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- PERTH OFFICE
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33 Tacoma Circuit, Canning Vale, WA 6155
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(08) 6323 5860
Privacy Policy
1 OUR PRIVACY POLICY
1.1 This Privacy Policy is issued on behalf of OSW Holding B.V., and its subsidiaries OSW Netherlands B.V., OSW Spółka Z Ograniczoną Odpowiedzialnością, One Stop Warehouse UK Limited, OSW Germany GmbH, OSW Italy S.r.l., OSW France SAS, OSW Sweden AB, OSW Operations Spain SL, hereafter (“OSW”, “we”, “us”, or “our”)
When we refer to OSW, we, us, or our, we are referring to the relevant entity within One Stop Warehouse which will be the controller for your data in the applicable circumstances, for example because you have entered into an agreement with the relevant entity.
1.2 We are committed to protecting and respecting your privacy and personal data and will only collect and use personal data in ways that are described here and ways that are consistent with our obligations and your rights under applicable law relating to the protection of personal data.
1.3 This Privacy Policy aims to give you information about how we collect and process your personal data when you use our products or services (including, but not limited to, the promotion, sourcing, ordering and provision of our products, solutions and supporting services) and/or when you visit our websites (including subdomains of our websites) through which we make our products and services available (“Platform”). Our Platform includes the following websites:
(b) https://www.greendeal.com.au/;
(f) https://osw.energy/fr/; and
1.4 This Privacy Policy would apply regardless of where you visit our Platform from and would apply to any data that you may provide through our Platform, when you use our products or services, or when you otherwise interact with us.
1.5 Our Platform, products and services are not directed at any person under the age of 18 years old. If you are under the age of 18, you must not use our Platform. Our Platform is not intended for children, and we do not knowingly collect data relating to children.
1.6 Please read this Privacy Policy carefully and ensure that you understand it. By using our Platform, products, or services, you agree to be bound by this Privacy Policy and consent to the collection, use, processing, and disclosure of your personal data as described in this Privacy Policy.
1.7 It is important you read this Privacy Policy together with any other Privacy Policy we may provide from time to time when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them.
1.8 References to “you” or “your” are to you as an individual using our Platform, products, or services, or otherwise contacting us (whether on behalf of yourself, or another individual or organisation).
2 WHO WE ARE AND HOW TO CONTACT US
2.1 This Platform is operated by One Stop Warehouse Pty Ltd, who acts as processor on behalf of the OSW entity you have entered or will enter into a contract with.
2.2 We are bound by applicable data protection laws in respect of the handling and collection of your personal data.
2.3 If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our Data Protection Officer at privacy.eu@osw.energy.
2.4 We have also appointed European representatives who can be contacted at:
| Email address: | privacy.eu@osw.energy |
3 WHAT PERSONAL DATA WE COLLECT ABOUT YOU
3.1 Personal data or personal information means any information about you that enables you to be identified personally.
3.2 Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data and other online identifiers that can be linked with such information in order to identify you. It does not include data where the identity has been removed (anonymous data).
3.3 Depending on the use you make of our products, services, or Platform, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(a) Identity Data includes your name, username or similar identifier, and gender.
(b) Contact Data includes residential address, billing address, email address for primary and secondary contacts, and telephone numbers.
(c) Financial Data includes bank account and payment card details, including credit card number and expiry date and security code (CVC).
(d) Transaction Data includes details about payments made to and from you in connection with our products, services, or Platform.
(e) Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Platform.
(f) Profile Data includes data about your interests, preferences, feedback, and survey responses.
(g) Usage Data includes information about how you use our Platform, products, or services.
(h) Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences (including in relation to our third parties).
3.4 Special Category Data includes information about your race or ethnicity, health, hobbies, religious or political beliefs, sex life, sexual orientation, political opinions, trade union membership, and genetic and biometric data. We do not ask you for any Special Category Data about yourself, nor do we ask you for any information criminal convictions and offences. However, if you choose to provide us with such types of personal data when you interact with us, you are giving us your explicit consent to process such data about you to the extent permitted by the UK/EU data protection regime (as applicable).
3.5 We may also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law and will not directly or indirectly reveal your identity. For example, we may aggregate your usage information to calculate the percentage of users accessing a specific feature of our Platform. However, if we combine Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
4 IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, or pursuant to a service that we have been asked to supply to you, and you fail to provide that data when requested, we may not be able to perform the applicable contract or deliver the applicable product/service. In this case, we may have to cancel any arrangement you have with us, but we will notify you if this is the case.
5 HOW WE COLLECT YOUR PERSONAL DATA
5.1 We use different methods to collect data from and about you, including through:
(a) Direct interactions. You may give us your personal data by entering information on our Platform, registering for an account on our Platform, placing an order for products or services with us, filling in forms or questionnaires, subscribing to our communications, by corresponding with us by phone or email, or by otherwise directly interacting with us.
(b) Automated technologies or interactions. As you interact with our Platform, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. Please see our Cookie Policies for further details.
(c) Third parties. We may receive personal data about you from various third parties, such as the partners we work with from time to time in relation to the running and operating of our Platform and the provision of our products or services. For example:
(i) We may receive Technical Data from advertising networks, search information providers, and analytics providers.
(ii) We may receive Contact, Financial and Transaction Data from technical and payment processing service providers we work with, including (but not limited to): Service Job platform, Green Bid, Solar Panel Validation and brand partners integrated on our Platform.
(iii) We may receive customer service data in connection with our IT services being provided in conjunction with our services.
(d) Publicly available sources. We may receive personal data about you from public sources including but not limited to publicly available social media accounts, Companies House, and law enforcement or government entities in any applicable jurisdiction.
6 PURPOSES FOR PROCESSING PERSONAL DATA
6.1 We will only use and process your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
(a) Where we need to provide product/services or information to you or to perform the contract we are about to enter or have entered with you.
(b) Where we have a legal or regulatory obligation we must comply with.
(c) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
6.2 We generally do not rely on consent as a legal basis for processing your personal data, save for third party direct marketing communications (see clause 7) and processing of Special Category Data provided by you (see clause 3.4).
6.3 We have set out below a description of the ways in which we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful base depending on the specific purpose for which we are using your personal data.
| Types of personal data | What we use your personal data for | Our reasons (legal bases) |
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To register you as a customer/user, create your account on our Platform, and communicate with you pursuant to your booking of a demonstration of any of our products/services |
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To provide and manage your access to our Platform, products, and services, including managing our relationship with you (such as notifying you about changes to our terms or privacy policy, or asking you to leave a review or take a survey) |
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To process your credit application, including to review your credit records and credit score. |
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To personalise and tailor your experience on our Platform (including making suggestions and recommendations to you about the products/services that may be of interest to you based on your purchases and activity), and to measure and understand the effectiveness of any advertising we serve to you |
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To process and deliver your orders for our products or services, including managing the payments fees, processing payments or debit payments for fees, and collecting/recovering money owed to us. |
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To administer and protect our Platform and business (including troubleshooting, data analysis, testing, system maintenance, validating against fraudulent transactions, support, reporting and hosting of data) |
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To be as responsive as possible to you, for example, when answering your queries. |
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To supply you with information by email, post, or other means that you have requested to receive or otherwise have opted-in to receive |
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To use data analytics to improve our Platform, marketing, products/services, and user relationships and experiences |
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To evidence our claims or charges where there is a dispute |
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6.4 We will only use and process your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
6.5 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7 MARKETING
7.1 We may send you marketing communications by email, text message, telephone, or otherwise via the Platform. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
7.2 We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which of our business offerings may be relevant to you.
7.3 We will get in your express opt-in consent before we share personal data with any third party for marketing purposes.
7.4 Opting out of marketing:
(a) You can ask us or third parties to stop sending you marketing messages at any time.
(b) Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
(c) If you choose to object to the communications, unsubscribe or withdraw your consent, this will not make our processing of your personal data before you withdrew your consent unlawful.
8 AUTOMATED DECISION MAKING
Automated decisions are made by technological means, mostly based on algorithms subject to predefined criteria. Such automated decision-making, taken solely by technological means without any human intervention, may have legal effects or similarly significant effects on you. We do not make such automated decisions.
9 HOW WE MAY SHARE YOUR PERSONAL DATA
9.1 We may share your personal data with certain parties as set out below:
(a) External third parties such as:
(i) Professional advisors including lawyers, bankers, auditors, and insurers.
(ii) HM Revenue & Customs and other regulators and authorities, whether in the UK, EU, US, Australia, or any other applicable jurisdiction.
(iii) Service providers whom we work with in connection with the running of our business and our providing the Platform, products, or services.
(iv) In case you apply for commercial credit through our credit application form, we will share your information with our credit insurance service provider NCI and/or Atradius as applicable. NCI and/or Atradius acts as independent data controller. Please visit the websites of NCI and Atradius for more information on the processing activities of NCI and Atradius respectively regarding credit checks and credit insurance - NCI: https://www.nci.com.au/ and Atradius https://atradius.com.au/.
(b) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
9.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
9.3 International transfers. Whenever we transfer your personal data out of the UK and/or EEA, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
(b) If we transfer your personal data to any other country which is not subject to an adequacy decision of the UK or the European Commission (as applicable) regarding an adequate level of protection of personal data, we will ensure that there is a legal basis and, if required, a relevant safeguard method for such data transfer so that your personal data are treated in a manner that is consistent with, and respects the applicable laws and regulations on data protection in the UK or the EEA (as applicable).
(c) Where we use certain service providers outside of the UK and/or the EEA (as applicable), we may use specific contracts approved for use in the UK and/or the EEA (as applicable) which give personal data the same protection it has in the UK and/or the EEA (as applicable).
10 DATA SECURITY
10.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.
10.2 In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
10.3 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
11 HOW WE WILL RETAIN YOUR PERSONAL DATA
11.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of providing our products/services to you and satisfying any legal, regulatory, tax, accounting or reporting requirements.
11.2 We may retain your personal data for a longer period in the event of a complaint of if we reasonably believe there is prospect of litigation in respect of our relationship with you.
11.3 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purpose for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
11.4 In some circumstances you can ask us to delete your data (see your legal rights below).
11.5 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
11.6 Otherwise, we securely erase or anonymise your personal data where we no longer require your information for the purposes collected.
12 YOUR LEGAL RIGHTS
12.1 Under UK/EU data protection laws (as applicable), you have a number of rights (subject to certain conditions) when it comes to your personal data. Your legal rights include:
(a) Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(i) if you want us to establish the data’s accuracy;
(ii) where our use of the data is unlawful but you do not want us to erase it;
(iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
(f) Request the transfer of your personal data to you or to a third party. We will provide you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use, or where we used the information to perform a contract with you.
(g) Withdraw consent at any time where we are relying on consent to process your personal data. However, your withdrawing of consent will not affect the lawfulness of any processing carried out before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
12.2 If you want to exercise any of the rights set out above or have any questions on them, please contact us. We usually act on requests and provide information free of charge but may charge a reasonable fee to cover our administrative costs of providing the information for baseless or excessive/repeated requests or further copies of the same information.
12.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
12.4 We may also be entitled under some circumstances to refuse to act on the request and will notify you if this is the case.
12.5 We try to respond to all legitimate requests as soon as we can. Generally, this will be within 4 weeks from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.
12.6 You also have the right to lodge a complaint about the way we handle or process your personal data with the ICO, the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with concerns before you approach the ICO, so please contact us in the first instance.
12.7 If you are a data subject in the EU/EEA, you should contact the relevant supervisory authority in your territory. A list of the supervisory authorities across the EEA can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en.
13 THIRD PARTY LINKS
Our Platform may include links to third party websites, plug-ins, and applications. Clicking on third-party links or enabling third-party connections may allow third parties to collect or share data about you. Third-party sites are not under our control, and we are not responsible for its content. When you leave our Platform, we encourage you to read the privacy policy of every website you visit.
14 CHANGES TO THIS PRIVACY POLICY
14.1 We keep this Privacy Policy under regular review and may update it from time to time. We reserve the right to make amendments to our Privacy Policy at any time. Historic versions can be obtained by contacting us.
14.2 Any changes we may make to this Privacy Policy will be posted on our Platform and, where appropriate, notified to you.
14.3 Unless otherwise provided in this Privacy Policy, it is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This Policy was last updated on 28 November 2023.
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