Privacy Policy

Last Updated: 8th of january, 2020

This privacy policy (the "Privacy Policy") explains how LUXEads Pty Ltd (“Company,” “we,” or “us”) collects, uses, shares, and protects information of the users of Company’s websites and mobile or other software applications where this Privacy Policy is posted (collectively, the “Website” or Service). The Website allows you to sign up for free items in the mail simply by providing your contact information and honest opinion on what you thought of each product you receive. We collect and share your information to vendors and partnering brands to fulfill your Goodie Boxes, and we then let these brands and consumers know what you think about the products. By using the Website, you are using or directing Company to intentionally disclose personal information to and using Company to intentionally interact with these third parties. BY USING THE WEBSITE, YOU AGREE TO BE BOUND BY OUR PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY YOU MAY NOT ACCESS OR OTHERWISE USE THE WEBSITE.

Please note that this Privacy Policy only applies to the Website, and not to websites, applications, operating systems, or other platforms of third parties (“Third Party” or “Third-Party Platforms”), even if such Third-Party Platforms are linked to or accessible from the Website. Each Third-Party Platform will have its own data collection and usage practices, and may use their own cookies, web beacons, and other technology to collect information from you. Company is not responsible for the content or practices of any Third-Party Platforms and, if you choose to visit or use them, you do so at your own risk.

1. Who controls your information?

Any information or other data provided to or gathered by Company is controlled by:

2. What types of information do we collect?

“Information,” as used in this Privacy Policy, means personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular user or household.

Company collects the following categories of information about users of the Website:

• Information You Provide to Us. We collect information from you when you voluntarily provide it to us over the Website, including as part of registering a user account or using the Service. Such information may include identifiers and personal information such as your name, email address, telephone number, and address.
• Content You Make Public. Company may collect information that you voluntarily upload to or about the Website for public display (“Public Information”), such as when you post a product review, comment on a good or service, or participate in a forum on the Website. Once you submit Public Information, neither you nor Company are able to control how it may be copied, shared, or used by third parties, even if you and/or Company later delete such Public Information. Accordingly, you should carefully consider what personal information you choose to include within your Public Information.
• Transaction Information. We may gather additional information from you when you use the Service or contact customer service regarding a prior transaction. Such information may include information regarding the products you requested. When you click on links on the Website, we may collect or create records regarding your preferences or tendencies.
• Device/Internet Connection Information. When you use the Website, we automatically gather information made available by your web browser (such as Microsoft Edge or Google Chrome), internet service provider (such as Comcast or Cox), and device (such as your computer, phone, or tablet), depending on your settings for each. For example, we may collect your IP address, information about the operating system or type of device you use, the device ID associated with your device, the date and time you access the Website, and your log in attempts.
• Internet Activity Information. We may also collect information about your browsing history, search history, and information regarding your interaction with a particular website, application, or advertisement, including the Website. We may collect information regarding the websites, application, or advertisement you visited immediately before and after your use of the Website.
• Geolocation Information. We may collect information about where you are located, both generally and at the time you access the Website. For example, we may collect your mailing address or ascertain your approximate location from your IP address.
• Other Information. We may collect other information from you, such as when you make a claim for a promotion run on the Website, when you request customer service assistance, or when you voluntarily subscribe to promotions, reminders, or newsletters.
• Inference Information. Company may also create new information about you by drawing inferences from the information identified in the categories listed above, such as to create a profile about you reflecting your preferences.

3. How and when do we collect information about you?

Company gathers information about you through the following sources and means:

• When you enter or upload information to the Website. Company collects information you provide to us, content you make public, transaction information, and geolocation information when you enter such information on a form on the Website (including during sign up), request products, sign up for newsletters or promotional material, enter contests, upload content, post in a forum, and otherwise interact with the Website.
• When you communicate with us. Company may also collect information you provide to us, content you make public, transaction information, geolocation information, and from you outside of the Website, such as when you contact our customer service department, email us (including any response to an email communication from Company), or communicate with Company via social media, such as by posting on a page hosted by Company or tagging Company in your own post. The information collected off the Website may be combined with that collected through the Website—for example, if you order a product from the Website and later call customer service about the order, the information collected in both interactions may be linked.
• Through Cookies, tracking tools, and other automated technologies. When you use any website, certain information can be automatically collected through technological means. When you access the Website, your web browser automatically sends us device and internet connection information and certain internet activity information as described in Section 2. Company also uses Cookies and web beacon technology to gather device and internet connection information, internet activity information, geolocation information, and biometric information. “Cookies” are files that are placed on your computer or other device by websites you visit. The primary purpose of a Cookie is to identify you as a unique user of the Website. Company uses the following types of Cookies, some of which may be placed by Third Parties, to customize your internet experience, keep you logged into websites, and remember your search terms:

Type of Cookie	Purpose of Cookie
Necessary	Necessary Cookies are essential in order for the Website to display and perform properly. Necessary Cookies are used to identify you, prevent security risks, and to allow you to perform account-related functions.
Preferences	Preferences Cookies are used to store preferences set by you and each user for their account, such as your language preferences. Preferences Cookies improve your experience using the Website.
Analytics and Performance	Analytics and Performance Cookies collect information on how you and other users interact with the Website. Often, this information is aggregated, as discussed in Section 4, and is used to improve the Website.
Advertising	We currently do not place any advertising Cookies; however, we reserve the right to use such Cookies to deliver Personalized Ads that may be of interest to you.

You can change your Cookie settings in your Internet browser (e.g., Chrome, Edge, Firefox). If you disable Cookies, some of the features of the Website may not function correctly. For more information, see https://www.allaboutcookies.org/. You can better learn about Third-Party practices at the following websites:

www.youronlinechoices.com/uk/your-ad-choices
www.networkadvertising.org/choices
www.aboutads.info/choices


4. How do we use your information?

Company may use the information we’ve gathered from you or your device, including through Cookies and Third Parties, for the following purposes:

• Business Purposes. When Company uses your information for a “Business Purpose,” it means such use is reasonably necessary and proportionate to achieve an operational purpose of the Company. The following are the Business Purposes for which we may use your information:

Business Purpose	Types of Information
For Security. Company uses the information we collect from you and other users to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and prosecute those responsible for that activity.	Information You Provide; Transaction Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information
To Fulfill Your Orders. We use the information we collect from you to process, fulfill, and ship your orders.	Information You Provide; Transaction Information; Device/Internet Connection Information; Geolocation Information
To Improve Products and Services. Company uses the information we collect from you and other users to improve products and services. For example, we may consider analytics, demographics, and user feedback collected via the Website in determining whether there is sufficient demand for a new product, plan, or service.	Information You Provide; Content You Make Public; Transaction Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Inference Information
To Improve the Website. Company uses the information we collect from you and other users to provide and improve the Website. We use information to debug and identify and repair errors that impair existing intended functionality of the Website. As explained above, we use Cookies, including those placed by Third Parties, to gather statistical information that helps us understand how you and other users engage with the Website and improve its performance via technological development.	Information You Provide; Content You Make Public; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Inference Information
To Personalize Your User Experience. We use information gathered from Cookies to authenticate your logins, determine whether you are logged in or not, to allow you to set personal preferences when using the Website, and to make it so you don’t have to reenter the same information when you visit the Website several times within a short timeframe.	Information You Provide; Transaction Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Inference Information
To Communicate with You. We use your information to personalize communication with you, and to respond to your requests regarding your orders and information on products and services. We also use your information to notify you of updates to the Terms or this Privacy Policy.	Information You Provide; Content You Make Public; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Inference Information
To Create Deidentified Aggregate Information. Company may combine your information with that of other users to create “Aggregate Information”—namely, statistical information about all users or a subset thereof. Aggregate Information is pseudonymized and deidentified. In other words, Aggregate Information cannot be used to identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer, including you. In turn, Aggregate Information may be used by Company for the Business and Commercial Purposes listed herein.	Information You Provide; Content You Make Public; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Inference Information

• Commercial Purposes. When Company uses your information for a “Commercial Purpose,” it means such use is intended to advance Company’s business interests, such as by inducing you to buy one of our products or services. The following are the Commercial Purposes for which we may use your information:

Commercial Purpose	Types of Information
To Advertise to You. We reserve the right to use information gathered through Cookies and web beacons, including those placed by Third Parties, to deliver ads to you via the Website and after you’ve left the Website. The purpose of “Personalized Ads,” “retargeting,” or “remarketing” is to deliver content and advertising that is of interest to you, and to avoid displaying irrelevant advertising to you. You can better learn about such advertising at the following websites: www.youronlinechoices.com/uk/your-ad-choices www.networkadvertising.org/choices www.aboutads.info/choices	Information You Provide; Content You Make Public; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Inference Information
To Build a Profile. Company may create new information about you by drawing inferences from the information identified in the categories listed above, such as to create a profile about you reflecting your preferences, which may be used by Company for advertising purposes.	Information You Provide; Content You Make Public; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Inference Information
To Advertise to Others. We may share your reviews (including any written, audio, or video content, your first name, and last initial, and your city and state), comments, and other content provided by you to advertise and market our Website and the services, including by reposting your reviews on the Website, in our advertising, or through our social media accounts.	Content You Make Public

• Scope and Legal Bases for Use. Company only processes your information to the extent that is necessary to accomplish the above-stated Business and Commercial Purposes, which serves as our legitimate interest.

5. How do we share your information?

Company may share your information with Third Parties for the following purposes:

• Business Purposes. When Company shares your information for a Business Purpose, it means such use is reasonably necessary and proportionate to achieve an operational purpose of the Company. The following are the Business Purposes for which we may share your information:

Third Parties	Business Purpose	Types of Information
Service Providers. These Third Parties provide services to Company that allow Company to operate the Website, provide services to customers, communicate with customers, and so forth.	For Security; to Fulfill Your Orders; to Improve Our Products and Services; to Improve the Website, to Personalize Your User Experience; and to Create Aggregate Information	Information You Provide; Content You Make Public; Transaction Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information
Partnering Brands. These are the third-party brands that provide the products through the Website.	To Fulfill Your Orders; to Improve Our Products and Services; to Improve the Website, to Personalize Your User Experience; and to Create Aggregate Information.	Information You Provide; Content You Make Public; Transaction Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information
Successor Entities. Should Company be subject to an acquisition, merger, sale or other change of control or business entity status, we reserve the right to transfer or assign your information as part of that acquisition, merger or sale.	For Security; to Fulfill Your Orders; to Improve Our Products and Services; to Improve the Website, to Personalize Your User Experience; and to Create Aggregate Information	Information You Provide; Content You Make Public; Transaction Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Inference Information
Government Officials and Private Parties Pursuant to Valid Legal Process. We may disclose your information in response to subpoenas, court orders, and other legal processes. In very rare circumstances, we may disclose personal information when we believe it is necessary in order to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals.	To comply with Company’s legal obligations and to prevent illegal, fraudulent, or injurious actions that may cause harm to individuals	Information You Provide; Content You Make Public; Transaction Information; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Inference Information

• Commercial Purposes. When Company shares your information for a Commercial Purpose, it means such disclosure is intended to advance Company’s business interests, such as by advertising our products or services. The following are the Commercial Purposes for which we may share your information with Third Parties:

Third Parties	Commercial Purpose	Types of Information
Other Consumers. We may share your reviews (including any written, audio, or video content, your first name, and last initial, and your city and state), comments, and other content uploaded by you to advertise and market our Website and the services, including by reposting your reviews on the Website, in our advertising, or through our social media accounts.	To Advertise to You, including through Personalized Ads; to Advertise to Others	Information You Provide; Content You Make Public; Device/Internet Connection Information; Internet Activity Information; Geolocation Information; Inference Information
	To Advertise to Others	Content You Make Public

6. Do we sell your information to others?

No. Company does not sell consumers’ personal information.

7. How do we protect your information?.

Company, and the Third-Party vendors we use to store your information, employ technical, administrative, and physical security measures that are designed to protect against the loss, misuse, and alteration of the information under our control. We regularly review our security procedures to consider appropriate new technology and methods. However, no system can be completely secure. Therefore, although we take steps to secure your information, we cannot promise, and you should not expect, that your personal and commercial information, or other communications, will always remain secure. The safety and security of your information also depends on you. Never share account information with anyone else and notify us as soon as possible if you believe your account security has been breached. 8. How long do we keep your information?

Company will retain your information for the length of time necessary to fulfill the Business Purposes and Commercial Purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law or valid court order. If you request deletion of your information pursuant to Section 10, your request will be processed according to the timeframes indicated therein and/or pursuant to any applicable legislation.

9. Do we transfer your information to a different country?

If you are visiting the Website from a location outside of the United States, your connection will be through and to servers located in the United States, and all information you provide will be processed and securely maintained in our web servers and internal systems located within the United States. By using the Website, you authorize and specifically consent to the transfer of personal data to the United States and its storage and use as specified above when you provide such information to us.

10. What are your rights when it comes to accessing, correcting, or deleting your information, and how can you exercise them?

You may access all information we’ve collected and retained about you for purposes of correcting, amending, downloading, or deleting such information. Access can be obtained by logging into your account, filling out a Contact Form, or contacting us at [email protected] with your full name and email address. To protect your privacy and security, we may take reasonable steps to help verify your identity before granting access, making corrections, providing you with information, or deleting information. If your request is through an agent, please also provide your agent’s full name and a verified statement of authority. We will not discriminate against you for making a request or asserting your rights.

If certain privacy laws apply to you, you may have the right to request that Company disclose the following to you:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information is collected;
• The business or commercial purpose for collecting personal information;
• The categories of third parties with whom we share personal information; and
• The specific pieces of personal information we have collected about you.

Under California’s “Shine the Light” law, California residents who provide personal information to the Website may request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please fill out a Contact Form, or contact us at [email protected].

11. How do we protect the privacy of children?

Company will never knowingly collect any personal information about children under the age of 13. If we obtain actual knowledge that we have collected personal information about a child under the age of 13, that information will be immediately deleted from our database. Because we do not collect such information, we have no such information to use or to disclose to Third Parties.

12. How can you receive and opt-out from marketing communications?

By providing your email address to Company through the Website or an email initiated by you, you consent to receive emails from us, including information concerning your account and advertising messages. Providing consent to promotional emails is NOT a condition of purchasing any goods or services from Company. You can unsubscribe to advertising emails at any time by clicking the unsubscribe link within the email or by contacting us at [email protected]. Please note that, even if you unsubscribe from advertising emails, we will still send you necessary, non-promotional emails about your order, account, or updates to our Privacy Policy and Terms of service.

13. Do we respond to Do Not Track (DNT) Signals?

DNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked. Company does not currently respond to DNT requests.

14. How will you know when we change the Privacy Policy?

Each time you use the Website, the then-current version of this Privacy Policy will apply. Although most changes are likely to be minor, we reserve the right to modify this Privacy Policy by posting such modification on this page; however, if changes are significant, we may provide a more prominent notice or email you. Unless we receive your express consent, any revised Privacy Policy will apply only to information collected after the effective date of such revised Privacy Policy, and not to information collected under any earlier version.

15. How can you contact us regarding this Privacy Policy?

The Website contains a Contact Form, which can be used for electronic contact. If you use this option, the data entered by you in the form will be transmitted to us and stored as part of your information. Alternatively, you can contact us via email at [email protected]. In this case, your information transmitted by email will be stored. If needed, your information will be relayed to our Third-Party partners for the sole purpose of processing any request by you in the communication.