Effective Date: June 2018

Introduction and Consent

The privacy of your personal information is a priority for Zero Proof Australia Pty Ltd (ABN 97 630 554 853) herein referred to as Lyre’s and its group companies (“Lyre’s”, “we”, “us”, “our”). This Privacy Policy explains how we collect, use, disclose and handle any personal information we collect from you, and how to contact us if you wish to access or correct your personal information, or complain about a breach of your privacy.

We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

By using our website or submitting personal information to us you are agreeing to the terms of this Privacy Policy. This Privacy Policy may be amended from time to time if our practices change. Please do not use the website or submit any personal information if you do not agree with its terms. You may find links to other websites not operated by Lyre’s but which are accessible through our websites. This Privacy Policy does not apply to such websites and you should consult the privacy policy of any other website you enter.

What kinds of personal information do we collect and how?

When you interact with Lyre’s including by purchasing products, subscribing to our loyalty program, creating an account online, in store, over the phone, via email, or via social media, we may collect and hold personal information about you. Personal information means information or pieces of information that could allow you to be personally identified. This enables us to identify you and provide you with information about Lyre’s products and services and allows us to facilitate any purchases or other enquiries. This information may include your name, address, phone number, screen name, email address, credit card information, shopping habits, preferences and health information.

We may also collect your personal information about you indirectly from third parties where you have agreed with them that your information may be disclosed to us, and with whom we have business relationships.

The following table contains further details of when we collect personal information, what we collect as well as how we use it:

When information is collected	What information we ask for	How and why we use your information
When you register with us	Email address Address Phone number Date of birth	We ask for this: — to create and manage your account with us — To assist with shipping/delivery — To communicate with you about your account If opting in for further communication: — To ensure we don’t communicate with subscribers who are underage — To send you birthday discount coupons — To send you communications about our goods, services, promotions via email, text or direct mail out. Your information will be stored in two platforms that are integrated via APIs therefore no manual handling of data takes place. Your account information will be store in a Bigcommerce website backend and if you choose to subscribe your information will also be pushed across to dotdigital (our email send provider platform) We rely on our contract with you and our legitimate interest in providing goods and services in the manner that we believe you expect as the lawful basis for collecting and using your personal information. We will keep this information until: — you close your account with us — we close your account
When you subscribe with us	Email address	Obtained via email subscription opt in forms across the Lyre’s website Used to send communications We rely on our agreement with you and our legitimate interest in providing promotional communications about our goods and services in the manner that we believe you expect as the lawful basis for collecting and using your personal information. Stored in dotdigital email send provider platform. We will keep your information until: — you unsubscribe from us — we unsubscribe you Your details will remain on dotdigital and marked as suppressed to ensure you will no longer receive communication.
When you order with us	Email address Address Phone number Credit card information	Obtained via Lyre’s website checkout form Used to fulfil orders and send transactional communications We rely on our contract with you and our legitimate interest in providing goods and services in the manner that we believe you expect as the lawful basis for collecting and using your personal information. Stored in bigcommerce website backend. Order details are then passed via API or manually exported and imported to the external 3PL warehouse system (Brandlink / My Brand platform) for packing and fulfilment and sent onto shipping providers for delivery. Credit card information will be hashed in the backend of BigCommerce and not accessible to any staff/users and credit card information will not be passed onto warehouse or shipping providers. We will keep your information until you request order history deletion from us
When you enquire with us	Email address Address Company names Phone number	Obtained via Lyre’s: Contact us page Trade enquiries page Shipping & Returns page Used to address customer service enquiries We rely on our contract with you and our legitimate interest in providing goods and services in the manner that we believe you expect as the lawful basis for collecting and using your personal information. Enquiries are not stored within the bigcommerce website backend. Your enquiry goes straight to the customer service email account inbox that is managed by Lyre’s customer service team. Pending upon the nature of your enquiry your information will be forwarded to relevant internal and external parties in order to answer your questions. Enquiries will not be marketed to unless user has chosen to opt in for marketing communications. We will keep your information within our inbox until you request deletion by us.
When you chat with us	Name Email address Date of birth Company names Phone number Preferences	Obtained via facebook messenger chat bot or Zendesk live chat functionality Used to address customer service enquiries and for further promotional communications We rely on our agreement with you and our legitimate interest in providing goods and services in the manner that we believe you expect as the lawful basis for collecting and using your personal information. Enquiries/chat history are stored within the messenger chat bot and pushed via API to Dotdigital should you choose to opt in via email/sms. When engaging with the messenger chat bot you agree with the messenger chat bot policy https://www.facebook.com/policy.php that we adhere to set by facebook. We will keep your information within the messenger chat and dotdigital until you request deletion/unsubscribes by us or you unsubscribe from our communications manually.

 

Why do we collect the information?

We collect your personal information so we can identify you and interact with you for the purposes described herein

Our legal basis for processing your personal information

When we use your personal information we are required to have a legal basis for doing so. There are various different legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

• consent: where you have given us clear consent for us to process your personal information for a specific purpose
• contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract
• legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations)
• legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests)

Sensitive personal information

We may also collect health information from you when reporting an adverse reaction to a product. This information must be collected in order to provide you with a suitable products and services and for our health and safety reporting obligations. We will not process this sensitive personal information without your explicit consent (unless required by any applicable law) and we will not process sensitive personal information by way of any automated process.

Do you have to identify yourself when you interact with Lyre’s?

If you wish to remain anonymous when you use the Lyre’s website, do not sign in to the website or provide any information which may identify you. Please note however that we are unable to perform a number of our functions without obtaining your identifying information. For example, we may require details about your identity if you register or log into our website, contact us with an enquiry or complaint, request to receive communications from us, participate in our promotions or competitions, require us to deliver products to you and, in some cases, process a payment.

How can you request not to receive direct marketing?

If you do not wish to receive direct marketing communications from us please follow the 'opt-out' or 'unsubscribe' instruction in that communication or on our website, or otherwise email us at hello@lyres.co and provide your name, e-mail address and postal address and information about the direct marketing communication you no longer wish to receive.

Who do we disclose your personal information to?

We may disclose your personal information:

• To third parties who store or process it on our behalf in order to assist us in providing, promoting and marketing as well as developing and improving our products and services. Companies include;
• Dotdigital (eMail & SMS send provider platform)
• Bigcommerce (website CMS backend)
• My Brand (brandlink Australian 3PL)
• Fusion Factory Comestry (Product information management system)
• Facebook Messenger chat bot (messenger chat service)
• We may combine personal information we receive about you with other information we hold about you. This includes information received from third parties and publicly available information;
• where required by law, or to government and enforcement agencies or individuals appointed by a government responsible for investigating and resolving disputes or complaints concerning Lyre’s products or where such disclosure is necessary to protect the safety or security of persons;
• to other companies within the Lyre’s group and to companies that may acquire part or all of Lyre’s or an affiliated company; and
• as otherwise permitted under applicable laws.

We will not disclose any health information to third parties or use it for any purpose other than as set forth herein.

Do we transfer, process or disclose your personal information overseas?

We may disclose your personal information to Lyre’s group companies and/or to third party service providers who provide services to Lyre’s including data warehousing, credit card processing and e-commerce services, mailing and logistics services, located overseas in Hong Kong, China, Japan, the United States and Australia. By disclosing personal information to us, you acknowledge and consent to these potential transfers.

How do we hold your personal information and keep it secure?

We hold your personal information in a combination of electronic and hard copy files. We may store your personal information with third party data storage providers.

We take all reasonable steps to ensure that the personal information we hold is protected from misuse, interference and loss, and unauthorised access, modification or disclosure by the use of various methods, including secure physical and technological storage. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. Where we provide your personal information to third party service providers, we require them to keep it secure in accordance with relevant data privacy laws and only use or disclose it for the purpose for which it was provided.

Please contact us immediately if you become aware or have reason to believe there has been any unauthorised use of your personal information that we hold.

Your rights and who to contact

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

• fair processing of information and transparency over how we use your use personal information
• access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address
• require us to correct any mistakes in your information which we hold
• require the erasure of personal information concerning you in certain situations
• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
• object at any time to processing of personal information concerning you for direct marketing
• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
• object in certain other situations to our continued processing of your personal information
• otherwise restrict our processing of your personal information in certain circumstances
• claim compensation for damages caused by our breach of any data protection laws

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

Please contact us via one of the following if you would like to exercise any of the above rights:

• Mail: "Attention: Online Privacy", Zero Proof Australia Pty Ltd, 12 Upward Street, Leichhardt, Sydney, NSW 2040
• email: hello@lyres.co

We will ask that you put your request for access in writing and provide us with proof of your identity.

How can you access further information or complain about a breach of your privacy?

If you believe that we have breached your privacy or have any questions in relation to this Privacy Policy, you can contact us via either the mailing address or email listed above.

We will investigate any complaint, and notify you of our decision in relation to the complaint, as soon as practicable after it is received. If we are unable to satisfactorily resolve your concerns about our handling of your personal information, you can contact the ICO at the following: https://ico.org.uk/concerns/ or telephone: 0303 123 1113.

Changes to this website privacy policy

This website privacy policy was published on 11/12/2019 and last updated on 11/12/2019.

Please read this cookie policy carefully as it contains important information on who we are and how we use cookies on our website. This policy should be read together with our www.lyres.com.au/privacy-policy which sets out how and why we collect, store, use and share personal information generally, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a complaint.

Who we are

This website is operated by Zero Proof Australia Pty Ltd (ABN 97 630 554 853) herein referred to as Lyre’s and its group companies (“Lyre’s”, “we”, “us”, “our”).

Our website

This cookie policy only relates to your use of our website, www.lyres.com.au

Cookies

A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of your internet service provider. This information helps us to better understand our customers and provide a better website user experience. Some of this data may be aggregated or statistical, which means that we will not be able to identify you individually.

For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below.

For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

Consent to use cookies and changing settings

We will ask for your permission (Consent) to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (e.g. to enable you to put items in your shopping basket and use our check-out process).

You can withdraw any consent to the use of cookies or manage any other cookie preferences by using your browser privacy dashboard. Visit google support here on how to disable https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en It may be necessary to refresh the page for the updated settings to take effect.

Our use of cookies

The table below provides more information about the cookies we use and why:

The cookies we use	Name	Purpose	Whether cookie is essential for us to provide you with a service that you have requested and whether we will seek your consent before we place the cookie
Checkout cookie	checkoutObj	This cookie will store the checkout cart and product name and bring it to the order-confirmation page. It will last for 7 days, but will be cleaned when the user makes another purchase	Yes, essential (we will therefore not request your consent before placing this cookie)
Shopping cart cookie	purchaseTime	Stores the purchase time when a user places an order, and carries it to the order-confirmation page. It will be stored for 7 days, but will be overridden when the user places another order.	Yes, essential (we will therefore not request your consent before placing this cookie)
Geo control cookie	popupCookie	Used to control the geo popup. When a user clicks the close button, it will be stored as a session cookie, and cleared when the browser is closed. When a user clicks either the ‘stay in Australia’ or ‘not in Australia’ button, it will be stored for 7 days. The only value for this cookie will be ‘closed’. Every time a user goes to any page (except the blog page), we will read the cookie and if the value is not closed, we will run the geo IP address check, and display the popup accordingly.	Yes, essential (we will therefore not request your consent before placing this cookie)

 

In addition to the above, we sometimes use a type of technology called a “pixel tag” on our websites or in our emails, alone or in combination with cookies. Pixel tags may be used to provide us and third parties who provide services to us with information about customer activity on our websites and/or when emails that we send are opened or accessed.

Your visits to our website may also be associated with location-based information: (i) you manually provide, (ii) derived from the IP address of your computer, (iii) where you have accessed our website from your mobile device, GPS information where that has been enabled on your device, or (iv) the proximity of your laptop computer, mobile wireless device, personal digital assistant, personal communication system, or other communications device (your "Personal Communication Device”) to the nearest radio tower or cell site. This information includes when your Personal Communication Device is activated as well as when and how you are using it. We may collect such data to verify the information you provide to us manually and to provide you with location based content. We may also associate it with your existing personal information solely for our internal use in order to improve your experience with us.

 

Third party access to the cookies

The cookies we use will only be accessed by us and those third parties named in the table above for the purposes referred to in this cookie policy. Those cookies will not be accessed by any other third party not named above.

How to turn off all cookies and consequences of doing so

If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.

For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

How to contact us

Please contact our Data Protection Officer if you have any questions about this cookie policy or the information we hold about you.

If you wish to contact our Data Protection Officer, please send an email to hello@lyres.com.au, write to Lyre’s Head Office 12 Upward Street, Leichhardt NSW 2040 or call +61 2 8030 5552.

Changes to this cookie policy

This policy was published on 11/12/2019 and last updated on 11/12/2019

We may change this policy from time to time, when we do we will keep you informed by updating all terms, statements, policies on our website.