Privacy Policy

1                    Your privacy is important to us

In this Privacy Policy, the expressions “Paullie Skin”, "we", "us" and "our" are a reference to Paullie Skin Pty Ltd ACN  667 855 101 and its Related Entities (as defined in the Corporations Act 2001 (Cth)) (Paullie Skin).

We comply with the Australian Privacy Principles (APPs) and the Privacy Act 1988 (Cth) (Privacy Act), which govern the way private sector organisations collect, use, keep secure and disclose personal information (as defined in Section 1).

If you are a resident of the European Union or the United Kingdom and we collect personal data from you, then we are required to comply with the GDPR (these bolded terms are defined in Section 14) in our processing of your Personal Data. Please refer to Section 14 to understand how we process your Personal Data and how you can exercise your “Data Subject” rights under the GDPR. Paullie Skin is committed to safeguarding your personal information. The purpose of this Privacy Policy is to generally inform you of:

  • how and when we collect personal information and Personal Data;
  • how we use and disclose personal information and Personal Data;
  • how we keep personal information and Personal Data secure, accurate and up-to-date;
  • how you can access and correct your personal information and Personal Data; and
  • how we will facilitate or resolve a privacy complaint.

If you have any concerns or complaints about the manner in which your personal information or Personal Data has been collected, used or disclosed by us, please contact us so that we can attempt to resolve the issue or complaint. Our contact details are set out in Section 13.

We recommend that you keep this information for future reference.

2                    What is personal information?

The Privacy Act defines “personal information” to mean any information or an opinion about an identified individual, or an individual who is reasonably identifiable:

(a)                whether the information or opinion is true or not; and

(b)                whether the information or opinion is recorded in a material form or not.

3                    What kind of personal information or Personal Data do we collect from you?  

(a)                We will only use or disclose your personal information or Personal Data (as applicable) for the primary purposes for which it was collected, or as consented to by you.

(b)                At or around the time we collect personal information or Personal Data (as applicable) from you, we will endeavour to provide you with a notice which details how we will use and disclose that specific information.

(c)                 We may collect the following personal information or Personal Data from you:

(i)                  (Contact Information): Your first name and last name, title, email address, postal and residential addresses, phone numbers, country of residence.

(ii)                (Billing Information): Your name, billing address, shipping address and phone numbers.

(iii)               (Financial Data): Your bank account details, credit card details or other payment information (to the extent required by law or by any payment processor);

(iv)               (Transaction Data): Details about payments to and from you, and other details of the Products and Services you have purchased from us.

(v)                (Technical Data): Information regarding the IP addresses used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, cookies, operating system and platform, type of device.

(vi)               (Profile Data): Your username or password (if any) to our Website, details regarding purchases or orders made by you, your interests, preferences, feedback, and reviews.

(vii)             (Usage Data): Information about how you use our Website, and Products and Services.

(viii)           (Marketing and Communications Data): Information regarding your preferencing in receiving marketing from us and your communication preferences, including information about your attendance at any marketing or promotional event held by Paullie Skin.

(ix)               (Third-Party Data): Information we may receive from third parties such as business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers, and search information providers, third party applications that plug into the Products and Services and payment providers or merchants.

(x)                (Social Media Activity): Information regarding your interaction on social media activity, including “likes”, comments posted, any feedback, photos posted or uploaded and other information pertaining to your social media, including LinkedIn, Facebook, and Twitter, which concern, or relate, to Paullie Skin.

4.1               Collection generally

(a)                As much as possible or unless provided otherwise in this Privacy Policy or a notification, we will collect your personal information or Personal Data (as applicable) directly from you.

(b)                When you engage in certain activities, such as placing an order through our Website, signing up to our Website or any promotional offer displayed on our Website or otherwise, or sending an inquiry or feedback to us, we may ask you to provide certain information. It is completely optional for you to engage in these activities.

(c)                 Depending on the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory information or any other information we require for us to provide our Products or Services to you, we may be unable to provide our Products or Services to you in an effective manner, or at all.

4.2               Other collection types

We may also collect personal information or Personal Data (as applicable) about you from other sources, such as promotional or marketing events or from third parties. Some examples of these alternative collection events are:

(a)                when we collect personal information or Personal Data (as applicable) about you from third parties;

(b)                when we collect personal information or Personal Data (as applicable) about you when you register to attend or attend an event; or

(c)                 when we collect personal information or Personal Data (as applicable) about you from publicly available sources including but not limited to, social media platforms (such as LinkedIn, Facebook, Twitter, Google, Instagram etc.), Australia Post and White Pages directory.

4.3               Notification of collection

If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply, including as described in this clause. Generally speaking, we will not tell you when we collect personal information or Personal Data (as applicable) about you in the following circumstances:

(a)                where information is collected from publicly available sources including but not limited to, Freedom of Information Act 1982 (Cth) searches, court judgments, directorship and bankruptcy searches, social media platforms (such as Facebook, Twitter, Google, Instagram etc.); or

(b)                as otherwise required or authorised by law.

4.4               Unsolicited personal information or Personal Data

In the event we collect personal information or Personal Data (as applicable) from you, or a third party, in circumstances where we have not requested or solicited that information (known as unsolicited information), and we determine in our absolute discretion that the personal information or Personal Data (as applicable) is not required, we will destroy the information or ensure that the information is de-identified.

4.5               How we hold your personal information or Personal Data (as applicable)

Once we collect your personal information or Personal Data (as applicable), we will either hold it securely and store it on infrastructure owned or controlled by us or with a third party service provider who has taken reasonable steps to ensure they comply with the Privacy Act. We provide some more general information on our security measures in Section 11 (Data security and quality).

5.1               Use and disclosure details

So that you can clearly see the purpose for which we may use and disclose your personal information or Personal Data, we have prepared the below tables.

Purpose

Type of Data

Who we may disclose the personal information or Personal Data to 

Website Users and Customers

To register you as a new customer or create an account with us, to identify you.

Contact Information

Billing Information

Financial Data

Profile Data

Third party service providers utilised in connection with any administrative matters.

 

Service providers (including IT service providers and consultants) who assist Paullie Skin in providing our Products and Services and marketing our Products and Services.

To process and deliver your ordered Products and Services including, manage payments, fees, and charges, and collect and recover money owed to us.

Contact Information

Billing Information

Financial Data

Transaction Data

Profile Data

Third party service providers utilised in connection with any administrative matters.

To manage our relationship with you which may include, notifying you about changes to our terms or privacy policy, asking you to leave a review or take a survey, engaging with you in relation to any support request or communication that you may submit.

Contact Information

Billing Information

Transaction Data

Profile Data

Usage Data

Third party service providers utilised in connection with any administrative matters.

 

Service providers (including IT service providers and consultants) who assist Paullie Skin in providing our Products and Services and marketing our Products and Services.

To administer and protect our business and Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

Transaction Data

Technical Data

Usage Data

Marketing and Communications Data

Third Party Data

Service providers (including IT service providers and consultants) who assist Paullie Skin in providing our Products and Services and marketing our Products and Services.

 

Third party service providers utilised in connection with any administrative matters.

To deliver relevant Website content and measure or understand the effectiveness of our Website and to ensure the proper function of our Website and online software.

Transaction Data

Technical Data

Usage Data

Marketing and Communications Data

Third Party Data

Social Media Activity

Service providers (including IT service providers and consultants) who assist Paullie Skin in providing our Products and Services and marketing our Products and Services.

 

Third party service providers utilised in connection with any administrative matters

To improve the Products and Services or businesses that we undertake.

Transaction Data

Technical Data

Usage Data

Marketing and Communications Data

Third Party Data

Financial Data 

Third party service providers utilised in connection with any administrative matters.

 

Third parties connected with the marketing process including, messaging service providers, marketing list providers or other third parties who assist us in providing our products and services to you.

To use data analytics to improve our Website, Products and Services, marketing, customer relationships and experiences and to gather anonymous statistics.

Transaction Data

Technical Data

Usage Data

Marketing and Communications Data

Third Party Data

Service providers (including IT service providers and consultants) who assist Paullie Skin in providing our Products and Services and marketing our Products and Services.

To provide you with our newsletters (if we choose to) and make suggestions and recommendations to you about goods, services or promotions that may be of interest to you, whether initiated by us.

Marketing and Communications Data

Social Media Activity

Transaction Data

Usage Data

Third party service providers utilised in connection with any administrative matters.

 

Third parties connected with the marketing process including, messaging service providers, marketing list providers or other third parties who assist us in providing our products and services to you.

 

Third parties connected with the marketing process including, messaging service providers, marketing list providers or other third parties who assist us in providing our Products and Services to you.

 

Any other authority or body as required or authorised by law.

To facilitate internal training, ensure the effective delivery of Products and Services and to resolve disputes or problems.

Marketing and Communications Data

Social Media Activity

Transaction Data

Usage Data

Technical Data

Third parties connected with the marketing process including, messaging service providers, marketing list providers or other third parties who assist us in providing our products and services to you.

 

To improve our Products and Services and business activities we undertake.

Marketing and Communications Data

Social Media Activity

Transaction Data

Usage Data

Technical Data

Third party service providers utilised in connection with any administrative matters.

 

5.2               Other uses and disclosures

We may also use or disclose your personal information or Personal Data (as applicable) and in doing so we are not required to seek your additional consent:

(a)                when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information or Personal Data (as applicable) to be used or disclosed for such a purpose;

(b)                if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health, or safety or to lessen or prevent a threat to public health or safety;

(c)                 if we have reason to suspect that unlawful activity has been, or is being, engaged in; or

(d)                if it is required or authorised by law.

5.3               Use and disclosure procedures

(a)                In the event we propose to use or disclose such personal information or Personal Data (as applicable) other than for reasons set out in the above table or as otherwise outlined in this Privacy Policy, we will first notify you or seek your consent prior to such disclosure or use.

(b)                Your personal information or Personal Data (as applicable) is disclosed to these organisations or parties only in relation to the products or services we provide to you or for a purpose permitted by this Privacy Policy.

(c)                 We take such steps as are reasonable to ensure that these organisations or parties are aware of the provisions of this Privacy Policy in relation to your personal information or Personal Data (as applicable).

5.4               Communications opt-out

If you have received communications from us and you no longer wish to receive those sorts of communications, you should contact us via the details set out at the top of this document and we will ensure the relevant communication ceases. Any other use or disclosure we make of your personal information or Personal Data (as applicable) will only be as required or authorised by law or as permitted by this Privacy Policy or otherwise with your consent.

6                    Sensitive information

6.1               Sensitive information generally

Sensitive information is a subset of personal information or Personal Data (as applicable). It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.

6.2               Collection and use of sensitive information

(a)                In general, we attempt to limit the collection of sensitive information we may collect from you, but depending on the uses you make of our Products this may not always be possible and we may collect sensitive information from you in order to carry out the services provided to you. However, we do not collect sensitive information from you without your consent.

(b)                The type of sensitive information we may collect about you is dependent on the services provided to you by Paullie Skins and will be limited to the purpose(s) for which it is collected. We set out some types of sensitive information we may collect about you in the table above.

(c)                 We do not use sensitive information to send you Direct Marketing Communications without your express consent.

6.3               Consent

We may collect other types of sensitive information where you have consented and agree to the collection of such information. Generally speaking, we will obtain this type of consent from you at (or around) the point in time in which we collect the information.

7                    Online Information and Google Analytics

7.1               Collection of personal information or Personal Data via linked websites

Our website may offer links to other websites. Those websites may also collect your personal information or Personal Data (as applicable) (including information generated through the use of cookies) when you visit them. We are not responsible for how such third parties collect, use or disclosure your personal information or Personal Data (as applicable), so it is important to familiarise yourself with their privacy policies before providing them with your personal information or Personal Data (as applicable).

7.2               Cookies and IP addresses

(a)                If you use our website, we may utilise "cookies" which enable us to monitor traffic patterns, trends and to serve you more efficiently if you revisit our website. In most cases, a cookie does not identify you personally but may identify your internet service provider or computer.

(b)                We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.

(c)                 However, in some cases, cookies may enable us to aggregate certain information with other personal information or Personal Data (as applicable) we collect and hold about you. Paullie Skin extends the same privacy protection to your personal information or Personal Data (as applicable), whether gathered via cookies or from other sources, as detailed in this Privacy Policy. As such, Paullie Skin does not aggregate non-personal information or Personal Data (as applicable) with any personal information or Personal Data (as applicable) unless we first notify you and obtain your consent.

(d)                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. However, if you disable cookies, you may not be able to access certain areas of our Website or take advantage of the improved web site experience that cookies offer.

7.3               Persistent cookies

We use persistent cookies to enable basic web traffic analysis using Google Analytics which, for example, shows us which areas of our Website are popular against those that are not visited often. This allows us to prioritise our enhancements to our Website and increase the productivity of our Website.

7.4               Google Analytics

We undertake and use Google Analytics on our Website. This feature does not use any sensitive personal information or Personal Data (as applicable) you have provided to us, nor do it use any personal information or Personal Data (as applicable). We do not facilitate the merging of your personal information with any non-personal information or Personal Data (as applicable) unless we notify you and you opt-in to that merger. Click here for more information about how Google collects and uses data.

7.5               Opt-out via Google

As a visitor to our Website, you can opt out of your data being used Google Analytics by visiting Google Analytics’ site here for currently available opt-outs for the web.

8                    Direct Marketing

8.1               Express informed consent

You give your information or Personal Data (as applicable) set out in the table at Section 5 of this document above to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications).

8.2               Inferred consent and reasonable expectations of direct marketing

Without limitation to paragraph 7.1, if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information or Personal Data (as applicable) for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.

8.3               Opt-out

If at any time you do not wish to receive any further Direct Marketing Communications from us or others under this Section, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the Direct Marketing Communication or by contacting us via the details set out at the top of this document.

9                    Anonymity and pseudo-anonymity

To the extent practicable and reasonable, we will endeavour to provide you with the option of dealing with Paullie Skin on an anonymous basis or through the use of a pseudonym. However, there may be circumstances in which it is no longer practicable for Paullie Skin to correspond with you in this manner and your personal information or Personal Data (as applicable) may be required in order to provide you with our products and services or to resolve any issue you may have.

10                Cross Border Disclosure

10.1           Cross border disclosures

(a)                Any personal information or Personal Data (as applicable) collected and held by Paullie Skin may be disclosed to, and held at, a destination outside Australia, including but not limited to the United States of America, Singapore and India, where we use third party service providers to assist Paullie Skin with providing our goods and services to you. Personal information may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related entity.

(b)                As we use service providers and platforms which can be accessed from various countries via an Internet connection, it is not always practicable to know where your information may be held. If your information is stored in this way, disclosures may occur in countries other than those listed above.

(c)                 In addition, we may in future use overseas IT services (including software, platforms or infrastructure) such as data storage facilities or other IT infrastructure. In such cases, we may own or control such overseas infrastructure or we may have entered into contractual arrangements with third party service providers to assist Paullie Skin with providing our Products and Services to you.

10.2           Provision of informed consent

(a)                By submitting your personal information or Personal Data (as applicable) to Paullie Skin, you expressly agree and consent to the disclosure, transfer, storing or processing of your personal information or Personal Data (as applicable) outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to personal information or Personal Data (as applicable). However, we will take steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

(b)                The Privacy Act requires us to take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information or Personal Data (as applicable) outside of Australia do not breach the Australian Privacy Principles. By providing your consent, under the Privacy Act, we are not required to take such steps as may be reasonable in the circumstances. However, despite this, we acknowledge the importance of protecting personal information or Personal Data (as applicable) and have taken reasonable steps to ensure that your information is used by third parties securely and in accordance with the terms of this Privacy Policy.

10.3           If you do not consent

If you do not agree to the disclosure of your personal information or Personal Data (as applicable) outside Australia by Paullie Skin, you should (after being informed of the cross border disclosure) tell us that you do not consent. To do this, either elect not to submit the personal information or Personal Data (as applicable) to Paullie Skin after being reasonably informed in a collection notification or please contact us via the details set out at the top of this document.

11                Data security and quality

11.1           Paullie Skin’s security generally

We have taken steps to help ensure your personal information or Personal Data (as applicable) is safe and protected from unauthorised access, use, disclosure, alteration, or destruction. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information or Personal Data (as applicable), especially where the Internet is involved.

Notwithstanding the above, we will take reasonable steps to:

(a)                make sure that the personal information or Personal Data (as applicable) we collect, use or disclose is accurate, complete and up to date;

(b)                protect your personal information or Personal Data (as applicable) from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and

(c)                 destroy or permanently de-identify personal information or Personal Data (as applicable) if it is no longer needed for its purpose of collection.

11.2           Accuracy

The accuracy of personal information or Personal Data (as applicable) depends largely on the information you provide to us, so we recommend that you:

(a)                let us know if there are any errors in your personal information or Personal Data (as applicable); and

(b)                keep us up-to-date with changes to your personal information or Personal Data (as applicable) (such as your name or address).

We provide information about how you can access and correct your information in Section 12.

(a)                You are entitled to have access to any personal information or Personal Data (as applicable) relating to you which we hold, except in some exceptional circumstances provided by law (including the Privacy Act). You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.

(b)                If you would like access to or correct any records of personal information or Personal Data (as applicable) we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out at the top of this document.

13                Resolving Privacy Complaints

13.1           Complaints generally

We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.

13.2           Contacting Paullie Skin regarding complaints

If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information or Personal Data (as applicable), please contact us by:

(a)                Telephone:  (07) 5649 6849

(b)                Email:    help@paullie.com

(c)                 Post:    18 Ashmore Road, Bundall Qld 4217

Please mark your correspondence to the attention of the Privacy Officer.

13.3           Steps we take to resolve a complaint

In order to resolve a complaint, we:

(a)                will liaise with you to identify and define the nature and cause of the complaint;

(b)                may request that you provide the details of the complaint in writing;

(c)                 will keep you informed of the likely time within which we will respond to your complaint; and

(d)                will inform you of the legislative basis (if any) of our decision in resolving such complaint.

13.4           Register of complaints

We will keep a record of the complaint and any action taken in a Register of Complaints.

14                European Union

14.1           Definitions

In this Section 14, the following defined terms have the associated meanings:

(a)                Data Subject has the meaning attributed to that term in the GDPR;

(b)                EEA means the European Economic Area;

(c)                 GDPR means:

(i)                  in respect to residents in the EEA – the General Data Protection Regulation, Regulation (EU) 2016/679 and any legislation and/or regulation implementing or made pursuant to it or which amends or replaces any of them, as it applies to the EEA; 

(ii)                in respect to residents in the UK – the UK General Data Protection Regulation under the Data Protection Act 2018 (UK) and any legislation and/or regulation implementing or made pursuant to it or which amends or replaces any of them, as it applies to the UK;

(d)                Personal Data has the meaning attributed to that term in the GDPR; and

(e)                UK means the United Kingdom.

14.2           Compliance with the GDPR

(a)                In providing our services, or collecting and using your Personal Data, we are required to comply with the GDPR where you are a resident of the EEA or the UK.

(b)                If you are a resident of the EEA or the UK for the purposes of the GDPR, then in addition to what is set out in Sections 1 to 13.4 above, the following applies to you.

14.3           Residents of the UK or the EEA

(a)                Our products may be purchased by residents in the UK and the EEA. You may make an enquiry with us, either on your own behalf or on behalf of another. If you are domiciled in the UK or the EEA, your Personal Information is processed by us in Australia. When you submit data, including Personal Information, to purchase our products, that data is being submitted directly into Australia and at no time is held in the UK or any country in the EEA. In such circumstances, we will be considered the controller of such data submitted.

(b)                We rely on the following provisions of the GDPR when transferring your data to our servers in Australia:

(i)                  (Article 49(1)(a)): at the time of submitting the data, you explicitly consented to the transfer of your data outside of the United Kingdom or the EEA and into Australia;

(ii)                (Article 49(1)(b)): the transfer of data into Australia is necessary for the performance of the contract you are entering with us when you submit your data;

(iii)               (Article 49(1)(c)): the transfer of data into Australia is necessary to conclude a contract between you and us, created when you submit the data; and

(iv)               (Article 1): to otherwise peruse our legitimate business interests outlined in this policy.

14.4           Rights as an EEA or UK Resident

(a)                As a Data Subject you may:

(i)                  (access) request access to your Personal Data held by Paullie Skin;

(ii)                (rectification) request to update or rectify any of the Personal Data that we hold about you by contacting us at the details specified below and request Personal Data updates;

(iii)               (erasure) withdraw your consent to Paullie Skin’s use of your Personal Data as described in this policy by deletion or erasure of your Personal Data that we hold where that data is no longer required for the purpose for which it was collected;

(iv)               (restriction on processing) obtain from the controller a restriction on processing of your Personal Data where:

(A)               accuracy of the Personal Data is contested;

(B)                the processing by the processor is unlawful (and you oppose erasure but request restriction of use);

(C)                Paullie Skin no longer needs your Personal Data; or

(D)               you have objected to processing pursuant to your right to object under Article 21(1) of the GDPR;

(v)                (data portability) request that Paullie Skin:

(A)               provides you with a copy of the Personal Data that Paullie Skin holds about you in a portable and machine readable form; or

(B)                share your Personal Data with a nominated third party,

(b)                If we hold your Personal Data, please submit your written request to our representative Privacy Officer using the contact details set out in Section 13 above.

(c)                 We will process your request promptly and in any event, within one month of receipt of receiving it.

(d)                If you have any concerns in relation to how we collect or process your Personal Data, then you also have a right to complain to a supervisory authority (within the meaning of the GDPR).

15                Consent, modifications and updates

15.1           Interaction of this Policy with contracts

This Privacy Policy is a compliance document prescribed by law rather than a legal contract between two or more persons. However, certain contracts may incorporate all, or part, of this Privacy Policy into the terms of that contract. In such instances, Paullie Skin may incorporate the terms of this policy such that:

(a)                certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not give rise to contractual obligations onto Paullie Skin, but do create contractual obligations on the other party to the contract; and

(b)                the consents provided in this policy become contractual terms provided by the other party to the contract.

15.2           Acknowledgement

By using our Website, or where you have otherwise been provided with a copy of our Privacy Policy or had a copy of it made reasonably available to you, you are acknowledging and agreeing:

(a)                to provide the consents given by you in this Privacy Policy; and

(b)                that you have been informed of all of the matters in this Privacy Policy.

15.3           Modifications and updates

We reserve the right to modify our Privacy Policy as our business needs require. We will take reasonable steps to notify you of such changes (whether by direct communication or by posting a notice on our website). If you do not agree to our continued use of your personal information or Personal Data (as applicable) due to the changes in our Privacy Policy, please cease providing us with your personal information or Personal Data (as applicable) and contact us via the details set out at the top of this document.

16                Definitions

16.1           Definitions in this Privacy Policy

In this Privacy Policy, the following words have the corresponding meaning:

(a)                Website means the Paullie Skin website accessible at www.paullie.com.

(b)                You means in the case of an individual using the Website or purchasing a Product through the Website, that individual, or in the case of an individual, using the Website or purchasing a Product through the Website on behalf of a company or other legal entity, the company or other legal entity.

(c)                 Paullie Skin, us, we, our means Paullie Skin Pty Ltd ACN 667 855 101.

(d)                Products means all products offered by Paullie Skin on the Website.

(e)                Services means all services offered by Paullie Skin on the Website.