Privacy policy

This Privacy Policy was last updated on 28 August 2026.

1. About this Privacy Policy

1.1   Strauss Australia Pty. Ltd. (Strauss, we, us or our) has implemented this Privacy Policy to provide information about what kinds of Personal Information we may collect or hold, how we collect, hold, use and disclose that Personal Information, choices you have regarding our use of that Personal Information, and your ability to access or correct that Personal Information. If you wish to make any enquiries regarding this Privacy Policy, you should contact our Privacy Officer in any of the ways specified in paragraph 17.

1.2   From time to time, we may share your Personal Information with our related companies and entities (related entities), for the purposes set out in this Privacy Policy. This Privacy Policy applies to the use of your Personal Information by us and by those related entities. Those related entities may also have their own privacy policies which set out additional detail or differences in their privacy practices. To the extent that a related entity's privacy policy is inconsistent with this Privacy Policy, that related entity's privacy policy will prevail over this Privacy Policy in relation to their actions and your dealings with them. Where the context allows, a reference in this Privacy Policy to Strauss, we, us or our is also a reference to those related entities.

1.3   Strauss operates a number of webshops through the Website, which may offer different features and functionality depending on the relevant webshop. For example, some webshops may allow users to browse products, subscribe to newsletters or create wishlists, while others may facilitate online purchases, account creation and other ecommerce services. As a result, the types of Personal Information we collect, and the ways in which we use tracking technologies and other tools, may vary depending on the webshop you access. Additionally, some of those Website features described in this Privacy Policy may not be available when a particular webshop is first launched, and functionality may be introduced progressively over time. This Privacy Policy is intended to describe the Personal Information handling practices that may apply across all Strauss webshops on the Website generally.

2. Personal Information

"Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

3. What Personal Information do we collect and hold?

3.1   The types of Personal Information we may collect about an individual will depend upon the nature of our interaction with them. Personal Information that we collect may include (but is not limited to) the following:

(a)   name

(b)   age and/or date of birth

(c)   contact details including telephone numbers (landline and/or mobile)

(d)   current address (including postal address)

(e)   email address

(f)   login credentials and account information for customer accounts

(g)   payment details, such as your credit card or bank account details

(h)   order and transaction information including delivery addresses, order numbers, shipment details and purchase history

(i)   geographical location

(j)   Australian Business Number (ABN), where relevant

(k)   credit information and credit score values where you choose payment methods requiring credit assessment, such as purchase on account

(l)   photographs and/or images of you from camera footage

(m)   information from social media accounts and profiles

(n)   technical information including browser type, operating system, IP address, date and time of access, pages visited, referrer URLs, campaign and referral information (including UTM parameters), device information, and similar technical information and similar technical information

(o)   usage data from your visits to our Website including duration, scope and technical information about the end device, cookies and visitor IDs, together with information about your interactions with the Website, including pages, products and collections viewed, searches performed, products added to a shopping cart and other browsing or engagement activities

(p)   customer and transaction-related information received through our ecommerce and marketing systems

(q)   customer preferences, professional field, customer type (private or business customer), and product interests

(r)   if you apply for a position with us, we will collect information from or in connection with your resume or job application, such as occupation and employment details including employment status and any previous work experience, and

(s)   any voluntary information that you provide us at the time of creating your account.

3.2   We collect and record Personal Information about individuals such as:

(a)   our customers, potential customers and their representatives

(b)   our suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders

(c)   contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to us

(d)   our employees past and present, including applicants, and

(e)   any other person who comes into contact with Strauss.

4. How and when do we collect Personal Information?

4.1   We collect your Personal Information to allow us to conduct our business functions, to provide, market and sell our products and services and for the specified purposes set out in paragraph 6. In some circumstances the collection of Personal Information may be required by law.

4.2   We may collect your Personal Information in the course of providing you with goods or services, or:

(a)   when you use or buy our products or services

(b)   when you provide us, or you offer or apply to supply us, with goods or services

(c)   when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card)

(d)   when you request information about us, our products or our services

(e)   when you provide feedback to us

(f)   when you visit or fill in a form on our Website (see paragraph 5)

(g)   when you register for or use an account on our Website

(h)   when you visit premises from which we operate

(i)   when you order services or products via our Website or by other means

(j)   when you contact us via any means including a contact form, email, telephone, messenger service, live chat or chatbot

(k)   when you interact with our customer service or support functions

(l)   when you visit premises from which we operate

(m)   when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations

(n)   when you submit a job application to us

(o)   when you otherwise contact us by telephone, fax, email, social media, post or in person, or

(p)   where we are otherwise required or authorised by law to do so.

4.3   Generally, when providing our products and services, dealing with our personnel, or obtaining goods and services from our service providers, suppliers or contractors, we collect Personal Information directly from the relevant individual where reasonable and practicable.

4.4   We may also collect Personal Information about you from third parties and other sources such as:

(a)   your nominated representatives (eg spouse, accountant, power of attorney, brokers and other professional advisors)

(b)   publicly available sources of information

(c)   related entities, companies and businesses of Strauss

(d)   third-party service providers including transport and delivery providers, payment service providers, debt collection agencies, or

(e)   credit reporting bodies (such as Equifax or Experian) where you choose payment methods requiring credit assessment,

but we will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.

4.5   If the Personal Information we collect includes sensitive information, including health information, we will ask for your consent to collect sensitive information, unless the law allows us to collect it without your consent.

4.6   Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.

4.7   In most cases, if you choose not to provide your Personal Information to us for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the Personal Information we require, we may not be able to provide you with requested information, products or services, or to effectively conduct our relationship with you. This is because your Personal Information is reasonably necessary for us to respond to your enquiry or sell and provide you with our products.

5. Information collected via our Website and mobile applications

5.1   Personal Information may be collected by us and by our third-party service providers who assist us in operating our website at https://www.au.strauss.com/ , including its subdomains and any other website we operate from time to time (collectively the Website).

5.2   We operate a number webshops on our Website with different functionality. For example, some webshops may only allow users to browse products, subscribe to newsletters and create wishlists, while others may enable you to create accounts, place orders and access additional ecommerce features. As a result, the features, integrations, service providers and technologies used, and the Personal Information collected through them, may vary depending on the particular webshop being accessed on our Website. Accordingly, not all of the features, integrations, service providers and technologies described in this Privacy Policy will be used across all of our Website at all times, and additional features, integrations, service providers and technologies may be introduced or modified from time to time as our online services evolve. However, this paragraph 5 is intended to describe the full range of Personal Information handling practices that may apply across the Website.

5.3   Through access and use of our Website, we and our service providers may collect the following personal information and technical information about your use of the Website.

(a)   your IP address;

(b)   device identifiers;

(c)   browser type and version;

(d)   operating system;

(e)   language preferences;

(f)   pages viewed;

(g)   links clicked;

(h)   search terms entered;

(i)   products viewed or purchased;

(j)   referring websites;

(k)   date and time of access; and

(l)   other information relating to your interactions with the Website,

We collect this information to operate, maintain, secure and improve our Website, provide our products and services, analyse our Website usage, personalise your experience, detect and prevent fraud and security incidents, and support our marketing activities.

Technical Information Collection

5.4   When you visit our Website, our system automatically collects data and information from the device you are using. This includes, among other things, the browser type (including language setting), operating system, IP address, date and time of access, pages visited, the website you visited previously (referrer URL), information about the files you call up, and similar technical information. This data is processed for the purpose of delivering the Website, and for the purposes of analysis and ensuring system security and stability, and for statistical purposes. We do not use this information to assign it to a specific person.

Cookies and similar technologies

5.5   Cookies are small text files that are stored on your device when you visit our Website. They contain a unique identifier and enable your browser to be recognised. This allows certain functions of our Website to be provided, settings to be saved and content or offers to be tailored to your interests. They are designed to make our services more user-friendly and more effective.

5.6   We use different types of cookies to give you the best shopping and browsing experience. We use necessary and functional cookies to make visiting our Website an attractive and user-friendly experience. They are also necessary to allow and facilitate the use of certain functions. We also use analysis and advertising cookies to create statistics on the use of our Website and to continuously optimise our services.

5.7   When you first visit our website, you can choose in the cookie banner whether you want to accept all cookies, only allow necessary cookies, or customise your settings.

5.8   In addition to cookies, we may use pixels, tags, web beacons, software development kits (SDKs), application programming interfaces (APIs) and similar technologies to collect information about how users interact with our Website and online services.

5.9   These technologies may collect information such as your IP address, browser type, device information, operating system, cookie identifiers, pages viewed, links clicked, referring websites, search terms, interactions with our Website, and other usage and performance information.

5.10   We use these technologies to:

(a)   provide and improve the functionality, security and performance of our Website

(b)   remember your preferences and settings

(c)   understand how users interact with our Website

(d)   analyse and improve the effectiveness of our products, services and marketing activities

(e)   conduct website testing, personalisation and optimisation activities

(f)   facilitate customer communications, reviews and feedback; and

(g)   provide you with content, offers and advertising that may be relevant to your interests.

5.11   We may use third-party providers to assist us with analytics, advertising, website optimisation, customer engagement, reviews, marketing communications, security and website functionality. These providers may collect information directly from your device or receive information collected through our Website in connection with the services they provide to us.

5.12   Depending on your cookie preferences, these providers may use the information collected through cookies and similar technologies for analytics, attribution, reporting, personalisation, advertising measurement, audience creation, campaign optimisation and related business purposes.

5.13   You may withdraw or modify your consent preferences for non-essential cookies and similar technologies at any time through our cookie preference settings. You may also configure your browser to refuse or remove cookies. However, doing so may affect the functionality of some parts of the Website.

Website Analytics / Online Advertising

5.14   We use analytics, advertising, marketing, customer engagement, website optimisation and similar technologies to better understand how users interact with our Website, improve our products and services, measure and optimise our marketing activities, personalise user experiences, and support the operation of our business.

5.15   These technologies may collect information such as your IP address, device information, browser information, cookie identifiers, pages viewed, links clicked, referring websites, interactions with our Website, transaction information, and other usage and performance data.

Google Analytics

5.16   We use Google Analytics. This is an analytics service by Google LLC (Google). It produces pseudonymous user profiles for visitors to our Website. Google uses permanent cookies. The information generated by the cookie concerning your use of the Website is processed by Google in the USA. In addition to the information described in the section on "Technical Information Collection" above, Google also processes the search term you used to find our Website via a search engine. We use Google Analytics with activated IP anonymisation. You can find further information on Google Analytics on the Google website at: support.google.com/analytics/answer/6004245?hl=en.

5.17   The data is processed for the purposes of market research and needs-based design of our Website. Google processes this data on our behalf in order to evaluate the use of our Website and to compile reports for us on activity on our Website.

5.18   You can prevent the storage of cookies and thus the use of Google Analytics in your browser's settings. You can also prevent the data produced by the cookie from being processed by downloading and installing the plug-in available via the Google Analytics opt-out page at the following link: tools.google.com/dlpage/gaoptout?hl=en.

5.19   This page also uses Google Analytics to provide cross-device analysis of the surfing behaviour of visitors to our Website, which is carried out via a user ID. You can deactivate the cross-device analysis of your use by preventing the storage of cookies or as noted in paragraph 5.10 above.

Google Ads (Google Adwords)

5.20   We use the Google Ads services 'Google Ads Conversion' and 'Google Ads Remarketing'. These are online marketing services by Google.

Google Ads Conversion

5.21   We use the online marketing service Google Ads to place adverts in the Google advertising network (e.g. in search results, in videos, on websites etc.), so that they are shown to users who probably have an interest in our products. Using the online marketing service ‘Google Ads Conversion’, we can determine the anonymous number of users that clicked our advert in the Google advertising network and were sent to a website on which a so-called conversion-tracking-tag has been installed; in this way we receive information about the conversion of our adverts and can establish how successful our advertising campaigns are.

5.22   This is achieved by creating a pseudonym user profile that is saved in a permanent cookie. We are not able to identify the actual user, we only receive a statistics-based analysis which we can use to see how effective individual advertising measures are.

Google Ads Remarketing

5.23   We also use Google Ads Remarketing. This function allows us to show users of our Website adverts that correspond to their interests on other websites of the Google advertising network. This is achieved by using a cookie that analyses the interaction of the user on our Website, e.g. which products the user is interested in, so that this user can be shown adverts that are relevant for him/her on other websites once they have left our Website. The cookies used for this purpose serve to identify a web browser, but not to identify a person.

5.24   The data is processed for market research and the needs-based design of our Websites. Google processes this data on our behalf to analyse how our Website is used and to optimise our advertising to the needs of our customers.

5.25   You can prevent cookies from being saved and therefore the use of Google Ads Conversion and Google Ads Remarketing by means of your cookies settings or as described in paragraph 5.10 above, or alternatively, you can change the settings of your browser. You can also prevent the processing of the data that was generated by the cookie by downloading and installing the plug-in from this link: http://www.google.com/settings/ads/plugin.

5.26   For more information about data privacy at Google, please visit the following website: https://business.safety.google/privacy/ and https://services.google.com/sitestats/en.html.

Google Tag Manager

5.27   We use Google Tag Manager (GTM) to manage and deploy tracking technologies on our services. GTM is a tag management system that enables us to implement and control analytics, advertising, and other website tracking tools without directly modifying our website code.

5.28   GTM does not itself create user profiles or provide analytics reports. Instead, it facilitates the collection and transmission of information to other services and platforms that we use, such as Google Analytics and advertising providers. Depending on the tags deployed through GTM, information collected may include your IP address, device and browser information, cookie identifiers, page views, clicks, website interactions, referral URLs, and other usage data.

5.29   We use GTM to help us understand how visitors use the Website, measure the effectiveness of our marketing activities, improve Website functionality, and enhance the user experience.

5.30   For more information about GTM and Google's privacy practices, please visit Google's Privacy Policy at https://policies.google.com/privacy and GTM documentation at https://support.google.com/tagmanager/.

Other Analytics, Advertising and Marketing Technologies

5.31   We may also use cookies, pixels, tags, web beacons, session replay tools, heat-mapping technologies, customer engagement platforms, marketing automation tools, review platforms, advertising technologies and other similar tools provided by third-party service providers.

5.32   These technologies may assist us to:

(a)   analyse Website traffic and user behaviour;

(b)   measure the effectiveness of advertising and marketing campaigns;

(c)   conduct website testing, experimentation and optimisation activities;

(d)   personalise content, promotions and user experiences;

(e)   facilitate customer communications and newsletter subscriptions;

(f)   collect and display customer reviews and feedback;

(g)   improve Website functionality, security and performance; and

(h)   better understand customer journeys and interactions with our Website.

5.33   Depending on the technologies used and your selected preferences, these providers may collect information including browsing activity, device and browser information, IP address, cookie identifiers, referral information, session activity, purchase activity, interactions with emails or advertisements, and other information relating to your use of the Website.

5.34   We may use providers in categories including analytics providers, advertising platforms, website optimisation providers, session replay and user experience analytics providers, marketing automation providers, customer review platforms, social media platforms and ecommerce technology providers. These providers may change from time to time as our business and technology requirements evolve.

5.35   These third-party providers may use information collected through their technologies in accordance with their own privacy policies and for purposes including analytics, attribution, reporting, audience creation, advertising measurement, campaign optimisation, personalisation and related business services.

Session recording software (Piwik PRO)

5.36   We may use session recording and replay software tools, such as Piwik PRO, to record information about a user's interactions on our Website exactly or as close as possible to how the user actually experienced it, including information such as the sequence of pages you visit, mouse movements, clicks, typing, scrolling, swiping, and tapping. We use this information to debug errors, optimise pages, better understand user behaviour, continuously adapt and improve our Website to the needs of our visitors, enhance the user experience and support customers. You can deactivate the web analytics service Piwik PRO by adjusting its use through your cookies settings.

For further information on data protection at Piwik PRO, please visit https://piwik.pro/privacy-policy/.

Embedded Third-Party Content

5.37   Some of the content on our Website may include applications made available by third parties, such as social media buttons or links that allow you to share content or links to our Website through the relevant third party platforms. These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them. We are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties. Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.

Meta Pixel

5.38   We use Meta Pixel and related advertising technologies provided by Meta to measure the effectiveness of our advertising campaigns, understand how visitors interact with our Website, and deliver advertising that may be relevant to users' interests.

5.39   Meta Pixel may collect information about your interactions with our Website, including pages visited, products viewed, purchases made, browser and device information, IP address, cookie identifiers, and other online activity information.

5.40   The information collected through the Meta Pixel helps us to:

(a)   measure and analyse the performance of our advertising campaigns

(b)   better understand how users interact with our Website

(c)   create audiences for advertising purposes

(d)   deliver relevant advertising on Meta platforms, including Facebook and Instagram; and

(e)   improve our products, services and marketing activities.

5.41   Information collected through the Meta Pixel may be shared with Meta. If you use Facebook, Instagram or other Meta services, Meta may associate information collected through the Meta Pixel with your Meta account in accordance with Meta's privacy practices. Meta may also collect information from users who do not have a Meta account or who are not logged in to a Meta service.

5.42   Depending on your cookie preferences, the Meta Pixel may use cookies and similar technologies to collect and process information about your use of the Website.

5.43   You can manage your preferences for advertising and analytics cookies through our cookie preference settings. You may also manage certain advertising preferences directly through your Meta account settings.

5.44   Personal information collected through the Meta Pixel may be disclosed to and processed by Meta and its related entities. For more information about how Meta collects, uses and handles personal information, please refer to Meta's Privacy Policy at https://www.facebook.com/privacy/policy/.

TikTok Pixel

5.45   We use the TikTok Pixel service provided by TikTok Technology Limited (TikTok). This service enables us to assign visitors to our Website to specific target groups in order to display appropriate advertisements to them on TikTok (for the purposes of this section, targeted advertising). We can also track the actions users take on our Website, such as visiting product pages or making a purchase (for the purposes of this section, measurements and analyses). This enables us to target our advertising measures and measure their success.

5.46   Cookies are set for this purpose, which can be used to collect information about your usage behaviour and transmit it to TikTok. If you are registered and logged in to TikTok, TikTok can assign this data to your profile. Even if you do not have an account, TikTok may still process your IP address or other identifiers.

5.47   We obtain your consent via the cookie banner by asking you to consent to the use of personal cookies.

5.48   . For more information about how TikTok collects, uses, and discloses personal information, please refer to TikTok's Privacy Policy available at www.tiktok.com/legal/privacy-policy and Business Products Terms available at www.ads.tiktok.com/help/article/tiktok-advertiser-tools-and-related-terms.

Personalised Product Recommendations

5.49   If you have given your consent, we will show you personalised product recommendations during your visit to our Website. For this purpose, we use an automated artificial intelligence learning system (AI) that accesses data from your previous activities in our web shop (e.g. orders, customer number, customer type: such as private or business customer, professional field, place of residence). The AI analyses this data to learn which products could be particularly relevant for which customer groups or individual users. If you withdraw your consent, no further Personal Information will be processed for this purpose. You give this consent by agreeing to the personalised product recommendation in the cookie banner. You can revoke your consent at any time with future effect using the cookie settings.

6. How do we use your Personal Information?

6.1   We use the Personal Information we collect about you for our business functions and activities in order to operate our business efficiently, and to market our products and services for the benefit of our customers.

6.2   We may collect, hold and use your personal information:

(a)   to identify and communicate with you

(b)   to enable us to provide you with requested information, products or services, including order processing, shipping, invoicing and payment processing

(c)   to administer returns, exchanges, refunds and related customer service processes

(d)   to administer loyalty, rewards, referral and similar customer engagement programs

(e)   to otherwise assist customers by providing them with information and support

(f)   to monitor shipping and provide shipping notifications

(g)   to help us to manage and enhance products or services we provide to you

(h)   to help us to manage and enhance goods and services we procure from our suppliers and subcontractors

(i)   to set up and maintain customer accounts for you and to provide you with associated functions and services, including to provide convenient functions such as wish lists, stored address and contact details

(j)   to obtain credit information from credit reporting bodies where you choose insecure payment methods, and to use this information to decide whether to grant the payment method

(k)   to transfer data to debt collection agencies if invoices remain unpaid despite multiple reminders

(l)   to enforce our legal claims

(m)   to personalise and customise your experiences on our Website

(n)   to promote and market our products and services to you

(o)   to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our clients, and our business partners

(p)   to conduct research for the purposes of improving existing products or services or creating new products or services

(q)   to supplement our FAQ page, optimise our chatbot or otherwise adapt our customer service to the needs of our customers and interested parties

(r)   to understand which content, products or services are particularly relevant for our customers and to tailor our communication and recommendations accordingly

(s)   to analyse and design our customer communication both individually and generally, using AI-supported systems where applicable

(t)   to process data about your use of our offers and your response to advertising measures in order to personalise the advertising experience and to continuously optimise our advertising measures

(u)   to use data-driven or AI-supported processes to form target groups, tailor content and offers to presumed interests, and further develop and improve measures based on results/feedback

(v)   to check for anomalies in orders to avoid payment defaults and protect customers from misuse of their personal data

(w)   to optimise our fraud detection systems by processing contract and order data and usage data from Website visits

(x)   to conduct automated checks for fraud or abuse, with human review where fraud or abuse is suspected

(y)   to provide and enable services and functions on our Website, including customisation and finishing services

(z)   to handle enquiries and optimise our customer service, including through live chat and chatbot services

(a)   to track which job advertisements visitors use to access our Website careers section and application forms and to evaluate the reach and effectiveness of our job advertisements

(b)   to collect, manage and analyse customer reviews, ratings, survey responses and other customer feedback

(c)   to personalise and enhance the customer experience, including through ecommerce platform features, product recommendations, audience measurement, analytics, advertising and similar functionality provided by our ecommerce service providers

(d)   to analyse conversion data attribution and engagement data arising from advertisements, marketing campaigns and promotional activities when you access our Website via advertisements or promotional materials in order to evaluate the effectiveness of our advertising efforts and optimise our measures

(e)   to provide for the safety and security of workers and onsite visitors

(f)   to help us manage our business operations

(g)   for business support purposes including maintenance, backup and audit

(h)   to process any job application submitted by you

(i)   to respond to any queries or complaints you may have

(j)   to investigate, review, mitigate risks associated with, and inform you of, a data or other security breach involving your personal information, or

(k)   to comply with our statutory and legal obligations.

6.3   We may aggregate personal information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes. This allows us to better inform ourselves and anticipate our customers' preferences and requirements, and to monitor and improve the effectiveness of our business, products and services. We may also de-identify information for inclusion in such aggregated databases or reports.

6.4   We generally process data transmitted and collected from you for the purpose of optimising our business processes and corporate planning. Where possible, we de-identify the data before subsequent processing.

6.5   In order to carry out internal company processes and achieve the purposes communicated to you, we use AI-based systems in addition to conventional IT systems.

6.6   We reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of the Website or to retain the content of any user session.

6.7   You consent to us using your Personal Information in the above ways and as set out in this Privacy Policy. You may withdraw your consent to direct marketing at any time by contacting us as set out in paragraph 17.

6.8   We may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:

(a)   in accordance with this Privacy Policy or any agreement you enter into with us, or

(b)   required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

7. Automated Decision Making: Order Fraud Prevention

7.1   We use automated decision-making to assist with fraud prevention. To secure orders placed through our online shop and protect the integrity of our payment processes, we use automated systems to analyse the Personal Information collected during an order to detect anomalies and indicators of fraudulent or unusual activity. The purposes of this processing are to:

(a)   prevent payment defaults and financial loss, and

(b)   protect our customers from the misuse of their Personal Information.

7.2   The Personal Information processed for fraud prevention purposes includes:

(a)   contract and order data, such as the items purchased, your name, address, contact details, and payment information, and

(b)   usage data collected during your visits to our Website, such as the duration and scope of your visit and technical information about the device you used to place the order.

We may also use cookies or device identifiers in connection with fraud detection.

7.3   The automated process works by evaluating your order data to check for fraud or unusual activity. If the system identifies suspected fraud or unusual activity, the matter is escalated to a member of our team for manual review and assessment by a human reviewer before any final decision is made. If, following this process, we are unable to proceed with your order or a contract is rejected on fraud prevention grounds, we will notify you of this outcome.

7.4   Upon your request, we will:

(a)   inform you of the main reasons for the decision reached in relation to your order, and

(b)   conduct a fresh human review of your circumstances, giving you the opportunity to provide additional information or context before a final determination is made.

To make such a request, please contact us using the details set out in paragraph 17 of this Privacy Policy.

7.5   We carry out fraud prevention activities ourselves and, where appropriate, with the assistance of selected third-party service providers. Where we engage such providers, your Personal Information is disclosed to them for the purpose of protecting the security of your transactions. This disclosure may involve the transfer of your Personal Information to recipients located outside of Australia, as described in paragraph 9 of this Privacy Policy.

8. When do we disclose your Personal Information?

8.1   We may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in this Privacy Policy. Depending on the circumstances and the nature of your engagement with us, we may disclose your Personal Information to our related entities, to third parties that provide products and services to us or through us, or to other third parties (such as your referee(s) in connection with a job application you have submitted).

8.2   We may also disclose your Personal Information to:

(a)   any of Strauss's internal divisions, business units or departments (this also includes other companies within the Strauss group, including our parent company, subsidiaries, affiliates and related bodies corporate, which may be located in Australia or overseas).

(b)   your nominated representatives

(c)   other organisations or individuals who assist us in providing products and services to you

(d)   professional service providers and advisors who perform functions on our behalf, such as lawyers

(e)   third-party providers from whom you order goods in our online shop, to the extent necessary for shipping

(f)   debt collection agencies if invoices remain unpaid

(g)   credit reporting bodies (such as Equifax or Experian) to obtain credit information where you choose insecure payment methods

(h)   representatives, agents or contractors who are appointed by us in the ordinary operation of our business to assist us in providing goods or services or administering our business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development)

(i)   banks and payment service providers for payment processing

(j)   transport companies, postal service providers, service providers for shipping control and shipping communication including providing shipping notifications

(k)   manufacturers for the purpose of handling warranty claims

(l)   law enforcement authorities, courts, arbitration boards, auditors, solicitors or tax advisers

(m)   insurance companies for the processing of possible claims

(n)   authorities, offices, parties involved in proceedings, tax authorities and insurance companies to fulfil contractual and legal obligations

(o)   external service providers including call centre agencies, letter shops and printing companies, agencies for data collection and data maintenance, IT service providers, service providers for data carrier destruction, providers for comparing sanctions lists

(p)   IT systems and providers used to process enquiries, including live chat and chatbot service providers

(q)   address dealers, public directories or other legitimate data providers for advertising purposes

(r)   banks, lenders, valuers, insurers, brokers, auditors, business consultants and IT service providers, and

(s)   Government, regulatory authorities and other organisations as required or authorised by law.

8.3   We may also disclose your Personal Information to our Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

8.4   To support our operational processes, we also use external service providers to whom personal data may be transferred in the course of their activities. If these service providers process Personal Information on our behalf, we enter into contractual arrangements which require them to handle your Personal Information lawfully. In some cases, your Personal Information may be disclosed to service providers located overseas, as described in paragraph 9.

8.5   As we continue to develop our business, we may buy, merge or partner with other companies or organisations, and in so doing, acquire customer Personal Information. In such transactions, Personal Information may be among the transferred assets. Similarly, in the event that a portion or substantially all of our business or assets are sold or transferred to a third party, we may also disclose certain information including your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of us, our business or any of our assets, including in insolvency.

9. Overseas disclosures

9.1   Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:

(a)   our offices or related entities are overseas

(b)   we outsource certain activities overseas

(c)   transactions, information, services or products have an overseas connection, or

(d)   our computer systems including IT servers are located overseas.

9.2   We use various international service providers for website delivery, ecommerce, platform services, content delivery networks, web application firewalls, analytics services, advertising and marketing services, customer enquiry processing, live chat services, payment processing, logistics and fulfilment services, and other IT functions. Such transfers may involve countries including, but not limited to:

(a)   the United States of America

(b)   member states of the European Union, including Germany, Ireland and Denmark, and

(c)   China.

9.3   When transferring data to overseas recipients, we will take reasonable steps to require the recipient to not breach the Australian Privacy Principles (APPs) in relation to your Personal Information.

9.4   By providing us with your Personal Information, you consent to the collection, use, storage, and processing of your Personal Information outside of Australia as set out in this Privacy Policy.

9.5   In particular, your Personal Information may be disclosed to the third parties in the countries listed in paragraph 9.2, and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy.

9.6   In order to provide our services to you, we use Shopify to power our online store. You acknowledge that your Personal Information will be disclosed to Shopify and stored on its servers, which are located outside of Australia. For more information on how Shopify processes your information, please refer to the Shopify Consumer Privacy Policy at https://www.shopify.com/au/legal/privacy/consumers.

9.7   We also use the following third-party services which may involve the transfer of your Personal Information to overseas recipients, including to servers located in the United States of America:

(a)   Google Ireland Limited in connection with Google Analytics, Google Ads, YouTube and Google Maps. Further information on Google's data protection practices can be found at: https://policies.google.com/privacy

(b)   Meta Platforms Ireland Limited in connection with Meta Pixel. Further information on Meta's data protection practices can be found at: https://www.facebook.com/privacy/explanation

10. Other uses and disclosures

10.1   We may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy. If we do so, we will generally seek to take reasonable steps to make it known to you at the time we collect or use your Personal Information, unless otherwise permitted by law.

11. Marketing

11.1   You consent to us using your Personal Information for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.

11.2   You have the option of subscribing to a free email newsletter on our Website. By subscribing, you provide your consent for us to send you the email newsletter. If you access our online shop via our newsletter and make a purchase, we may process this data to understand our customers' preferences and improve our products and services. After you have subscribed to the newsletter, you have the option of providing further details about yourself in order to personalise your newsletter and provide you with newsletters that match your interests.

11.3   If you have given us your consent, we will use your contact details to inform you about our products, services or events, as well as to send you satisfaction surveys. This also includes sending you a link for evaluation via third-party evaluation platforms. You can revoke your consent to receive promotional emails at any time with future effect, e.g. by notifying us using the contact details in paragraph 17 or via the 'unsubscribe' link in emails.

11.4   We may use email addresses and address details that we have received in connection with the sale of goods or services for direct advertising of goods and services similar to those you have already purchased from us. When you shop with us, we may also use your address details to send you print advertising with information about our products.

11.5   If you do not want to receive marketing information from us, you can unsubscribe in any of the following ways:

(a)   clicking on the 'Unsubscribe' or subscription preferences link in a direct marketing email that you have received from us

(b)   logging into your account on the Website and editing your communication preferences, or

(c)   contacting us using the contact details specified in paragraph 17.

11.6   From time to time, we may conduct promotions, competitions and giveaways that are subject to separate terms and conditions. Those terms and conditions may include eligibility requirements relating to marketing communications. Please review the applicable promotion terms and conditions before participating.

12. Storage and security of Personal Information held by us

12.1   We aim to keep your Personal Information secure. Any Personal Information that is collected via our Website or which is held on our computer systems is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and organisational methods.

12.2   We implement technical and organisational measures to ensure system security and stability, and to avert danger - for example, in the event of a cyber attack.

12.3   If we find that we no longer require or have no further need for your Personal Information we may de-identify it or remove it from our systems and destroy all record of it.

12.4   We store your Personal Information for as long as is necessary to fulfil the relevant purposes.

13. You can access and update your Personal Information

13.1   You are generally entitled to access Personal Information that we hold about you. If you request access to your Personal Information, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, Strauss may charge for providing access to this information, however such charge will not be excessive and will not apply to the making of the request itself.

13.2   However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide you with a written notice setting out the reasons for the refusal (unless it would be unreasonable to do so) and the mechanism available to complain about the refusal.

13.3   You can access and correct some of your Personal Information through the Website or mobile application by logging into your customer account and updating or editing your profile at any time. Your customer account allows you to control and manage processes relating to your use of our web shop (e.g. view and manage orders, store address and contact details) and use other convenient functions (e.g. wish lists).

13.4   Alternatively, a request for access can be made by contacting our Privacy Officer in any of the ways specified in paragraph 17. We will respond to your request within a reasonable period.

13.5   We take all reasonable steps to ensure that any Personal Information we collect and use is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.

13.6   Please contact us in any of the ways specified in paragraph 17 if you believe that the Personal Information is inaccurate, out-of-date, incomplete, irrelevant or misleading, and we will use all reasonable efforts to correct the information within a reasonable period.

13.7   It would assist us to ensure we properly understand your request, and allow us to respond more promptly, if requests are made in writing and include as much detail as possible.

14. How do we deal with complaints about privacy?

14.1   If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact our Privacy Officer in any of the ways specified in paragraph 17 and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.

14.2   It would assist us to respond to your complaint promptly if it is made in writing. Please detail information relevant to your complaint.

14.3   We will notify you of the outcome of our investigation. If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

15. Your Rights

15.1   In addition to the rights described elsewhere in this Privacy Policy, you have the following rights in relation to your Personal Information:

(a)   Right to access: You can request information from us about whether we hold Personal Information about you and request access to that information

(b)   Right to correction: If any Personal Information we process about you is incorrect, inaccurate, out-of-date, incomplete, irrelevant or misleading, having regard to a purpose for which it is held, you can notify us and have the right to have this information corrected (or, if we disagree, you have the right to have a statement associated with the record of Personal Information we hold stating that the information is incorrect).

(c)   Right to lodge a complaint: You have the right to lodge a complaint with us about our processing of your Personal Information if you disagree with how your Personal Information is being handled, as set out in paragraph 14.

16. Updates to this Privacy Policy

16.1   We may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology. All Personal Information held by us will be governed by our most recent Privacy Policy, posted on our Website. Any changes to this Privacy Policy may be advised to you by updating this page on our Website. We will aim to provide reasonable advance notice of such changes though this may not always be possible depending on the circumstances. We encourage you to check this page from time to time for any changes.

17. What to do if you have a question, problem or complaint, or want to contact us about our use of your Personal Information or this Privacy Policy

17.1   If you:

(a)   have a query or concern about this Privacy Policy or our Personal Information handling processes

(b)   wish to make a complaint in relation to a breach of your privacy

(c)   would like to access your Personal Information held by us

(d)   would like to update or correct your Personal Information held by us, or

(e)   would like to opt out of direct marketing,

please contact our Privacy Officer, in any of the following ways:

Attention: Privacy Officer

Email Address:  modlinger@strauss.de

Mailing Address: Mitterweg 36a 83233 Bernau a. Chiemsee Germany

Phone: 0176-32572896