CL 1. We respect your privacy

(a) Ume Co Pty Ltd (Ume Co or We) respects your right to privacy and is committed to safeguarding the privacy of our customers and website visitors. This policy (Privacy Policy) sets out how we collect and treat your personal information.

(b) To the extent applicable, we adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) and the EU General Data Protection Regulation (GDPR).

(c) “Personal information” is any information relating to an identified or identifiable natural person. This includes information such as your name, email address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly.

(d) You may contact us in writing at umeco@umeco.au for further information about this Privacy Policy

CL 2. What personal information is collected

(a) Umeco will, from time to time, receive, process and store personal information you submitted to our website, provided to us directly or given to us in other forms.

(b) We may collect basic personal information such as your name, phone number, address and email address to enable us to send you information, provide updates and process your product or service order.

(c) We may collect additional personal information at other times, including but not limited to, when you provide feedback, provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.

(d) Additionally, we may also collect any other personal information you provide while interacting with us.

CL 3. How we collect your personal information

(a) Umeco collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access our website and when we engage in business activities with you. 

(b) We may also collect personal Information about you from third parties to whom you have provided your personal information and in respect of which you have given that third party permission to share with us. Such parties may include our related entities and subsidiaries (including our related bodies corporate as defined in the Corporations Act 2001 (Cth) (Corporations Act) and our business partners. If we do, we will collect, store and process such personal information in accordance with this Privacy Policy. 

(c) By providing us with personal information, you consent to our collection and use of your personal information subject to terms of this Privacy Policy.

CL 4. How we use your personal information

(a) Ume Co may use personal information collected from you to provide you with information about our products or services. We may also make you aware of new and additional products, services and opportunities available to you.

(b) Ume Co will use, process, store and disclose your personal information only for the purposes for which the information is collected, including without limitation to:

(i) provide you with products and services during the usual course of our business activities;

(ii) administer, protect, improve or optimise our business activities;

(iii) manage, research, optimise and develop our website, products and services (including performing data analytics);

(iv) provide you with information about our website, products, services, rewards, surveys, contests or other promotional activities or events sponsored or managed by us or our business partners;

(v) communicate with you by a variety of measures including, but not limited to, by telephone, email, sms or mail;

(vi) investigate and respond to any complaints;

(vii) create industry reports from de-identified data;

(viii) verify your age;

(ix) enable the seller of products and services displayed on our website to provide and deliver products and services to you;

(x) process payment for products and services (including on behalf of a third-party seller of the product and services displayed or our website;

(xi) any other purpose which you have consented to; and

(xii) a directly related purpose to any of the above purposes.

(c) You give Ume Co permission to use your name, likeness, biographical information, company logos, company offering images, company offering information, company history information and current company information and other related information in connection with Umeco’s community and related promotional materials. You understand that you will not receive compensation for such use.

If you withhold your personal information, it may not be possible for us to provide you with our products and services or for you to fully access our website.

(d) We may use, store or disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request.

(e) If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.

CL 5. Direct marketing

(a) We may use and process your personal information to send you information about products and services which we believe are suited to you and your interests or to invite you to attend special events, only if:

(i) we have your express consent (whether provided under this Privacy Policy or otherwise), which you may withdraw at any time by contacting us in writing at umeco@umeco.au;

(ii) we have a legal basis; or

(iii) we are otherwise permitted by applicable laws.

(b) At any time, you may opt out of receiving direct marketing communications from us. Unless you opt out, your consent to receive direct marketing communications from us and to the handling of your personal information as detailed above will continue. You can opt out by following the unsubscribe instructions included in the relevant marketing communication or by contacting us in writing at umeco@umeco.au.

CL 6. Disclosure of your personal information

(a) Ume Co may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, technology partners, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this Privacy Policy. We may similarly disclose your personal information to our related entities and subsidiaries, including our related bodies corporate (as that term is defined in the Corporations Act). Our technology partners may also disclose your personal information amongst themselves as and when required, but only with the prior permission of Ume Co.

(b) If we do disclose your personal information to a third party, we will take reasonable steps to make such third party aware of this Privacy Policy.

CL 7. General Data Protection Regulation (GDPR) for the European Union (EU)

(a) This clause 7 applies to you to the extent that you are afforded the relevant rights under the GDPR.

(b) Ume Co will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.

(c) We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.

(d) We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.

(e) We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure.

(f) We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.

(g) We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.

(h) We do not collect or process any personal information from you that is considered “Sensitive Personal

Information” under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.

(i) You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.

CL 8. Your rights under the GDPR

(a) If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used, including the right:

(i) to be informed how your personal information is being used;

(ii) access your personal information;

(iii) to correct your personal information if it is inaccurate or incomplete;

(iv) to delete your personal information;

(v) to restrict processing of your personal information;

(vi) to retain and reuse your personal information for your own purposes;

(vii) to object to your personal information being used; and

(viii) to object against automated decision making and profiling.

(b) If you wish to exercise any of your rights under the GDPR, please contact us at any time at the contact details in this Privacy Policy.

(d) We may ask you to verify your identity before acting on any of your requests.

CL 9. Hosting and International Data Transfers

(a) Information that we collect may from time to time be stored, processed or transferred between parties or sites located in countries outside of Australia, including, but are not limited to, the United States of America (USA).

(b) We and our other group companies have offices and/or facilities in the USA. Transfers to each of these countries will be protected by appropriate safeguards, these include one or more of the following: (i) the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; (ii) the use of binding corporate rules, a copy of which you can obtain from Ume Co’s Data Protection Officer.

(c) The hosting facilities for our website are situated in the USA. Transfers to each of these Countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from Ume Co’s Data Protection Officer.

(d) Our Suppliers and Contractors are situated in the USA. Transfers to each of these Countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from Ume Co’s Data Protection Officer.

(e) You acknowledge that any personal information you transmit through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others. See also Section 10(d) of this Privacy Policy.

CL 10. Security of your personal information

(a) Umeco is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

(b) Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.

(c) The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

(d) When transmitting personal information from your computer to our website or to us, you must keep in mind that the transmission of information over the internet is not always completely secure or error-free. Other than liability that cannot lawfully be excluded, we will not be liable in any way for or in connection with any breach or security or any unintended loss or disclosure of such information.

CL 11. Access to your personal information

(a) You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth) and GDPR, to the extent that such laws are applicable. If you would like a copy of the information

which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at umeco@umeco.au.

(b) We will not charge you for making the request to access your personal information. However, we may charge you a reasonable fee that is not excessive to cover the costs we incur to retrieve your Personal Information from our database.

(c) We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law.

CL 12. Complaints about privacy

(a) If you have any complaints about our privacy practices, please feel free to send in details of your complaints to umeco@umeco.au. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.

CL 13. Changes to Privacy Policy

(a) Please be aware that we may change this Privacy Policy in the future. We may modify this Policy in whole or in part at any time, in our sole discretion and without notice. All modifications to the Privacy Policy will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

CL 14. Website

(a) When you visit our website

When you come to our website, we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, your secure ID, device type, geo-location information, computer and connection information, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

(b) Cookies

We may from time to time use cookies, web beacons and similar technologies (together, Cookies) on our website. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Most web browsers automatically accept Cookies, but you can choose to reject or delete Cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website, products and services. Our website may from time to time use Cookies to analyse website traffic and help us provide a better website visitor experience. In addition, Cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords. These ads may appear on this website or other websites you visit.

(c) Third party sites

Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Ume Co is not responsible for the privacy practices of other such websites. This Privacy Policy applies solely to information collected by us, and we encourage our users to be aware, when they leave our website, to read the privacy information statements of each and every website that collects identifiable information.

This Privacy Policy was last updated on 27 Feb 2024