This policy covers situations where we, BILLY PHAIN, process your personal information. It also covers situations where approved partners use your personal information on our behalf.

2.1 We act as the “data controller”, which means that we determine “why” and “how” your personal information is collected and used.

2.2 Please see our Corporate Information for further details about us.

2.3 To be able to deliver our products and services to you, we need to share your personal information with approved partners who generally act as our “data processors”.

2.4 Certain partners, such as our social media, could also determine “why” and “how” your personal information is used. They have their own privacy and cookies policies, so remember that the personal information you give them will be subject to their rules and not ours.

3.1 The processing of your personal information will comply with your privacy legislation and rely on the legal bases set out in the ‘Lawful Purposes’ sections below.

3.2 If you would like more information on the purposes and legal bases, you can contact us.

When you interact with us, either online or in person, you may share with us your personal information when:

• You buy a product;

• You link your social media account to our BILLY PHAIN profile;

• You subscribe to our newsletter;

• You interact with us or seek advice and share personal information through our customer services, websites, our social media pages, or interact with us in person; or

• You use your device to browse activity across different websites.

We mainly obtain information directly from you and process it by automated means when you interact with us. We collect your personal information through:

• Our sales or customer service personnel;

• Our Website. We may also use cookies or other online advertising technologies for this purpose;

• Any means we make available to you - for example, when you buy a product, we may collect certain personal information relating to your payment; and

• From third-party sources such as social media.

Our general approach is to retain your personal information only for as long as it is needed. We may retain personal information for a shorter or longer time, for instance, where we are obliged to do so in accordance with relevant legal, tax and accounting requirements.

7.1 We design our services with your safety in mind. We have adopted specific technical and organisational security measures to protect personal information against accidental or unlawful destruction, accidental loss, alteration, unauthorised disclosure or access.

7.2 For example, we strictly control the scope of authorisation of our personnel’s access to the personal information that we collect and process.

7.3 We regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorised access and use.

7.4 We take commercially reasonable steps to make sure that our business partners and third-party service providers are able to protect your personal information.

7.5 If you have any concerns that your personal information has been put at risk, please contact us as soon as possible.

We may have to share your personal information outside the country where you have first shared it with us. When we do so, it will always be for the purposes described in this privacy policy and where we are satisfied with the levels of protection and security implemented in compliance with applicable privacy legislation.

9.1 We do not sell your personal information, and have not done so in the past 12 months.

9.2 We may allow selected third parties (such as approved advertising partners) to collect your personal information via automated technologies on our websites in an effort to provide you with content and advertisements that may be of interest to you and on the legal bases set out in this privacy policy.

We may share and disclose your personal information for business purposes with:

• Approved partners acting as service providers:

  • Retailers, resellers, delivery providers, fulfilment companies and transaction partners.

  • Marketing services, advertising providers, communication (email, SMS, MMS) providers and social networks.

  • IT service providers.

  • Audit, law firms and similar corporate professional service providers, data analysis providers.

• Actual or potential buyers as part of a business transfer.

• Law enforcement body, regulatory body, government agency, court, lawyers.

• At your request or for our legitimate interest or compliance with laws and regulations.

11.1 Subject to your applicable privacy legislation, you may be entitled to one or more of the following rights and exercise them on your own or via a legal representative acting on your behalf. You will never be discriminated against when you exercise your right in good faith under any applicable privacy law.

• Right of access, rectification and erasure

• Right to withdraw consent

• Right to personal information portability

• Right to restriction of processing

• Right to object to processing

• Right to lodge a complaint

11.2 If you need any further information regarding your rights or how to exercise any of your rights, or if you have any complaints or questions regarding our privacy practices, please contact us.

12.1 We may occasionally make changes to this privacy policy. We will post the updated privacy policy on our website.

12.2 We may also notify you in case of material changes and, where required by applicable law, we will seek your consent to those changes.