R.M.Williams Group Privacy Policy

The R.M.Williams Group recognises the importance of your privacy and understands that the security of your personal information is important to you. We are committed to protecting the personal information you provide to us.

This Privacy Policy explains how the R.M.Williams Group manages the personal information that we collect, hold, use, and disclose and how to contact us if you have any further queries about our management of your personal information.

By using any of our services you confirm you have agreed to our Terms and Conditions and have read and understood this Privacy Policy.

This Privacy Policy does not apply to websites maintained by other companies or organisations to which we link, and we are not responsible for any personal information you submit to third parties via our website. Please ensure that you read the privacy policy of such other companies or organisations before submitting your personal information to them.

The R.M.Williams Group Privacy Policy applies to the following R.M.Williams Group companies:

Australia

• R.M.Williams Pty Ltd (ACN 007 527 166) (R.M.Williams Australia)

United States of America

• R.M.Williams US NY LLC (R.M.Williams NY) o R.M.Williams US TX LLC (R.M.Williams TX) o R.M.Williams US CA LLC (R.M.Williams CA) o R.M.Williams US Trade LLC (R.M.Williams US Trade) (together R.M.Williams US Group)

United Kingdom

• R.M.Williams (UK) Limited (R.M.Williams UK)

New Zealand

• R.M.Williams (New Zealand) Proprietary Limited (R.M.Williams NZ)

Netherlands

• R.M.Williams B.V (R.M.Williams Netherlands)

For European Union data protection purposes when we act as a controller in relation to your personal data R.M.Williams Netherlands is our representative in the European Union.

Personal information and data

When we say ‘personal information’ or ‘personal data’ we mean identifiable information about you like your name, email address, address, telephone number, payment information, support queries and so on. If you can’t be identified, then this Privacy Policy doesn’t apply.

For the purposes of this Privacy Policy, we will use the term ‘personal information‘ however this is to be read as ‘personal data' for European Union data protection purposes.

What personal information does the R.M.Williams Group collect?

During our business, the R.M.Williams Group may collect personal information about you that is necessary for us to perform our functions and activities. The R.M.Williams Group will only collect personal information about you by lawful and fair means and not in an unreasonably intrusive manner.

The types of personal information we may collect and hold may vary depending on the nature of our interaction with you and may include:

• identifying and contact information (such as name, home address, shipping/billing addresses, email address and telephone phone number)

• credit card and payment details

• product order history and purchase information

• information you provide to us, for example reviews

• social media usernames such as in relation to Facebook, Instagram, and Twitter

• demographic data including preferences and interests

• website usage and other technical data such as details of your visits to our websites or information collected through cookies and other tracking technologies

• if you are a candidate for employment when you complete forms in relation to the recruitment and selection process for the purpose of assessment.

The R.M.Williams Group may collect personal information about:

• customers while providing our products and services to them

• third parties providing a service to the R.M.Williams Group

• employees and contractors of the R.M.Williams Group.

How does the R.M.Williams Group collect personal information?

The R.M.Williams Group may collect your personal information in several ways including

• through our websites

• in person in our retail stores

• over the telephone,

• through social media channels

• through other communications such as by email and through surveys and competitions.

If you are a customer, the R.M.Williams Group typically collects your personal information directly from you but may also collect your personal information from third parties such as payment system providers and third-party analytics companies.

Our retail store in Denmark is operated by a franchisee, Herast Interest AB (Denmark Franchisee), and R.M.Williams UK may collect your personal information from the Denmark Franchisee.

For what purposes does the R.M.Williams Group collect, hold, use, and disclose your personal information?

We will only use your personal information where we are permitted to do so by applicable law. Under European Union data protection law, the use of your personal information must be justified under one of a number of legal grounds. The principal legal grounds that justify our use of your personal information are for our legitimate interests to allow us to operate our websites, provide you with our services and to manage our relationship with you.

We may also use your personal information for other purposes which may include:

Communication

• providing you with information you have requested from us or we are required to send you

• operational communications like changes to our website and services

• marketing communications in accordance with your marketing preferences

• asking you for feedback 

• To enhance our website and services

• To protect you so that we can detect and prevent any fraudulent or malicious activity

To market to you

• In addition to sending you marketing communications, we may also use your personal information to display targeted advertising to you online – through our own websites or through third party websites and their platforms.

To analyse, aggregate and report

• We may use the personal information we collect to produce aggregated and anonymised analytics and reports which we may share publicly or with third parties.

In general, the R.M Williams Group collects, holds, uses and discloses personal information for the following purposes:

• to process, fulfil and deliver your orders and provide you with our products and gift vouchers

• to keep you informed of the status of your orders

• to register you for, and provide you with, our services

• to invoice and process any fees payable in relation to our products and services

• to provide you with a personalised shopping experience

• to perform authentication and identity checks

• to record your communications with our personnel

• to manage our relationship with you and your account with us, and to contact you for follow up purposes

• to provide you with promotional materials

• to conduct market research and customer satisfaction surveys

• to conduct competitions and promotions

• to verify and update personal information held by us

• to recruit and train personnel

• to review, develop and improve our products and services

• to conduct internal and demographic studies and monitor customer patterns

• to handle and address customer complaints

• to comply with legal or regulatory obligations

• for other purposes required or authorised by or under law, including purposes for which you have provided your express or implied consent.

Our range of products and services and our functions and activities may change from time to time.

If you provide your email address, telephone and/or mobile phone number, you also consent to the R.M.Williams Group using your email address, telephone and/or mobile phone number to contact you (including by telephone call, SMS or email) for any of the above purposes.

We also collect information automatically, for example when you visit our website like your IP address and device type. We also collect information when you navigate through our website and services, including what pages you looked at and what links you clicked on. This information helps us get a better understanding of how you are using our website and services so we can continue to provide you with the best experience.

Some of this information is collected using cookies and similar tracking technologies. You can read our cookies notice here.

To whom may the R.M.Williams Group disclose your personal information?

In order to carry out the above purposes, a R.M.Williams Group entity may disclose your personal information to:

• our related bodies corporate

• our employees, contractors or services providers to the extent reasonably necessary to fulfill our obligations to you which includes other persons or organisations engaged by the R.M.Williams Group to assist the R.M Williams Group in carrying out the above purposes such as payment system providers, providers of targeted online advertising, social media platforms, IT support providers, shipping and courier delivery providers, mailing houses, retail management solution providers and other eCommerce providers

• credit reference or fraud prevention agencies

• regulatory authorities

• parties involved in a prospective or actual transfer of our assets or business.

If we are unable to collect your personal information

If we are unable to collect your personal information some or all of the following may occur:

• we may be unable to provide products or services to you, to the requested standard or at all

• we may be unable to communicate with you to provide information about products and services that you have purchased from us, or may intend to purchase in the future

• we may be unable to tailor the content of our marketing communications to suit your preferences

• your experience when interacting with us may be delayed or not as efficient as you may expect

• if you are a candidate for employment we may not be able to process your applicable for a position with the R.M.Williams Group.

How does the R.M.Williams Group hold your personal information and manage the data quality and security of your personal information?

We may hold your personal information in either electronic or hard copy form.

If you provide information to us electronically we retain this information in our computer systems and databases. This includes computer software programs, internet servers and hosted internet solutions provided by third parties.

If you chose to unsubscribe from receiving emails from the R.M.Williams Group, please unsubscribe using the link provided at the bottom of an email sent to you and follow the prompts. This will unsubscribe you from receiving emails in our systems, however it will not remove the details you have provided R.M Williams from our systems. If you would like to have all of your details removed from our systems, please contact dataprivacy@rmwilliams.com and request for your details to be deleted from our systems (unless we need to retain it for the purposes set out in this Privacy Policy). There is more on this below.

We recognise that information security is an integral element of data privacy. While no data transmission (including over the internet or any website) can be guaranteed to be secure from intrusion, we implement a range of commercially reasonable physical, technological and procedural measures to help protect personal information from unauthorised access, use, disclosure, alteration or destruction in accordance with applicable legal requirements.

Information that you provide to us is stored on our or our service providers secure servers and accessed and used subject to our security policies or standards, or those agreed with our service providers.

Our third party service providers and parties we may engage that process personal information on our behalf (for the purposes listed above) are also contractually obligated to respect the confidentiality of our personal information.

To the extent required by applicable law, the R.M Williams Group will take reasonable steps to:

• make sure that the personal information that we collect, hold, use and disclose is accurate, complete and up to date

• protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure.

The R.M.Williams Group will take reasonable steps to ensure that personal information that is held which is no longer required, including under any contractual or legal requirement, is destroyed or de-identified in a secure manner.

How long do we hold your personal information?

We will retain your personal information for as long as is necessary to fulfill the purpose for which this data collected and any other permitted linked purpose (for example certain transaction details and correspondence may need to be retained in order to comply with regulatory requirements). Our retention periods are also based on our business needs and good practice.

What are your rights?

Right to access

You have the right to request information about the personal information we hold about you at any time. You can contact us, and we will provide you with your personal information via email.

Right to portability

Whenever we process your personal information by automated means either based on your consent or based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal information you have submitted to us.

Right to rectification

You have the right to request rectification of your personal information if the information is incorrect, including the right to have incomplete personal information completed. If you have an R.M Williams account you can edit your personal information in your account and on membership pages.

Right to erasure

You have the right to erase any personal information processed by us at any time except for the following situations:

• you have an ongoing matter with customer service

• you have an open order which has not yet been shipped or partially shipped

• you have an unsettled debt with us, regardless of the payment method

• you are suspected of misusing or have misused our services within the past four years

• your debt has been sold to a third party within the past 3 years or one year for deceased customers

• your credit application has been rejected within the past 3 months

• if you have made a purchase, we will keep the personal information linked to your transaction for bookkeeping purposes.

Your right to object to processing based on legitimate interest

You have the right to object to processing of your personal information that is based on our legitimate interest. We will not continue to process the personal information unless we can demonstrate either legal claims or legitimate grounds for the process which overrides your interest and rights.

Your right to object to direct marketing

You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes.

Right to restriction

You have the right to request that we restrict the processing of your personal information under the following circumstances:

• if you object to processing based on our legitimate interest, we must restrict all processing of such data pending the verification of the legitimate interest

• if you have asserted that your personal information is incorrect, we must restrict all processing of such data pending the verification of the accuracy of the personal information

• if the processing is unlawful, you may oppose the erasure of personal information and instead request the restriction of the use of your personal information

• if we no longer need the personal information, but you require the data to defend legal claims.

Does the R.M.Williams Group transfer personal information overseas?

When we share data, it may be transferred to, and processed in, countries other than the country you live in. These countries may have laws different to what you’re used to. Some of our associated companies with whom we share personal information may also be located overseas. These associated companies will often be subject to privacy and confidentiality obligations dictated by laws in their own jurisdictions. Nevertheless, we will take such steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach relevant privacy law or principles.

For individuals in the European Economic Area (EEA) this means that your data may be transferred outside of the EEA. Where your personal information is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data or to a third party where we have approved transfer mechanisms in place to protect your personal information.

Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

Marketing

We may use your personal information to contact you (including by telephone call, SMS or email) in relation to products, services or other offers we think may be of interest to you.

When you register to create an account on any of our websites, you will be given the option to opt-out of subscribing to our regular update service which will send you email and direct mail alerts for new products, features, enhancements, special offers, contests, events of interest, and one-off marketing promotions.

You may also opt-out of receiving marketing information at any time using one of the following means:

• By logging into your account on our website and changing your direct marketing preferences

• By clicking ‘unsubscribe’ at the bottom of a direct marketing email sent by us; or By email: dataprivacy@rmwilliams.com 

Please allow 5 working days for us to action your request.

If you request not to receive marketing material from a R.M.Williams Group entity, please note that we may still contact you in relation to our ongoing relationship with you. For example, if you have submitted an order for a product with us, we may contact you in relation to that order.

Remarketing

We use third party vendors to advertise online and third party affiliations to run advertising on these platforms. Third party vendors, including Google, show our ads on sites across the Internet by using cookies to serve ads based on someone's past visits to our websites. These third party affiliations may contact you by phone to discuss our products and services. You can opt out of Google's use of cookies by visiting Google's Ads Settings. If you want to permanently opt out of Google’s DoubleClick cookie, you can install the DoubleClick opt out extension. You also have the option to opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative.

We use third party vendor remarketing services including Google’s ‘Customer Match’ and Facebook’s ‘Custom Audience’ to display ads. This means if you have provided us with your contact details, unless you opt-out of receiving direct marketing from us, we may upload these to third party vendors who perform remarketing services on our behalf.

Microsoft Clarity

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioural metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimisation, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

Google reCAPTCHA

We use “Google reCAPTCHA” (hereinafter referred to as “reCAPTCHA”) on our website. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”).

The purpose of reCAPTCHA is to determine whether data entered on our website e.g. information entered into a contact form, is being provided by a human user or by an automated program. To determine this, reCAPTCHA analyses the behaviour of the website visitors based on a variety of parameters. This analysis is triggered automatically as soon as the website visitor enters the site. For this analysis, reCAPTCHA evaluates a variety of data e.g. IP address, time the website visitor spent on the site or cursor movements initiated by the user. The data tracked during such analyses is forwarded to Google.

reCAPTCHA analysis runs entirely in the background. Website visitors are not alerted that an analysis is underway.

It is in our legitimate interest, to protect our web content and web forms against misuse by automated industrial espionage systems and against SPAM.

For more information about Google reCAPTCHA and the Google Privacy Policy and Terms of Service which apply, please follow these links:

reCAPTCHA and https://policies.google.com/privacy.



Cookies

To make our websites more convenient to use, our site uses cookies (very small files that are sent by us to your computer or other access device) which we can access when you visit our site in the future. This information allows us to make our websites easier to use as the cookies allow our servers to remember your details between visits to our site. Sensitive information such as credit card information is never stored in cookies.

There are four types of cookies. By using any of our websites you agree that we can place these types of cookies on your device and access them when you visit any of our websites in the future:

Website functionality cookies: enable you to browse the website and use features such as our shopping basket

Website analytics cookies: to measure and analyse how our customers use the website, including Google Analytics Display Advertising Features. This allows us to continuously improve our websites and your shopping experience.

Customer preference cookies: the website will remember preferences you make (for example your user name, language or location). This makes your browsing experience simpler, easier and more personal to you.

Targeting cookies or advertising cookies: these cookies are used to deliver adverts relevant to you. In addition, they limit the number of times you see an advertisement as well as helping us measure the effectiveness of our advertising campaigns.

If you want to delete any cookies that are already on your computer, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies.

Please note that by deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our websites.

How can you access or correct your personal information and contact the R.M.Williams Group?

If for any reason you are concerned that the personal information held by us is not correct and you have an account with us, please visit our website where you created your account and, after logging into the website using the ‘Sign In' menu on the home page, your personal information will be made available for review and change in the 'My Account' section. Only you or, upon your request, the Customer Care department, may access your personal information from the website using your password and User ID. Your personal information may be changed online within My Details, Shipping Details, and My Email Preferences. You can change or delete saved credit/debit card details each time you make a purchase. You will also be able to delete saved credit/debit card details by adding or editing a shipping/billing address. If you change your billing or shipping address while your order is still being processed, the order will be re-processed through security validation checks.

If you would like to seek access to the personal information we hold about you, or you would like to request that we correct the personal information we hold about you and you do not have an account with us, please contact us. We will provide you with access to your personal information within 30 days, and will take reasonable steps to amend any personal information about you which is inaccurate or out of date. In some circumstances and in accordance with applicable laws, the relevant R.M.Williams Group entity may not permit you access to your personal information, or may refuse to correct your personal information, in which case we will provide you reasons for this decision.

How the R.M.Williams Group handles complaints

If you have any concerns or complaints about the manner in which your personal information has been collected or handled by a member of the R.M.Williams Group, please advise us of your concern or complaint in writing and send it to the Privacy Officer. Your concern or complaint will be considered or investigated and we will endeavour to respond to your complaint within 30 days. It is our intention to use our best endeavours to resolve any complaint to your satisfaction. However, if you are unhappy with our response, you may contact the supervising privacy regulatory authority in your country of residence.

You can contact us by email at dataprivacy@rmwilliams.com, or by post at: R.M.Williams, 121 Frost Road, Salisbury, South Australia 5108, Australia.

Changes to our Privacy Policy

This Privacy Policy is effective from 1 January 2020. As this Privacy Policy is updated from time to time, to obtain a copy of the latest version at any time, you should visit one of our websites at:

Australia: www.rmwilliams.com.au

New Zealand: https://www.rmwilliams.com.au/nz/

United States: www.rmwilliams.com

Canada: rmwilliams.com/ca

United Kingdom: www.rmwilliams.com/uk

Denmark: rmwilliams.com/dk

France: rmwilliams.com/fr

Germany: rmwilliams.com/de

Ireland: rmwilliams.com/ie

Norway: rmwilliams.com/no

Netherlands: rmwilliams.com/nl

Sweden: rmwilliams.com/se

Switzerland: rmwilliams.com/ch

or contact the relevant Privacy Officer as above.