PRIVACY POLICY

At Big Sugar Pty Ltd (“Zehrai”) we are committed to protecting the privacy and security of our customers and site visitors, including you. The BIG SUGAR team members are customers themselves, both of BIG SUGAR and other Internet sites. We therefore fully appreciate and respect the importance of data privacy and security on the Internet.

We believe you should feel both informed and empowered when it comes to our handling and usage of your information. This notice therefore explains:

• what information we collect when you’re using any BIG SUGAR website or app, or when you’re communicating with us;
• why we collect that information;
• how we may then use that information;
• how long we keep your information, and how we protect it whilst we have it;
• what we won’t do with your information; and

So you only need to look in one place to find out all you need to know, this notice covers all BIG SUGAR websites, apps and services. That includes the BIG SUGAR.com site, the BIG SUGAR mobile site, the BIG SUGAR iOS and Android applications.

Because we’re an online fashion destination, the wording does have to get a little technical at times. But we’ve done our best to try to explain things as clearly as we can. We’re unlikely to have done this perfectly though, so we’re always happy to take any questions, comments or suggestions relating to this notice. Just contact us info@bigsugar.com.au team if you’d like to discuss this with us.

Our over arching data principles

Everything we do relating to your information is covered by the following over-arching data principles:

• Your information belongs to you, not us – you should be able to control it, and you should know about, and be comfortable with, everything that we do with your information;
• We will only collect and use your information either (a) for genuine business purposes that we’ve explained clearly to you and that you haven’t objected to, or (b) where we’re legally required to do so – and as soon as those purposes have been fully achieved, we will delete your information
• We will be as clear and open as we can with you on what information we collect, why we collect it and how we use it, so you are informed and able to make decisions to control your information in the ways you’re comfortable with;
• As long as we have your information, we will keep it up to date and protect it as if it was our own sensitive information, using appropriate security safeguards, having kept on top of and appropriately taken into account the latest industry standards and best practice.

How do we collect information about you?

When you directly give it to us (“Directly Provided Data”)

When you sign up for our site, or any time you visit BIG SUGAR, or purchase our products, or communicate with us, you may choose to voluntarily give us certain information – for example, by filling in text boxes, or clicking on active buttons on our side, like ‘Add to Bag’. All this information requires a direct action by you at that time in order for us to receive it.

What personal information do we collect about you, why do we collect it and what do we do with it?

At the headline level, we collect two types of information:

• “personally identifiable” information (meaning it can be used to specifically identify you); or
• “non-personally identifiable” information (meaning it relates to you but can’t be used to specifically identify you i.e. anonymous data like your unique BIG SUGAR customer number).

When explaining the specific information we collect about you, we will endeavour to confirm which is “personally identifiable” and which is “non-personally identifiable” on the other.

The easiest way to explain the specific information we collect about you is to look at every different point of interaction you may have with BIG SUGAR, as we collect different information at different points in your user or customer journey with BIG SUGAR. These interaction points include the following:

• Browsing our site;
• Saving an item;
• Making a purchase from BIG SUGAR (i.e. adding to bag, checking out and completing a purchase);
• Contacting BIG SUGAR Customer Care, either about an order or for any other reason;
• Using BIG SUGAR social media channels;
• Clicking on BIG SUGAR banners, hyperlinks or plugins.

Set out below is an explanation of what information we collect at each of these interaction points, along with confirmation of (a) whether you directly give it to us, or we collect it with your permission, or whether it is collected by our technical systems; and (b) whether it is “personally identifiable” information or “non-personally identifiable” information:

• Browsing BIG SUGAR: irrespective of whether you are logged in when on BIG SUGAR, we use cookies and code which is embedded in our systems to gather and record certain System Collected Data regarding the visitors to the site, such as:

o The IP address of the computer or the proxy server that you use to access BIG SUGAR – this is personally identifiable information;

o The type of device used to access our Services, your computer operating system details and settings, your type of web browser and your settings for that browser, the name of your ISP, (if you are accessing BIG SUGAR using a mobile device) your mobile device, your mobile operating system, your mobile device identifier provided by your mobile device operating system, and location data (if you have that functionality set up) and other general device or systems information – this is non-personally identifiable information;

o Statistical information and log data about number of visits to certain pages on the site (e.g. the home page); the pages you viewed and activities you carried out during your visit; the date and time of your visit; the duration of an individual page view, the paths taken by visitors through the site – this is also non-personally identifiable information.

• Purchasing from BIG SUGAR: To purchase products from BIG SUGAR, you will need to do the following:

o Click the relevant button on the site to add the product(s) to your bag – at which point our systems will collect this Directly Provided Data relating to the identity, size and other product attributes of the item(s) you’ve added, so the item(s) can then be displayed in your ‘Bag’ until the end of that visit. This is non-personally identifiable information

o Select certain options relating to the delivery of the products you wish to order – our systems will collect this Directly Provided Data relating to your delivery selections in order to be able to fulfil and deliver your products to you by your required delivery method, should you complete your order. This is non-personally identifiable information;

o Input certain details relating to your credit card, or login details for certain other payment systems, such as PayPal. This Directly Provided Data will be collected by our systems, so we can take the required payment for the products you wish to purchase, should you complete your order. These details are personally identifiable information.

o To complete your order, you finally need to click the relevant button to ‘Place Order’. When we have this Directly Provided Data, we will record the full details of the completed order in our systems for as long as you are registered with us, so we can (a) fulfil and deliver your order, (b) add it to your order history and have a record of your purchases in order to deal with any queries you may have or process any returns you may wish to make, and (c) include it within the financial records of our business transactions. This is all personally identifiable information provided by you.

• Contacting BIG SUGAR Customer Care: if you contact our customer care department for any reason (for example when you submit a question using the Ask a Question or Help Form or if you communicate with us on Live Chat), irrespective of which of the available communication channels you use to contact us, we will record the contact and collect all applicable information relating to the contact. Details of the contact with you will be both Directly Provided Data and personally identifiable information, which we will then:

o Keep and use to help us categorise your specific question or contact, respond to it, and, if applicable, investigate, deal with and resolve any issue or incident, and

• Using or interacting with BIG SUGAR social media channels: When you use or interact with any of our social media channels (like Facebook and Twitter), we may collect, record and retain certain System Collected Data and User Authorised Data regarding your activities on those social media channels, such as the frequency of your visits. For example, if you choose to use the Facebook “like” button to indicate you like any of our pages or apps, or if you tag any of your social media contacts or link to them in any content you post, we will record this information. This is most like to be non-personally identifiable information but may also include personally identifiable information depending upon your settings with those channels.

Any content you put or add on any of our social media channels will be Directly Provided Data, which may be personally identifiable information depending upon the content. We will collect, record and use that content and any other information you provide when putting or adding it to any of our social media channels (including any information that you have permitted those social media channels to share with us or that is allowed by your user settings on those sites).

Finally, any additional information about you that you need to provide when you use a particular social media channel or app will be explained in the terms and conditions for that app.

• Clicking on BIG SUGAR emails, banners, hyperlinks or plugins: if you view or click on emails that we have sent you, or on banners, hyperlinks or plugins we have placed on our website or other websites, both the fact that you have done so , as well as the address of the site you were on when you did so, will be Directly Provided Data that we will record. This is all non-personally identifiable information. We will use this information to track and analyse how successful those emails, banners, hyperlinks or plugins are in engaging with you. We are constantly innovating to improve BIG SUGAR and the Services, which means we may create new ways to collect information from you. If we do, we’ll tell you about any new information we are collecting through updates to this notice.

How may we use your information?

We collect all of this information from you for a number of different purposes, which we want you to understand – all of these purposes apply wherever BIG SUGAR does business. A number of specific uses for specific data is already detailed above. But we often need to use lots of different types of information or data collectively in order for BIG SUGAR to work and in order to be able to provide the Services to you. These more fundamental purposes include the collective use of your information:

• To ensure that our site’s content is presented as effectively as possible for you, and to enable you to participate in interactive features of our site, when you choose to do so – for example by providing you with more customised services and a more customised experience on BIG SUGAR through things like language-specific profile pages, updates, and content, news, style advice and/or recommendations relevant to you to customise your experience on BIG SUGAR

• To ensure that our users are genuine and to ensure that we are paid for goods that we despatch – for example, by using personal information, or disclosing that personal information to a credit reference or fraud prevention agency, in order to confirm your identity and conduct appropriate anti-fraud checks. Any such credit reference or fraud prevention agency may keep a record of that information but please note that a formal credit check is not performed and your credit rating will not be affected.

• To update you on our latest products, news and special offers – If you have provided us with your email address and elected to receive marketing communications from us, we will occasionally update you on our latest products, news and special offers via e-mail, post, telephone and other means available through the Services, including mobile text messages and push notifications.

• To create a link to our app in your social media channels – some of our apps may give you the option to post updates to your Facebook wall or other social media channel, and to the wall of your social media friends, or to send invitations to your friends. This may create a link to our app, dependent on your privacy settings in that social media channel. When you send an invitation, please be aware that it may contain your social media username and profile picture so your friend knows who sent them the invitation.

• To target BIG SUGAR banners and ads to you when you’re on certain other websites (what’s called Digital Marketing Re-targeting) – we do this using a variety of digital marketing networks and ad exchanges, and advertising technologies like web beacons, pixels, ad tags, cookies, and mobile identifiers, and the banners and ads you will see will be based on your previous use of BIG SUGAR (for example, your BIG SUGAR search history, the content you read on BIG SUGAR, etc.) or on BIG SUGAR banners or ads you’ve previously clicked on.

• To carry out polls, surveys, analysis and research on how our site is being used, customer views, what we could do better etc., – these polls, surveys, analysis and research may be conducted by BIG SUGAR, or third parties. BIG SUGAR or those third parties may follow up with you via email regarding your participation unless you have opted out of receiving email messages. We may use third parties to deliver incentives to you to participate in polls, surveys, analysis or research, and verifying your contact information, which may require your contact information and other personally identifiable information to be provided to the third party fulfilling the incentive offer.

• To make BIG SUGAR’s products and services better and to develop new ones – BIG SUGAR uses and stores site statistical information and log data, to help it identify potential areas to improve the services we offer.

How we DON’T use your information

WE WILL NOT Share your information with third-party advertiser or ad networks: We do not currently display third party adverts on our website and, even if we did, we would not support sharing your personally identifiable information with any third-party advertiser or ad network.

Protecting your security

We are always striving to make sure your information is protected. As soon as we receive your information, we use various security features and procedures, taking into account industry standards, to try to protect the personal information that you provide and to prevent unauthorised access to that information. For example:

• We also offer secure “https” access to the transactional parts of BIG SUGAR.com website (that is to the bits where you are required to provide Directly Provided Data). [This includes to existing SSL access over mobile devices].

• Access to your data on BIG SUGAR is password-protected, and sensitive data (such as credit card information) is protected by SSL encryption when it is exchanged between your web browser and the BIG SUGAR Services. To further secure your credit card, we also don’t keep details of the security code (or CCV number) that you need to input in order to complete an order using your credit card.

We will do our best to protect your personal data. Unfortunately, security cannot be guaranteed though. There are therefore a number of general things we would also recommend that you do. Please help keep your account safe by using a strong password that includes characters other than just letters. We will also encourage you not to use the same password across all or many of your online accounts. As emails, instant messaging, and similar means of communication are not encrypted, we also would recommend not communicating any confidential information through these means.

Contacting us

Both the information you provide to us, and the information we collect, is controlled by BIG SUGAR.com Limited, including for the purpose of the Data Protection Act 1998 (the Act) and any other applicable laws.

We are always keen to hear from our customers (especially if you feel we’ve let you down or fallen short of your expectations). We are always grateful for any time you spend providing us with the knowledge we need to ensure our customers are completely satisfied – after all, we want you to return to the site and to recommend us to your friends and family. If you have any questions or feedback about this statement, or if you would like us to stop processing your information, please do not hesitate to contact a customer service member of the BIG SUGAR team, who will be delighted to answer any questions you may have. You can either contact customer care via the BIG SUGAR website, or, write to us at: