We are committed to the protection of your private information. This is why we have a Privacy Statement so you can see what we are about, what we will do and how you can contact us.
This Privacy Statement applies to websites, www.skins.net and *.skins.net (“Websites”) and to our SKINS family of companies including but not limited to SKINS Global Holding AG, SKINS International Trading AG, SKINS North America LLC, SKINS GmbH, SKINS Services Ltd and True Alliance Brands Pty Ltd (Authorised Australian Distributor). The contact details relevant to your country or region are set out below in the “Contacts” section.
In this Privacy Statement we use the terms “we”, “us” and “our”. This is a reference to SKINS, just in case you were in any doubt.
SKINS complies with;
- (a) the European Union’s General Data Protection Regualtion (GDPR) as and from 25 May 2018; and
- (b) the Australian Privacy Principles (“APPs”). This includes the Privacy Act 1988 (Cth), the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth) and the Privacy Regulation 2013 (Cth);and
- (c) the United States Federal Trade Commission Act (15 U.S.C. §§41-58) prohibiting unfair and deceptive practices –
Hereinafter referred to as the “Privacy Legislation”. The Privacy Legislation are rules and regulation that sets out our clear obligations and guidelines with respect to privacy. We apply those obligations and guidelines in how we communicate with you and deal with your information.
Our Data Protection Officer (DPO) is Grant Bayley, Chief Information Officer of the SKINS Group. Our DPO can always be contacted at firstname.lastname@example.org (“Privacy Address”). Please direct privacy matters to the Privacy Address.
1. Right to Access
If you wish you to access any personal information that we hold about you for the purposes of review, amendment or otherwise, please contact us with your request to the Privacy Address. We shall provide you with a digital copy of the information free of charge. If you wish for your data to be transmitted to another controller, please advise in writing. We will seek to verify transmission instructions directly with you prior to transmission to authenticate the authorisation.
2. Right to be Forgotten
This is also known as ‘Data Erasure’. If you wish for your data that is held by us to be erased, including the dissemination of data and the use by third parties of your data, please contact us with your request to the Privacy Address. Data erasure will include data that is no longer relevant to the original processing purpose. However, please note that some data maybe retained for legal and tax accounting reasons relevant to where we trade.
3. So what is this Privacy Statement about?
This Privacy Statement outlines how we collect personal information, how we maintain, use, disclose and secure that information and destroy information that is no longer needed. It also provides some detail about your privacy rights along with our general rights and obligations and our statement in relation to the personal information we keep on record.
The Websites provide information about and details of SKINS products and services, some of which are available for purchase online. Users are required to register their personal details prior to purchasing goods from the Websites. Acceptance of the SKINS Terms and Conditions is a pre-requisite to use of the e-commerce component of the Website.
4. Personal Information held by SKINS
We only collect personal information that is necessary to assist us in providing our services. In most situations the information we collect about you is provided to us directly by you, for the purpose of purchasing SKINS products from the Websites.
Generally, we keep a record of one or more of the following types of personal information about users of the Websites:
- (a) information that identifies them, such as their name, date of birth, address, IP address, telephone number, e-mail address, bank account or credit card details and any other information provided by them, as well as any information provided by them about third parties, such as a name and delivery address;
- (b) account transaction information for any purchases made via the Websites; and
- (c) historical commentary regarding any conversations held between our users and SKINS; and
- (d) survey data from users being answers to questions provided by consent
All information collected is required and used for our business purposes only. We will not share, rent or sell your personal details with any third party to SKINS. Our servers are located in the USA, Ireland, The Netherlands and Germany.
5. Collection of Personal Information
SKINS may collect personal information about you in a number of ways, including, but not limited to:
- (a) directly from you, when you submit information online or provide information by phone or in documents; and
- (b) any other form of information submitted to us by you or any other person such as third parties who submit your name and address, as a point of contact and/or delivery address.
- (c) via agents or service providers, via other websites or via lists from other sources both from other companies and from other public documents and via strategic partners.
6. Use of Personal Information
Unless you object, this information may be used to:
- (a) contact you;
- (b) deliver your purchase orders to you or the nominated delivery address;
- (c) fulfil administrative functions associated with your purchase order, for example billing;
- (d) carry out secondary purposes related to the primary purpose of carrying out our business functions, such as providing products purchased by you to you;
- (e) effectively manage your accounts and carry on our business;
- (f) assess, process and investigate queries and/or complaints made by you;
- (g) update your records;
- (h) send news, information about our activities and general promotional material which we believe may be useful to you;
- (i) monitor who is accessing the Websites or using services offered on the Websites; and
- (j) profile the type of people accessing the Websites.
If you do not wish to have your personal information used in this manner or for any other specific purpose you can e-mail us at the Privacy Address.
You may, at some point (but we hope not), want to tell us to stop contacting you. If so, you may remove yourself from future messages, news, promotional materials and the like by following the instructions found within the sent message. After the Opt-Out request is processed, a final message will be sent to you confirming removal of the address.
Alternatively, you may send your request to the Privacy Address.
8. Protection and Security of Personal Information
We take all reasonable steps to protect all personal information we collect or hold about our users from misuse and loss, and from unauthorised access, modification and disclosure to the best of our ability. We have physical, electronic and procedural safeguards to protect your information that is held by us, and this includes among other things, preventing users from accessing information they have no need to access, by employing industry standard techniques such as firewalls, virus scanning tools and encryption; by using secure networks when transmitting electronic data; by practising a ‘clean desk statement’; and by providing secure storage for physical records.
SKINS do not store any payment method credentials (credit card numbers, expiry dates, CVV numbers, 3D-Secure credentials). When you complete a transaction on our website, we use payment pages hosted by a Payment Service Srovider (“PSP”), thus preventing their disclosure to SKINS. The PSPs that SKINS use do retain a restricted set of payment method credentials as permitted by the Payment Card Industry Data Security Standard (PCI DSS) for purposes such as (but not limited to) fraud prevention and issuance of refunds.
We utilise “cookies” which enable us to monitor traffic patterns and to serve you more efficiently if you revisit the site. A cookie does not identify you personally but it does identify your computer. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance.
We will not sell or otherwise provide your personal information to a third party, or make any other use of your personal information, for any purpose which is not incidental to your use of the Websites. For the removal of doubt, personal information will not be used for any purpose which a reasonable person would not expect.
SKINS uses secure methods to destroy or de-identify any personal information as soon as the law permits, provided the information is no longer needed by us for any purpose.
PLEASE NOTE: The information that you provide to us will be sent and shall pass through our internet servers located in the USA, Ireland, The Netherlands and Germany. Some of your information will also be held by our ERP system in Switzerland under the direct control of SKINS International Trading AG. Further, our administration of privacy matters across the SKINS family of companies and under this Privacy Statement is carried out in Switzerland by SKINS International Trading AG. As such, personal information that you provide to us will necessarily pass outside the borders of the Commonwealth of Australia for the purposes of successfully completing any transactions or requests from you.
9. Rights to Disclose Personal Information
We may need to disclose personal information to various organisations and/or parties (such as delivery service providers, information technology services providers, marketing service providers, market research agents, business partners and affiliate companies of SKINS) from time to time to help us to provide and market our goods and services to you. In some instances, we may need to disclose personal information to organisations and/or parties in a foreign country where, for example, this disclosure or transfer of personal information is necessary to enable the performance of our services (such as customs departments and postal services).
Such disclosure will be only for purposes related to the primary purpose for which your personal information was collected, and will not be for any purpose that you would not reasonably expect.
For all other purposes, your consent is generally required prior to disclosure of personal information, however we may still use or disclose that information if:
- (a) we subsequently notify you of the intended use or disclosure and you do not object to that use or disclosure;
- (b) we believe that the use or disclosure is reasonably necessary to assist a law enforcement agency or an agency responsible for government or public security in the performance of their functions; or
- (c) we are required by law to disclose the information.
We will preserve the content of any e-mail you send us if we believe we have the legal requirement to do so.
Your e-mail message content may be monitored by us for trouble-shooting or maintenance purposes or if any form of e-mail abuse is suspected.
Personal information which we collect may be aggregated for analysis but in such circumstances we would ensure that individuals remain anonymous.
If you request us not to use personal information in a particular manner or at all, we will adopt all reasonable measures to observe your request.
10. Correction of Information
We take all reasonable steps to ensure that all personal information we hold is accurate, complete and up to date. Users and other individuals should update and maintain their contact details within their online account, by logging into the Websites using their personal login and password and accessing their account information.
If something is not right then tell us at the Privacy Address.
11. Access to Information
Individuals are entitled to request access to any personal information relating to them that has previously been supplied to us over this Websites. They are entitled to edit or delete such information unless we are required by law to retain it.
We will process requests within 30 days. More time may be needed, depending on the nature of the request. Appropriate identification of the individual concerned will be confirmed before access is provided.
There is no fee charged for requesting access to your personal information, however we may charge you for the reasonable cost of processing your request.
In certain circumstances, we may refuse or limit your access to your personal information. If we do so, we will inform you in writing as to the reasons why that sets out:
- (a) the reasons for the refusal except to the extent that, having regard to the grounds for the refusal, it would be unreasonable to do so; and
- (b) the mechanisms available to complain about the refusal; and
- (c) any other matter prescribed by the regulations.
12. Contacting us
If you wish to comment on, query or complain about our Privacy Statement, contact us via the Privacy Address or using the details provided below:
True Alliance Brands Pty Limited
19 O'Riordan Street
Alexandria, NSW 2015
+61 (0)2 8306 3300 /phone
Rest of World
SKINS International Trading AG
+41 (0)41 500 5500 /phone
13. Changes to our Privacy Statement
We may amend this Privacy Statement from time to time. Not all changes to our Privacy Statement will require the consent of our users, for example where office security procedures are changed. We will notify our users of any change to our information handling statement that requires your consent before implementing.
This Privacy Statement was last updated on 15 May 2018.