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PRIVACY POLICY

WEAREONN.COM

WE ARE ONN Pty Ltd ACN 675 298 638 (“ONN”) recognises the importance of privacy and is committed to protecting your personal information. We comply with the Privacy Act 1988 (Cth) and the Australian Privacy Principles, which set standards for the collection, access, storage, and use of personal information. This Privacy Policy outlines how ONN manages your personal information and explains your rights regarding the information we collect.

1. INTRODUCTION

1.1 This Privacy Policy outlines how we manage your personal information. It describes the types of personal information we collect, the purposes for which it is collected, and how we handle, use, and disclose that information.

1.2 This Privacy Policy applies to all your dealings with ONN, whether through our website (www.weareonn.com) or otherwise. By interacting with ONN, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. Please check our website regularly for any updates.

1.3 We collect personal information to provide you with the products and services you request, and to inform you about other products or services we offer. Additionally, we may collect personal information to comply with legal obligations. Generally, we do not collect sensitive information (such as health records) unless necessary to provide our services or as permitted by law.

1.4 ONN may disclose relevant personal information to external organisations assisting us in delivering services. These organisations are required to comply with confidentiality agreements and may include overseas entities where applicable.

1.5 You can access the personal information we hold about you and request corrections if the information is inaccurate, incomplete, or outdated. If we deny access to your information, we will explain why, unless restricted by law.

2. COLLECTION OF PERSONAL INFORMATION

Why We Collect Information
2.1 ONN collects personal information when reasonably necessary for one or more of our functions or activities, including:

(a) Providing you with the products or services you request, and, unless you opt out, informing you about other services we or our partners offer. Communication may include electronic methods, such as email or SMS.
(b) Complying with legal and regulatory obligations.
(c) Monitoring and improving the quality of our products and services.
(d) Aggregating data for statistical and research purposes.
(e) Assisting with customer queries and support.
(f) Implementing measures to detect and prevent fraudulent activity.

3. INFORMATION WE COLLECT

3.1 The personal information we collect may include:

  • Your name, address, date of birth, gender, and occupation.

  • Contact details such as telephone numbers, email addresses, and postal addresses.

  • Financial and payment information for processing transactions.

3.2 Where necessary, we may also collect information about individuals associated with you, such as:
(a) Trustees;
(b) Partners;
(c) Company directors or officers;
(d) Agents or representatives;
(e) Beneficial owners; and
(f) Individuals engaging with us for one-off transactions.

3.3 We may take steps to verify the information provided to ensure its accuracy.

4. HOW WE COLLECT INFORMATION

4.1 ONN collects personal information directly from you whenever possible. This may occur through interactions such as:

  • Completing forms on our website;

  • Correspondence via email or phone; or

  • Participating in promotions, surveys, or events hosted by ONN.

4.2 If it is impractical or unreasonable to collect information directly from you, we may collect it from other parties, such as agents, family members, or colleagues, based on your instructions or with your consent.

5. INFORMATION COLLECTED FROM OTHERS

5.1 When collecting information from someone other than you, we will notify you of this collection and its circumstances, where reasonable and practical to do so.

6. INCOMPLETE OR INACCURATE INFORMATION

6.1 Providing incomplete or inaccurate personal information may limit our ability to offer you the products or services you request.

7. CONSENT

7.1 Where required, we will seek your consent before collecting, using, or disclosing your personal information for specific purposes.

7.2 If you do not provide consent, we may not be able to deliver the requested products or services, as certain information is necessary for these purposes.

8. WITHDRAWING CONSENT

8.1 If you have provided consent to ONN for the collection, use, or disclosure of your personal information, you may withdraw your consent at any time by contacting us directly.
8.2 Please note that withdrawing consent may affect our ability to provide certain products or services to you, as some information is essential for their delivery.

9. SENSITIVE INFORMATION

9.1 ONN will only collect sensitive information (e.g., health, racial or ethnic origin, or other sensitive data) about you if:

  • You have given prior consent to its collection; or

  • The collection is required or authorised by law.

10. DEALING WITH UNSOLICITED PERSONAL INFORMATION

10.1 If ONN receives unsolicited personal information, we will determine if it is necessary for our functions or activities and ensure its collection complies with relevant laws.
10.2 If the information is not required or reasonable to retain, it will be securely destroyed or de-identified.
10.3 For unsolicited sensitive information, ONN will obtain your explicit consent to retain it, regardless of the circumstances.

11. INTEGRITY OF YOUR PERSONAL INFORMATION

11.1 Quality of Personal Information

  • ONN is committed to ensuring that the personal information we collect, use, or disclose is accurate, up to date, complete, and relevant.

  • Please inform us of any changes to your personal information, or if you believe the information we hold is inaccurate.

  • We may also update your information by using publicly available sources where necessary.

12. SECURITY OF PERSONAL INFORMATION

12.1 ONN takes the security of your personal information seriously and implements robust practices and policies to protect against misuse, interference, loss, unauthorised access, modification, or disclosure.
12.2 These measures are regularly reviewed to maintain their effectiveness and adequacy.
12.3 When personal information is no longer needed for any purpose, it will be securely destroyed or de-identified.

13. USE OR DISCLOSURE OF PERSONAL INFORMATION

13.1 Use or Disclosure

ONN will only use or disclose your personal information for the purpose for which it was collected (“primary purpose”) unless:
(a) You have provided your consent;
(b) The use or disclosure is for a related secondary purpose, and:

  • If the information is sensitive, it is directly related to the primary purpose; or

  • If the information is not sensitive, it is related to the primary purpose;

(c) The use or disclosure is required or authorised by Australian law or a court/tribunal order;

(d) A permitted general situation applies, such as to prevent a serious threat to life, health, or safety;
(e) A permitted health situation applies, in which case ONN will de-identify the information before disclosure; or
(f) The use or disclosure is reasonably necessary for enforcement-related activities by an enforcement body.

13.2 Record of Disclosure

When disclosing personal information in line with Section 13.1(e), ONN will retain a record of the disclosure (e.g., emails or correspondence).

14. WHO WE MAY COMMUNICATE WITH

14.1 Entities We Exchange Information With

Depending on the services provided, ONN may exchange your personal information with the following entities:
(a) Courier, transport, and freight forwarding companies;
(b) Government and private mail services;
(c) Venues, Wholesalers, Bottle Shops, Events, Health and fitness clubs, gyms, or other organisations within the ONN network;
(d) Brokers or agents referring your business to ONN;
(e) Individuals acting on your behalf, such as lawyers, accountants, financial advisers, or executors;
(f) Regulatory bodies or government agencies, as required or authorised;
(g) Investors or advisers;
(h) Other organisations that collaborate with ONN to deliver services.

14.2 Additional Use or Disclosure

The use or disclosure of your personal information may extend beyond these examples where necessary.

15. OUTSOURCING

15.1 Disclosure to Outsourced Service Providers
ONN may disclose personal information to third parties for functions such as:

  • Bulk mailing and direct marketing;

  • Market research and system improvement;

  • Bookkeeping, invoicing, and debt recovery;

  • Statement production; and

  • Information technology support.

15.2 Confidentiality Obligations
All contractors, agents, and service providers with access to your personal information are bound by confidentiality agreements. They are prohibited from using the information for purposes other than ONN’s authorised activities.
15.3 Commitment to Information Security
ONN works exclusively with parties that share our commitment to safeguarding personal information.

16. DISCLOSURE REQUIRED BY LAW

16.1 ONN may be required to disclose personal information to comply with legal obligations, such as:

  • Court orders or statutory notices;

  • Taxation, superannuation, social security, or corporate regulatory requirements;

  • Laws related to sanctions, anti-money laundering, or counter-terrorism financing.

17. DIRECT MARKETING

17.1 Use of Personal Information for Direct Marketing

ONN will use or disclose your personal information for direct marketing purposes only if:

  • We have collected the information directly from you; and

  • You have not opted out of receiving direct marketing communications.

17.2 Purpose of Direct Marketing

Direct marketing involves using your personal information to share details about ONN’s services or offers that may be of interest to you.

17.3 Opting Out of Marketing Communications

If you prefer not to receive marketing communications, you can opt-out by:
(a) Emailing us at: hello@weareonn.com; or
(b) Writing to us at:
ONN Headquarters
2015 Gold Coast Hwy
Miami, QLD 4220, Australia

18. CROSS-BORDER DISCLOSURE OF PERSONAL INFORMATION

18.1 Conditions for Disclosing Information Abroad
ONN may disclose personal information to overseas recipients only when:
(a) The recipient complies with the Australian Privacy Principles; or
(b) You have enforceable rights to protect the information under laws or binding schemes equivalent to the Australian Privacy Principles; or
(c) You consent to the disclosure after being informed of potential risks; or
(d) Disclosure is required or authorised by Australian law or court/tribunal order; or
(e) A permitted general situation applies under the Privacy Act 1988 (Cth).

19. GENERAL DATA PROTECTION REGULATION (GDPR)

19.1 Commitment to GDPR Compliance

ONN ensures that the collection and processing of personal data, whether through our website or other means, complies with the General Data Protection Regulation (GDPR).

19.2 Principles of GDPR Compliance

When collecting personal data, ONN adheres to these principles:

  • Only collecting data strictly necessary for specified purposes;

  • Clearly outlining whether the provision of data is mandatory or optional;

  • Ensuring access is limited to ONN unless otherwise disclosed.

19.3 Security and Rights

All personal data is processed securely. For information or to exercise your rights under GDPR, contact us directly using the details in this policy.

20. CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

20.1 Rights Under the CCPA
If you reside in California, the California Consumer Privacy Act (CCPA) grants you the following rights:

  • Right to Know: Access the personal information we hold about you;

  • Right to Portability: Transfer your personal information to another service;

  • Right to Rectification or Erasure: Request corrections, updates, or deletion of your information.

20.2 Exercising Your Rights
To exercise these rights, contact ONN using the details in this policy.
20.3 Authorized Agents
You may designate an authorized agent to submit requests on your behalf. To do so, contact us via email at hello@weareonn.com.au.

21. ADOPTION OF GOVERNMENT-RELATED IDENTIFIERS

21.1 ONN will not adopt a government-related identifier of an individual as its own unless required or authorised by an Australian law, regulation, or court/tribunal order.

22. USE OR DISCLOSURE OF GOVERNMENT-RELATED IDENTIFIERS

22.1 ONN will use or disclose government-related identifiers of individuals only when:
(a) It is reasonably necessary to verify your identity for ONN’s activities or functions;
(b) It is reasonably necessary to fulfil obligations to a government agency or a State/Territory authority;
(c) Required or authorised by Australian law, regulation, or a court/tribunal order;
(d) It is within a permitted general situation under the Privacy Act 1988 (Cth) (excluding items 4 and 5 of the table in subsection 16A(1)); or
(e) It is reasonably necessary for enforcement-related activities conducted by or on behalf of an enforcement body.

23. ACCESS TO PERSONAL INFORMATION

23.1 Right to Access
You can request access to the personal information we hold about you.
23.2 Process for Limited Requests
Simple requests, such as verifying recorded contact details, can often be handled by phone.
23.3 Process for Substantial Requests
For larger requests, we require written documentation. Upon receipt, we will:

  • Provide an estimate of any applicable access charges;

  • Confirm your intent to proceed.

23.4 Access Charges
While we will not charge you for submitting a request, access charges may apply to cover administrative costs such as locating, collating, and explaining the requested information.
23.5 Response Timeline
We aim to fulfill access requests within 14 days but may extend to 30 days in exceptional circumstances.
23.6 Verification of Identity
Your identity must be verified before providing access.

24. EXCEPTIONS TO ACCESS

Certain circumstances may legally permit or require ONN to deny or limit access to personal information. If this occurs, we will provide an explanation, such as offering an overview of a commercially sensitive decision rather than direct access to evaluative information.

25. REFUSAL TO GIVE ACCESS

25.1 Notification of Refusal
If we deny access to your personal information, you will receive a written notice explaining:

  • The reasons for refusal;

  • Complaint mechanisms available;

  • Other relevant details.

25.2 Alternative Arrangements
Where possible, we will explore alternative methods of providing access that accommodate your needs.

26. CORRECTION OF PERSONAL INFORMATION

26.1 Commitment to Accuracy
We will correct personal information we believe to be inaccurate, outdated, incomplete, irrelevant, or misleading. You can also request corrections to your information.
26.2 Notification to Other Entities
If we correct information previously disclosed to another APP entity, we will notify them upon your request, unless it is impracticable or unlawful.

27. REFUSAL TO CORRECT INFORMATION

27.1 If we refuse a request for correction, a written notice will be provided outlining:

  • Reasons for the refusal;

  • Complaint mechanisms available;

  • Other relevant information.

28. REQUEST TO ASSOCIATE A STATEMENT

28.1 If ONN refuses to correct your personal information, you may request that a statement be associated with the information to indicate it is inaccurate, outdated, incomplete, irrelevant, or misleading. ONN will ensure this statement is clearly visible to users of the information.

29. CONTACT US AND COMPLAINTS

29.1 Contact Details
For questions, information requests, or privacy complaints, contact us via:

29.2 Complaint Process
If you have a complaint:
(a) Gather all supporting documents related to your complaint;
(b) Contact us to review and, where possible, resolve your issue immediately.
If unresolved, you can contact the Office of the Australian Information Commissioner (OAIC):

  • Phone: 1300 363 992 (Australia) or +61 2 9284 9749 (International).

30. FURTHER INFORMATION ON PRIVACY

30.1 For more information on privacy in Australia, visit the OAIC website: http://www.privacy.gov.au.

DATE LAST REVISED
This policy was last revised in December 2024.

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