This Privacy Policy is held by Triumph International (NZ) Limited and its overseas holding, subsidiary and related companies that are members of the Triumph group (“us”, “we”, “our”, “Triumph”).

ONE

Protecting Your Privacy

At Triumph, we are committed to providing the highest level of customer service. Central to that task is protecting your privacy. This Privacy Policy sets out how we manage your personal and other information. We are required to communicate to you concerning the privacy of your information. Please keep this information for future reference or you may revisit it here at any time or request a copy by contacting our Customer Service Centre 0508 415 415. This policy, which applies whether you visit our stores, use your mobile device or visit our online store, provides you with information about:

• how we use your data;
• how we hold your information;
• how we ensure your privacy is maintained;
• when we may disclose your information

TWO

Your Information

"Your Information" refers to your personal information as that is defined under the Privacy Act 1993. Your Information held by us may include all or some of the following:

• your name;
• date of birth;
• current and previous addresses;
• telephone or mobile phone numbers;
• email addresses;
• bank account or credit card details;
• signature;
• occupation;
• proof of identity such as your driver's licence number or passport number;
• login password;
• IP address used
• date and time at the moment of access
• amount of data sent in bytes
• browser used
• source/reference from which you came to the page
• operating system used
• a photograph or video surveillance recording of you if you are physically present in our stores; and
• if you are an employment candidate we may collect other information as further set out in application forms or as a part of the recruitment process. This may include information relating to your previous employment, working eligibility rights, suitability for the applied for role and referee details.

You generally have an option not to identify yourself and to use a pseudonym or to remain anonymous when dealing with us. The use of pseudonym’s may be impractical and prevent us from being able to provide you with our products and services. This is particularly the case where you order goods which need to be delivered to your postal address or goods subject to age restrictions.

We may also collect other information from you that is not personal information because it does not identify you personally. This information may be retained with Your Information and may include the following:

• Your shopping preferences and a list of products and services that you have purchased from Triumph. This may include your shopping history, product types, specifications, sizes, colours, product reviews or other attributes of products and services we have provided to you or may provide to you in the future;
• information we require to deliver or fulfil warranty obligations;
• your marketing preferences including the type of marketing material you wish to receive and the method of delivery;
• information you provide to us via our customer service centre, website, submission forms, applications forms or directly to team members within our stores;
• device identification information when you use a computer, mobile phone, smart phone, tablet or other device to interact with us through our online store. This information may include session cookies, your device IMEI number, IP address or MAC address.
• other publicly available personal data, including any which you have shared via a public platform (such as a Twitter feed or public Facebook page).

You may choose not to provide certain personal information. However, if this is the case, we may not be able to provide you with the services you have indicated that you require.

NOTE: You can modify your information at any time by logging into your account online or require a correction/removal of your information by contacting our Data Protection Officer by email at queries.au@triumph.com. 

THREE

How We Collect Your Information

Your Information may be collected from you in a number of ways:

• From you directly when you provide your personal details through our website, by phone or email or complete our forms;
• From third parties such as credit reporting agencies, business or commercial partners or your representatives;
• From publicly available information;
• From organisations identified under the heading of "When we disclose your personal information";
• From conversations with our team members;
• From your visits to our website;
• If you are a candidate for employment, when you complete the forms in relation to recruitment and the selection process and from your nominated referees;
• From time to time, legislation may require that we collect certain personal information.

Any payment transactions will be encrypted using SSL technology. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

FOUR

How We Hold Your Information

Your Information may be stored by us in hard copy or electronic format, in data storage facilities either owned by us or operated by our service providers. All reasonable steps are taken to ensure the security of Your Information.

The duration of the storage of personal data is determined by the respective legal retention period (e.g. commercial and tax retention periods). After expiry of this period, we take measures in respect destroying personal information that is no longer needed for any lawful purpose. 

FIVE

How We Use Your Information

We may use Your Information to:

• provide you with products and services that you have requested from us;
• communicate with you, including about products and services, special offers and events which might interest you;
• answer your questions and provide you with information or advice;
• create orders, transaction records, agreements for the sale of products or services, accounts, tax invoices or receipts;
• provide Your Information to third parties that assist us in providing products and services that you have requested, such as delivery service providers;
• carry out administration, marketing, planning, fraud and loss prevention activities, procurement, product and service development, quality control and research to improve the way Triumph and service providers provide products and services to you;
• consider and respond to complaints made by you;
• comply with laws or regulations or to comply with any directions given by regulators or authorities;
• if you are a candidate for employment, to assess your suitability for a position at Triumph

A. Newsletter Subscription

If you have consented to this, we may use your information to send you a newsletter which provides you with information about us and our products which may be of interest to you. We may send this newsletter electronically (by email or SMS) or by mail.

If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so. You may opt out of receiving marketing communications at any time by responding via the channel in which you receive the marketing communication, or by contacting us (see contact information below). You can unsubscribe from emails by clicking the unsubscribe link on the footer of the email communication you have received.

We do not provide your personal information to any other organisations for the purposes of direct marketing. We use third party service providers to process and send our newsletters. Such service providers process your personal information only on our behalf and according to our instructions and we remain responsible for protecting your privacy under the Act.

B. Your Account & Orders

We collect information that you provide by filling in forms on our website. This includes information provided at the time of setting up a customer account to use our web shop or ordering our products.

• You can modify your information at any time by logging into your account. Your information will be stored in our customer data base when you click "Registration".
• Following registration, you will receive automatic confirmation by email that your customer account has been set up. You must keep your user identification and password confidential and not share it with anyone.
• We keep details of transactions you carry out through our Site and of the fulfilment of your orders.

C. Use of Payment and Service Providers

Some Credit Card details maybe stored by Triumph for the processing of payment. If you select an alternative means of payment for any order, such as PayPal and Afterpay, you provide the personal and financial information needed to process your application or purchase directly to each provider associated with processing the payment. The companies that administer these programs are independent of Triumph and have their own privacy policies.

D. Cookies

Our websites use cookies to collect information. This includes information about browsing and purchasing behaviour by people who access our websites. This includes information about pages viewed, products purchased and the customer journey around our websites. Some of the cookies we use are deleted after the end of the browser session, i.e. after closing your browser (so-called session cookies). Other cookies remain on your terminal and enable us or our partner companies (third-party cookies) to recognize your browser on your next visit (persistent cookies). If cookies are set, they collect and process specific user information such as browser and location data as well as IP address values according to individual requirements. Persistent cookies are automatically deleted after a specified period, which may vary depending on the cookie. Please, continue reading, to find further information on the cookies.

What is a Cookie? 
A Cookie is a small text file that a website stores on your PC, telephone or any other device, with the information about your navigation on that website. Cookies are essential for the effective operation of our website and to help you shop with us online, they are necessary to facilitate browsing and to make it more user-friendly, and they do not damage your computer.

What information is collected by Cookies?
Some cookies collect information about browsing and purchasing behaviour when you access this website via the same computer or device. This includes information about pages viewed, products purchased and your journey around a website. We do not collect sensitive personal information, such as your address, your password, your credit or debit card data, etc., in the Cookies we use.

Who uses the information stored in Cookies?

• The information stored in the Cookies from our website is used exclusively by us to enable you to make a purchase on our websites
• third parties who participate with us in marketing programmes, , including Facebook, Bazaar Voice; and
• third parties who broadcast web banner advertisements on behalf of Triumph International

How do I avoid using Cookies on your websites?
You may refuse to accept/restrict/block or delete cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our Site. While settings are different in each browser, Cookies are normally configured in the "Preferences" or "Tools" menu.

You will find these for the respective browsers under the following links:

• Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
• Firefox: https://www.mozilla.org/en-US/privacy/websites/#cookies
• Google: https://support.google.com/accounts/answer/61416?co=GENIE.Platform%3DDesktop&hl=en
• Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
• Opera: https://help.opera.com/en/latest/web-preferences/#cookies

Please note that the functionality of our website may be limited if cookies are not accepted.

E. Google Analytics

Our websites use Google Analytics, a service which transmits website traffic data to Google servers in the United States. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. The reports from Google Analytics are shared with our global brand management team in Switzerland and Germany. The reports are not shared with third parties and are used to help us understand website traffic, webpage usage and sales conversion.

If you use this website, you consent to the processing of data about you by Google as set out in Google's Privacy Policy and for the purposes set out above. You can opt out of Google Analytics by one or more of the following methods:

• If you disable or refuse the cookie;
• If you disable JavaScript; or
• If you use the opt-out service provided by Google at https://tools.google.com/dlpage/gaoptout

F. Use of Videos

This website uses the Youtube embedding function for display and playback of videos offered by the provider Youtube, which belongs to Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google").

To this end, the extended data protection mode is used to ensure, according to provider information, that user information will only be stored once the playback function of the video is started. When the playback of embedded YouTube videos is started, the provider sets "YouTube" cookies in order to collect information about user behavior. According to indications from Youtube, the use of those cookies is intended, among other things, to record video statistics, to improve user-friendliness and to avoid improper actions. If you are logged in to Google, your information will be directly associated with your account when you click on a video. If you do not wish to be associated with your profile on YouTube, you must log out before activating the button. Google saves your data (even for users who are not logged in) as usage profiles and evaluates them. Such an evaluation takes place in particular according to Art. 6 (1) point f GDPR on the basis of the legitimate interests of Google in the insertion of personalised advertising, market research and/or demand-oriented design of its website. You have the right to object to the creation of these user profiles, whereby you must contact YouTube to exercise this right.
Regardless of whether the embedded video is played back, a connection to the Google network "double click" is established when visiting this website. This may trigger further data processing beyond our control.

Further information on YouTube data protection can be found in the provider's data protection statement at: https://policies.google.com/privacy?hl=en

G. Retargeting, Remarketing & Referral Marketing

• Bing Ads (Microsoft Corporation)

This website uses the conversion tracking technology "Bing Ads" from Microsoft (Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA). Microsoft Bing Ads will place a cookie on your computer if you access our website via a Microsoft Bing ad. Cookies are small text files that are stored on your computer system. These cookies lose their validity after 180 days. They are not meant for personal identification. If the user visits certain pages of this website and if the cookie has not yet expired, we and Microsoft are able to recognize that the user has clicked the ad and has been forwarded to this page (conversion page).
The information collected via the conversion cookie is meant to compile conversion statistics, i.e. to register how many users have arrived at a conversion page after clicking the ad. We hereby learn the total number of users who clicked our ad and were forwarded to a conversion tracking tag page. However, we do not obtain any information by which users can be personally identified.

If you do not wish to participate in tracking, you may object to this usage by easily deactivating the Bing Ads conversion tracking cookie via your internet browser and your user settings. In this case, you will not be included in the conversion tracking statistics. 
For more information about Microsoft Bing Ads' privacy policy, please visit: https://privacy.microsoft.com/en-US/

• Facebook Custom Audience via the Pixel Process

This website uses the "Facebook Pixel" of Facebook Inc, 1 Hacker Way, Menlo Park, CA 94025, USA ("Facebook"). If the user has given us his explicit consent, his behavior can be tracked after he has seen or clicked on a Facebook advertisement. This process is designed to evaluate the impact of Facebook ads for statistical and market research purposes and may help to optimize future advertising efforts.
Data collected shall remain anonymous and cannot be used to draw any conclusion about the identity of the user. However, those data are stored and processed by Facebook to enable a connection to the respective user profile and to allow Facebook to use those data for its own advertising purposes in accordance with the Facebook Privacy Policy (https://www.facebook.com/about/privacy/). You may allow Facebook and its partners to place ads on and outside of Facebook. A cookie may also be stored on your computer for these purposes. These processing operations only take place if express consent is given in accordance with Art. 6 (1) point a GDPR.

Consent to the use of the Facebook pixel may only be given by users who are older than 13 years of age. If you are younger, please ask your legal guardian for permission.

We have entered a Controller Addendum to determine the respective responsibilities for compliance with the obligations under the GDPR with regard to the Joint Processing as specified in the Applicable Product Terms.

• Facebook Ireland is a Joint Controller of the Joint Processing and that the information required by Article 13(1)(a) and (b) GDPR can be found in Facebook Ireland’s Data Policy at https://www.facebook.com/about/privacy.
• We use Applicable Products as well as collection and transmission of Personal Data that constitutes Joint Processing as set out in the Applicable Product Terms.
• Further information on how Facebook Ireland processes Personal Data, including the legal basis Facebook Ireland relies on and the ways to exercise Data Subject rights against Facebook Ireland, can be found in Facebook Ireland’s Data Policy at https://www.facebook.com/about/privacy.

If you want to disable the use of cookies on your computer, you can set your Internet browser so that cookies can no longer be stored on your computer in the future and/or cookies that have already been stored will be deleted. However, when disabling all cookies, some functions of our internet pages may no longer be able to be executed. You can also disable the use of cookies by third parties such as Facebook on the following Digital Advertising Alliance website: http://www.aboutads.info/choices/

• Google AdWords Remarketing

Our website uses the functions of Google AdWords Remarketing and Google’s Customer Match, which enables us to advertise our website and brand in Google search results, Gmail ads, Youtube, as well as third-party websites. Provider is Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). To this end, Google places a cookie in the browser of your terminal device, which automatically uses a pseudonymous cookie ID on the basis of pages you visited to allow interest-based advertising. Processing is based on our legitimate interest in the optimal marketing of our website in accordance with Art. 6 (1) point f GDPR.

Any additional processing will only take place if you have agreed with Google that your Google Internet and app browsing history will be linked to your Google Account and information from your Google Account will be used for personalized ads you view on the web. If you are logged in to Google while visiting our website, Google will use your data in connection with Google Analytics data to create and define target group lists for cross-device remarketing. To this end, Google temporarily links your personal data with Google Analytics data to create target groups.
You can permanently disable the setting of cookies for advertising preferences. You may download and install the browser plug-in available at the following link: https://www.google.com/settings/ads/onweb/

Alternatively, you can contact the Digital Advertising Alliance at www.aboutads.info to find out how to set cookies and to make the relevant settings. Finally, you can set your browser so that you are informed about the setting of cookies and decide individually whether to accept them or to exclude the acceptance of cookies for certain cases or in general. If cookies are not accepted, the functionality of our website may be limited.

Further information and the data protection regulations regarding advertising and Google can be viewed at: http://www.google.com/policies/technologies/ads/

 H. Intercom Live Chat Services

Use of Intercom Services: We use third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you visit our website or use our product. As a data processor acting on our behalf, Intercom analyzes your use of our website and/or product and tracks our relationship by way of cookies and similar technologies so that we can improve our service to you. For more information on Intercom's use of cookies, please visit https://www.intercom.com/legal/cookie-policy. We may also use information collected through Intercom as a medium for communications, either through email or through messages within our product(s). The Intercom Messenger Apps and Apps in Inbox products may also provide you with access to other third party applications such as Stripe. You should consult these third parties' privacy notices for further information on their use of your personal data. As part of our service agreements, Intercom collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. For more information on the privacy practices of Intercom, please visit https://www.intercom.com/legal/privacy. Intercom’s services are governed by Intercom’s terms of use which can be found at https://www.intercom.com/legal/terms-and-policies. If you would like to opt out of having this information collected by or submitted to Intercom, please contact us.

I. PushOwl Website Notifications

We engage third-party providers to deliver updates to customers via web push notifications, where express consent is provided. These notifications include website updates and direct marketing purposes.
Our third party provider collects personal and non-personal information needed to perform their functions. To view the information collected and to view the compliance for Push-Owl website notifications, please visit here.
If you subscribed to receive notifications from your browser and wish to unsubscribe from Push Notifications, please visit this link  and follow the instructions related to your Browser.

K. Online Fitting Consultations 

Your personal privacy is important to us. Our online fitting consultations are conducted in private with experienced fit specialists to provide assistance on fit and product information. We engage third-party providers to deliver our online fitting consultations. These providers collect personal and non-personal information needed to perform their functions. We use this information to communicate with you for fitting appointments.  
For the booking of an online fitting consultation, we engage Calendly as a third-party provider that operates the appointment booking tool and captures relevant information required to confirm. To view the information collected, how it is stored and used, please visit https://calendly.com/pages/privacy 
Zoom Video Meetings are used for the private one-on-one consultations between staff and customers who book a service. These video meetings are not recorded by Triumph or Zoom. To view the information collected, how it is stored and used, please visit https://zoom.us/privacy  
When your consent is provided during your booking, we may send you more information on services, products and promotions that may be of interested to you as marketing communication. You may unsubscribe at any time by email at queries.au@triumph.com

J. Product Ratings & Reviews

We use reputable third-party provider, Bazaarvoice for the gathering of Rating and Review information, where a customer has provided this via a submission form. These reviews are used for display and marketing purposes. Our third-party provider collects personal and non-personal information needed to perform their functions. To view the information collected and how it is used, please view: https://www.bazaarvoice.com/legal/privacy-policy/

Six

Data Protection Rights

You have the right to ask us not to process your personal information for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your information. You can also exercise the right to withdraw at any time by contacting us at queries.nz@triumph.com.

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal information to these websites.

SEVEN

Access to Your Personal Information

You have a right to access any of Your Information that we hold. If you would like to access Your Information, please contact us using the contact details set out below. We reserve the right to charge an administration fee for searching for and providing that information to you.

You may also use these contact details to notify us of any privacy complaint you have against us, including if you think that we have failed to comply with the Australian Privacy Principles (APP). We will acknowledge your complaint promptly and give you an estimated timeframe within which we will respond to your complaint. We will seek to resolve any complaints with you directly. However, you may wish to lodge a complaint with a regulator such as the Australian Information Commissioner (www.oaic.gov.au).

EIGHT

When We Disclose Your Information

We may need to disclose Your Information to organisations outside of Triumph for any of the uses outlined in "How Your Information is Used". Any disclosure of Your Information in this way is limited to what is required for us to provide products and services to you. These organisations carry out various functions for us including information technology services, customer enquiries, ratings and reviews, debt-recovery functions, installation, maintenance and repair services, marketing, telemarketing and market research and website analysis.
All reasonable measures are taken to ensure that these organisations are bound by confidentiality and privacy obligations in relation to Your Information.

A. We may also disclose your information to:

• our employees, contractors or service providers to the extent reasonably necessary to fulfil our obligations to you;
• our business advisors, including lawyers, accountants or other professional service providers to the extent reasonably required;
• suppliers and other third parties with whom we have commercial relationships, for business, marketing and related purposes;
• if you are a candidate for an employment position involving a third party with whom we have an agreement, to that third party to assess your application; and
• Government and regulatory authorities and other organisations, as required or authorised by law.

B. Overseas Disclosure

We may disclose your personal information to service providers and third parties overseas. We take all reasonable steps to ensure that overseas recipients of your information do not breach the privacy obligation which apply to your information.

We may disclose your personal information to the following locations:

• India, for finance processing including but not limited to invoice payment and processing, credit management, and cash applications.
• India, for third party support application Push-owl notifications
• Germany and Switzerland to our global brand management team
• Australia to our Australian head office
• New Zealand to our New Zealand office
• USA for third party support applications Zoom and Calendly

NINE

Contact Us

If you have any questions or concerns regarding your personal information, please contact our Data Protection Officer in New Zealand by email at queries.nz@triumph.com or the Data Protection Officer for Europe by email dpo@triumph.com. 

Triumph Privacy Policy May 2018
Triumph IRD No. 52-049-288