We collect personal information to properly provide services or products to you. Personal information is any information that is recorded in any form about a person (irrespective of whether it is true or not) from which that person may be identified. Generally, we will tell you why we are collecting information when we collect it and how we plan to use it, or these things will be obvious when we collect the information.

We usually collect personal information directly from you although sometimes the agents or service providers that we engage to administer services on our behalf, may also collect the information from you.

If the operators of those third party websites collect information about you, we have arrangements in place with those third parties that allows us to collect or have access to that information. STS is not responsible for the privacy practices of such third parties and this Privacy Policy does not apply to them.

We may collect personal information from you when you:

• make an inquiry;
• visit our website and related websites;
• make an inquiry or interact with us via our social media platforms including LinkedIn;
• participate in a promotion, competition or survey;
• complete a warranty claim or other claim in relation to any of our products; join our mailing list; and
• provide your details to access our services

When we do obtain information through automated means, we will display to you the information collected and give you the opportunity to amend or correct the information prior to its formal recording with our systems.

The types of personal information we may collect from you include:

• general personal details such as your name, date of birth, gender, title, contact number, address and email address;
• business details such as your name, title, contact number, address and email address, retail shop address, retail sales platform;
• your location details through your smart phone or device or IP address.

When you browse our website, our internet service provider makes a record of your visit and logs information for internal review and statistical purposes. We are then provided with the country of origin of the user’s server address, date and time of visit to the site, and the pages viewed.

We may share your information with our Related Entities. We or they may also use your personally identifiable information to assist us in improving Sea to Summit services or products.

Sea to Summit and our Related Entities may use your information to (each a “Purpose”):

• manage and work with our service providers and contractors to fulfil your request for products and services such as processing transactions and payments, providing refunds and discounts, and processing any warranty claims;
• create orders, transaction records, agreements for the sale of products or services, accounts, tax invoices or receipts;
• provide your personal information to third parties that assist us in providing products and services you have requested, such as delivery service providers and fulfilment managers;
• communicate with you, and build and maintain our relationship with you;
• fulfil administrative functions associated with these products and services, for example billing and warranty claim services, marketing purposes and to send you account and service updates (such as updates to our terms and conditions);
• identify and develop new products and services you may be interested in and improve the services and support we provide to you;
• conduct, monitor and analyse our business and internal operations;
• carry out quality control and research to improve the way that Sea to Summit and its Related Entities and service provides provide products and services to you;
• comply with applicable laws and other regulatory, accounting or reporting obligations to protect, exercise or defend our legal rights;
• process and respond to your requests, enquiries or complaints;
• monitor visitors to our website and analyse their behaviour to help make our service and offerings better (which is further explained below); and
• comply with laws or regulations or to comply with any directions given by regulators or authorities.

If Sea to Summit intends to use your personal information for any other purpose not listed in this document, Sea to Summit will seek your consent before doing so.

In addition, we may collect information regarding your use of our website such as identifying when you visit our website or contact us. As a general rule we do not collect sensitive information. However, if we do, it will usually be for the purposes of providing Sea to Summit services or products. If the law requires us to, we will seek your consent to collect such usage information.

If you do not provide accurate personal information as requested by Sea to Summit, you understand that Sea to Summit, or our Related Entities, may not be able to provide you with one or more of the products or services sought, or the same level of service it intends to provide to, or provides, to others.

We may collect certain non-personal information to optimise Sea to Summit services (including our apps and websites) for your Internet-enabled device (e.g. the identity of your Internet browser, the type of operating system or device you use, your IP address and the domain name of your Internet service provider). We may use such non-personal information for internal purposes, including but not limited to improving the content of our sites and apps and assisting with the diagnosis of problems or support issues associated with our supply of Sea to Summit products or services.

Sea to Summit may use personally identifiable information in aggregate form to improve Sea to Summit products and services (including our websites) and make them more responsive to the needs of our customers. This statistical compilation and analysis of information may also be used by Sea to Summit or be provided to others as a summary report for marketing, advertising or research purposes.

At this time, Sea to Summit primarily uses Google Analytics to obtain this information. You can find out more information about the processing or web analytics data by Google Analytics at https://support.google.com/analytics/answer/6004245?hl=en.

Your personal information may be disclosed in connection with any Purpose to any of the following:

• our employees, contractors or service providers, to the extent reasonably necessary to fulfil our obligations to you. This may include internet service providers, IT systems administrators, mailing houses, couriers, payment processors, and data entry service providers;
• retail brands and suppliers who provide goods and services to us;
• our related companies and brands (within and outside of Australia);
• our business advisors, including lawyers, accountants or other professional service providers, to the extent reasonably required;
• suppliers and other third parties with whom we have commercial relationships, for business, marketing and related purposes;
• if required by law, to any person authorised by such law; and
• for any other purpose permitted by law.

As set out earlier, Sea to Summit may disclose your personal information to any of Sea to Summit’s Related Entities located outside of Australia.

If we engage third-party providers or contractors, we will take all reasonable steps to ensure that they do not breach any privacy requirements in relation to the information shared with them.

As Sea to Summit is a global business and some of our third party service providers have operations overseas or who are located overseas, we may need to disclose your personal information to our Related Entities or third parties, whether located within or outside Australia for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we are permitted to disclose your Personal Information to such third parties (whether located within or outside Australia) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your Personal Information for one or more of the above Purposes. Before we disclose your Personal Information to a recipient outside of Australia, we will comply with the Privacy Act in doing so. We will take reasonable steps to ensure that the overseas recipient of the Personal Information will not breach the Privacy Act in relation to the Personal Information.

We hold your personal information in hard copy and electronically. Your privacy is important to us. To the extent required to comply with the applicable privacy laws, we will take reasonable steps to protect the personal information that we hold in our possession from misuse, interference, loss and unauthorised access, modification or disclosure.

By registering for and/or participating in the use of our services you understand that Sea to Summit may collect and hold the personal information provided indefinitely.

Sea to Summit strives to ensure the security, integrity and privacy of personally identifiable information of our customers. We use a variety of physical and electronic security measures including restricting physical access to our offices and firewalls and secure databases to keep personal information secure from misuse, loss or unauthorised use or disclosure. Unfortunately, no data transmission over the Internet can be guaranteed to be totally secure and you accept this inherent risk. Accordingly, Sea to Summit and our Related Entities are not responsible for any event arising from unauthorised access of your personal information.

It is your responsibility to implement sufficient procedures and checks to satisfy the security of your computers (including web-enabled communication devices) and data from viruses, Trojans, hackers and other forms of unauthorised access by any person or program.

If at any time you believe that the integrity of your account with Sea to Summit has been breached, please contact enquiries@seatosummit.com.au

You have the right to access most personal information we hold about you and if we deny access in some circumstances, we will tell you why. To request access, please contact our Privacy Officer as set out at the end of this document.

Please note that we may only be able to provide you with current details of personal information we hold about you. We are not able to guarantee that we can provide you with details of personal information held about you at a particular point in time.

If you note any error in the personal information we hold about you, we ask that you contact our Privacy Officer to initiate our corrective procedures.

Sea to Summit may employ programs having cookies, or other functionality similar to cookies, to assist you in using the website or in us providing our services to you. Please note that Cookies are nothing more than a string of letters and numbers – they cannot determine the identity of individual users. Cookies allow us to collect information about your visit history and activity on our website and this information helps us improve your experience of our website.

If you have concerns regarding the use of cookies by any site, you can change the settings of your Internet browser to disable the use of cookies.

Where Sea to Summit receives a request for personal information about one or more of our customers from a law enforcement or regulating agency, and Sea to Summit have taken advice that the request is legally valid and enforceable, Sea to Summit shall disclose that information to the law enforcement or regulating agency.

When this occurs, unless the request otherwise prohibits it, Sea to Summit will contact you as soon as practicable to seek your consent for the disclosure of your personal information and inform you of the law enforcement or regulating agency who made the request and the personal information to be provided in response to the request.

If we are not required to seek your consent prior to disclosure or if we are prohibited from informing you of the disclosure, then Sea to Summit will comply with the relevant laws and your personal information may be disclosed without your consent and without notice to you.

Sea to Summit uses personally identifiable information for essential communications, such as e-mails and critical service details.

If Sea to Summit changes its method of communicating with you, you will be advised of the reason for the change and the new method of communication through the website.

While we endeavour to protect the personal information of users of our website, we cannot guarantee the security of information you disclose online. You disclose that information at your own risk. You should be aware that no method of transmission over the Internet or method of electronic storage is 100% secure.

Remember to close your web browser when you have finished your user session. This is to ensure that others cannot access your personal information and correspondence. You as an individual are responsible for the security of and access to your own computer or web-enabled communications device.

Ultimately, you are responsible for maintaining the secrecy of your username and passwords and any account information. Please be careful and responsible whenever you are using the Internet.

If you become aware of unauthorised access, please let us know as soon as practicable.

From time to time, Sea to Summit may vary this privacy policy. Such variations may, for example, be made to keep them in line with updates to its business, to comply with legislative changes or for security or technical reasons. Your continued use of the website after such variations come into effect is deemed acceptance of the new privacy policy.

If you have any concerns or complaints about the way in which your personal information has been collected, used or managed by us, please direct it to our Privacy Officer by email to enquiries@seatosummit.com.au.

Otherwise, further information on your rights to privacy can be found at www.privacy.gov.au.

Sea to Summit also welcomes feedback of any sort on its website and services that our subscribers or visitors send to us. This information helps us to administer and improve our services and may be shared with others. Please direct any feedback to enquiries@seatosummit.com.au.

This Privacy Policy and your use of our website and our services is governed in all respects by the laws of Western Australia, Australia and you agree to submit to the exclusive jurisdiction of the courts of Australia.