Smiley Organics - Privacy Statement

Introduction
Smiley Organics recognises that your personal information is important to you and that you are concerned with its collection, use and disclosure. Smiley Organics, like other companies operating in Australia, is bound by the National Privacy Principles as set out in the Privacy Act 1988 (Cth) which set clear standards regarding these activities.
VnC Online’s policy on the collection, use and disclosure of customer personal information is set out below.

Why does Smiley Organics collect Personal Information?

The personal information you provide to Smiley Organics may be collected, used and disclosed for a number of purposes connected with our business operations, which include:

• providing you with products and/or services requested;
• dealing with requests, enquiries, complaints, and other customer care related activities;
• marketing our products and services and providing advice on our products;
• developing and improving our products and services;
• the operation and administration of accounts or subscriptions that you have with us;
• payment processing;
• carrying out certain checks (for example, for our fraud or theft prevention processes, if you wish to open an account with us);
• carrying out any activity in connection with a legal, governmental or regulatory requirement that we have to comply with, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution;
• interacting with companies or organisations with whom Smiley Organics has a business relationship (where you work for such an organisation);
• reconciling payments due to Smiley Organics from suppliers in relation to goods or services provided to you by those suppliers; and
• purposes relating to any third party acquisition or potential acquisition of an interest in Smiley Organics or its assets.

We may also use your personal information for other purposes related to those described above which would be reasonably expected by you.

Generally, you have no obligation to provide any information requested by us. However, if you choose not to do so, we are unlikely to be able to provide you with the goods and services that you want or carry on the other activities set out above.

What Personal Information does Smiley Organics collect?

The type of personal information we collect or which we may hold about you may include:

• your name;
• your address;
• your date of birth;
• your telephone number(s);
• your e-mail address;
• payment information;
• transaction information;
• your user name and password;
• information on how you use our products and services;
• your Internet Protocol ("IP") address, server address, domain name and information on your browsing activity when visiting one of our websites

How does Smiley Organics collect your personal information?

We collect personal information in a number of ways including:

• when you order goods or services from us;
• when you set up an account with us;
• when you purchase certain products from us;
• when you subscribe to our catalogues or mailing lists;
• when you browse one of our websites (further information is set out later in this Statement);
• when you complete surveys or provide online feedback or product reviews; and
• when you publicly comment about us on social media sites (for example so that we can answer questions about our products).

Marketing

When you create an account with us your details will be added to our mailing list to receive information relating to Smiley Organics and our products. You may also choose to receive such information by subscribing to our mailing list via one of our websites.

To opt-out of receiving Smiley Organics marketing materials, you will need to unsubscribe. To do this, simply select the "unsubscribe" option in one of the emails that you receive from us. Please note that if you have an account with Smiley Organics, we may still need to send you essential information about your account.

Sharing your Personal Information

Smiley Organics may disclose or receive personal information or documents about you to/from:

• our service providers who assist us in providing our services, including organisations that assist us with customer support, payment processing, administration, archival, data storage, research, mail and delivery, marketing, auditing, consulting, financial and legal advisory, banking, security or technical services. In some cases these service providers may collect your personal information on our behalf;
• law enforcement agencies to assist in the prevention, investigation and prosecution of criminal activities;
• parties involved in any third party acquisition or potential acquisition of an interest in Smiley Organics or its assets; and
• to other third parties where you have specifically consented to the disclosure of information to these third parties.

Security of your Personal Information

We will take reasonable steps to ensure that the personal information that we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment protected from unauthorised access, modification or disclosure.

How to access your Personal Information

Upon your request, Smiley Organics will take reasonable steps to let you know, generally, what sort of personal information we hold, for what purposes and how we collect, use and disclose that information.

Upon your request, Smiley Organics will provide access to your personal information that we hold (except in certain circumstances set out in the Privacy Law). Smiley Organics reserves the right to charge you an administration fee of $25 for providing access to your personal information and will, of course, require some proof of your identify before providing information to you.

We take all reasonable precautions to ensure that the personal information we collect, use and disclose is up-to-date. However, the accuracy of that personal information depends to a large extent on the information you provide to us. To help ensure the accuracy of the personal information we hold about you, we ask that you:

• let us know if you become aware of any errors in the personal information that we hold about you; and
• inform us of changes to your personal information, such as changes to your name or address or other contact details,using the contact details set out at the end of this Statement. In addition:
• if you are a subscriber to our mailing list you can also update your details via the "unsubscribe" option in one of the emails that you receive from us;

Additional information for users of our Website

If you visit the www.vnconline.com.au website (the "Websites") to read, browse or download information, our system may record information such as the date and time of your visit to the Website, the pages accessed and any information downloaded. This information is used (i) for statistical and reporting purposes; (ii) for website administration, security and maintenance purposes; and (iii) to direct you to material on our Websites that we believe will be of interest to you.

Like many websites, our Website may use "cookies" from time to time. Cookies are small text files that we transfer to your computer's hard drive through your web browser to enable our systems to recognise your browser and your log-in status. Cookies may also be used to record non-personal information such as the date, time or duration of your visit, or the pages accessed, for website administration, statistical and maintenance purposes. Any such information will be aggregated and not linked to particular individuals. The default settings of browsers like Internet Explorer usually allow cookies, but users can easily erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of the Website may not function fully for users that disallow cookies.

While we take great care to protect your personal information on our Website and use state-of-the-art data transmission encryption, unfortunately no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information that you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us. Once we receive your transmission, we make our best effort to ensure its security in our possession.

The Websites may contain links/ plug-ins to other sites. We are not responsible for content of, or the privacy practices or policies of, those sites.

Exemptions

Smiley Organics sometimes handles personal information relying on exemptions under the Privacy Act, for example in relation to (i) employee records; (ii) related bodies corporate; (iii) provision of services to State or Territory authorities; and (iv) operations outside Australia relating to personal information of non-Australians.

Any permitted handling of personal information under such exemptions will take priority over this privacy statement to the extent of any inconsistency.

Privacy Queries

If you have any queries or concerns, further information can be obtained by contacting our Privacy Officer by email info@smileyorganics.com.au or by post to The Privacy Officer, Smiley Organics, PO Box 963, Ryde, NSW, 1680.

Smiley Organics ABN 78 284 871 581
Version 1 - Date of Publication 24 June 2013