The Smiggle Privacy & Cookies Policy
Who We Are
Hi there! We are Smiggle – where a smile meets a giggle!
And this is our Privacy & Cookies Policy! If you're a customer or even if you’re just visiting our website or stores, then this policy is for you.
Smiggle is a company with stores all over the world! Because of this, we have a few companies set up in each of the countries we operate in including for the websites that we sell our products from.
If you’re buying things from our Australian website or visiting our Australian stores, then you are dealing with Smiggle Pty Ltd ACN 100 379 226 whose registered office is at 457 St Kilda Road, Melbourne, Victoria 3004.
If you’re buying things from our New Zealand website or visiting our stores in New Zealand, then you are dealing with Kimbyr Investments Limited (NZBN 9429040001807) (trading as Smiggle), whose registered address is 38 Sir Woolf Fisher Drive, Highbrook, Auckland, 2013, New Zealand.
If you’re in Europe and you’re buying things from our UK website or visiting our stores, then the ‘data controller’ of your personal data is Smiggle UK Limited (registered in England & Wales, company number 06720710) and our registered office is at 10 John Street, London, WC1N 2EB. Smiggle UK Limited is a registered data controller at the UK Information Commissioner’s Office under number ZA025548.
We also have companies set up for our stores in Hong Kong, Singapore, and Malaysia. Contact us if you’d like the details of the registered addresses of those companies.
We are also part of Just Group Limited ACN 096 911 410 whose registered office is at 457 St Kilda Road, Melbourne, Victoria 3004, Australia (to make things a little easier, we refer to the ‘Just Group’ in this policy).
About This Privacy & Cookies Policy
When you interact with us, we collect data.
We have written our Privacy & Cookies Policy to set out how we collect, hold, use and disclose that data. We want you to know who to contact if you want to give us feedback on any issues about the policy or how we collect and process your data.
Our policy applies whether you’re interacting with us online, in stores or through our customer service team – and wherever you live in the world.
Sometimes we will need to update this policy, for example, to explain a new process or to comply with new laws. The last time we changed the policy was on 1 April 2019. If we update the policy, we’ll put a new one on our website.
Respecting Your Privacy – Our Commitment
We know how important your personal information is to you, and we are committed to safeguarding that information.
We will follow all the data protection and privacy laws that apply. This policy doesn’t limit any of those laws.
Your Choices And Rights
You’re in control!
- tell us to stop using your data (for example, to stop receiving emails);
- turn off cookies
- ask us to access the personal information we hold about you and how it’s used, or to correct things that aren’t accurate;
- request that we transfer your information to you or another service provider; and
- request that we delete your personal information or stop processing it and collecting it, if it’s no longer necessary for us to hold that data.
Sometimes your rights are subject to exceptions permitted by law, for example, where an access request might prejudice law enforcement activities. We’ll give you reasons if we can’t comply with a request. Please send any requests to our Data Protection Officer (details below).
If you have any concerns about any aspect of our privacy practices, you can also report it to the relevant data protection supervisory authority in your country of residence, work, or the place of any alleged infringement.
What Types Of Personal Information Do We Collect & Why?
- Contact details: for example, your name, address, phone number, and email address. We use this to update you on your order & fulfill it, send you emails about our new products, fraud prevention, and detection, showing you our adverts for Smiggle as your browse the web, targeted advertising including on social media networks, and finding out more about what you and other customers like;
- Transaction information: we use this to take payments, give refunds, and for fraud prevention and detection (don’t worry, we don’t keep your payment details);
- Order history: we use this to perform our contract with you so you can purchase products from us so that our customer service team members can provide you with support and assist with returns and refunds, and so that we can find out what you and other customers like to make sure we are providing you with the best possible shopping experience;
- The month of birth: for our birthday club VIPs, so we can send birthday month offers;
- VIP and Craver Saver info: we use this to help us run, and so you can be a member of, our loyalty programs;
- Competition entries: we use this so you can participate in promotions and competitions, including contacting all our lucky prize winners;
- How you use our site: we use this to give you a better shopping experience overall;
- Personal identification details such as your date of birth (we sometimes use this to detect and prevent fraud);
- Your communication and marketing preferences: we use this information to make sure we are only sending marketing communications you have consented to receiving;
- Your location: so we can offer you a unique shopping experience depending on where you live;
- Your interests, preferences, feedback, and survey responses: we use this to give you a better shopping experience, for our internal market research purposes and to deliver targeted advertising to you based on those interests; and
- CCTV and your image: in some of our higher-risk stores we use CCTV to prevent crime. If you visit these stores your image may be captured. In some of our stores, we use CCTV cameras for crime and theft prevention.
This list is not necessarily complete and in certain circumstances, we may need to collect additional information for one or more of the purposes set out in this privacy & cookies policy.
If you don’t want to give us your personal information or you want to remain anonymous, that’s okay too! But this may restrict our ability to provide you with our services or access to certain features on our websites (for example, you can check out as a guest without creating an account or signing up to our database, but we still collect certain personal details from you to fulfill your order).
Our “Legal Bases” For Collecting Your Personal Information
Data protection laws require us to have a legal basis for using your data. Here are the reasons why:
- Consent. We can collect and process your information with your consent and for a specific purpose. For example, when you opt-in to receive marketing communications from us. You can always change your mind! All our emails have an unsubscribe option or just contact us (see below).
- Contract. In certain circumstances, we need your personal information to comply with a contract we have with you (or if we’ve asked you to take a particular step before entering into that contract). For example, ordering from us is a contract you have with us.
- Legitimate interest. This is where processing your data is needed for our legitimate interests or those of a third party, provided those interests aren’t outweighed by yours. Our legitimate interests include improving our service, determining whether marketing campaigns are effective, and enabling us to enhance our business. For example, we combine the purchase history of our customers to identify trends and make sure we can keep up with demand.
- Legal compliance. Sometimes we’re required by law to collect and process your information. For example, where we pass on details of people involved in fraud or criminal activity to the police (such as anything captured on CCTV); or where we might be required to pass on information about a product recall.
Cookies let you log in and out of your account.
Cookies are just one way we protect you from security risks. For example, we use them to detect when someone might be trying to hack your account.
We use the following third party cookies:
Sharing Your Info
We use carefully selected third parties in certain parts of our business. The relevant organisations include those:
- who deliver customer relationship management;
- who are involved in the warehousing and delivery of online orders;
- involved in the payments system including financial institutions, merchants and payment organisations;
- involved in providing, managing or administering your product or service such as third party suppliers, other Just Group brands, loyalty and affinity program partners, printers, posting services and call centers;
- involved in maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems; and
- which are Just Group brands (being Dotti, Jacqui E, Jay Jays, Just Jeans, Peter Alexander and Portmans) or carefully selected third parties who wish to tell you about their products or services that might better serve your online and lifestyle needs, promotions or other opportunities, where you have opted-in to receive these.
Like we said at the start, Smiggle is a global brand with stores all over the world! And because we were born in Australia, we need to send some of your personal information to the Just Group. We also use some third parties to administer part of our service delivery, so some of the uses and disclosures may occur outside of your country of residence. This means that sometimes we’ll need to transfer your personal information between countries and in particular to Australia (where our central database is operated).
If you’re in Europe, this means we may transfer your personal data to other jurisdictions for processing at a destination outside the European Economic Area ("EEA") which may not provide the same level of protection of personal data as within the EEA. By submitting your personal data, you agree to this transfer, storage and processing. Where we transfer personal data outside of the EEA, we will take reasonable steps to protect your data and prevent any third parties outside of your country of residence using your personal data in any way that’s not set out in this privacy & cookies policy. If we do transfer your data out of the EEA, our standard practice is to use standard data protection clauses for such transfers. You can request a copy by contacting us (the contact details are below!). And, if you’re resident in Ireland, you agree and acknowledge that we may disclose your personal information to any member of our group as defined in section 155 of Companies Act, 1963 (as amended), which includes our subsidiaries, our ultimate holding company and its subsidiaries.
Security & Data Retention
Your information is stored securely whether in an electronic or physical form. We take all reasonable steps to protect all personal information from misuse, loss, interference, unauthorised access, modification or disclosure. If you transact with us online, make sure you keep your account details secure and contact us if you think you’re account has been accessed or your privacy rights have been breached.
We’ll hold on to your personal information only for as long as is necessary for the purpose we collected it or where we have a legitimate interest to continue doing so. Sometimes we are required by legal or regulatory requirements to keep hold of some of your information even after you have closed your account with us, this may be to resolve disputes, prevent fraud, tell you about a product recall or to apply our terms and conditions.
We acknowledge and support the importance of children’s privacy and safety. We do not knowingly collect personal information from children under 16.
If you become aware that a child under 16 has provided us with personal data without parental consent, please contact us through our Data Protection Officer whose details are set below. If we become aware that a child under 16 has provided us with personal information without parental consent, we will attempt to delete this information as soon as possible.
Want to know more, or to exercise any your rights set out in this policy? The best way is to contact our Data Protection Officer by email at firstname.lastname@example.org
Thanks for reading, and be sure to check out our website for any changes to our policy.
If you have a customer service question that’s unrelated to privacy, please go back to our home page and check out our contact details under ‘Contact us’.