This Policy explains in general terms how Sleep Sophie and its subsidiaries, related bodies corporate and franchisees (collectively referred to in this document as ‘Sleep Sophie’ ‘we’ ‘our’ or ‘us’) protects the privacy of your personal information. We are firmly committed to protecting the privacy and confidentiality of personal information and maintain various physical, electronic and procedural safeguards to protect personal information in our care.
Sleep Sophie is bound by the Privacy Act 1998 (Cth) (‘Act’). This document sets out the Sleep Sophie’s policy in relation to the protection of personal information, as under the Act and the Australian Privacy Principles (‘APP’).
The APPs regulate the handling of personal information.
Section 1: What is Personal information?
Personal information is information which relates to a living individual who can be identified from that information, or from that information and other information in a person’s possession, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identified individual, and any indication of intention in respect of an individual.
Section 2: Employee Records
This policy does not apply to the collection, holding, use or disclosure of personal information that is an employee record.
An employee record is a record of personal information relating to the employment of an employee. Examples of personal information relating to the employment of the employee include, but are not limited to, health information and information about the engagement, training, disciplining, resignation, termination, terms and conditions of employment of the employee. Please see the Act for further examples of employee records.
Section 3: Information we may collect from you
We may collect all or some of the following information relating to you:
(a) Information you give us. You may give us information about you by filling in forms on our website www.SleepSophie.com.au (‘our site’) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you use our site, purchase a product from us, search for a product, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description or details and photograph;
(b) Information we collect about you. With regard to each of your visits to our site or use of our app, we may automatically collect the following information;
(i) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
(ii) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and
(c) Information we receive from other sources. We may receive information about you if you use any of the other websites or applications we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
In some circumstances, we may collect personal information from you which is regarded as sensitive information pursuant to the Act. Sensitive information includes types of personal information such as your racial or ethnic origin, religious beliefs or affiliations, criminal record and health information. We will only collect sensitive information when necessary in accordance with section 3.3 of the Australian Privacy Principles as set out within the Act, about you with your consent and where reasonably necessary for, or directly related to, one or more of our functions or activities (e.g. to make delivery arrangements on your behalf). Where you provide sensitive information to us, you consent to us using that sensitive information for the purpose for which it was collected. For example, if you provide address details and contact information to us in connection with a product purchase, you consent to us using and disclosing that contact information in connection with arranging product delivery on your behalf.
Section 4: Unsolicited Personal Information
In the event that we receive unsolicited personal information that could not have been obtained through solicited means on reasonable terms, we confirm that the information will be destroyed as soon as reasonable possible.
Section 5: Uses made of the information
By providing us, or otherwise allowing us to collect, your personal information, you consent to us using and disclosing your personal information for the purposes for which it was collected, and for related or ancillary purposes. We use information held about you in the following ways:
(a) Information you give to us. We will use this information to:
(i) carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
(ii) provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
(iii) provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data;
(iv) notify you about changes to our service;
(v) ensure that content from our site is presented in the most effective manner for you and for your computer; and
(vi) make travel arrangements as required including flights, hotels, vehicle hire, excursions and travel insurance;
(b) Information we collect about you. We will use this information:
(i) to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
(ii) to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
(iii) to allow you to participate in interactive features of our service, when you choose to do so;
(iv) as part of our efforts to keep our site safe and secure;
(v) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
(vi) to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them;
(vii) identification of fraud or error;
(viii) internal accounting and administration; and
(ix) other purposes permitted or required by law (e.g. to prevent a threat to life, health or safety).
(c) Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive); and
(d) We are only allowed to store your personal information for as long as necessary having regard to the purpose for which it was collected or a related or ancillary purpose. We may therefore delete your personal information after a reasonable period of time and, if you have not used our services for some time, you may have to re-enter or re-supply your personal information to us.
Section 6: Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 46 of the Corporations Act 2001 (Cth) if applicable.
We may share your information with selected third parties including:
(a) Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
(b) Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in 4220). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; and
(c) Analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
(i) In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
(ii) If Sleep Sophie, or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
(iii) If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect the rights, property, or safety of Sleep Sophie our customers, or others. This includes exchanging information with other companies, organisations and government department for the purposes of fraud protection and credit risk reduction; and
(iv) where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter.
Other than the above, we will not disclose your personal information without your consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), disclosure is authorised or required by law or disclosure is otherwise permitted by applicable privacy laws.
When you provide, or otherwise allow us to collect, your personal information, you consent to your personal information being disclosed to certain overseas recipients, as set out below under ‘Where we store your data’. Where we disclose your personal information to an overseas recipient, you agree that we will not be required to ensure the recipient’s compliance with Australian privacy laws or otherwise be liable or accountable for how the recipient handles your personal information. If you have any objections to your personal information being disclosed to an overseas recipient, please let us know.
Section 7: Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside Australia. It may also be processed by staff operating outside Australia who work for us or for one of our suppliers or travel providers. Such staff maybe engaged in, among other things, the fulfilment of your booking, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy.
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Sleep Sophie regularly reviews security and encryption technologies and will strive to protect your personal information as fully as we protect our own confidential information.
Section 8: Your rights
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by contacting us a PO Box 6028, GCMC, QLD 9726 or by email at [email protected]
Before we disclose personal information about you to a third party, we will take steps as are reasonable in the circumstances to ensure that you are aware that we have collected the information and the purpose of collection the third party does not breach the APPs in relation to the information.
If you wish to make a complaint in relation to the collection and use of your personal information or any effects to your rights with respect to your personal information, or place a request to amend information held about you, please follow the link outlined under the Complaints heading of this Policy.
Section 9: Access to information
Subject to any exceptions set out in applicable privacy laws, we invite you to access any personal information we may hold about you. Where personal information we hold about you is not accurate, complete, up-to-date or relevant, you may ask us to correct that personal information, and we will respond to your request within a reasonable time. We reserve the right to confirm the identity of the person seeking access or correction to personal information before complying with such a request. If we deny access or correction, we will provide you with the reason for such denial. If you wish to access or seek correction of any personal information we hold about you, please contact us.
You are legally obliged to always provide accurate information and you agree to update it whenever necessary. You also agree that, in the absence of any update, we can assume that the information submitted to us is correct.
You can also choose not to provide us with some of the information we request, however as a result we may not be able to complete your arrangements.
Section 10: Opt-Out Policy
Subscribers of our site and our app can opt out of receiving further information from us at any time. You will also be given a fast and easy option of opting out on all communications. Email us at [email protected] to unsubscribe.
Section 11: Tracking Technologies AND Cookies
Please note that in order for us to provide you with optimum service, we use ‘cookies’ on our website.
Section 12: What are cookies?
A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer’s hard disk so that the website can remember who you are. Cookies will typically contain the name of the domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number.
Two types of cookies are used on this web site – session cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the site, and persistent cookies, which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).
Cookies allow us to obtain information regarding users of our site which essentially helps us to provide you with a better user experience and tailor our services to your individual needs. We may collect information such as your IP address, online activity, web browser details and online activity. We will not however collect or store any of your passwords or other highly sensitive data.
We use the following types of cookies on our website:
Category 1: Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies certain services you have asked for cannot be provided.
Category 2: Analytical / Performance Cookies
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
Category 3: Functionality Cookies
These cookies are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
By using our website, you agree that we can place these types of cookies on your device.
Section 13: Further information
To find out more information about cookies, please visit www.allaboutcookies.org.
Section 14: Protecting your information
We take website security very seriously and we are committed to safeguarding your personal information. We conduct various physical, electronic, administrative and managerial security procedures in order to protect personal information from loss and misuse, and from unauthorised access, modification, disclosure and interference.
Section 15: External Links
Please note that our website contains certain literature and hyperlinks to websites owned by third parties. This privacy statement covers websites owned and controlled by us only. Links to other websites and any information collected by these sites are not covered by this privacy statement.
Section 16: Monitoring
To ensure that we carry out your instructions accurately, to help improve our service and in the interest of security, we may monitor and/or record: (1) your telephone calls; and (2) customer activities on our website. All recordings are and shall remain our sole property.
Section 17: Updates and Changes
As our privacy statement may change due to developments in the law we encourage you to re-read this from time to time so you are aware of any changes in how we gather and use your personal information. We reserve the right to change our Policy at any time and for any reason. Any changes to this Policy will be either posted on our website, brochure and/or made available on request.
Section 18: Anonymity and Pseudonymity
You have the option of not identifying yourself, or using a pseudonym, when dealing with Sleep Sophie in relation to a particular matter. This does not apply where:
(a) Sleep Sophie is required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves; or
(b) it is impracticable for Sleep Sophie to deal with individuals who have not identified themselves or who have used a pseudonym.
However, in some cases if you do not provide Sleep Sophie with your personal information when requested, Sleep Sophie may not be able to respond to your request or provide you with the goods or services that you are requesting.
Section 19: Complaints
You have a right to complain about the Sleep Sophie handling of your personal information if you believe that Sleep Sophie has breached the APPs. If you wish to make such a complaint to Sleep Sophie, you should first contact the Privacy Officer in writing. Your complaint will be dealt with in accordance with Sleep Sophie’s complaints procedure and Sleep Sophie will provide a response within a reasonable period.
If you are unhappy with the Sleep Sophie’s response to your complaint, you may refer your complaint to the Office of the Australian Information Commissioner.
Section 20: Privacy Officer contact details
The Sleep Sophie’s Privacy Officer can be contacted in the following ways:
- Telephone number: 1300 9 SLEEP
- Email address: [email protected]
- Postal address: PO Box 6028, GCMC, Qld 9726.
Section 21: Contact
Questions, comments, and requests regarding this Policy are welcomed and should be addressed to [email protected] any complaints should also be addressed to the aforementioned link.