Terms &

Privacy Policy

This privacy policy sets out how we, Asembl Brands Pty Ltd (ABN 48 611 160 797), treat the privacy of customers, users of our services and website, our suppliers, and others we interact with or about whom we obtain personal information.

We respect the privacy rights of individuals and are committed to protecting your privacy in accordance with the Australian privacy laws. This policy details how we collect, store, use and disclose personal information.

In this privacy policy, the term “personal information” has the meaning it has in the Privacy Act (1988)(Cth) and includes information (including opinions) about an identifiable individual, including names, addresses, telephone numbers, email addresses, dates of birth, signatures, credit card information, information about professional qualifications, and if and where applicable, includes information that constitutes “sensitive information” as defined under the Privacy Act.

1. Collection and Storage of Personal Information and Data

We collect some personal information about individuals.

The personal information we collect from or about you could include your name, email address, telephone number, address and other contact details, date of birth and age, details of your employer or other business you work for or represent, and credit and payment related information. In most circumstances we do not collect “sensitive information”.

We collect personal information in circumstances including the following:

  1. When you, as an individual in your own capacity or on behalf of your employer become a customer of our business;
  2. when you telephone us or visit our website and provide feedback, or you make an enquiry to which a later response is requested and to do so requires your contact details;
  3. through written correspondence from you, including letters and emails;
  4. when you ask to be included on marketing distribution lists, sign up to our website or interact with us on social media;
  5. when you otherwise register for or subscribe to one of our services;
  6. when our customer provides personal information about third parties with the consent of that individual to doing so;
  7. when you pay for goods/services using a credit card;
  8. when as a supplier, your contact and other details are provided;
  9. when we negotiate or enter into an agreement with you for the provision or acquisition of goods or services; and
  10. when we receive applications for employment and when evaluating job applicants and personnel, which may include collection of details such as employment history and educational qualifications.

We may use ‘cookies’ to collect data (not personal information) relating to your general internet usage. This data may include IP-addresses, browser versions, number of visits and similar such data relating to your navigation of the internet and our site. A cookie is a small text file that is placed on your computer or device’s hard drive. Cookies help us to improve our site and to deliver a better and more tailored service, for instance by storing information about your preferences and allowing us to recognise you when you return to our site.

You may refuse to accept cookies by activating settings on your internet browser.

We hold personal information in our own secure databases, and, to some extent, for marketing purposes in the database of our marketing platforms (subject to obligations regarding privacy and confidentiality) to conduct electronic direct marketing, in accordance with legislative requirements.

2. Use and disclosure of Personal Information

We use the personal information collected from you for the purpose it was provided or collected, including in the following ways:

  1. For the purposes of collection described in (1) above;
  2. To manage our relationship with you and perform our obligations under the agreement you conclude with us when purchasing services;
  3. To respond to enquiries received from you;
  4. To process, confirm, fulfil and update you about and to carry out our obligations arising from any contracts entered into between you and us;
  5. To perform authorised financial transactions with you;
  6. To provide services to you and to tailor possible service solutions to you, as a customer;
  7. To provide services to our customers who have provided personal information to us in their databases (having obtained rights to disclose to us in accordance with their privacy policies and practices) for the purposes of providing services to those customers. We do not purchase or otherwise use third party email marketing lists that have not been compiled by or on behalf of our customers;
  8. To verify your identity and to assist you if you have forgotten any user name or password;
  9. To communicate with you and provide you with information (whether by email, post or other means) about our goods or our services, where you have requested or consented to receiving this from us or where this provision is otherwise permitted at law;
  10. To notify you about changes to our provision of goods and services, or policies and agreements relating thereto;
  11. To tailor specific product offerings and marketing communications to you, based on your preferences and habits;
  12. To receive and address feedback from you;
  13. To protect our legal interests and fulfil our regulatory obligations (if and to the extent necessary) and
  14. in other circumstances, with your prior consent or where permitted by law.

We may also provide personal information to third parties outside our company for limited purposes, such as to help us in providing goods and services to customers. Those persons and business may include:

  1. Our online payment gateway service providers, for the purpose of facilitating payments;
  2. Third party software providers who store details of customer accounts for us or who provide other IT services;
  3. Third party contractors who perform some email and digital marketing functions for us, under an agreement governing the use and disclosure of personal information; and
  4. Our professional advisors, subject to confidentiality.

3. Other disclosures

We may also disclose your personal information to third parties outside our company:

  1. Where we have your express permission to do so;
  2. Where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties;
  3. If all or substantially all of our assets are acquired by a third party, in which case personal information which we hold about our customers may be one of the transferred assets (subject to the same constraints on use and disclosure as under this policy); and
  4. If we are under a duty to or are otherwise permitted to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions or to protect the rights, property, or safety of our personnel or customers . This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services to us or our customers. We deal with third parties that are required, under contract or under the Privacy Act, to meet the privacy standards required by law in handling your personal information, and use your personal information only for the purposes that we gave it to them.

4. Security of personal information

We take all reasonable steps to protect your personal information, including by implementing internal and external security, restricting access to personal information to those who have a need to know, maintaining technological products to prevent unauthorised computer access and regularly reviewing our technology to maintain security.

We use secure methods of storage for physical materials containing personal information.

5. Disclosure and transfer of information overseas

We disclose or transfer some personal information outside Australia, for operational purposes, including to sub-contractors who perform digital marketing and email services (and provide related reports to us). The recipients are located in India, the Philippines, Lebanon, Israel and the United Arab Emirates. The recipients are bound by agreements with us to treat personal information as if they were bound by the Australian Privacy Principles.

Unless we have your consent, or an exception under the Australian Privacy Principles applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.

6. Client Obligations

The Client represents and warrants that the Processing of Client Data is in compliance with Australian privacy and Data Protection Laws, including by establishing a lawful basis if and as required, and that the instructions provided to Asembl Brands Pty Ltd shall comply with applicable Privacy and Data Protection Law. In the event Australian Privacy and Data Protection laws do not apply to the Client, then Client must abide by whatever other Data Protection Laws and data security laws and regulations are applicable to it, and at a minimum:

  1. Obtain and maintain any and all authorizations, permissions and informed consents, as may be necessary under applicable laws and regulations, in order to allow Asembl Brands Pty Ltd to lawfully process and use the Client Data within the scope of the Services; and
  2. have, properly published and abide by an appropriate privacy policy that complies with all applicable Data Protection Laws.

7. Questions and concerns and access to/ correction or updating of your personal information

You have a right to access and correct the personal information we hold about you. To obtain a copy of the personal information we hold about you, please write to us at:

Paul Garrity Asembl Brands Pty Ltd [email protected]

Please provide sufficient detail about the information in question to help us locate it. We will then use commercially reasonable efforts to promptly determine if there is a problem and take the necessary corrective action within a reasonable time.

8. Changes to our privacy policy

We may modify, alter or otherwise update this privacy policy at any time. We will post revisions on our website. We encourage you to review this policy from time to time.

Last update:  November 2023

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