Seeley is Australia’s largest air conditioning manufacturer and a leader in developing cooling and heating products and provides a software platform and online platform (“Platform”) relating to its goods and services (our “goods” and “services”). Seeley is based in Adelaide, South Australia but offers its goods and services to customers all over the world (including in the United Kingdom, the United States, South Africa, and throughout Europe).
For the purposes of the GDPR, Seeley is both the “data controller” and a “data processor” of Personal Information and is legally responsible for how Personal Information is collected and used. This policy sets out how we collect, hold, protect, use or disclose your Personal Information, and how you may access your Personal Information.
What information do we collect?
We collect and hold your Personal Information which may include your name, address, phone number, birthday, email, related company name (if applicable), credit history and reference information, and other information relating to you, your business or relevant to our supply of goods and services to you.
We may also collect non-personally identifiable information about you (such as anonymous usage data, IP addresses and location, device type, browser or platform type etc.)
Further examples of the information (including Personal Information) we collect are set out below.
How do we collect Personal Information?
We collect your Personal Information during the course of providing our goods and services to you. This includes, without limitation, when you use our Platform (including by completing forms on our Platform), provide information to us via our sales support team or by email, when you complete paper forms, when you register an account or a warranty with us via our Platform, when you elect to receive our newsletters, alerts or other marketing materials, or otherwise via customer enquiries and communications.
Generally, we collect your Personal Information directly from you or automatically through your use of our Platform but we may also collect your Personal Information from other people or organisations if you have given your consent (including from third party credit history providers (if applicable), and payment providers).
More detailed examples of the information we collect include:
Personal information you may give us when you buy our goods or services, use our Platform or set up an account with us
Personal information we collect automatically when you use our Platform or register for an account with us
We collect information about your interaction with our Platform, your usage preferences, and your communications with us. This is information we receive from devices you use when you access our Platform. This information could include the following:
Personal information collected from other sources
Why do we need your Personal Information?
We only collect or hold your Personal Information for legitimate purposes, including to provide you with our goods and services, for the proper administration of our Platform, and to comply with our legal obligations to you including by honouring warranty or return claims in accordance with our terms of sale and applicable law.
In particular, we need your Personal Information to:
(together our “Required Purposes”)
If you do not provide us with your Personal Information, we not be able to carry out all of the Required Purposes or fulfil our obligations arising under the Required Purposes.
Can you remain anonymous or use a pseudonym?
Generally speaking, we do not allow you to use a pseudonym or to otherwise remain anonymous, as this is impractical for our business purposes.
We also note that if you do not provide us with some or all of the Personal Information we request, we may not be able to provide you with the relevant goods or services. This may also have an effect on whether we can begin or continue a relationship with you, and whether you can use or access our Platform.
What disclosures do we make?
Generally speaking (and as described above under the heading “Why do we need your Personal Information”) we will disclose your Personal Information for our Required Purposes. We may also disclose your Personal Information with your consent, where we are authorised or required to do so by law, or to our related entities, partners or service providers (including hosting providers, payment processors, security service providers, and support service providers) in order to assist us to provide our products or services to you. We may also disclose your information to third parties such as retailers, distributors, service agents and contractors who are affiliated with us; or marketing or market research companies.
Some of our related entities, partners and service providers or the services they provide may be based outside of Australia (including in the United States, the United Kingdom, South Africa, in France, Italy and Spain). By providing us with your Personal Information, you acknowledge that your Personal Information may be used, stored and disclosed overseas, including in jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. To protect your Personal Information we take care to work with entities, partners and service providers who are based in countries that provide adequate levels of data protection, or we otherwise take steps to ensure that your Personal Information receives adequate levels of data protection in the jurisdictions in which it is processed in accordance with all applicable privacy laws (including the GDPR).
Personal Information of minors
We do not knowingly collect or solicit Personal Information from anyone under the age of 16 years of age or knowingly allow such persons to use our goods or services (including by registering an account on our Platform). If we become aware that we have collected personal information from a person under the age of 16 years without parental consent, we will take all reasonable steps to delete that information.
Do we use “cookies”?
When you visit our Platform, the server may attach a “cookie” to your computer’s memory, which is a small file that asks permission to be placed on your computer’s hard drive. “Cookies” allow web applications to respond to you as an individual. A “cookie” assists us to store information about how you use our Platform and to make assumptions about what information may be of most interest to you, your needs, likes and dislikes. This information is generally not linked to your identity and is instead used for statistical analysis purposes. We may use knowledge of your user experience to better understand what goods or services may be of interest to you and to collect statistical information.
Using other sites
Is your Personal Information confidential and secure?
We take all reasonable steps to keep your Personal Information secure and to ensure it is protected against misuse, loss, unauthorised access, modification or inappropriate disclosure. We may keep your Personal Information in both hard copy and electronic forms, but adopt appropriate technical and organisational security measures to protect it including by storing it in secure systems accessible only to authorised personnel.
We also urge you to take steps to keep your Personal Information safe, such as choosing a strong password and keeping it private, as well as logging out of your account on our Platform, and closing your web browser when you are finished using the Platform on a shared or unsecured device.
Your choices and rights
We welcome your enquires and comments and encourage you to contact us to update your Personal Information if it changes. You may confirm if we are processing your Personal Information and request a copy of it. For your protection, however, we may require that you confirm your identity before we provide a copy of your Personal Information to you. You may also update or correct your Personal Information by contacting us at [email protected]
In some instances, you may request that we delete your Personal Information. In accordance with and subject to relevant privacy laws (including the GDPR), you may object to certain Personal Information being processed and request that processing of your Personal Information be limited. You may also limit or manage our communications with you by “unsubscribing” from certain email, newsletter and marketing updates, and by requesting to close your account on our Platform.
If you choose to limit the Personal Information we process about you we may not be able to communicate with you or fulfil our Required Purposes outlined above. This may include limiting or ceasing your use of our Platform, or otherwise ceasing to provide you with our goods and services.
Queries and complaints
If you have a question or want to make a complaint about how we handle your Personal Information please contact us using the details below. We will review any question, complaint or concern you may have and will respond to you after we have carefully considered it. We will, where reasonably possible, take steps to investigate and resolve complaints within 30 days. Please note, we may require further information from you in order to resolve any complaints. If we need more time, we will notify you about the reasons for the delay and seek to agree a longer period with you (if you do not agree, we may not be able to resolve your complaint).
We can be contacted at:
Seeley International Pty Ltd
PO Box 164
Lonsdale, South Australia 5160
For more information about privacy issues in Australia and protecting your privacy, please visit the OAIC website at www.oaic.gov.au. For more information about the GDPR, please contact the European Data Protection Supervisor, the European Union’s independent data protection authority or visit their website at: https://edps.europa.eu/.