As at September 2014
1. Your privacy
Brazilian Butterfly Pty Ltd (ABN 24 196 416 066) and its related entities (Brazilian Butterfly, we, us, our) is committed to protecting your personal information in accordance with the Australian Privacy Principles (APPs) in the Privacy Act as well as other applicable legislation, such as the Spam Act, the Do Not Call Register Act, and health privacy legislation.
2. What we collect
We collect personal information when it is reasonably necessary to do so in order to provide you with our products or services. This is usually collected through information provided by you on your client information form and/or through promotions, competitions and consumer queries.
This information may include:
• your name, gender, postal address, contact number(s) and email address
• information about your preference for products or services we offer
• information on any health conditions you may have
• your credit card details for products, services and cancellation fees (if applicable)
• information on the products and services we have provided to you in salon or online
• a record of any queries you have made
• employment information
• other information you have provided to us
Brazilian Butterfly will only collect other personal information, including sensitive information, in accordance with the Privacy Act.
Where it is lawful and practicable to do so, individuals may transact business with Brazilian Butterfly without providing personal information or by providing information under a pseudonym.
3. How we collect personal information
i. Collection of personable information from Individuals
Brazilian Butterfly will collect personal information directly from individuals via:
• Purchasing a product or service in store
• Participating in promotional activities
• Contacting Brazilian Butterfly directly via email, phone, SMS, website
ii. Collection of personal information through websites and Apps
iii. Sensitive information
Brazilian Butterfly only collects sensitive information (eg health information) where it is reasonably necessary for our functions or activities and either you have consented, or we are required or authorised by law to do so.
4. Why we collect personal information
a. Main purposes
The main purposes for which we collect, hold, use and disclose personal information are:
• processing transactions, in-store and online, and delivering products and services
• to provide any associated loyalty program
• promoting Brazilian Butterfly and its products and services, including through direct marketing, events and competitions, public relations and social media
• performing research and statistical analysis, including for customer satisfaction and product and service improvement purposes. This may include matching
information we collect against other information held by third parties. (We may also
use and disclose de-identified data for these purposes)
• helping us tailor existing or develop new products, services or offers, and to help us
selectively target promotional offers and opportunities
• developing or seeking to deliver new ranges of products or services
• protecting the security of our salons, staff, clients, suppliers and merchandise
(including theft and fraud prevention)
• answering queries, resolving complaints and responding to social media
• recruiting staff and contractors
• reviewing prospective franchisee enquiries
• general planning and administration
We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or which are required or authorised by or under law, and for which you have provided consent.
b. Direct marketing and opting out
By providing your address, email address and telephone numbers to Brazilian Butterfly, you consent to Brazilian Butterfly contacting you for the purposes set out above. We may send this information in a variety of ways, including by mail, email, social media, SMS, telephone and if you download the Brazilian Butterfly App. You can opt out of being contacted by:
• contacting our head office by email at firstname.lastname@example.org, by phone on (03) 9756 5700 or by writing to Brazilian Butterfly Head Office, Unit 5, 23 Kelletts Road, Rowville VIC 3178.
• advising us if you receive a marketing call that you no longer wish to receive these calls; or
• using the unsubscribe facility that we include in our electronic messages (e.g. email or SMS) or through our website to opt out of receiving those messages.
You can opt out of receiving notifications via the Brazilian Butterfly App if you turn off Push Notifications in your phone settings.
c. Email and mobile communication
If you provide us with an email address or phone number, you consent to electronic communication such as notices or reminders being sent to you via that address or number. You may prefer to provide to us with your personal email address or phone number rather than, for example, an email address accessible by your work colleagues.
5. Who we may share your personal information with
We may share your personal information with third parties where appropriate for the purposes set out above, including:
• financial institutions for payment processing
• referees whose details are provided to us by job applicants
• Brazilian Butterfly's contracted service providers or partners, including: overseas and local agents, delivery and shipping providers, information technology service providers, venues and event organisers, marketing and communications agencies, research and statistical analysis providers, call centres, hard copy and electronic mail houses, manufacturers and suppliers, external business advisers (such as recruitment advisors, auditors and lawyers), and those third parties who offer Brazilian Butterfly-branded products, such as insurance or credit card facilities
• regulatory, investigative or government bodies to comply with laws
We may ask one of these third parties to contact you directly for a specific purpose, and provide us with information collected from you in the course of providing the relevant products or services. Those companies will be permitted to obtain only the personal information necessary to deliver their services. Brazilian Butterfly takes reasonable steps in the circumstances to ensure that these organisations are bound by privacy obligations to protect personal information otherwise Brazilian Butterfly will seek the individual’s consent.
6. Cross border disclosure
We may disclose personal information to overseas recipients, who are located in places such as Japan, Singapore, India, Hong Kong, the Philippines, the United States of America and other countries or jurisdictions depending on the nature of the services those recipients provide to Brazilian Butterfly (for example storing data via a cloud service, or where Brazilian Butterfly’s customer relationship management system is hosted on servers located overseas, or where delivery address information for online orders is managed via a third party located overseas).
7. Data quality and security
We hold personal information in a number of ways, including in printed documents, electronic databases and email contact lists. Printed documents may be held at Brazilian Butterfly’s head office, or archived in boxes and stored in secure offsite facilities. We take reasonable steps to:
• ensure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
• protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and
• destroy or permanently de-identify personal information that is no longer needed for purposes permitted by the APPs.
You can help us keep your information up to date, by letting us know about changes to your details.
The steps we take to secure personal information include website protection measures, security restrictions on access to Brazilian Butterfly's computer systems, controlled access to Brazilian Butterfly's corporate premises, policies on document storage and security, personnel security and training and workplace policies. While we endeavour to protect the personal information of users of our website, we cannot guarantee the security of information you disclose online: you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact Brazilian Butterfly as set out in section 10. If you become aware of any security breach, please let us know as soon as possible.
iii. Third party sites
8. Access and correction
Please contact our head office if you would like to access or correct the personal information that we hold about you. We may ask you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.
We will generally provide you with access to your personal information within 30 days, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (eg by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. If we correct personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, we will take reasonable steps to do so, unless this would be impracticable or unlawful.
10. Complaints or Questions
Mail: Privacy at Brazilian Butterfly Head Office, Unit 5, 23 Kelletts Road, Rowville VIC 3178
Telephone: (03) 9756 5700
All complaints received will be dealt with fairly and in a timely manner considering all the circumstances of the complaint. In most cases, we expect that complaints will be investigated and a response provided within 30 days of receipt of the complaint. If the matter is more complex and our investigation may take longer, we will contact you and tell you when we expect to provide our response.
11. Changes to this Policy