administer the website and provide products to you. Solo Brands may receive information about you from third parties to enhance our ability to serve you, to tailor our content to you, and to offer you information that we believe may be of interest to you.
2. REASONS FOR COLLECTING AND USING YOUR PERSONAL INFORMATION
We collect personal information from you in the variety of ways listed above to carry out our business, to assess and manage your needs, and to provide our goods and Services. For example, we may use your personal information to:
- operate this website, including to tailor content to you based upon your interests, purchases, and preferences;
- analyse the functionality of this website;
- provide you with products and fulfill product orders;
- develop new products or service features and to improve, research, develop and expand our goods, services or benefits;
- protect the safety and interests of us or other visitors to the website;
- provide product information, marketing, or advertising, including in relation to any events or activities organised by us;
- communicate with you via email or SMS (based upon your explicit written consent) related to your account, products, and other services to you, and as required by law, order of a court, tribunal or regulator or if we reasonably believe that the use or disclosure of the information is reasonably necessary for enforcement related activities.
Information is also generated whenever a page is accessed on our website that records information such as the time, date and specific page. We collect such information for statistical and maintenance purposes that enables us to continually evaluate our Services performance.
In addition to cookies, Solo Brands and its partners use flash cookies, pixels, server logs, web beacons, and other similar technology to administer the website, identify devices, track users’ movements around the website, analyse trends, and to gather information about those visiting our website.
4. DIRECT MARKETING
We will also use and disclose your personal to send direct marketing to you from:
- our related bodies corporate; and
- third parties who provide services to us.
The direct marketing may relate to:
- our goods or Services;
- the products and services of other parties; and
- new activities, events, and services or to provide product information, marketing, or advertising which we believe may be of interest to you.
You may opt-out of receiving this direct marketing through the unsubscribe function that will be made available to you with each direct marketing communication.
5. REASONS FOR DISCLOSING YOUR PERSONAL INFORMATION TO THIRD PARTIES
We do not sell your personal information. Except as provided below, we do not share or disclose your personal information. We may disclose your personal information in the following situations:
- At your instruction. If you request us to make your information available to a third party, and such request furthers the purposes of our Services, we will do so.
- Vendors and Service Providers. In certain cases, we use the services of third-party vendors and service providers to assist us in providing the Services. We may share your personal information with such vendors and service providers solely for that purpose, such as fulfilling orders, processing payments, sending communications, limiting communications, conducting surveys, security reasons, or developing and improving our Services, including this website. These third parties are required to maintain the confidentiality of this information and are prohibited from retaining, sharing, storing or using this information for any other purposes.
- Business transitions. If we go through a business transition, such as a merger, acquisition, liquidation or sale of all or a portion of our assets, the information we have about you will, in most instances, be part of the assets transferred. We reserve the right to transfer that information in connection with such transactions without notice to you. We will not be required to obtain your consent for such a transfer.
- Affiliates. We may share your information with our parent company, subsidiaries, affiliates, or sister companies as part of our marketing or advertising strategy.
- Current and Potential Employees. We may use the services of third parties to help us to recruit new employees and independent contractors and to manage our interactions with current employees and independent contractors. We do our best to contractually ensure that these third-party service providers comply with the policies we have adopted. We only use employment information for the direct purpose of the employment or independent contractor relationship.
- Legal grounds. We may disclose your information if required to do so by law or in the good faith belief that such action is necessary to conform to applicable law, comply with a judicial proceeding, court order or legal process served on us, protect and defend our rights or property, or investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our terms of service.
- Consent. We may also share your personal information with your consent.
If our processing of your personal information is based on your consent, you may withdraw your consent at any time, and we will cease collecting your personal information. However, in some cases, this may result in your inability to receive partial or full access to the Services. In addition, your withdrawal of consent does not prevent us from retaining and processing personal information if we are required or entitled to do so by applicable law.
6. DISCLOSING YOUR PERSONAL INFORMATION OVERSEAS
We may disclose personal information overseas to our related bodies corporate or to our third-party service providers including those who provide us with IT, data storage and processing services. These overseas entities are located exclusively within the United States and Netherlands.
Unless we have your consent, or an exception under Australian Privacy Law applies, we will only disclose your personal information to the above overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.
7. RETENTION AND SECURITY
We maintain reasonable physical security over paper and electronic data. We also maintain reasonable computer and network security systems. We take reasonable steps to destroy or de-identity information that we no longer require.
The internet is not a secure method of transmitting information. We cannot and do not accept responsibility for the security of information you send to or receive from us over the internet, or for any unauthorized access or use of that information.
8. PERSONAL INFORMATION AND CHILDREN
We do not knowingly collect personal information from persons under the age of 15. We request that if you are younger than 15 to please not submit any personally identifiable information to us or to our Services.
9. HOW YOU CAN ACCESS YOUR PERSONAL INFORMATION
We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up to date. If your personal details change, such as your address or phone number, please contact us by email at [email protected].
An individual may access and seek the correction of the personal information we hold about them by contacting us using the contact details set out below. At your request, we will provide you with a copy of any personal information which we hold about you, unless an exception under the Privacy Act 1988 (Cth) applies. We may charge a fee for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information.
We may decline a request to access or correct an individual's personal information in certain circumstances in accordance with applicable law. If we refuse a request, we will provide a reason for our decision.
10. CONTACTING US
Privacy Questions – Legal Counsel
1001 Mustang Dr.
Grapevine, TX 76051
We will promptly acknowledge and investigate any complaint about the way we manage personal information. In most cases, we will investigate and respond to a complaint within 30 days of receipt of the complaint but more complex matters may take longer.
If an individual is not satisfied with our response to a complaint, a complaint may be made to the Office of the Australian Information Commissioner by using the contact details at www.oaic.gov.au.
11. CHANGES TO THIS STATEMENT
Effective Date: July 19, 2022