SEELEY INTERNATIONAL PRIVACY POLICY
This privacy policy sets out how Seeley International Pty Ltd, its subsidiaries and related bodies corporate (“Seeley”/ “we” / “us”/ “our”) handle “personal information” or “personal data” that you provide to us or that we collect when you use our goods and services (“Personal Information”)
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).
We have created this privacy policy to demonstrate our commitment to the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”) (as amended from time to time), and to the extent that Seeley offers its goods and services to individuals in the European Union and the United Kingdom, or otherwise monitors the behaviour of individuals in the European Union and the United Kingdom, we have created this privacy policy to comply with the European Union’s General Data Protection Regulation (“GDPR”).
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
- Identifying information such as your name, date of birth, addresses, telephone numbers or email addresses when you register for an account with us.
- Other content that you input or that is otherwise connected to your account.
- Financial information (such as credit card or bank account numbers).
- You may also provide us other information through a web form, by updating or adding information to your account, through your communications with our sales support or support services teams, or when you otherwise communicate with us regarding our goods and services (including via our Platform).
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:
- Location information (including location information from your mobile device (if applicable)).
- Computer and connection information such as statistics on your page views, traffic to and from sites, referral URL, ad data, your IP address, your browsing history, and your web log information.
- We use cookies, web beacons, unique identifiers, and similar technologies to collect information about the pages you view, the links you click, and other actions you take when using our Platform, or within our marketing or email content.
- We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link
Personal information collected from other sources
- We supplement the personal information we collect directly with information collected from third parties. For example, we also collect information from and share information with third party credit history providers.
- We may also share personal information with social media platforms with your consent.
- If you give us personal information about someone else, you must do so only with that person’s authorisation. You should inform them how we collect, use, disclose, and retain their personal information according to this privacy policy.
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:
- provide you with the goods and services we offer including to create accounts, register a warranty claim, assist you to locate distributors selling our products, and processing payments for our goods and services;
- maintain our business relationship with you by answering any questions or queries you may have about Seeley, our goods and services (including the Platform), communicating with you about our goods and services, creating and updating our database(s) and other records, providing sales and support services to you and otherwise responding to your enquiries;
- market and advertise to you including by sending you newsletters, special offers, and promotions, or otherwise contacting you about goods and services, or information we think may interest you. We may contact you through phone, email, or SMS;
- improve the quality and design of our goods and services by storing, tracking, analysing and processing customer preferences and trends, as well as user activity on our Platform to create new features, functionality and services in relation to the Platform;
- assist our dealers, distributors, service agents and other third parties we deal with to improve the quality of their service to you; for example in selling, supplying, installing and servicing our products;
- comply with the law including by honouring warranty claims and any contractual obligations we may have with you; and
- exercise our legal rights including exercising rights we may have under law or a contract between us and you, or between us and a third party,
(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
Our Platform may contain links to other websites, platforms or applications. We are not responsible for the privacy practices of the owners of those websites, platforms, or applications. We recommend that you read the privacy policy of any website, platform, or application that asks you to provide your Personal Information.
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:
Privacy Officer
Seeley International Pty Ltd
PO Box 164
Lonsdale, South Australia 5160
Australia
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/.
Changes to our Privacy Policy
We may need to change this privacy policy from time to time. When we do amend it, the changes will be effective immediately upon being made public on our website. We will use reasonable measures to notify you of any relevant changes to this privacy policy, but please be aware that it is your responsibility to review our privacy policy regularly and make sure you keep up to date with any changes.