Privacy and online safety are important to Charlomont. We honour without reservation our obligation to respect and protect the personal and other data of the parties with whom we deal. We offer all clients and users the undertaking that we comply with the EU General Data Protection Regulations (GDPR) that are in effect from 25 May, 2018.

We are an online retailer and we collect data about customers and businesses (“Data”) when they use our social media pages and our websites (collectively, “Services”). This privacy policy describes how we collect, use and disclose Data.

In this privacy policy, we sometimes refer to “You”. “You” may be a visitor to one of our websites, a user of one or more of our Services (“User”), or a customer of a User (“Customer”). We’ll do our best to clarify who we are referring to at various points in the policy. This policy does not apply to third-party websites, products, or services even if they link to our Services, and You should consider the privacy practices of those third-parties carefully. If You disagree with the practices described in this policy, You should (a) take the necessary steps to remove cookies from Your computer after leaving our website, and (b) discontinue Your use of our Services.

The Charlomont Group Pty Ltd (“Charlomont“, we or us) are committed to protecting the privacy of your personal information. We are bound by the Australian Privacy Principles under the Privacy Act 1988(Cth) and comply with the EU General Data Protection Regulations (collectively ‘the Acts’) about how we handle your personal information.

By interacting with us, submitting information to us, or signing up for any or services offered by us, you agree and consent to Charlomont using and disclosing your personal data in the manner set forth in this Privacy Policy.

1. OVERVIEW

The Data we collect depends on how our Services are used. Sometimes we receive Data directly, such as when you register for updates on our website, promotions or when you register to utilise the features of our website or purchase a product.

Other times, we may get Data by recording interactions with our Services by, for example, using technologies like cookies and web beacons. We also get Data from third parties, like our financial partners or identity verification services.

The collection and use of data from a variety of sources is essential to our ability to provide our Services – and to help keep the Services safe. Data is critical in helping us to increase the safety of Your online payments, and reduce the risk of fraud, money laundering and other harmful activity.

2. DATA WE COLLECT

Personal Data

We call Data that identifies, or that could reasonably be used to identify, You as an individual “Personal Data”. We collect Personal Data in different ways. For example, we collect Personal Data when a You register for a giveaway on the Charlomont website or social media, a Customer makes payments or a person responds to Charlomont emails or surveys. We also receive Personal Data from other sources, such as our partners, financial service providers, identity verification services, and publicly available sources. Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. The Personal Data that we may collect includes:

Contact details , such as name, postal address, telephone number, email address;

, such as name, postal address, telephone number, email address; Financial and transaction Data , such as credit or debit card number, and bank account information; and

, such as credit or debit card number, and bank account information; and Other Personal Data, such as date of birth.

Charlomont uses social networking services such as Facebook, Twitter and Instagram to communicate with the public about its activities. Charlomont may collect your personal information when you communicate with us by using these social networking services, and the social networking services will also handle your personal information for their own activities. These social networking sites have their own privacy policies.

Other Data.

We call Data other than Personal Data “Other Data”. We collect Other Data through a variety of sources. One of our sources for Other Data is cookies and other technologies that record Data about the use of our websites, websites that implement our Services, and the use of our Services generally. Other Data that we may collect includes:

Browser and device data , such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the version of the Services You are using ;

such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the version of the Services You are using Cookie and tracking technology data , such as time spent on the Services, pages visited, language preferences, and other anonymous traffic data; and

such as time spent on the Services, pages visited, language preferences, and other anonymous traffic data; and Company data, such as a company’s legal structure, product and service offerings, jurisdiction, company records, and information submitted through the Medi-Secure-Safe Certification Application.

3. HOW WE USE DATA

Personal Data

We and our service providers use Personal Data to: (i) provide the Services; (ii) detect and prevent fraud; (iii) mitigate financial loss or other harm to Users and Customers; and (iv) promote, analyze and improve our products, systems, and tools. Examples of how we may use Personal Data include:

To verify an identity for compliance purposes;

To conduct manual or systematic monitoring for fraud and other harmful activity;

To respond to inquiries, send service notices and provide customer support;

To provide a customer service;

For audits, regulatory purposes, and compliance with industry standards;

To develop new products;

To send marketing communications;

To target our advertising;

To improve or modify our Services; and

To conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business.

Other Data

We may use Other Data for a range of different purposes, provided we comply with applicable law and our contractual commitments. In some countries (for example, European Economic Area countries), local legal regimes may require us to treat some or all of Other Data as “personal data” under applicable data protection laws. Where this is the case, we will process Other Data only for the same purposes as Personal Data under this privacy policy.

In addition, where permitted under the Acts, we may from time to time also collect, use or disclose your personal data to conduct market research, understand and analyse customer behaviour, location, preferences and demographics for us to inform you of relevant offers or to provide information about products and services as well as special offers which may be relevant to your preferences and profile.

4. HOW WE DISCLOSE DATA.

Charlomont does not sell or rent Personal Data to marketers or unaffiliated third parties. We share Your Personal Data with trusted third parties, including:

To Charlomont Affiliates.We share Data with entities worldwide that we control, are controlled by us, or are under our common control, to provide our Services. Charlomont Pty Ltd. is the party responsible for overall management and use of the Data by these affiliated parties; To Ticadoc Service Providers.We share Data with service providers who help us provide the Services. Service providers help us with things like payment processing (i.e., banks, credit bureaus, payment method providers), website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, Medi-Secure-Safe Certification and auditing; To Authorized Third Parties.We share data with parties directly authorized by a User to receive Data, such as when a User specifically authorizes us to do so. An example of this is the potential use of Amazon to deliver a prize to you. The use of Data by an authorized third party is subject to the third party’s privacy policy; To Third Parties.We will share Data with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or equity (including in connection with any bankruptcy or similar proceedings); and Safety, Legal Purposes and Law Enforcement.We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, You or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside Your country of residence.

5. SECURITY.

We use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If You have reason to believe that Your interaction with us is no longer secure (for example, if You feel that the security of Your account has been compromised), please contact us immediately.

6. ADVERTISING.

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to You when You access our websites, based on Data relating to Your access to and use of our websites on any of Your devices, as well as Data received from third parties. To do so, these companies may place or recognize a unique cookie, or similar tracking technology, on Your browser (including the use of pixel tags). They may also use these technologies, along with data they collect about Your online use, to recognize You across the devices You use, such as a mobile phone and a laptop, and to make decisions about the advertisements You see. If You would like more information about this practice, and to learn how to opt out of behavioural advertising delivered by Network Advertising Initiative member companies in desktop and mobile browsers on the particular device on which You are accessing this Privacy Policy, please visit the Network Advertising Initiative and Digital Advertising Alliance.

You may download the AppChoices app to opt out in mobile apps. In order to understand and improve the effectiveness of our advertising, we may also use web beacons, cookies, and other technologies to identify the fact that You have visited our website or seen one of our advertisements, and we may provide that Data to one or more third party advertising networks. The Data we provide may include the time and date of Your visit to our website, pages viewed, links clicked and other information that does not disclose your ‘real world’ identity. Those advertising networks may recognize the web beacon or cookie associated with Your visit to our website when You visit other websites on which they serve advertising, and they may make decisions about the advertisements You see based on it. We may choose to work with Google AdWords, Doubleclick, AdRoll, Facebook or other advertising networks. Each of these companies has its own privacy policy, which we encourage You to review.

7. CHOICE, ACCESS AND YOUR RIGHTS OVER PERSONAL DATA THAT WE CONTROL

Upon request, we will provide you with details regarding your personal data that has been collected by us or which is under our control. If you would like to change information that we maintain about you, you may log into your account and change it or submit a support request for any information to which you don’t have access or the ability to change yourself. Information covered by this Privacy Policy may be deleted upon your request, provided that such deletion may impact our ability to provide you with the Services. You may also request that we update or correct your personal data by writing us at:

The Privacy Officer

Charlomont Group

info@charlomont.com

You may opt-out of receiving most e-mails from us by following the “unsubscribe” instructions provided in the e-mails. Alternatively, you may contact us as described herein. If you are our customer, you may not be able to opt out of all emails, including certain administrative or billing communications which are important to the ongoing maintenance of your account.

We may keep your personal data for as long as reasonably required to meet the purposes described herein. Additionally, we will retain this information as required by law, as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

8. RETENTION PERIOD.

We will retain Personal Data for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Please note that we have a variety of obligations to retain the Data that You provide to us, including to ensure that transactions can be appropriately processed, settled, refunded or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if You close any Charlmont Account, or service we will retain certain Data to meet our obligations. There may also be residual Data that will remain within our databases and other records, which will not be removed.

9. USE OF SERVICES BY MINORS.

The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services. By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence.

10. JURISDICTION AND CROSS-BORDER TRANSFER.

Our services are global and Data (including Personal Data) may be stored and processed in any country where we have operations or where we engage service providers, and we may transfer Data to countries outside of Your country of residence, which may have data protection rules that are different from those of Your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that Your Data remains protected to the standards described in this privacy policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Data.

11. UPDATES TO THIS PRIVACY POLICY AND NOTIFICATIONS.

We may change this Privacy Policy. The “Last updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the Services.

We may provide You with disclosures and alerts regarding the Privacy Policy or Personal Data collected by posting them on our website and, if you are a User, by contacting You through your email address. You agree that electronic disclosures and notices have the same meaning and effect as if we had provided You with hard copy disclosures. Disclosures and notices in relation to this Privacy Policy or Personal Data shall be considered to be received by You within 24 hours of the time they are posted to our website or, in the case of Users, sent to through one of means listed in this paragraph.

12. COMPLAINTS

If you have questions about this Privacy Policy, if Charlmont does not agree to provide you with access to your personal information; or if you have a complaint about our information handling practices, you can contact our Privacy Officer on the details above.

In particular, if you wish to make a complaint about how we have handled your personal information, you should forward a written complaint to our Privacy Officer.

We will respond in writing within 30 days of receipt of a complaint. If you are not satisfied with our decision, you can contact us to discuss your concerns.

If the complaint remains unresolved, you have the option of notifying the Office of the Australian Information Commissioner (OAIC).

How to contact us: