Privacy Policy

1. Our Privacy Policy

1.1. Bowen & Pomeroy Pty Ltd ACN 004 174 887 (We, us, our) respects your privacy and is committed to protecting your personal information. Our privacy policy outlines our approach to privacy and how we collect, use and protect your personal information and sets out your rights in relation to accessing the personal information we hold about you.
1.2. Personal information is defined in the Privacy Act 1988 (Cth) and means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
1.3. We are bound by the Australian Privacy Principles contained in the Privacy Act.

2. How we collect personal information

2.1. We only collect personal information you give us directly, or which is collected automatically as part of your activities or membership with us (including usage data or cookies on our website (Site)). For example, when you:
2.1.1. make a purchase or enquiry;
2.1.2. register for an account or program;
2.1.3. subscribe to marketing communications;
2.1.4. complete electronic and paper forms;
2.1.5. call us, email us or interact with us via SMS or social media;
2.1.6. visit or use our Site;
2.1.7. send us information via the ‘Contact Us’ page on our Site;
2.1.8. send us information when using any part of our Site; and/or
2.1.9. view electronic communication that you receive from us, including where you open emails, the links you view from the email and what webpages you view from the email and the number of pages viewed.
2.2. When we collect personal information, we will ensure the individual has given consent or there is some other lawful basis for collection and processing. At or before the time of collection (or as soon as practicable afterwards), we will notify you of the matters required by the Australian Privacy Principles, including why we are collecting the information, who we may give it to, and how we will use or disclose it.

3. What personal information we collect

3.1. The personal information that we collect includes:
3.1.1. identifying information, including your name, contact details including your email, home address and billing address;
3.1.2. transactional information, including information you provide as part of a transaction with us or that is generated as a result of that transaction or historical transactions;
3.1.3. information about your account or membership with us;
3.1.4. financial information, including payment details, credit card numbers or bank details;
3.1.5. information we are required or authorised to collect and process under law to identify you or verify information you have provided;
3.1.6. usage information, including data about your interaction with our website through devices you use; and
3.1.7. computer and connection information such as page views, traffic, uniform resource locators (URLs), internet protocol (IP) address and web log information.
3.2. When you visit our Site, we may place cookies on your browser to enhance and manage our website and improve our business and the services we provide to you. We and/or Google may use this information to optimise and place advertisements, including advertisements of third party vendors, on our own and third party websites. Google’s ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Use and Privacy Policy. Cookies can be managed by accessing the individual settings in your browser.
3.3. Our Site does support “Do Not Track” requests.
3.4. We may collect personal information from people who are not customers or suppliers of our business but whose personal information is given to us by those individuals via our Site or in the course of a transaction or recruitment. If you give us information you must only do so with that individual’s authorisation and you should inform them of this privacy policy.
3.5. We do not generally collect sensitive information. Where we do collect sensitive information, we will obtain your consent and comply with the Australian Privacy Principles relating to sensitive information.
3.6. If we receive personal information that we did not solicit, we will determine whether we could have collected the information in accordance with the Australian Privacy Principles. If we determine that we could not have collected the information, and it is lawful and reasonable to do so, we will destroy or de-identify that information as soon as practicable.
3.7. Our services are not intended for children and we do not knowingly collect personal information from individuals who are children.
3.8. We may use social media (including LinkedIn, Facebook, Instagram and/or YouTube) to communicate with you or the public. We may collect personal information that you provide us via social media for the purposes of engaging and consulting with you. Any personal information we collect via social media will be handled appropriately in accordance with this privacy policy. Social media platforms may also collect your personal information for their own purposes and when you agree to their terms of service and privacy policy, you may be agreeing to your personal information being transferred outside Victoria, or Australia. To protect your privacy and the privacy of others, you should refrain from posting any personal information (including phone numbers and email addresses) in your comments or replies.

4. Why we collect personal information

The purpose for which we collect personal information is to enable the effective provision of our services to you and our other customers, including to:
4.1. execute your requests for our goods and services;
4.2. process your transactions and manage your accounts;
4.3. improve and optimise our services, business and our users’ experience;
4.4. send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
4.5. send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting, including via email, SMS or post, unless you inform us that you do not consent to receiving such direct marketing communications. You may opt out of receiving direct marketing communications at any time by using the unsubscribe facility in our electronic communications, contacting us using the details in clause 9.1, or notifying us by any other reasonable means. We will give effect to your opt-out request within a reasonable period. Upon request, we will notify you of the source of the personal information we used for direct marketing purposes, unless it is impracticable or unreasonable to do so. Our electronic marketing activities will comply with the requirements of the Spam Act 2003 (Cth);
4.6. administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
4.7. comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
4.8. consider your employment application (if applicable).

5. When we will use, process or disclose personal information

5.1. We will only use, process or disclose your personal information for the primary purpose for which it was collected or otherwise as relevant national laws allow. We may otherwise use and disclose your personal information to detect, prevent and investigate fraudulent behaviour, if you have given us consent for the use or disclosure or it is required or authorised by law.
5.2. If those purposes for which we have collected the information involve providing personal information about an individual to any third party, we will take appropriate and reasonable steps to ensure any personal information is protected.
5.3. We may disclose personal information for the purposes described above to:
5.3.1. our employees and related bodies corporate;
5.3.2. data processors, including third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
5.3.3. professional advisers, dealers and agents;
5.3.4. payment systems operators (e.g. merchants receiving card payments);
5.3.5. our existing or potential agents, business partners or partners;
5.3.6. our sponsors or promoters of any competition that we conduct via our services;
5.3.7. anyone to whom our assets or businesses (or any part of them) are transferred;
5.3.8. specific third parties authorised by you to receive information held by us; and/or
5.3.9. other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

6. Where your personal information will be held and processed

6.1. We will process your personal information on servers in Australia.
6.2. We will provide your information to third parties that provide services to us solely for the purpose of providing those services, including third parties that provide our payment gateway, marketing and technology support services. This may include providing your information to third parties that are located outside of Australia.
6.3. Where your personal information is transferred outside Australia (including to the United States of America, United Kingdom, India, Bangladesh and the European Union), we will take reasonable steps to ensure that overseas recipients do not breach the Australian Privacy Principles in relation to that information. We remain accountable for the handling of your personal information by overseas recipients. Before disclosing your personal information to an overseas recipient, we will either obtain your consent to the disclosure, take reasonable steps to ensure the recipient is bound by a law or binding scheme substantially similar to the Australian Privacy Principles, or ensure the recipient is subject to contractual arrangements requiring Australian Privacy Principles compliant handling of your information.

7. Security and retention of personal information

7.1. We take reasonable steps to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure and against other misuse. For example, we use two factor authentication. However, we cannot guarantee the security of your personal information.
7.2. We will only use, process or store personal information for as long as required for the purpose for which it has been collected, including where such purpose relates to our legitimate interests, and for a longer period where you have given consent to such processing, as long as such consent is not withdrawn. We may be obliged to retain personal information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. When your personal information is no longer needed for any purpose for which it may be used or disclosed under this policy or applicable law, we will take reasonable steps to destroy or de-identify that information, unless we are required by law to retain it.

8. Third parties and information you receive through us

8.1. Our Site may contain links to third party websites. We are not responsible for the privacy policies of any third party websites. We recommend that you review the privacy policy of each website you visit.
8.2. Where you transact with another person or entity through us, we may enable you to obtain the personal information of that person or entity. You acknowledge that in these circumstances you are the data controller of that data and you should, where required, inform that other person about your privacy practices and otherwise comply with relevant national laws.
8.3. Using the personal information of any person you receive through us for any other purpose other than to perform the transaction we enable is prohibited by this policy.

9. Your rights and our complaints procedure

9.1. You may contact us to make a compliant or enquiry in relation to your personal information via the details below:
9.1.1. by post:

Bowen & Pomeroy Pty Ltd
48–52 Hallam South Road
Hallam VIC 3803

9.1.2. by email: [email protected]
9.2. You have certain rights in relation to the personal information we collect and hold about you. We will allow an individual to:
9.2.1. know what personal information we maintain about you and request a copy of your personal information, which we will provide within a reasonable period (and in any event within 30 days of receiving your request) in a form requested by you, if it is reasonable and practicable to do so. We may charge a reasonable fee for providing access but will not charge for making a request. We may refuse access in certain circumstances permitted by law, such as where providing access would have an unreasonable impact on the privacy of others, or where the request is frivolous or vexatious. If we refuse access, we will provide you with written reasons for the refusal; and
9.2.2. request us to correct information we hold about you to ensure the personal information we collect and hold is accurate, up to date and complete.
9.3. In addition to the information contained in this privacy policy, we may provide you with additional information concerning particular services or the collection and processing of personal information upon request.
9.4. To make a complaint about how we handle your personal information, you may contact us. We will respond to your complaint within a reasonable time after it is received. If you are not satisfied by our response, you may acquire further information regarding privacy from the Office of the Australian Information Commissioner.
9.5. We may make changes to this privacy policy at any time by giving notice on this page and, as far as technically and legally feasible, sending a notice to you. We recommend you check this page often, referring to the effective date of the last modification listed at the bottom.

Effective: 17 April 2026