About this Policy
The Privacy Act 1988 (Cth) (Privacy Act) applies to the collection and use of your personal information. Debenhams (registered as PSEA Dept.Stores Pty Ltd, ABN 83 095 018 803) is part of the Greenlit Brands General Merchandise Pty Ltd (ABN 80 081 408 791) (Greenlit Brands GM) group of companies which include the Best & Less, Debenhams, Harris Scarfe, Mozie, Postie and Store & Order brands (GBGM Group). Debenhams and the GBGM Group (Debenhams, our, us, we) are committed to the protection of the personal information of all of our customers. We have developed this policy in line with the ‘Australian Privacy Principles’ (APPs) and the Privacy Act to provide you with information on how we deal with your personal information including how we collect, hold, use and disclose your personal information and how you may access and correct it.
Please take some time to read through this policy before you provide us with any personal information. We also encourage you to check this policy regularly as it may change from time to time. If you have any suggestions or concerns that are not addressed in this policy, please contact us.
What kind of personal information do we collect?
We will only collect personal information about you if it is reasonably necessary for our functions and activities. We may collect information from you that personally identifies you such as your name, email address, home address, telephone number, gender, date of birth, age, details of communications with us (written or verbal), personal interests, the number of children you have and their ages and gender and, in some instances, government identifiers (such as your driver’s licence).
We generally will not collect sensitive information about you (such as racial or ethnic origin, political opinions, religious or philosophical beliefs or details of health or disabilities). However, in some cases we may ask you to provide information related to your health or disabilities to assist us in providing you with specific services. We will only collect and use sensitive information in compliance with the APPs.
You have the option of not identifying yourself or dealing with us using a pseudonym in relation to particular matters. However you will appreciate that, in some circumstances, it may not be possible for us to deal with you if you do not identify yourself.
How do we collect personal information?
We collect personal information directly from you in the normal course of business, including electronically when you visit our websites. You may be asked to provide us with personal information when you:
- make online shopping purchases, including via third party payment platforms;
- make in-store shopping purchases;
- return goods without a receipt;
- subscribe to our newsletters or join our mailing lists;
- complete one of our forms, including online through our social media channels, wholesale account application forms, or forms provided with our goods;
- enter into competitions or trade promotions;
- sign up to the Debenhams Customers Experience App (known as the Debenhams Australia App in the Apple App store and Google Play store);
- request goods to be delivered to you or services to be provided to you;
- register a gift card;
- register as a customer, or otherwise use, our websites; and/or
- make an enquiry with us or correspond with us.
We may collect personal information about you from third parties where you have consented to such collection, or would reasonably expect us to collect your personal information in this way.
You consent to us collecting, holding, using and disclosing such information in accordance with this policy.
If we receive information about you from a third party and it is not information we need in respect of our business activities, we will destroy or de-identify that information (provided it is lawful to do so).
If we collect personal information about you from other entities and you have not already given your consent to that collection, we will take such steps as are reasonable in the circumstances, to notify you that we have collected personal information, how it was collected, and why we have collected it and provide you with a copy of this policy.
We collect personal information (which may include sensitive information) if you register or apply for a job with us. As part of that process, you agree that we may collect personal information about you from you and your referees, recruitment agencies and related service providers. This personal information is collected for recruitment purposes and will be used solely for that purpose. You consent to us disclosing such personal information to third party service providers who provide recruitment related services to us.
How do we hold personal information?
We will use all reasonable endeavours to maintain the security of your personal information and to protect your personal information from misuse, interference and loss and against unauthorised access, modification or disclosure. Any personal information that we receive is securely stored and access is restricted to the GBGM Group and our authorised personnel. Although we ask for credit card information in order to process some requests from you, we do not store complete credit card information on our web server. We use secure payment platforms to process online orders all in a ‘secure socket layer’ environment and our websites all use GlobalSign EVSSL Certificate.
How do we use personal information?
If we hold personal information about you that was collected for a particular purpose, we will not use or disclose it for another purpose unless: (a) you consent; (b) you would reasonably expect us to use or disclose it for that other purpose; or (c) it is required or authorised by law or a court/tribunal order.
We generally use personal information, and you consent to us using your personal information, to:
- deliver or help you manage our products or services;
- complete transactions with you or on your behalf;
- enable us to undertake a credit assessment;
- conduct promotions or competitions;
- help us manage and improve our services and websites;
- communicate with you;
- where you have consented to receive direct messaging, send you ongoing information, offers and promotional material about opportunities, products and services which we believe may be of interest to you;
- manage and resolve legal, consumer or commercial complaints and issues;
- conduct market research and analysis;
- manage and recruit employees;
- carry out internal functions including training and internal audits.
When returning or exchanging goods, we require you to provide proof of purchase from us. If a return is approved without proof of purchase, we will require suitable personal information from you for the purposes of identification. This personal information may be recorded with the transaction as part of our fraud prevention program. Information collected in these circumstances will only be used for this purpose.
We may promote our goods and services to you via SMS alerts but only if you have consented to receive such information via SMS. To stop receiving all Debenhams SMS alerts follow the instructions in the SMS alert. You will receive a confirmation message and then no further SMS alerts will be sent to your number.
Who do we disclose personal information to?
We do not disclose your personal information to anyone else unless:
- you have consented to the disclosure;
- you would reasonably expect, or have been told, that your information is passed to those individuals, businesses or agencies;
- we sell all or part of our business, merge with another company or business, or restructure our business (or contemplate doing any of the foregoing), in which case we may transfer or disclose your personal information to the parties involved in the transaction for the purposes of that transaction;
- if it is reasonably necessary, in our opinion, to protect our rights or property or that of any third party or to avoid injury to any person; or
- it is otherwise required or authorised by law.
You consent to us disclosing your personal information to our authorised personnel and to:
- other companies in the GBGM Group;
- to companies that perform services on our behalf, such as delivery services, mail outs, customer liaison services, data entry services, trade promotion or gift card administration, account management services and debt collection services;
- our professional advisors, including auditors and lawyers;
- payment system operators and financial institutions; and
- organisations authorised by us to conduct promotional, research and/or marketing activities.
We take reasonable steps to ensure that third parties that we disclose your personal information protect your privacy to the same standard expected of us.
If you have provided us with your personal information for the express or implied purposes of receiving direct marketing, you hereby consent to us, other companies in the GBGM Group and our business partners using your personal information to advertise or send you information about their products and services which we think may be of interest to you.
You will be given the opportunity to “opt out” or unsubscribe from receiving direct marketing communications from us. Alternatively, you may contact us at the address below to “opt out” of, or unsubscribe from, any future communications. Debenhams will use all reasonable endeavours to comply with that request within a reasonable period, and in any event, within five business days.
You acknowledge that we may disclose your personal information overseas in situations where:
- entities to whom we are permitted to disclose your personal information under this policy are based overseas; or
- the personal information we collect is stored on servers located overseas.
You acknowledge that as a result of your consent to such disclosure (if any), clause 8.1 of the APPs does not apply.
How do you access and correct your personal information?
Where we hold personal information about you, we will provide you with access to the information on request within a reasonable time if it is reasonable and practicable to do so. Where you make a request for access to your credit reporting information, we are obliged to first obtain sufficient information to allow us to protect the security of the information, and to verify your identity and entitlement to such information. You will therefore need to provide sufficient identifying information to obtain access.
There are some exceptions where we may refuse to give you access and these are set out in clause 12.3 of the APPs. In that case, where required, we will give you written notice setting out the reasons for our refusal and the mechanisms available if you wish to complain about our refusal.
We may impose a reasonable charge for giving you access to your personal information.
If we are satisfied that your personal information is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take reasonable steps to correct your personal information. In addition, if you request us to correct your personal information, we will take reasonable steps to do so within a reasonable time. If you request it, we will also take reasonable steps to notify any other entity of the changes if we have previously provided your personal information to that entity. There is no fee for correcting your personal information.
How do you contact us or make a complaint?
If you have any questions or comments on this policy, are concerned about how your personal information is being handled or if you would like to make a complaint in respect of our obligations under the APPs, please contact our Privacy Officer by:
- emailing us at: privacy@greenlitbrandsGM.com.au
- calling us on: 03 9863 2200; or
- writing to us at: Attention Privacy Officer, Debenhams, L1, Building 8, Botanicca Corporate Park, 576 Swan Street, Richmond VIC 3121.
We will acknowledge receipt of your complaint as soon as we can and in any event within 7 days and will let you know if we need any further information from you.
We aim to resolve complaints as quickly as possible. If we do not believe we will be able to resolve your complaint in a timely manner, we will let you know what is happening and a date by which you can reasonably expect a response.
If you are unhappy with our response, you may complain to the Office of the Australian Information Commissioner about the handling of your personal information.
The Commissioner can be contacted at:
GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992