Welle Pty Ltd and all of its subsidiaries (together "we", "our" or "us") are strongly committed to being responsible custodians of the information you provide us and the information we collect in the course of operating our business.

This Privacy Policy explains how, as a data controller, we may collect, use, and share information that we obtain about you directly or indirectly in accordance with applicable data privacy laws.

Where you use our services, or your personal data is processed in connection with such services, we will be the data controller of such information.

This Privacy Notice does not apply to any third party websites which may be accessible through links from this website (please see the section Online services - Links to third party sites, services and contentbelow for more information).

Organisation Name: WELLECO UK LIMITED Company Number: 9233743

This Privacy Policy explains and describes:

• When this Privacy Policy applies.
• The types of personal data we collect.
• How we use the personal data we collect.
• How and when we may disclose personal data that we collect.
• How we protect your personal data and keep it secure.
• What cookies are and how we use them.
• What happens when you access third-party services and content.
• What types of content we use.
• How we use different types of content.
• Your legal choices and rights.
• The status of this policy and any changes that are made to it.
• How to contact us.

This Privacy Policy applies when you:             

• use our website;
• register as a user on our website;
• buy products from our website;
• provide your consent to receive email marketing communications; and / or
• contact us with a query;

This Privacy Policy applies to www.welleco.com.au, www.welleco.co.uk, www.welleco.com, www.welleco.eu (the "site") and any other website, mobile app or other online service created or hosted by us from time to time on which this privacy policy appears (together, our "online services") through which we may collect certain details if, for example, you want to subscribe to our email newsletters that we may periodically issue.

In addition, our online services make use of cookies and similar technologies, as described in more detail below.

"Personal data" is any information that can be used to identify you or that we can link to you.

Where you use our online services, we will collect personal data directly from you. 

We collect information that you voluntarily provide to us, including when you communicate with us via email or other channels; when you register an account, when you sign up for our email and when you respond to our communications or requests for information.

The information you provide may include current and historical personal data including your name, contact details, title, historical purchase, product preferences and shopping habits.  We may also collect personal data about your other dealings with us, including any contact we have with you in person, by telephone, email or online.

We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review.

We will handle any unsolicited information in accordance with law, including destroying or de-identifying such information where we are required to do so.

When you use our online services, we may collect the following:

• Information you provide by completing forms (this includes information you give us, submitting material, requesting services, entering competitions, registering for any of our online offerings or subscribing to our newsletters or other services).
• Information you provide by your participation in competitions.
• Information you provide to us if you contact us, for example to raise a concern about a product
• Details of visits made to our online services including, but not limited to, the volume of traffic received, logs (including, where available, the IP address and location of the device connecting to the online services and other technical information and identifiers about the device and the nature of the visit) and the resources accessed.
• Where our online services require that you enter a password or other information in order to access certain features, we will collect such credentials when you enter them.

Where we intend to use your personal data, we rely on the following legal grounds:

Performance of a contract: We may need to collect and use your personal data to enter into a contract with you or to perform a contract that you have with us. For example, where you purchase one of our products, we will need to use your personal data to enable the courier company to deliver the products you have ordered.

Legitimate interests: Where we consider use of your information as being (a) non-detrimental to you, (b) within your reasonable expectations, and (c) necessary for our own, or a third party’s legitimate purpose, we may use your personal data, which may include:

• for our own direct marketing or continued communication;
• the prevention of fraud;
• our own internal administrative purposes;
• personalisation of the products we provide to you;
• ensuring network and information security, including preventing unauthorised access to electronic communications networks and stopping damage to computer and electronic communication systems;

Compliance with a legal obligation:We may be required to process your information due to legal requirements, including in relation to tax laws

Consent:You may be asked to provide your consent in connection with certain services that we offer, for example in respect of any processing of your personal data for our marketing purposes where you subscribe to our email newsletter. Where we are reliant upon your consent, you may withdraw this at any time by contacting us as set out below.

We use your information in order to provide you with, and improve, our services, for example:

• To arrange for the delivery of our products you have ordered.
• To respond to your enquiries.
• To facilitate our internal business operations, including to fulfil our legal or regulatory requirements.
• To maintain and develop our relationship with you.
• For our business purposes, including data analysis, submitting invoices, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement.
• To maintain and update our records including our database of contacts.
• To provide you on an ongoing basis with information and services, including relevant marketing communications related to us, and other information or materials, that you request from us or which we feel may interest you where you have indicated that you would like to receive these from us.
• To ensure that content from our online services is presented in the most effective and secure manner for you and the device on which you are accessing our services, and to improve such online services.
• To allow you to use or access your online account.
• As we believe reasonably necessary or appropriate to: comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protector your, our, or others’ rights.
• To provide you with information or advertising relating to our products or services, when in line with the preferences you have shared with us.

We may not be able to do some or all of these things without your personal data. 

If at any time we intend to change the purpose for which we hold your personal data, for example to offer you with a complimentary service that we may provide in the future, we will give you prior notice of that new purpose so you are aware of this.

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

We also use the Device information that we collect in advertising and targeting. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our site or on third party sites.

If you would like to opt out of the technologies we employ on our site, you may do so by blocking, deleting, or disabling them as your browser or devices permits.

We may, in providing our products and operating our business, allow access to your personal data to different entities within our group for our internal administrative purposes such as billing and promoting special events, products and services, provided in all instances that such processing is consistent with the applicable law.

In addition, we may exchange your personal data with third-party service providers contracted to us where any of the following apply:

• We deem reasonably necessary to provide you with the products that you have required at any particular time (e.g. to arrange delivery of the products you have purchased).
• Such sharing is to law enforcement bodies or other government authority.
• We need to enforce or apply our terms and conditions to which you have agreed
• It is necessary to protect the rights and interests, property, or safety of us, our clients or others.
• It is relevant in the circumstances to disclose the information to parties with whom we have co-promotional arrangements (e.g. such as jointly sponsored events)
• Our agents or contractors who assist us in providing our services require such information, for example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.
• We use third party service providers to provide services that involve data processing, for example archival, web-hosting, analytics providers in connection with the operation of our online services, event hosting, information technology providers, professional advisory (including legal, accounting, financial and business consulting), delivery, technology, website, banking, payment processing, client contact, and marketing. Our key 3^rdparty providers are: Web Hosting via Shopify Plus www.shopify.com & Payment Processing via Shopify Payments www.shopify.com. You can read more about how Shopify uses your Personal Information here: https://www.shopify.com/legal/privacy. Additionally, we employ Payment Processing support via Paypal  https://www.paypal.com and AfterPay https://www.afterpay.com and Website Analytics via Google Analytics https://www.google.com. 
• All, or most, of the assets of or any single business unit within  Welle Pty Ltd are merged with or acquired by a third party, or we expand or re-organise our business, in which case your personal data may form part of the transferred or merged assets.
• We are under a legal, regulatory or professional obligation to do so (for example, in order to comply with a Court Order).

Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to fulfil the service they provide you on our behalf. When such third parties no longer need your personal data to fulfil this service, they will dispose of such details in line with our procedures unless they are themselves under a legal obligation to retain information (provided that this will be in accordance with applicable data privacy laws).

We also provide anonymous statistical information about users of our websites and related usage information to reputable third parties, including analytics and search engine providers.

We own the database rights in the information collected via our online services. We do not sell, rent, or otherwise share information that reasonably identifies you or your with unaffiliated entities for their independent use except as expressly described in this Privacy Policy or with your express prior permission.

We may share information that does not reasonably identify you or your organisation as permitted by applicable law.

Where you are submitting personal data from within the European Economic Area (“EEA”), such information will be transferred to countries outside the EEA.

By way of example, personal data you enter to create an online account is currently stored in the United States of America.  We may though store this in any other location as determined by us acting at our discretion, and it may also be transferred if one or more of our third party service providers with whom we share personal data are located, or have their servers located, outside your country or the country from which the data were provided.

As we transfer your information outside the EEA in this way, we will take steps to ensure that your privacy rights continue to be protected.

We retain the information we collect no longer than is reasonably necessary to fulfil the purposes that such data was originally collected in accordance with our internal data retention polices or to comply with our legal and regulatory obligations.  Such information is stored for no longer than 7 years.  

We take steps to hold information securely in electronic or physical form. 

Our information security policy is supported by a variety of processes and procedures, and we store information in electronic databases requiring logins and passwords. All employees, officers or contractors of  and third party providers with access to confidential information are subject to access controls and confidentiality obligations, and we require our third party data storage providers to comply with appropriate information security industry standards.

Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet is not completely secure, and as such we cannot guarantee the security of your data transmitted to our online services which is at your own risk.

If you communicate with us using a non-secure web platform, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient. 

Once we have received your information, we will take reasonable steps to use procedures and security features to try to prevent unauthorised access, modification or disclosure. 

You can help us to keep your information secure by ensuring that any user name or password in relation to our online services is kept strictly personal to you and will not be made available to any other person.  You should stop using your username and password and notify us immediately if you suspect that someone else may be using your user details or password.

Our website and services delivered online use cookies and other similar technologies, for example, to distinguish you from other users when you browse our websites or use our online services and also to allow us to improve our online services.

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site.

We may, for example, collect information about the type of device you use to access our online services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on our online services, the web pages you view immediately before and after you access our online services, whether and how you interact with content available on our online services, and the search terms you enter on our online services.

Our website sets cookies which remain on your computer for differing times. Some expire at the end of each session and some remain for longer so that when you return to our website, you will have a better user experience.

Which cookies we use

Detailed below are the cookies we use and why and how long they last.

A persistent Cookie gets entered by your web browser into the “Cookies” folder on your computer and remains in your Cookies folder after you close your browser. Persistent Cookies may be used by your browser on subsequent visits to the site.

 A session Cookie is held temporarily in your computer's memory and disappears when you close your browser or shut down your computer.

We may also use web "beacons" (also called "clear GIFs" or "pixel tags") in conjunction with Cookies for the same reasons. Web beacons are small strings of code that are placed in an internet page.

We collect standard internet log information and details of visitor behaviour patterns by using Google Analytics cookies. We do this to compile reports and to help us find out things such as the number of visitors to the various parts of our website, so that this can be improved. This information does not identify visitors or collect any personal details. We do not make any attempt to find out the identities of those visiting our websites. We will not associate any data gathered in this way with any personal data from any source. For more information about Google Analytics cookies please see the link here, and further information about how Google uses your Personal Information is available here.

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services. For more information about Google Analytics Opt-out Brower Add-on please see the link here. You can also opt-out of Google Analytics here.

Control of cookies

Web browsers allow you to exercise some control of cookies through the browser settings. Most browsers enable you to block cookies or to block cookies from particular sites. Browsers can also help you to delete cookies when you close your browser. You should note however, that this may mean that any opt-outs or preferences you set on our website will be lost. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit allaboutcookies.org which includes information on how to manage your settings for the major browser providers.

Text Marketing Terms and Conditions

We are using a text messaging platform, which is subject to the following terms and conditions. By opting-in for our text marketing and notifications in, you agree to these terms and conditions.
By entering your phone number in the checkout and initialising a purchase, subscribing via our subscription form or a keyword, you agree that we may send you text notifications (for your order, including abandoned cart reminders) and text marketing offers. You acknowledge that consent is not a condition for any purchase.

The website uses cookies to help keep track of items you put into your shopping cart including when you have abandoned your cart and this information is used to determine when to send cart reminder messages via SMS.

We will not share your opt-in to an SMS campaign with any third party for purposes unrelated to providing you with the services of that campaign. We may share your Personal Data, including your SMS opt-in or consent status, with third parties that help us provide our messaging services, including but not limited to platform providers, phone companies, and any other vendors who assist us in the delivery of text messages.

If you wish to unsubscribe from receiving text marketing messages and notifications reply with STOP to any mobile message sent from us or use the unsubscribe link we provided you with in any of our messages. You understand and agree that alternative methods of opting out, such as using alternative words or requests will not be accounted as a reasonable means of opting out. Message and data rates may apply.
For any questions please text "HELP" to the number you received the messages from. You can also contact us for more information. If you wish to opt out please follow the procedures above.

Online services - Links to third party sites, services, content and user content

In addition to our online services, our websites may contain links to websites of partners, advertisers and third parties. Those sites may collect personal information under the terms of their privacy policies independent of Welle Pty Ltd. We have no responsibility for the content or operation of those websites and Welle Pty Ltd is not responsible for matters arising from their use. While we strive to protect your personal information, we cannot warrant the security of information you transmit to us, and you do so at your own risk. You are solely responsible for maintaining the secrecy of your password and/or any account information.

We engage third parties that support the operation of our online services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms.

We use this information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page here.

You can opt out of targeted advertising by:

Unsubscribing to our email communications. To unsubscribe, you can use the unsubscribe link found at the bottom of the email to op out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding WelleCo and our Services and you will not be able to opt out of these communications (e.g., communications regarding our updated to our Terms or this Privacy Policy).

To opt out of personalized advertising services, please use the links below:

• Facebook
• Google
• Bing

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal here.

Do Not Track

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

Content

For purposes of this Privacy Policy, the term “Content” includes, without limitation, information, data, text, photographs, illustrations, videos, audio clips, artwork, interfaces, products, written posts and comments, software, scripts, graphics, interactive features and other content generated, provided or otherwise made accessible on or through our online services. While we try to make sure that all content contained in online services (other than any user-generated content, if applicable) is correct, it is not intended to amount to authority or advice on which reliance should be placed. Information made available through online services is not a substitute for information from experts or professionals in the applicable area. You acknowledge that all content accessed by you while using the Services is at your own risk and you will be solely responsible for any damage or loss to you or any other party resulting therefrom. We do not guarantee that any content you access on or through our online services is or will continue to be accurate.

User Content

Any content that is submitted to us or to our online services by users, or otherwise added, uploaded, distributed or posted to our online services, whether publicly or privately transmitted, including, without limitation, product reviews, survey responses and comments (“user content”), is the sole responsibility of the person who originated such user content. User content also includes content provided by users through third party services such as a user’s social media account (e.g., Facebook, Instagram, Twitter, etc.) if such content mentions, tags or otherwise interacts with Welle Pty Limited, our online services or any of our products or services. You represent that all user content submitted by you is accurate, complete, up-to-date and in compliance with all applicable laws, rules and regulations. User content that you submit must not: (i) contain any content that infringes intellectual property rights, data protection or privacy rights of an individual; (ii) be defamatory or threatening; (iii) impersonate any person or entity; (iv) contain unauthorized advertising; or (v) transmit or distribute any virus and/or other code that has contaminating or destructive elements. We make no representations, warranties or guarantees with respect to any user content that you access on or through our online services.

By submitting user content through our online services, you hereby grant us a worldwide, perpetual, irrevocable, non-exclusive, sub-licensable (through multiple tiers), fully paid, royalty-free license and right to use, copy, transmit, distribute, publicly perform and display (through all media now known or hereafter created), edit, modify and make derivative works from your user content (including, without limitation, your name and likeness, photographs and testimonials) for any purpose whatsoever, commercial or otherwise, without compensation to you. You also hereby do and shall grant each user of the site and/or our online services a non-exclusive, perpetual license to access your user content through the site and/or our online services, and to use, edit, modify, reproduce, distribute, prepare derivative works of, display and perform such user content, including after your termination of your Account or our online services. In addition, you waive any so-called “moral rights” or rights of privacy or publicity in your user content. For clarity, the foregoing license grants to us and our users does not affect your other ownership or license rights in your user content, including the right to grant additional licenses to your user content, unless otherwise agreed in writing. You represent and warrant that you have all rights to grant such licenses to us without infringement or violation of any third party rights, including, without limitation, any privacy rights, publicity rights, copyrights, trademarks, contract rights or any other intellectual property or proprietary rights.

Any feedback, reviews, comments, suggestions or recommendations for modifications, improvements or changes to our online services that you provide to us (“feedback”) shall be solely owned by us (including all intellectual property rights therein and thereto). You hereby irrevocably assign to us and agree to irrevocably assign to us all of your right, title and interest in and to all feedback, including, without limitation, all worldwide patent, copyright, trade secret, moral and other proprietary or intellectual property rights therein. At our request and expense, you will execute documents and take such further acts as we may reasonably request to assist us to acquire, perfect and maintain our intellectual property rights and other legal protections for the feedback.

Under applicable data protection legislation we have a duty of care to ensure that your personal data is accurate and up to date.

If you wish to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate, you can maintain your own information if you have registered with us for an account.  If you have consented to receive email marketing communication and there is information your wish to update or correct that you cannot maintain yourself, then please contact us at customerservice@welleco.com 

Where you have consented to our processing of certain personal data, you can at any time withdraw such consent and/or tell us not to contact you with updates and information regarding our products either at the point such information is collected, (by checking the relevant box) or, where you do not wish us to continue to use your information in this way, by following the unsubscribe instructions on any communications sent to you. You can also exercise this right at any time by contacting us using the contact details at the end of this privacy policy.

You can request:

• access to the personal data we hold about you;
• corrections or updates to your details;
• the right to be forgotten;
• the portability of personal data that you have provided to us in a structured, commonly used and machine-readable format.

You also have the right to object to, or request the restriction of, our use of your personal data.

If you would like to exercise any of the rights set out in this section, please contact us using the details set out below.  We may refuse to provide access where we have legitimate reasons for doing so under applicable data privacy laws, and in exceptional circumstances may charge a fee for access if the relevant legislation allows us to do so, in which case we will provide reasons for our decision.

You may submit a complaint to the Information Commissioners Office, details of which can be found at https://ico.org.uk/global/contact-us. (UK) or https://www.oaic.gov.au/about-us/contact-us(Australia).

If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.

Your provision of personal data to us or use of our online services constitutes your acceptance of the terms of this Privacy Policy.

As technologies and information governance practices develop, and data privacy laws (and surrounding guidance) evolve, we may need to revise this Privacy Policy. You should therefore review this page regularly to ensure that you are aware of any changes to its terms.

We will post any Privacy Policy changes on this page and, if the changes are significant or may materially impact upon your rights, we will provide a more prominent notice or contact you by other means (including, for certain services, email notification of Privacy Policy changes).

To find out more please visit www.welleco.com.au, www.welleco.co.uk or www.welleco.com dependent on where you are geographically located.

If you have any questions, concerns or comments about this Privacy Policy, or want to submit a written complaint about how we handle your personal data, please email us at customerservice@welleco.com.