Privacy policy

In this Privacy Policy, 'us' 'we' or 'our' means Steady Freddy. We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your personal information. 


By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy. When we update the Privacy Policy in a material way, we will update the ‘last modified date’ specified in clause 13. All changes to the Privacy Policy are effective when they are posted on our website. For further information about our Privacy Policy or practices, you can contact us using the contact details specified in clause 13. 


Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.


Definitions

In this Privacy Policy, the following capitalized terms have the following meanings:


GDPR means EU General Data Protection Regulation.


Non-personal Information means information that does not relate to a person and/or cannot be used to identify a person. 


Personal Information means any information which can be used to identify an individual and is described in detail in clause 2.  


Platform means this website, app, platform and any service offered under the name “Steady Freddy”.


Privacy Act means the Privacy Act 1974.


Products mean any goods or services offered on the Platform. 


Social Media Platform means any social media platform, including without limitation Facebook, Twitter, Tiktok, Instagram, Snapchat and Pinterest.


Spam Act means the Controlling the Assault of Non-Solicited Pornography and Marketing (CAN-SPAM) Act 2003. 

Uploaded Content means any content whatsoever that you upload to the Platform, including but not limited to any descriptions, reviews, usage data, feedback, comments, chats, or media.


User means any person using or registering on the Platform whatsoever.


What personal information do we collect?

We may collect Personal Information about you when you use the Platform, register on the Platform or interact with us in any way. 


Information you provide to us

We collect all information that Users voluntarily provide to us through using the Platform or interacting with us. This includes the information provided:

  1. during registration;
  2. during correspondence, inquiries, support services or phone calls, or customer surveys; or
  3. uploaded onto the Platform in any way.


The Personal Information we may collect includes without limitation:

  1. basic information such as your first and last name; 
  2. contact information including email address and phone number; 
  3. demographic information such as postal code, age, and gender; 
  4. information related to products, goods or services purchased by you or services provided by you through the Platform;
  5. information collected from the Social Media Platform(s) linked to a User profile;  
  6. other relevant information (profession, tastes, preferences and interests); 
  7. photographs, images, audio, video or other personal content provided by you; 
  8. geographic location; 
  9. login credentials for third-party websites;
  10. other information obtained by your use of the platform; and 
  11. any other information that enables Users to be personally identified. 

Information we automatically collect:

We also automatically collect certain technical data that is sent to us from the computer, mobile device and/or browser through which you access the Platform (Automatic Data). Automatic Data includes without limitation, a unique identifier associated with your access device and/or browser (including, for example, your Internet Protocol (IP) address) characteristics about your access device and/or browser, statistics on your activities on the Platforms, details of the products and services we have provided to you or that you have enquired about or provided through us, including any additional information necessary to deliver those products and services and respond to your inquiries, or information about how you came to the Platform. We collect Automatic Data based on your consent which was granted to us by you when you registered as a User and accepted this Privacy Policy.


Information we obtain from others

We may also purchase or collect or receive Personal Information from third-party sources, such as other Users, suppliers, Social Media platforms or other third-party integrations, and we may combine this information with data we already have about you.  This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide that may be of interest to you. We will ensure that any marketing campaigns are aligned to GDPR requirements.


Why do we collect, use and disclose personal information?

We may collect, hold, use and disclose your Personal Information for the following purposes:


  1. to enable you to access and use our Platform, including to enable you to purchase products or services;
  2. to operate, protect, improve and optimize our Platform, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
  3. to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and the information requested by you;
  4. to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
  5. to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners; and
  6. to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.


We may also disclose your Personal Information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymized consumer insights so that we can better understand your preferences, skills and interests, personalize your experience and enhance the products and services that you receive or provide.

 

The information we collect is not distributed, sold or leased to third parties for commercial purposes, except to provide or avail services you have requested or for other purposes when we have your permission or when we are obliged to do so.


Do we use your personal information for direct marketing?

We and/or our carefully selected business partners may send you direct marketing communications and information about our products and offers. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt out of receiving marketing materials from us by contacting us through the contact us feature below, or by using the opt-out facilities provided (eg an unsubscribe link).


To whom do we disclose your personal information?

We may disclose Personal Information for the purposes described in this Privacy Policy to:

  1. our employees and related bodies corporate;
  2. third-party suppliers and service providers (including providers for the operation of our Platform and/or our business or in connection with providing our Products and services to you or procuring any services from you);
  3. professional advisers, dealers and agents;
  4. payment systems operators (eg merchants receiving card payments such as Stripe (Shopify Payments, Paypal and all major credit cards);
  5. our third-party logistics providers 
  6. our tax compliance service providers
  7. our existing or potential agents, business partners or partners;
  8. our sponsors or promoters of any competition that we conduct via our services;
  9. anyone to whom our assets or businesses (or any part of them) are transferred;
  10. specific third parties authorized by you to receive information held by us; and/or
  11. other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorized or permitted by law.

Using our website and cookies

We may collect Personal Information about you when you use and access our website. While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.


We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other devices. They enable the entity that put the cookie on your device to recognize you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.


We may also use cookies to enable us to collect data that may include Personal Information. For example, where a cookie is linked to your account, it will be considered Personal Information under the Privacy Act. We will handle any Personal Information collected by cookies in the same way that we handle all other Personal Information as described in this Privacy Policy.


We may also use cookies to enable us to collect data of Users for marketing Products.


For a full list of cookies please contact us.


Security

We may hold your Personal Information in either electronic or hard copy form. We take reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorized access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your Personal Information. However, we cannot guarantee the security of your Personal Information.


Retention

You may close your account by contacting us. You may also request the deletion of your Personal Information by contacting us. If your Personal Information is deleted, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use our website.  


Unless you request that we delete your Personal Information, we may retain your Personal Information as long as you are registered to the Platform as a User and for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Information it may persist on backup or archival media for an additional period of time for legal, tax or regulatory reasons or for legitimate and lawful business purposes.


Exclusions

Links: Our Platform may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights to those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.


Children: - Children's Online Privacy Protection Act: We do not knowingly collect Personal Information from children under the age of thirteen (13). If you are under the age of thirteen (13), please do not submit any Personal Information through the Platform. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information through the Platform without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Platform, please contact us and we will endeavor to delete that information from our databases.


Personal Information Provided to Others: This Privacy Policy does not apply to any Personal Information that you provide to another User or visitor through the Platform or through any other means or information posted by you to any public areas of the Platform. 


Accessing or correcting your Personal Information

Up to two times every year, you can access the Personal Information we hold about you by contacting us. Sometimes, we may not be able to provide you with access to all of your Personal Information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your Personal Information.


If you think that any Personal Information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.


We will consider and respond to all requests in accordance with all applicable laws.


Making a complaint

If you think we have breached the Privacy Act or any other relevant privacy law, or you wish to make a complaint about the way we have handled your personal information, you can contact us. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take. 


The EU General Data Protection Regulation (GDPR) 

To the extent that the EU General Data Protection Regulation (GDPR) applies to us and your Personal Information, this clause applies.


California Consumer Privacy Act (CCPA)

Pursuant to the California Online Privacy Protection Act of 2003 (OPPA), if you are a resident of California, you may request certain information regarding our disclosure of personal information to third parties for marketing purposes.

 

Legal Grounds for Processing Your Personal Information 

Our legal grounds for us processing your Personal Information for the purposes set out in clause 4 above will typically be because: 

  • you provided your consent; 
  • it is necessary for our contractual relationship; 
  • the processing is necessary for us to comply with our legal or regulatory obligations; and/or 
  • the processing is in our legitimate interest as a platform that allows us to purchase Products or provide services (for example, to protect the security and integrity of our systems and for you to provide us services through postings on your Social Media Platforms, etc.). 


Transfers of Personal Information 

As we are a global company, we may need to transfer your Personal Information outside of the country from which it was originally provided. This may be intra-group or to third parties that we work with who may be located in jurisdictions outside the European Economic Area (EEA), Switzerland and the UK which have no data protection laws or laws that are less strict compared to those in Europe. 


Whenever we transfer Personal Information outside of the EEA, Switzerland or the UK, we take legally required steps to make sure that appropriate safeguards are in place to protect your Personal Information. Feel free to contact us for more information about the safeguards we have put in place to protect your Personal Information and privacy rights in these circumstances. 



Personal Information Retention 

We retain your Personal Information for as long as necessary to continue to purchase Products or enable you to provide us services, or for other important purposes such as complying with legal obligations, resolving disputes, and enforcing our agreements. 

If you have an account with us, we will typically retain your Personal Information for a period of 90 days after you have requested that your account is closed or if it's been inactive for 7 years. 



Your Rights

Data protection law provides you with rights in respect of Personal Information that we hold about you, including the right to request a copy of the Personal Information, request that we rectify, restrict or delete your Personal Information, object to profiling and unsubscribe from marketing communications. 


To exercise any of your rights, please contact us. Please note that requests to exercise data protection rights will be assessed by us on a case-by-case basis. There may be circumstances where we are not legally required to comply with your request because of the laws in your jurisdiction or because of exemptions provided for in data protection legislation. 

If you have a complaint about how we handle your Personal Information, please contact us. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.


Data controller and a data processor 

EU data protection law makes a distinction between organizations that process Personal Information for their own purposes (known as "data controllers") and organizations that process Personal Information on behalf of other organizations (known as "data processors"). If you have a question or complaint about how your Personal Information is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Information. 


We act as a data controller unless stated otherwise.


Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us: privacy@steadyfreddy.com