PRIVACY POLICY
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Updated: 12.01.2024
Pawn & Co is committed to protecting the privacy of your personal information. This Privacy Policy ("Policy") explains how we collect, use and disclose information about our customers, team members, suppliers (and their employees) and people who apply for employment with us. It also explains how to contact us if you have any questions about the management of your personal information or would like to access the personal information we hold about you. This Policy describes how we comply with our obligations under the Australian Privacy Act 1988 (Cth).
"We", "us", "our" and "Pawn & Co" means Smallchange Holdings Pty Ltd ACN 158 0041 304 (trading as ‘Pawn & Co’). In handling data, including personal information, we will comply with all relevant laws.
Collection of personal information
1. The types of information that we collect about you could include:
• identification information, including name, driver’s licence number or student identification number;
• contact details, including home/business addresses, email addresses and telephone numbers;
• demographic information such as age/date of birth, household information, personal interests and gender;
• details about your Pawn & Co purchases and transaction history with us and your Pawn & Co product and service preferences;
• details about purchases, product or service preferences, transaction history and current or pending transactions, browsing and marketing interactions (such as the products viewed or added to your shopping cart) on website, apps, social media, and email communications;
Updated: 12.01.2024
• digital information, such as cookies (which are small data files transferred onto devices when a website or apps are accessed), tags and pixels (which 'tag' devices), device type and software versions used, device identifiers (like IP address), location data (where available and not disabled by the user), dates, times, file metadata, referring website/app, data entered, and user activity such as links clicked, app installations, app launches, adding items to a basket, adding items to a wish list, browsing habits within our website or apps and other information as allowed in your device permissions;
• social media account names or tags (where you have engaged with us on a social media platforms);
• payment information where you have paid by credit card or ebit card;
• images from video surveillance, body cameras and other cameras used in and around our venue (including on footpaths, car parks and publicly accessible spaces);
• inferred information and characteristics as a result of undertaking data analysis;
• information provided in surveys, feedback, complaints or commentary;
• if you apply for employment with us, details regarding your employment history, educational qualifications, referee details and similar information.
2. We will usually collect personal information about you directly from you. We may also collect personal information from our Related Companies and from trusted third parties that we may work with from time to time. We may also collect deidentified data from (and share deidentified data with) third parties for data analysis purposes.
3. Often you can deal with us anonymously or by using a pseudonym, but in this situation we may not be able to provide you with the full range of services available. For example, we will not be able to admit entry if you do not provide suitable photographic identification.
Updated: 12.01.2024
4. The main ways we collect personal information are:
• during your order or purchase of products from us;
• when you contact or visit us, including visiting a venue, making an inquiry, making a complaint or providing feedback, seeking a refund, attending an event, or if you are a supplier or service provider in connection with the supply of products and services by your business to us;
• if you access our website or apps, including by the use of cookies, tags and pixels, which may track what you view on our website or apps and also other websites/apps that you visit. Cookies, tags and pixels may also come from third party services (such as Google and Facebook) for the purpose of collecting data to enable website or app performance measurement and personalised advertising;
• if you interact with us via social media platforms;
• if you subscribe to any of our publications (including any mailing lists) or subscriptions or use any of our apps;
• if you participate in any competition or promotion that we conduct;
• through our security cameras, body cameras or other cameras used in our venues (including on footpaths, car parks and publicly accessible spaces);
• if you use a loyalty or membership program or team member discount in connection with a transaction or Pawn & Co account;
• if you undertake any of our induction, safety or compliance processes;
• if you submit an employment application to us;
• from publicly available sources, including from Australian Government agencies, internet search platforms and social media platforms such as Facebook;
• from any person authorised to act on your behalf or authorised to provide your personal information to us; and
• from anyone sharing information with us for security and/or law enforcement purposes;
Use and disclosure of personal information
5. We use and disclose your personal information in connection with carrying on our business, (including to provide products and services to you and relating to our involvement in loyalty schemes or membership programs that we participate in).
6. We may use your personal information to:
• sell, deliver, administer, improve and personalise our products and services;
• administer our website and apps and personalise your experience on them;
• provide advice regarding our products and services to you;
• process payments;
• manage our venues, supply arrangements and inventory;
• consider feedback and remedy complaints that you may make to us and communicate with you;
• promote and advertise our products and services (e.g. by including your feedback in our advertising) and to undertake competitions and events;
• personalise advertising and content displayed to you (including the layout and content of our website/app, and advertisements displayed to you on or via third party websites, apps or platforms such as Facebook);
• monitor our sales of products and services and for quality control purposes, including undertaking customer surveys and analysis, or seeking feedback from customers;
• assist in determining your product or service preferences;
• undertake database compilation and management, data processing, data analysis and matching, market research or trend analysis (including with information obtained from third parties) to better understand our customers’ preferences, personalise websites/apps and (where you have consented to receiving offers or direct marketing) to offer products or provide services of greater interest to you or engage in direct marketing;
• to derive insights about you in order to better understand your preferences and interests, personalise your experience, enhance the products and services you receive, and to tell you about products and services that may be of interest to you. We may also use third parties and trusted service providers to undertake the process of creating these consumer insights.
• in the case of our suppliers or service providers, to manage the provision of products and services to us;
• to monitor and measure the use of our websites or apps, including web-based referral channels, data entered and digital behaviour such as links clicked;
• to assist us in ensuring security, health and safety and customer and team member protection in our venues (including on footpaths, car parks and publicly accessible spaces);
• to assist us in administering our policies, or to investigate complaints in relation to team member conduct;
• in the case of images from body cameras, for security or store safety purposes;
• in the case of inferred characteristics produced through data analysis, for improving products and service offerings;
• to recruit and assess our employees or engage contractors;
• to maintain and update our records; and for purposes related to any of the above or which are disclosed to you at the time the relevant personal information is collected.
7. We work with a number of third parties in carrying on our business and may disclose your personal information to:
• third parties to facilitate the provision of products and services to you;
• marketing, advertising and promotions services providers and event organisers in connection with our marketing, advertising and events;
• third party platforms who display advertising or content (including personalised advertising) based on your personal information or preferences (including social media platforms such as Facebook);
• third parties who provide services to us in connection with our business operations, including data monitoring, data analysis and data matching activities, monitoring trends in customer preferences or transactions and the operation and maintenance of our website/apps;
• credit reporting agencies, for example if your business is a supplier to us;
• third parties who provide other administrative and operational services to us in connection with our business, including financial institutions, security services providers, market research or feedback collection companies, IT service providers, payment processers and collectors, mailing houses and card manufacturers;
• our professional advisers to enable them to provide services to us;
• third parties necessary to assist us in investigating and preventing any potential, suspected or actual breaches of policy or law, fraudulent activities or security activities;
• law enforcement agencies, government agencies or other third parties, where required under or authorised by law;
• other persons notified to you at the time the relevant personal information is collected; and
• in special circumstances – for example, if we were to sell our business or part of our business, your information may be disclosed to potential purchasers and their advisers as part of that process;
• from time to time we may provide aggregated and de-identified information to other business partners for various purposes.
Transfer of information overseas
8. Some of our service providers may be located overseas or may store information (including your personal information) that we provide to them overseas. We require overseas recipients to use personal information only for the purpose provided and to Updated: 12.01.2024 implement confidentiality and data protection arrangements. Your information may also be stored on computer servers located outside of Australia. Any offshore disclosures will be to entities located in the United States of America, the United Kingdom, European countries and the Asia Pacific region.
Marketing, advertising and customer insights
9. From time to time, we may also use and disclose the personal information we collect about you to contact you or send you direct marketing and personalised communications, to personalise the appearance of our website and apps to you, to invite you to complete a product review, to send you targeted and personalised news, offers and promotions of our products and services and provide tergeted advertising content to you (including through third party websites, apps and social media platforms such as Facebook).
10. Generally, we will provide direct marketing and personalised communications to you where you have requested or consented to receiving them. If you do not wish to receive direct marketing or personalised communications you can opt-out by contacting us at the address listed below, by using the unsubscribe link or opt out details provided in the direct marketing communication or in the case of online advertising by changing your browser options in the digital platforms you use such as Google or Facebook.
11. The third parties who assist us in marketing and advertising to you or the device you use may use cookies, pixels or tags, to obtain information about your preferences when you access online platforms, apps or websites other than Pawn & Co’s website/apps. Your preferences collected in this manner may be disclosed to us. You can manage your preferences regarding targeted online advertising directly through the digital platforms you use, such as Google or Facebook.
Security and storage
12. Pawn & Co will take reasonable steps to protect the security of your personal information that we hold. We have security measures in place to protect personal information under our control from misuse, interference, loss, unauthorised access, modification or disclosure. For example, Pawn & Co seeks to ensure that personal information held electronically by or for Pawn & Co is held on secured servers in controlled facilities.
Accessing and correcting your information and questions
13. You can request access to your personal information, or request that your information be corrected, by contacting us at the address below.
14. If you have a question about this Policy or wish to make a complaint about the way we have collected, used, held or disclosed your personal information, please contact us at the address below. We may need to contact you for further details.
15. If you wish to make a formal complaint, please make your complaint in writing to our Privacy Officer. We will consider your complaint promptly and contact you to seek to resolve the matter. If we have not responded to you within a reasonable time, you are entitled under the Privacy Act 1988 (Cth) to make a complaint to the Office of the Australian Information Commissioner to resolve that complaint.
How to contact Pawn & Co
You can contact us in writing or by email as set out below:
Pawn & Co’s Privacy Officer
PO Box 3795 Caroline Springs, VIC 3023
Email: privacyofficer@pawnandco.com.au
How to contact OAIC Australia:
Office of the Australian Information Commissioner
Website: www.oaic.gov.au
Phone: 1300 363 992
Changes to this Policy
Pawn & Co may update this Policy from time to time. We may let you know of significant changes to this Policy by posting a notification on our website. The current version of this Policy was last updated in January 2024.
