PRIVACY POLICY

This Privacy Policy sets out the approach which cylk will take in relation to the treatment of Personal Information. It includes information on how cylk collects, uses, discloses and keeps secure, individuals' Personal Information. It also covers how cylk makes the Personal Information it holds available for access to and correction by the individual.

This policy has been drafted having regard to cylk's obligations under the Privacy Act 1988 (including the new National Privacy Principles) (the Privacy Act).
This Policy is a public document and has been prepared in light of National Privacy Principle 5, Opennes.

1. COLLECTION

1.1 cylk will only collect Personal Information where the information is necessary for cylk to perform one or more of its functions or activities. In this context, "collect" means gather, acquire or obtain by any means, information in circumstances where the individual is identifiable or identified.
1.2 cylk collects Personal Information primarily to supply customers with the products and services ordered from it and its related companies. cylk also collects and uses Personal Information for secondary purposes including:
i. billing and account management
ii. business planning and product development; and
iii. to provide individuals with information about promotions, as well as the products and services of cylk affiliated companies and other organisations.
iv. to enhance the online shopping experience by displaying products and/or services that match the personal preferences of individuals based on their previous website browsing history and/or buying activity.
1.3 cylk will not collect Sensitive Information from individuals except with consent and only where it is necessary for cylk to collect such information for an activity or function.
1.4  cylk will not collect Personal Information secretly or in an underhanded way.
1.5 cylk will take steps to ensure that individuals on purchased lists are or have been notified of the information as outlined at 1.3.

2. USE

2.1 cylk will obtain an individual's consent for Use of non-sensitive Personal Information for Secondary Purposes at the time of collection, unless the Use is a related Secondary Purpose which would be within the relevant individual's Reasonable Expectations.
2.2 cylk uses personal information primarily for the purposes listed in 1.2 above.
2.3 If cylk relies on the Direct Marketing exception to Direct Market to individuals it will ensure that:
i. the individual is clearly notified of their right to Opt Out from further Direct Marketing;
ii. there is only one Use of the information before the Opt Out right is given and this Use applies across all cylk Related Bodies Corporate (if the information is shared between those Related Bodies Corporate);
iii. the individual is given an Opt Out in all further instances of Direct Marketing if they have not previously chosen to Opt Out; and
iv. if the individual Opts Out of all Direct Marketing the Opt Out will be respected by cylk and all its Related Bodies Corporate.
2.4 cylk will not use Sensitive Information for Direct Marketing.
2.5 cylk may use Personal Information to avoid an imminent threat to a person's life or to public safety. It may also use Personal Information for reasons related to law enforcement or internal investigations into unlawful activities.
2.6 cylk will not use Personal Information without taking reasonable steps to ensure that the information is accurate, complete and up to date.

3. DISCLOSURE

3.1 cylk may Disclose Personal Information to related or unrelated third parties if consent has been obtained from the individual. This will include obtaining the individual's consent for Disclosures made under the credit reporting requirements of the Privacy Act.
3.2 cylk may Disclose Personal Information between Related Bodies Corporate. Where information is Disclosed to such a Related Body Corporate, that Related Body Corporate is bound by the original Primary Purpose for which the information was collected.
3.3 cylk may Disclose Personal Information to unrelated third parties to enable outsourcing of functions (such as billing, customer relations management and order fulfillment), where that is Disclosure or Use for a related Secondary Purpose and has been notified to individuals or where such Disclosure is within the individual's Reasonable Expectations.
3.4 cylk will take reasonable steps to ensure that its contracts with third parties include requirements for third parties to comply with the Use and Disclosure requirements of the Privacy Act.
3.5 cylk may Disclose Personal Information to law enforcement agencies, government agencies, courts or external advisers where permitted or required by law.
3.6 cylk may Disclose Personal Information to avoid an imminent threat to a person's life or to public safety.
3.7 If a Disclosure is not for a Primary Purpose; is not for a related Secondary Purpose; or upfront consent has not been obtained, cylk will not Disclose Personal Information otherwise than in accordance with the exceptions set out at 3.1 to 3.6 above.
3.8 cylk does not generally sell or share its customer lists on a commercial basis with third parties but if it did, it would only do so if we had the appropriate consent of the individual involved. If the consent provided is conditional, cylk will take steps to ensure (by contract) that the use of its customer list by third parties does not exceed the scope of the consent.

4. INFORMATION QUALITY

4.1 cylk will review, on a regular and ongoing basis, its collection and storage practices to ascertain how improvements to accuracy can be achieved.
4.2 cylk will take steps to destroy or de-identify Personal Information after as short a time as possible and after a maximum of seven years from the date of the last customer interaction, unless the law requires otherwise.

5. INFORMATION SECURITY

5.1 cylk requires employees and contractors to perform their duties in a manner that is consistent with cylk’s legal responsibilities in relation to privacy.
5.2 cylk will take all reasonable steps to ensure that paper and electronic records containing Personal Information are stored in facilities that are only accessible by people within cylk who have a genuine "need to know" as well as "right to know".
5.3 cylk will review, on a regular and ongoing basis, its information security practices to ascertain how ongoing responsibilities can be achieved and maintained.

6. ACCESS AND CORRECTION

6.1 cylk will allow its records containing Personal Information to be accessed by the individual concerned in accordance with the Privacy Act.
6.2 cylk will correct its records containing Personal Information as soon as practically possible, at the request of the individual concerned in accordance with the Privacy Act.
6.3 Individuals wishing to lodge a request to access and/or correct their Personal Information should do so by contacting cylk Customer Service, as per the details on the website.
6.4 cylk can charge a fee for processing an access request but will generally not do so unless the request is complex or is resource intensive.

7. OPENNESS

7.1 cylk Customer Service representatives will be the first point of contact for inquiries about privacy issues. Individuals wishing to make an inquiry or complaint regarding privacy, should do so by contacting cylk Customer Service, as per the details on the cylk website.
7.2 cylk websites will contain a prominently displayed privacy statement and will include a copy of cylk Privacy Policy.

8. ANONYMOUS TRANSACTIONS

8.1 cylk will not make it mandatory for visitors to its web sites to provide Personal Information unless such Personal Information is required to answer an inquiry or provide a service. cylk may however request visitors to provide Personal Information voluntarily to cylk (for example, as part of a competition or questionnaire).
9. TRANSFERRING PERSONAL INFORMATION OVERSEAS
9.1 cylk will take reasonable steps to limit the amount of Personal Information it sends to unrelated organisations overseas.
9.2 If Personal Information must be sent by cylk overseas for sound business reasons, cylk will require the overseas organisation receiving the information to provide a binding undertaking that it will handle that information in accordance with the National Privacy Principles, preferably as part of the services contract.

10. GLOSSARY

Collection Information means the information outlined in 1.3 notified to individuals prior to, or as soon as practical after, the collection of their Personal Information.

Direct Marketing means the marketing of goods or services through means of communication including written, verbal or electronic means. The goods or services which are marketed may be those of cylk or a Related Body Corporate or those of an independent third party organisation.

Disclosure generally means the release of information outside cylk, including under a contract to carry out an "outsourced function".

Opt Out means an individual's expressed request not to receive further Direct Marketing.

Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion.

Primary Purpose is the dominant or fundamental reason for information being collected in a particular transaction.

Reasonable Expectation means a reasonable individual's expectation that their personal information might be Used or Disclosed for the particular purpose.

Related Body Corporate means that where a body corporate is:

  • a holding company of another body corporate;
  • a subsidiary of another body corporate; or
  • a subsidiary of a holding company of another body corporate, the first mentioned body corporate and the other body corporate are deemed to be related to each other.

 

Sensitive Information means:

  • information or an opinion about an individual's:
    • racial or ethnic origin; or
    • political opinions; or
    • membership of a political association; or
    • religious beliefs or affiliations; or
    • philosophical beliefs; or
    • membership of a professional or trade association; or
    • membership of a trade union; or
    • sexual preferences or practices; or
    • criminal record;
  • Health Information about an individual.

Use means the handling of Personal Information within cylk.

 

Security Policy

The Internet is a hostile environment with global resources. As such, Cylk Pty Ltd, trading as cylk, maintains highly regulated security policies and procedures to all external and internal communications of cylk. All protocols use communication techniques that employ widely accepted error detection and/or recovery mechanisms. We have a secure connection that ensures that the information transmitted is safeguarded. We use Secure Socket Layer (SSL) encryption technology to encrypt the information sent from your computer to our computer so that nobody can decode it, intercept it or read it. This way we ensure your privacy is kept.

 

PAYMENT

Your personal online security is very important to us. To help ensure your shopping experience is safe, simple and secure we use eWAY Payment Gateway for online credit card transactions.

All online transactions performed on this site are secured payments. Payments are fully automated with an immediate response.  Your complete credit card number cannot be viewed by cylk or any outside party.  All transactions are performed under 128 Bit SSL Certificate.  All transaction data is encrypted for storage within eWAY’s bank-grade data centre, further protecting your credit card data.  eWAY is an authorised third party processor for all the major Australian banks.  eWAY at no time touches your funds; all monies are directly transferred from your credit card to the merchant account held by cylk.  To ensure your information is kept private, we do not process or store any payment information in our database.

The following payments are accepted.

Credit card

Visa, Mastercard, American Express (please check with your bank to ensure your card is valid for online purchases).  Visa and Mastercard are verified by a secure code.

Paypal

You can choose to pay with credit card or your already registered paypal account. 

Contacting cylk
If you require further information regarding cylk’s Privacy Policy, you can contact the cylk Client Services department at online@cylk.com.au or on +61 3 8415 6406.