Privacy policy

Vanessa Megan Holdings Pty Ltd ACN 671 628 327
We, Vanessa Megan Holdings Pty Ltd ACN 671 628 327 (Vanessa Megan Holdings or we) respect your right to privacy. We are committed to safeguarding the privacy of our customers and website and social media visitors. This policy sets out how we collect and treat your personal information.

This privacy policy applies to personal information or data collected in Australia and internationally including from people in the European Union and the United States. This policy also includes our anti-spam notice and our copyright notice.  You consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.

This policy explains how we collect and process personal information when you purchase our products and services, personal information you submit to our websites and social media, or provide to us directly, or give to us in other forms, or when you otherwise contact us by visiting websites and social media owned, hosted, or operated by Vanessa Megan Holdings including www.vanessamegan.com, www.metamorphosisskincare.com, biode.com and any other site that we have owned or operated, do own and operate or may own or operate in the future, and including social media sites (each a “Site”, collectively, the “Sites”).

What is personal information?
"Personal information" is information we hold which is identifiable as being about you. This includes information such as your name, email address, phone number, address, identification number, or any other type of information that can reasonably identify an individual, either directly or indirectly. 

We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.

Australian privacy policy
We comply with the Australian Privacy Act (Cth) as it applies to Vanessa Megan Holdings.

What personal information do we collect and hold? 
We collect information about you and your interactions with us, for example, when you register to purchase our products, purchase or use any of our products, subscribe to our newsletters, respond to a survey or offer, make an enquiry through our Sites, call us or otherwise visit our Sites. The information we collect from you may include your identity and contact details, your history of purchases and use of our products and services and details of enquiries or complaints you make, including:

(a) Name, email, address, phone number
(b) Job title, organisation information
(c) Usernames and passwords
(d) Transaction data for products and services you have purchased from us
(e) Demographic information such as postcode, preferences and interests
(f) IP address and your use of our sites
(g) Copies of your communications with us
(h) Billing details. Payment card details are processed and stored via third party service providers. We encrypt your payment card details in your browser and securely transfer this data to our relevant third party payment provider to process a payment.

We may also collect information about how you access, use and interact with the sites including:

(a) the location from which you have come to the site and the pages you have visited; and
(b) technical data, which may include IP address, the types of devices you are using to access the Sites, device attributes, browser type, language and operating system.

Cookies
We use cookies on the Sites. A cookie is a small text file that the Sites may place on your device to store information. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our Sites for any of your future visits to the Sites. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the Sites. You may refuse to use cookies by selecting the appropriate settings on your browser. Please note that if you do this, you may not be able to use the full functionality of the Sites.

Why do we collect, hold and use your personal information?
We collect, hold and use your personal information so that we can:
(a) provide you with products and services, and manage our relationship with you;
(b) contact you including to respond to your queries or complaints;
(c) comply with our legal obligations and assist government and law enforcement agencies or regulators; or
(d) identify and tell you about other products or services we think may be of interest to you.

If you do not provide us with your personal information, we may not be able to provide you with our services, communicate with you or respond to your enquiries.

How do we collect your personal information?
We will collect your personal information directly from you whenever you interact with us. We may collect information from third parties such as using Google Analytics.

How do we use the information we collect?
The personal information we collect from you may be used in one or more of the following ways to help us understand your needs and provide you with a better service:

(a) To deal with purchases, enquiries, requests and support
(b) To create and administer records about any online account that you register with us(c) To improve our Sites
(d) For Sites and system administration and security
(e) To process transactions and to provide products to our customers and end-users
(f) For recruitment purposes, in the event you apply for a job with us
(g) To administer contests, promotions, surveys, or other content across our sites
(h) To send periodic transactional emails. The email address you provide to process your order and purchase a product will only be used to send you information and updates pertaining to your order.

Where it is in accordance with your marketing preferences, we will send occasional marketing emails about our products and services, which you can unsubscribe from at any time using the link provided in the message.

(i) For general business purposes including to improve customer service, respond to your customer service requests and support needs, to help us improve the content and functionality of our Sites, to better understand our users, to protect against wrongdoing, and to manage our business.

How do we store personal information?
We store most information about you in computer systems and databases operated by us or our external service providers. Some information about you is recorded in paper files that we store securely.

We implement and maintain processes and security measures to protect personal information we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.

We also take reasonable steps to destroy or de-identify personal information once we no longer require it for the purposes for which it was collected or for any secondary purpose permitted under the APPs.

Who do we disclose your personal information to and why? 
We may transfer or disclose your personal information to our related companies. We may disclose personal information to external service providers so that they may perform services for us or on our behalf.

We may also disclose your personal information to others where we are required or authorised by law to do so, you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances, or we are otherwise permitted to disclose the information under the Privacy Act.

If the ownership or control of all or part of our business changes, we may transfer your personal information to the new owner.

Your rights including access to and correction of your personal information
You may access or request correction of the personal information that we hold about you by contacting us. Our contact details are set out below. There are some circumstances in which we are not required to give you access to your personal information.

You have the following rights under this privacy policy:

(a) Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of our Sites or the products and/or services offered on or through it.

(b) Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

(c) Restrict: If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

(d) Access: you may request details of the personal information that we hold about you.  An administrative fee may be payable for the provision of such information.

(e) Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

(f) Complaints: If you wish to make a complaint about how we have handled your personal information, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.

(g) Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication

There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material)

You can contact us at any time by emailing us at info@vanessamegan.comand we’ll be able to assist with your data inquiries, requests and data protection issues. We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up to date, complete, relevant and not misleading.

Do we use your personal information for marketing?
We will use your personal information to offer you products and services we believe may interest you, but we will not do so if you tell us not to. Where you receive electronic marketing communications from us, you may opt out of receiving further marketing communications by following the opt-out instructions provided in the communication.

We do not sell or trade your personal information to third parties. Where we disclose your personal information to third parties, we will request that the third party handle your personal information in accordance with this privacy policy. You acknowledge that some overseas third parties may not be regulated by the laws that we comply with.

Security
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Data Retention
We may retain your personal information as long as you continue to use the Sites, have an account with us, or for as long as is necessary to fulfill the purposes outlined in the policy. You can ask to close your account by contacting us at the details at the bottom of this document, and we will delete your personal information on request. We may, however, retain personal information for an additional period as is permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.

Links to other Sites
Our Sites may contain links to other websites of interest. However, once you have used these links to leave our sites, you should note that we do not have any control over other websites. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. Please exercise caution and look at the privacy statement applicable to the website in question.

European Union - GDPR Privacy Notice
This privacy policy sets out our commitment to protecting the privacy of Personal Data provided to us, or otherwise collected by us, offline or online, including through the Sites, in compliance with the EU General Data Protection Regulation.
Capitalized words have the following defined meanings. The following definitions have the same meaning regardless of whether they appear in singular or in plural.

Definitions
For the purposes of this GDRP Privacy Notice:

• Account means a unique account created for you to access our Service or parts of our Service.
• Company (referred to as either Vanessa Megan Holdings, We, us or our in this Agreement) refers to Vanessa Megan Holdings Pty Ltd.
• Cookies are small files that are placed on your computer, mobile device or any other device by a Sites, containing the details of your browsing history on that Sites among its many uses.
• Country refers to New South Wales, Australia
• Device means any device that can access the Service such as a computer, a mobile phone or a digital tablet.
• Personal Data is any information that relates to an identified or identifiable individual.
• Service refers to the Sites.
• Service Provider means any natural or legal person who processes the data on behalf of Vanessa Megan Holdings. It refers to third-party companies or individuals employed by Vanessa Megan Holdings to facilitate the Service, to provide the Service on behalf of Vanessa Megan Holdings, to perform services related to the Service or to assist Vanessa Megan Holdings in analyzing how the Service is used.
• Third-party Social Media Service refers to any websites or any social network sites through which a User can log in or create an account to use the Sites.
• Usage Data refers to data collected automatically, either generated by the use of the Site or from the infrastructure itself.
• You means the individual accessing or using the Sites, or the company, or other legal entity on behalf of which such individual is accessing or using the Sites as applicable.

Personal Data
While using our Sites, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Usage Data

What Personal Data is collected?
Please see the section titled “What personal information do we collect and hold? ” above.

How is Personal Data used?
Please see the section headed “Who do we disclose your personal information to and why” above.

Disclosure of your Personal Data
Please see the section headed “Who do we disclose your personal information to and why” above.

Information from Third-Party Social Media Services
Vanessa Megan Holdings may allow you to create an account and log in to use the Sites through following Third-party Social Media Services.

If you decide to register through or otherwise grant us access to a Third-Party Social Media Service, we may collect Personal data that is already associated with your Third-Party Social Media Service's account, such as your name, your email address, your activities or your contact list associated with that account.

You may also have the option of sharing additional information with Vanessa Megan Holdings through your Third-Party Social Media Service's account. If you choose to provide such information and Personal Data, during registration or otherwise, you are giving Vanessa Megan Holdings permission to use, share, and store it in a manner consistent with this privacy policy. 

Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on our Sites and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse our Sites. For more information please see the section titled “Cookies” above.
Your rights under the EU GDPR
Under the European Union (EU) General Data Protection Regulation (GDPR), as a data subject you have the right to:
(a) access your data;
(b) have your data deleted or corrected where it is inaccurate;
(c) object to your data being processed and to restrict processing;
(d) withdraw consent to having your data processed;
(e) have your data provided in a standard format so that it can be transferred elsewhere; and
(f) not be subject to a decision based solely on automated processing.

Data Subject Rights
We have processes in place to deal with Data Subject Rights requests. Our actions and responsibilities will depend on whether we are the controller or processer of the personal data at issue. Depending on our role as either a controller or processor, the process for enabling Data Subject Rights may differ, and are always subject to applicable law. Please refer to the Contact Details section of this policy if you would like to make a Data Subject Rights request.

Retention of your Personal Data
Vanessa Megan Holdings will retain your Personal Data only for as long as is necessary for the purposes set out in this privacy policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Vanessa Megan Holdings will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Sites, or we are legally obligated to retain this data for longer time periods.

Security of your Personal Data
The security of your Personal Data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

United State privacy policy
This privacy policy sets out our commitment to protecting the privacy of Personally Identifiable Information provided to us, or otherwise collected by us, offline or online, including through the Site. This privacy policy applies to users of the Site who visit without transacting business (Visitors) and users who make use of the various services offered by Vanessa Megan Holdings (Customers).

Personally Identifiable Information 
Personally Identifiable Information refers to any information that identifies or can be used to identify, contact, or locate the person to whom such information pertains, including, but not limited to, name, address, phone number, fax number, email address, financial profiles, social security number, and credit card information. Personally Identifiable Information does not include information that is collected anonymously (that is, without identification of the individual user) or demographic information not connected to an identified individual

What Personally Identifiable Information is collected?
Please see the section titled “What personal information do we collect and hold?” above.

How is Personally Identifiable Information used?
Please see the section headed “How do we use the information we collect?” above.

How is Personally Identifiable Information disclosed?
Please see the section headed “Who do we disclose your personal information to and why?” above.

How is Personally Identifiable Information stored and secured?
Personally Identifiable Information collected by Vanessa Megan Holdings is securely stored and is not accessible to third parties or employees of Vanessa Megan Holdings except for use as indicated above.

What choices are available to Visitors regarding collection, use and distribution of the information?
Visitors and Customers may opt out of receiving unsolicited information from or being contacted by us and/or our vendors and affiliated agencies by responding to emails as instructed, or by contacting us using the details at the end of this privacy policy.

What partners or service providers have access to Personally Identifiable Information from Visitors and/or Customers on the Site?
Vanessa Megan Holdings has entered into and will continue to enter into partnerships and other affiliations with a number of vendors. Such vendors may have access to certain Personally Identifiable Information on a need to know basis for evaluating Customers for service eligibility. Our privacy policy does not cover their collection or use of this information

How does the Site keep Personally Identifiable Information secure?
Our employees are familiar with our security policy and practices. The Personally Identifiable Information of our Visitors and Customers is only accessible to a limited number of qualified employees who are given a password in order to gain access to the information. We audit our security systems and processes on a regular basis. Sensitive information, such as credit card numbers or social security numbers, is protected by encryption protocols, in place to protect information sent over the Internet. While we take commercially reasonable measures to maintain a secure Site, electronic communications and databases are subject to errors, tampering and break-ins, and we cannot guarantee or warrant that such events will not take place and we will not be liable to Visitors or Customers for any such occurrences.

How can Visitors correct any inaccuracies in Personally Identifiable Information?
Visitors and Customers may contact us to update Personally Identifiable Information about them or to correct any inaccuracies by emailing us at info@vanessamegan.com 

Can a Visitor delete or deactivate Personally Identifiable Information collected by the Site?
We provide Visitors and Customers with a mechanism to delete/deactivate Personally Identifiable Information from the Site’s database by contacting info@vanessamegan.com

However, because of backups and records of deletions, it may be impossible to delete a Visitor’s entry without retaining some residual information. An individual who requests to have Personally Identifiable Information deactivated will have this information functionally deleted, and we will not sell, transfer, or use Personally Identifiable Information relating to that individual in any way moving forward.

What happens if the privacy policy Changes?
We will let our Visitors and Customers know about changes to our privacy policy by posting such changes on the Sites. 

Links
The Sites contain links to other websites. Please note that when you click on one of these links, you are moving to another Sites. We encourage you to read the privacy statements of these linked websites as their privacy policies may differ from ours.

Children's Privacy Notice
We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we take steps to remove that information from our servers. If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, we may require your parent's consent before we collect and use that information

Complaints 
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.

We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.

Changes to this policy 
From time to time, we may change our policy on how we handle personal information or the types of personal information which we hold. Any changes to our policy will be published on our website. You may obtain a copy of our current policy from our Sites or by contacting us at the contact details below.

Contact Information
Vanessa Megan Holdings Pty Ltd ACN 671 628 327
2A Shepherd Street
Marrickville, New South Wales, 2204

Anti-Spam Policy Notice
This sets out our policy with regard to the use of spam marketing techniques in connection with internet marketing. In the event that we deem you to be in violation of these policies, we shall immediately revoke your rights and close any active account. We have a strict policy against spamming. We do not send unsolicited mass emails or unsolicited emails of any kind in connection with the marketing of our programs, products and services. We reserve the right to terminate your account and participation in our programs “for cause” if we deem you to be in violation of our anti-spamming policies. We also reserve the right to suspend your account and participation pending review upon receipt of any complaint or other evidence that you may be engaging in any spamming activity. We consider spamming to be any activity whereby you directly or indirectly transmit email messages to any email address that has not solicited such email and does not consent to such transmission. If you are spammed by anyone regarding our products, services, Sites, or any other matters, please report this activity to Vanessa Megan Holdings.

Copyright Notice
You acknowledge that the Sites contain information and/ or software, photographs, audio and video clips, graphics, links and other material that are protected by copyright, trademark or other proprietary rights of Vanessa Megan Holdings or third parties, including but not limited to product names, logos, designs, titles, and words or phrases which may be registered in certain jurisdictions (collectively, the Content). You agree to comply with any additional copyright notices, information, or restrictions contained in any Content available on or accessed through. If you want to use any content of for any reason you must obtain prior express written permission of Vanessa Megan Holdings.

You may not modify, publish, transmit, transfer or sell, reproduce, create derivative works from, distribute, perform, display, or in any way exploit any of the content, in whole or in part. Content consisting of downloadable software may not be reverse-engineered unless specifically authorized by Vanessa Megan Holdings or the owner of the software’s patent and or copyright. Subject to the provisions of this Copyright Notice, you may post on content owned by you (such as your original statements), content for which you have received express permission from Vanessa Megan Holdings, and content in the public domain. You assume all right and responsibility for determining whether any content is in the public domain. You grant to Vanessa Megan Holdings the right to edit, copy, publish, distribute, translate and otherwise use in any medium and for any purpose any content that you place on without compensation to you. You represent and warrant that you are authorized to grant all rights set forth in the preceding sentence.

You may not download content that is indicated to be for sale except under the terms of the sale. Such content is the protected and copyrightable property of Vanessa Megan Holdings. Free content may be downloaded for your personal use or non-commercial distribution consistent with the terms in this Copyright Notice. When using both purchased and free content, you will maintain and include all copyright and other notices contained in such content. Except as expressly permitted by the copyright laws, no copying, storage, redistribution or publication of any content is permitted without the express permission of Vanessa Megan Holdings or the owners of such content or their authorized persons other than Vanessa Megan Holdings.

Publications, products, content or services referenced herein or on the Site are the exclusive trademarks of Vanessa Megan Holdings. Other product and company names mentioned in the Site may be the trademarks of their respective owners.