PRIVACY POLICY

BACKGROUND

WOW International Group Pty Ltd (ACN 669 023 634) (“WOW”) operates the website located at www.wowwomen.com.au (the Website). WOW is committed to protecting the information that it collects, stores and uses about you when you provide it to WOW on the Website or when purchasing any of WOW’s products or services (Products). WOW respects your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act), and acknowledges that it must only collect, manage and disclose your personal information in accordance with that Act. Unless the context requires otherwise, terms in this Privacy Policy that are defined in the Privacy Act have the same meaning as in that Act.

By visiting the Website or purchasing any of WOW’s Products, you acknowledge and agree that your information will be managed in accordance with this Privacy Policy. Please read the Privacy Policy carefully before accessing Website and purchasing any of WOW’s Products. You can view the most current version of the Privacy Policy at any time by accessing this page.

The headings used herein are included for convenience only and do not otherwise affect this Privacy Policy.

OPERATIVE PROVISIONS

  • 1 Personal Information

1.1 What is Personal Information?

‘Personal Information’ refers generally to any information WOW may collect about you that can be used to personally identify you, including (without limitation and depending on the circumstances) your:

(a) name;

(b) image;

(c) age or date of birth;

(d) current or previous residential address;

(e) telephone number;

(f) email address;

(g) profession or occupation; and

(h) credit card details.

1.1 How WOW Collects Your Personal Information

(a) WOW may collect your Personal Information:

(i) directly from you, including (without limitation) when you access and use the Website, create a registered account on the Website, or purchase any of WOW’s Products;

(ii) through third parties, such as when you use WOW-associated applications and social media platforms;

(iii) when you correspond with WOW, or make enquiries about any of its Products;

(iv) when you provide WOW with your preferences, opinions and thoughts through customer surveys;

(v) when WOW or any of its agents (in their sole discretion) record any WOW forums or webinars that you attend;

(vi) during conversations or interviews you have with WOW’s employees or agents;

(vii) if you ask to be placed on WOW’s subscription or mailing lists; or

(viii) when you become a client of WOW, or otherwise use its Products.

(b) When WOW collects your Personal Information, it will (where appropriate and possible) explain to you the purpose of collecting the information and how WOW plans on using the information.

1.2 Purposes of Collecting Personal Information

(a) WOW collects your Personal Information to enable it to perform its business activities and functions, operate the Website, and provide you with its Products and the best possible customer service.

(b) Without limiting clause 1.3(a), WOW may collect, hold, use and/or disclose your Personal Information to:

(i) enable you to access the Website, and any associated applications or social media platforms;

(ii) contact you;

(iii) comply with internal recordkeeping and other administrative requirements;

(iv) provide its Products to you;

(v) fulfil any requests or orders you make for WOW’s Products (including by processing your payment information, arranging for shipping, and providing you with invoices and order confirmations);

(vi) send you marketing communications and information about its Products via mail, SMS or email, provided WOW complies with any applicable laws in relation to such communications (such as the Spam Act 2003 (Cth));

(vii) answer your enquiries;

(viii) conduct market research and consider business development opportunities;

(ix) provide you with information and advice about WOW’s existing and new Products;

(x) comply with any law, rule, regulation, or decision or direction of a regulator; and

(xi) cooperate with any governmental authority.

1.3 Disclosing Your Personal Information

(a) For the purposes of clause 1.3(a), WOW may disclose your Personal Information to:

(i) its employees, contractors, agents, business partners and related entities;

(ii) its contractors or service providers, including (without limitation) web hosting providers, IT system administrators, mailing houses, couriers, payment system operators, data storage providers, maintenance providers, marketing and advertising providers, debt collectors, and professional advisers (such as accountants, solicitors, business advisers and consultants);

(iii) its suppliers and other third parties with whom it has commercial relationships, including (without limitation) for business, marketing, promotion and related purposes; and

(iv) any other person (whether natural or otherwise) with your prior written consent.

(b) Further to clause 1.4(a), WOW may disclose your Personal Information to courts, tribunals, regulatory authorities and law enforcement officers, including:

(i) where required by law (including, without limitation, to respond to a subpoena, search warrant or other lawful request for information);

(ii) in connection with any actual or prospective legal proceedings; or

(iii) to establish, exercise or defend WOW’s legal rights (e.g. where you have failed to pay WOW for any products or services it has provided to you).

(c) WOW will only disclose your Personal Information under clause 1.4(a) where:

(i) it has sought, and been provided with, assurances from the party receiving the Personal Information that the information will be handled in accordance with the Privacy Act; and

(ii) if your Personal Information is to be stored, transferred or accessed in a country outside of Australia, that other country maintains laws that will protect your Personal Information to at least the same standard as the Privacy Act.

1.4 Transferring Your Personal Information

If WOW experiences a change in control of its business, or sells or transfers its assets, it reserves the right to transfer its user databases (including any personal and non-personal information contained in those databases) to the purchaser to the fullest extent permitted by law, provided that any such information is only disclosed in good faith and where WOW has sought assurances from the purchaser that it will maintain the confidentiality of the information.

1.5 Retention of Your Personal Information

(a) In relation to your Personal Information, WOW may:

(i) hold the information (in either electronic or hard copy form) for as long as necessary to fulfil the purposes for which the information was collected, including to satisfy any legal, accounting or other reporting requirements;

(ii) anonymise the information (i.e. so that you can no longer be identified by it) for research or statistical purposes, in which case WOW may use the information for an indefinite period of time without further notice to you; and

(iii) destroy the information on the latter to occur of:

(A) the information no longer being needed; or

(B) WOW no longer being required by law to retain it.

(b) In determining the length of time for which your Personal Information should be retained under clause 1.6(a)(i), WOW must have regard to:

(i) the amount, nature and sensitivity of the Personal Information;

(ii) the potential risk of harm to you from any unauthorised use or disclosure of your Personal Information;

(iii) the purposes for which WOW requires your Personal Information, and whether those purposes can be achieved through other means; and

(iv) any applicable legal requirements.

1.6 Requesting Access to and Correcting Your Personal Information

You may request access at any time to any Personal Information WOW holds about you, in which
case:

(a) if WOW determines that you are entitled to access the information, it must attempt to provide you with suitable means of accessing it and may charge you a reasonable fee to cover administrative and other costs that it incurs in providing the information to you; or

(b) if WOW determines that it cannot grant you access to the requested information (e.g. where granting access would interfere with the privacy of others or result in a breach of confidentiality), WOW must provide you with written reasons for denying you access to the information.

1.7 Correcting Your Personal Information

(a) If you believe any Personal Information WOW holds about you is incorrect, out of date, irrelevant, misleading, incomplete or inaccurate, then you may send a written request to WOW at any time for the Personal Information to be corrected.

(b) If you submit a request pursuant to clause 1.8(a), WOW will:

(i) take all reasonable steps to correct any information WOW determines (in its sole discretion) needs to be corrected; and

(ii) not charge you for making any corrections to your Personal Information.

  • 2 Sensitive Information

1.2 What is Sensitive Information?

‘Sensitive Information’ is a subset of Personal Information that is given a higher level of protection under the Privacy Act, and may (depending on the circumstances) include information WOW collects about your:

(a) racial or ethnic origin;

(b) political opinions;

(c) religious or philosophical beliefs;

(d) membership of trade unions or other professional associations;

(e) sexual orientation or practices; or

(f) criminal record.

1.3 Using Your Sensitive Information

WOW must only collect, hold, use and disclose your Sensitive Information for:

(a) the primary purpose for which it was collected;

(b) any secondary purposes that are directly related to the primary purpose, including where WOW believes it reasonably necessary to disclose your information to a third party in order to provide its Products to you; and

(c) any other purposes for which you provide your prior written consent to WOW, or where otherwise required by law.

  • 3 Website Tracking

(a) In this clause:

(i) ‘cookies’ refer to small summary files with a unique ID number that are placed in your computer’s browser to store your preferences, but which do not disclose your email address or other personally-identifiable information; and

(ii) ‘web beacons’ refer to small pieces of code placed on a website to monitor a visitor’s behaviour and collect data about the visitor’s use of a website.

(b) For the purposes of improving the experience of those using the Website, WOW reserves the right to:

(i) employ tracking software to assist WOW in understanding how the Website is used, including through Facebook, click funnels, Infusionsoft, Remarketing with Google Analytics, and Google Analytics Demographics and Interest Reporting (which collects data about traffic on the Website via cookies and anonymous identifiers);

(ii) log IP addresses (i.e. the electronic addresses of computers connected to the internet), browser type, internet service provider and referring/exit pages, in order to analyse trends, administer the Website, track users’ movements, and gather broad demographic information;

(iii) use cookies and web beacons to:

(A) recognise your computer each time you visit the Website without you needing to register an account;

(B) track services you use, so that (with your consent) WOW can send you news about these services; and

(C) measure traffic patterns to determine which areas of the Website have been visited.

(c) If you do not wish to:

(i) allow Google Analytics to collect your data, you may opt out at https://tools.google.com/dlpage/gaoptout/ ;

(ii) receive cookies, you can set your internet browser so that your computer doesn’t accept them (for more information about cookies and how to disable them, please visit: http://www.allaboutcookies.org ); or

(iii) receive targeted advertising on Facebook or Google, you may opt out by visiting https://www.facebook.com/settings/?tab=ads or https://www.google.com/settings/ads/anonymous respectively.

  • 4 Security

4.1 Transmission of Information Via the Website

(a) While WOW will endeavour to take all reasonable steps to protect any information you may provide on the Website (including Personal Information), you acknowledge and agree that the internet is inherently insecure and hence:

(i) WOW can provide no assurances regarding the security of information that you transmit via the Website; and

(ii) any information you decide to transmit via the Website is done at your own risk.

(b) If you decide to participate in a discussion forum, chatroom or webinar offered by WOW, you acknowledge and agree that:

(i) any information you provide may be made broadly available to other participants in the discussion forum, chatroom or webinar; and

(ii) each participant’s opinion is their own, and is in no way reflective of WOW’s opinion.

4.2 Third Party Websites

Where WOW provides links to any third party websites (such as, without limitation, social media sites) (Third Party Websites), you acknowledge and agree that:

(a) these Third Party Websites are not under WOW’s control;

(b) WOW accepts no responsibility for the conduct of any person (whether natural or otherwise) associated with these Third Party Websites; and

(c) WOW recommends that you read and understand the Third Party Websites’ respective Terms and Conditions of Use and Privacy Policies prior to using the website.

  • 5 Contacting WOW

(a) You may contact WOW at any time by sending an email to info@wowwomen.com.au, including if you:

(i) have any questions or concerns about this Privacy Policy;

(ii) wish to opt out of receiving marketing communications from WOW, in which case WOW will ensure your name is removed from its subscription/mailing list;

(iii) wish to withdraw your consent to WOW collecting and retaining your data (including your Personal Information), in which case WOW will arrange for your data to be deleted as soon as practicable provided it has otherwise complied with all of its legal obligations in relation to your data; or

(iv) believe your privacy has been breached, in which case WOW will investigate your complaint (provided it has received proper details of the alleged breach), treat your complaint confidentially, and endeavour to resolve your concerns in a timely and appropriate manner.

(b) If you withdraw your consent to WOW collecting and retaining your data under clause 5(a)(iii):

(i) your use of the Website may be affected; and

(ii) WOW may be unable to:

(A) provide its Products to you (either to the same standard or at all);

(B) provide you with information about any Products that you may want (including information about special promotions); or

(C) tailor the content of the Website to your preferences, and hence your experience of the Website may not be as enjoyable or useful.

  • 6 Variations

(a) WOW may, from time-to-time and in its sole discretion, vary or amend this Privacy Policy by posting an updated version on the Website.

(b) Your continued use of the Website constitutes your acceptance of the Privacy Policy as varied or amended from time-to-time.

This privacy policy was last updated on December 3, 2023