Privacyverklaring

This Privacy Policy explains our policy for dealing with personal information that we collect through the following channels (here and after, the Collection Channels):

• our online properties (here and after, each a Website), including;
• our websites, including, but not limited to, steelblue.com and www.howlerboots.com;
• any related Steel Blue website, social media page, internal website, intranet and any Steel Blue mobile or tablet applications;
• any website, social media page, internal website, intranet, and any mobile or table applications relating to any Steel Blue product or range as may exist from time to time as stated on steelblue.com, www.howlerboots.com or elsewhere; and
• any other means through which an individual provides personal information to Steel Blue, including either physically or electronically.

You may contact us with any queries you may have in respect of this Privacy Policy or your personal information by contacting Steel Blue’s privacy officer via email: Marketing@SteelBlue.com or telephone: +61 8 9209 3322.

PERSONAL INFORMATION IS IMPORTANT TO STEEL BLUE

1. Steel Blue is committed to safeguarding personal privacy. It recognises that you have a right to control how your personal information is collected and used. Providing personal information is an act of trust and it is taken seriously. Unless given consent to do otherwise, Steel Blue will only collect and use personal information as set out below.
2. Throughout this Privacy Policy, we refer to your ‘personal information’, which means information which identifies you as an individual or which renders you reasonably identifiable. Your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address and workplace contact details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences.
3. Steel Blue has developed and implemented its Privacy Policy with respect to personal information to reflect world best practice on privacy policies. These principles meet and exceed the requirements of the Privacy Act 1988 (Cth) (as amended) and the 13 Australian Privacy Principles and the European General Data Protection Regulation (GDPR) of 2018, https://www.eugdpr.org/
4. In order to keep up with changing legislation and best practice, we may revise this Privacy Policy at any time without notice. We will post any changes to this Privacy Policy on our Websites, so we encourage you to check this Privacy Policy from time to time.
5. In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

ANONYMITY AND PSEUDONYMITY

6. Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our Collection Channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the information identified below.

KINDS OF PERSONAL INFORMATION THAT STEEL BLUE COLLECTS AND HOLDS

7. Personal information that may be requested includes:

• contact information such as your full name, telephone number, mobile telephone number, current and valid email address, residential address, region, suburb and postcode;
• your gender;
• testimonials about our products or services;
• complaint details;
• information regarding your employment including your company;
• information about your employment history and future plans, and documents relating to your employment;
• information regarding your education and qualifications;
• information about your experience with our products or services or third party products or services listed on a Website. This information is requested in order to tailor our subsequent communications to you and continuously improve our products and services;
• the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to Steel Blue and used for the purposes set out in this policy (which may include using their details for marketing purposes); and
• any other personal information which you provide directly to Steel Blue. Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this Privacy Policy).

SENSITIVE INFORMATION

8. We will only collect sensitive information with your consent. Where you provide us with any sensitive information (including, but not limited to, information about your medical and/or criminal history) in connection with what is requested by a Collection Channel, we will only use this information for the purposes stated on the Collection Channel. We do not retain this information in our database.

HOW STEEL BLUE/HOWLER COLLECTS AND HOLDS PERSONAL INFORMATION

9. Steel Blue will only collect or monitor any personal information about you with your consent including as provided in this Privacy Policy or if it is otherwise lawful to do so. The only personal information collected by us is what has been provided to us in accordance with this Privacy Policy or has been provided to us lawfully by third parties.

ACTIVE INFORMATION COLLECTION

10. Personal information may be collected (and combined) via our Collection Channels if you:

• have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party;
  sign-up and/or register to become a member of any Collection Channel;
• purchase a product or make an order via a Collection Channel;
• subscribe to any newsletters, updates, alerts or news and media releases, or request launch or event information or information about our products or services or other information services as well as third party products or services;
• complete and submit any forms to us;
• contact us directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
• participate in any offers, promotions or marketing activities;
• provide us with any testimonial;
• interact with a Website for a specific purpose; or
• interact with or browse a Website generally.
• Personal information is requested in order to facilitate or provide you with certain content, products or services, and information about such content, products or services (including the uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), marketing materials, newsletters, electronic newsletters (e-newsletters), news and media releases / launch information, and also to advise you of other Steel Blue or third party products, services, offers, competitions or events which may be of interest. No one is obligated to provide personal information. However, failure to do so may result in Steel Blue being unable to facilitate or provide you with certain content, products or services, products or services information, upcoming promotion, competition, offer or event information or accept competition entries (where applicable).

CHILDREN

12. Personal information will not be collected by any person who is known by Steel Blue to be under the age of fifteen (15) without the consent of a parent or legal guardian. Persons under age fifteen (15) may only use our Websites with the involvement and consent of a parent or legal guardian.

PASSIVE INFORMATION COLLECTION

13. We may use passive information collection and tracking technologies in HTML emails that we send to our visitors for a number of purposes including: to determine whether our visitors have opened or forwarded those emails and/or clicked on links in those emails; to customise the display of banner advertisements and other messages after a visitor has closed an email; and to determine whether a visitor has made an enquiry or a purchase in response to a particular email.

PURPOSES FOR WHICH STEEL BLUE COLLECTS, HOLDS, USES AND DISCLOSES PERSONAL INFORMATION

14. Personal information collected will be used for the following primary purposes:

• For the purposes for which it was collected (as advised in this Privacy Policy).
• For the purposes stated in a privacy collection statement on a particular Collection Channel.
• To fulfil obligations in respect of any upload terms of use, sale and purchase contract and/or any other contract between you and Steel Blue;
• To provide you with information about your transactions (including uploading, access to, and receipt of content on a Website, and purchase transactions undertaken on a Website), content, services and products, to provide direct marketing materials, events, special offers, competitions and promotions in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email) or any other form of electronic, emerging, digital or conventional communications channel.
• To maintain our relationship with you.
• To render services related to Steel Blue/Howler (such as enquiries).
• To provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages.
• To respond to customer enquiries and/or complaints;
• To obtain opinions or comments about products and/or services.
• For the purposes described above, personal information may be shared with Steel Blue group companies, Steel Blue/Howler promotional partners and other trusted third parties (and their directors, servants and agents) either in Australia or overseas. Failure to provide personal information may result in Steel Blue being unable to provide you with certain content, information, upcoming promotion, event or product information and/or accept promotion entries (where applicable).
• In order to operate a Website or deliver a service (including for example, processing of credit card payments or delivery of promotions), personal information may also be shared with Steel Blue group companies, selected service providers and/or other trusted third parties either in Australia or overseas countries. Steel Blue group companies, selected service providers and/or other trusted third parties may be engaged by Steel Blue to perform a variety of functions, such as data storage, fulfilling orders, conducting market research, processing credit card payments, assisting with promotions and providing technical services for our Websites. These companies may have access to personal information if needed to perform such functions.
• Steel Blue/Howler recognises the trust with which you provide personal information, and except as stated in this Privacy Policy, such information will not be used or disclosed for any other purposes without consent. However, Steel Blue/Howler reserves the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect the rights or property of Steel Blue, any member of the Steel Blue group, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.

CONTACT BY STEEL BLUE/HOWLER

18. Steel Blue group companies (and their directors, servants and agents), Steel Blue promotional partners or trusted third parties (and other selected service providers and other non-Steel Blue companies or professionals) either in Australia or overseas, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the primary purposes for collection of personal information as stated above.
19. Steel Blue does not send advertising or marketing information without obtaining prior consent, for example the consent contained within this Privacy Policy, or if it is otherwise lawful to do so. If you receive communications from Steel Blue which you do not wish to receive, you may remove your name from the database either by utilising the functional unsubscribe facility (if the communication is via commercial electronic message) or by contacting Steel Blue via email: Marketing@SteelBlue.com or telephone: +61 8 9209 3322. Please allow 30 days for this request to be processed.

ABILITY OF OTHERS TO VIEW INFORMATION

20. Steel Blue/Howler may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users, provide reviews for content, products and/or services or interact with or vote on particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others outside of our Websites. Steel Blue is not responsible for the conduct of others who may read, collect and use this information.

YOUR RIGHT OF ACCESS

21. You have the right to access and review your personal information that may be recorded on the Steel Blue database. Information may be reviewed by contacting Steel Blue’s privacy officer via email: Marketing@SteelBlue.com or telephone: +61 8 9209 3322. Please allow 30 days for this request to be processed.

CHANGING AND DELETING THE INFORMATION WE HAVE ABOUT YOU

22. Information contained on the database may be amended, or your preferences for contact from us changed, by contacting Steel Blue’s privacy officer via email: Marketing@SteelBlue.com or telephone: +61 8 9209 3322. Please allow 30 days for this request to be processed.
23. In the same way, a request may be made to delete personal information, and all reasonable steps to delete the information will be made, except where it is required for legal reasons. Deletion of information may result in Steel Blue being unable to facilitate or provide you with information about certain transactions (including the uploading, access to, and receipt of content on a Website), other content, services or product information, upcoming promotion, competition or event information, and/or provide certain content, goods or services.
24. We are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this policy.

STORAGE AND SECURITY OF PERSONAL INFORMATION

25. Steel Blue/Howler will endeavour to take all reasonable steps to keep secure any personal information recorded (including your credit card details), and to keep this information accurate, up to date, complete and relevant. The information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas.

DISCLOSURE OF PERSONAL INFORMATION TO OVERSEAS RECIPIENTS

26. In some cases, Steel Blue/Howler may disclose your personal information to overseas recipients. Steel Blue employees, data processors and other trusted third parties are obliged to respect the confidentiality of any personal information held by Steel Blue. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. Steel Blue will not be held responsible for events arising from unauthorised access to personal information.

STEEL BLUE AND LINKS TO OTHER WEBSITES

27. Our Websites may, from time to time, contain links to the websites of other organisations which may be of interest to you. Their inclusion cannot be taken to imply any endorsement or validation by us of the content of the third party website. Linked websites are responsible for their own privacy practices and you should check those websites for their respective privacy statements. Steel Blue is not responsible, nor does it accept any liability, for the conduct of companies linked to our Websites.

RELATED STEEL BLUE WEBSITES

28. All Websites operated by Steel Blue will adhere to this Privacy Policy.

SALE OF THE COMPANY

29. If Steel Blue/Howler merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

GOOGLE ANALYTICS

30. With Google Analytics we measure how you use the steelblue.com and www.howlerboots.com websites. We use this knowledge to improve our website. In order to measure how you use our website, we enable Analytical Cookies. This Cookie comes from Google and is deleted after a maximum of 26 months. Google does not share anonymous data with third parties. Google Privacy Policy.

• Social Media & Remarketing
  We use Profiling Cookies that allow us to see what products you are viewing on our website, to enable us to re-market to you. For example, we can show you relevant ads on Facebook. Without these Cookies, your personal offers will be missed. This Cookie comes from Facebook and is stored for a maximum of two years. Facebook does not share information with third parties. Facebook Privacy Policy.
  
• Cookie Consent
  The consent to use Cookies is lent by clicking on the ‘’Okay’’ button located within the initial banner available on the Steel Blue website and can be revoked at any time. Cookies can be disabled within your browser settings.

EMAIL MARKETING

1. We use MailChimp as our email marketing platform. You have the opportunity to update some of your information by electing to update or manage your preferences via an email campaign that you have received from us. You can unsubscribe from a list via an email campaign that you have received from us. You may contact us to unsubscribe from all Steel Blue email campaigns by contacting the Steel Blue Privacy Officer via email: Marketing@SteelBlue.com or telephone: +61 8 9209 3322.
   When you interact with a campaign from Steel Blue or browse our website, MailChimp may collect information about your device and interaction with the email by using cookies and tracking technology. For further information please see MailChimp Privacy Policy, and more specifically, Privacy for Contacts.

PROBLEMS OR QUERIES

30. If you have any questions about our Privacy Policy, or any problems or complaints about how we have collected, used, stored, handled and/or disclosed your personal information, please contact our privacy officer via one of the following channels:
    

    Address:	The Privacy Officer 18 Irvine Drive Malaga WA 6090
    Telephone:	+61 8 9209 3322
    Email:	Marketing@SteelBlue.com

31. Please allow 30 days for this request to be processed. If you do not receive a satisfactory response from Steel Blue to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at http://www.oaic.gov.au/about-us/contact-us-page. (Australia only).

Last revised: May 28, 2018.