Privacy Policy

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This Privacy Policy sets out our commitment – that’s us, Toothy HQ (ABN 15 763 463 427 ) trading as Tinkle Co (“Tinkle”, “we”, “us”) - to protecting the privacy of personal information we collect about you, including through our website (which you’ll find at www.tinkleco.com.au) as well as through our other business operations or directly from you.

Please read this Privacy Policy carefully. We understand that reading legal documents can be painful, so we’ve tried to make all of our legal documents as easy to understand as possible. Feel free to contact us using the details below if you have any questions.

By giving us personal information, you’re indicating that you have had sufficient opportunity to access this Privacy Policy and that you’ve read and accepted it and consent to the collection, use, holding and disclosure of your personal information as outlined.

If you don’t want to provide personal information to us, then you don’t have to, however this may affect your use of this website.

1. Types of personal information we collect

    The types of personal information we collect may include your:

    • Name
    • Address(es)
    • Telephone number
    • Email address(es)
    • Credit card details (please note that credit card information isn't stored by us, but by the billing provider we use on the website)
    • Other contact details

    If you would like to deal with us anonymously or use a pseudonym, feel free to do so. However, there isn’t much point in sending your Tinkle toothbrushes to a fictitious address, so please provide a real email and postal address when signing up for our subscription toothbrush service.

    2. How we collect personal information

      We collect the above information from you when you make an enquiry with us (for example, by telephone or email), purchase a subscription for our Tinkle toothbrushes from us, sign up for a service via our website (such as our newsletter) or submit a contact enquiry on our website.

      We are committed to using lawful and fair means to collect personal information and will collect personal information about you only from you, your searches and enquires and your use of our website, unless you give consent to us to collect your personal information from a third-party.

      Third parties may also use cookies, web beacons and similar technology to collect or receive information from our website or from you and from elsewhere on the internet and use that information to provide measurement services and targeted advertising (such as the Facebook pixel, Google Analytics and AdWords). If we receive your personal information from third parties, we will protect it as set out in this Privacy Policy.

      We will destroy or de-identify information where we believe that the information has been provided to us unlawfully or unfairly or if we no longer need the information.

      3. Why we collect, hold, use and disclose personal information

        We collect, hold, use and disclose your personal information as is reasonably necessary for us to perform our core functions and activities, including for the following purposes:

        • to contact and communicate with you
        • to provide Tinkle toothbrushes or other goods to you
        • to maintain a database of customers, subscribers or similar
        • to market to you and others, including remarketing (this may involve the use of a Facebook pixel or similar technology to allow us to display our advertising to you elsewhere on the internet, for example, on Google or Facebook)
        • for internal record keeping
        • for statistical purposes
        • as required by law

        Where we disclose your personal information to third parties for these purposes, we will do our best to ensure that their Privacy Policy adheres to similar standards of privacy protection and/or request that they follow this Privacy Policy regarding handling of your personal information. We will also be diligent in ensuring that the personal information we disclose is accurate, up-to-date, complete and relevant.

        We will not use or disclose personal information for the purpose of direct marketing unless you have consented to the use or disclosure of the information for that purpose.

        We will not disclose your personal information to overseas recipients.

        Please note that we will not disclose your personal information for any purpose other than the purpose for which it was collected without your consent, unless we are required to do so by law.

        4. Use of cookies

          As you probably know, a cookie is a small text file that’s placed on your computer to help us remember your preferences, like your login information or location. Cookies are used for a variety of reasons. We use cookies to make it easier and faster for you to use our website. We also use cookies for security purposes to protect you online. We and our third-party vendors may also use cookies to display advertisements to you elsewhere on the internet.

          5. Links to other sites

            For your convenience we sometimes include links to other helpful websites from our website (such as to the organisations supported by Tinkle through your toothbrush purchases). Please note that this Privacy Policy only applies to information that we collect on our website (not any other website). As we aren’t responsible for data collection on those other websites, our Privacy Policy won’t apply. We can’t guarantee any of the privacy practices of other websites, so please be safe and make sure you read their privacy policy before giving them your personal information.

            6. How you can access and correct your personal information

              Access: You can request details of personal information that we hold about you in certain circumstances set out in the Privacy Act 1988 (Cth) (the Act). We may refuse to provide you with information that we hold about you in certain circumstances set out in the Act in which case we will provide you with written notice setting out our reasons for such refusal. Otherwise, we will endeavour to provide access to the information if it’s reasonable and practicable to do so. In most cases we’ll do this free of charge, but if your request requires significant effort or expense on our part, we might ask you to compensate us for that.

              Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details set out below. We rely in part on you advising us when your personal information changes. We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date and to notify you and any party we have previously disclosed your information to (if relevant) of the correction, unless it is impracticable or unlawful to do so.

              Deletion: If you want us to delete personal information we hold about you or to not collect information from you for a specific purpose, such as targeted advertising, please contact us using the details set out below. Please note that if we agree to delete your information, because of backups and records of deletions, it may be impossible to completely delete your information without retaining some residual information. We will functionally delete the information and we will not sell, transfer, or use personal information relating to you in any way.

              We will respond to any request to access, correct or delete information within a reasonable time.

              7. How we maintain the security of your information

                We are committed to ensuring that the personal information we hold is secure and protected from misuse, interference, loss and unauthorised access, modification or disclosure. We undertake the following precautions to protect personal information we hold:

                • our website contains pages encrypted with SSL (Secure Sockets Layer) to ensure the safety of any data that is submitted through use of this website
                • your membership portal on our website is password protected
                • our website is hosted within Australia on Australian-based servers
                • we limit access to personal information to a “need-to-know” basis
                • we protect devices we use to collect, hold, use and disclose personal information with industry-standard anti-virus software
                • our devices are protected by cryptographic keys and are stored in secure premises
                • data is securely stored on secure servers
                • our email data is encrypted
                • all hard copies of personal information are kept in secure storage with access by authorised personnel only
                • all conversations involving the discussion of personal information take place in private, where conversations are unable to be overheard by unauthorised personnel
                • if we no longer need personal information, we take reasonable steps to delete or de-identify the information

                While we take commercially reasonable measures to maintain a secure website and business, electronic communications and databases are subject to errors, tampering and break-ins, and we cannot guarantee or warrant that such events will not take place and we will not be liable to you for any such occurrences. If a data breach occurs involving your personal information and the breach is likely to cause harm to you, we will notify you as soon as possible after the occurrence in accordance with our obligations under the Privacy Act and related legislation.

                8. How you can make a complaint about a privacy breach

                  If you believe that we have breached this Privacy Policy and want to make a complaint about that breach, please contact us using the details set out below. If you are unsatisfied with our response, the Office of the Australian Information Commissioner may be able to assist you with a review of our decision. Contact the OAIC for more information.

                  9. How you can unsubscribe or opt out

                    We like to keep our customers and website visitors up to date, so from time to time we’ll send you newsletters, invitations and updates. Not to worry: our emails will always come with an "Unsubscribe" button, so you can opt out at any time. To unsubscribe from our email database, or opt out of communications, use the “Unsubscribe” button in our communication or contact us using the details set out below.

                    You can block the use of cookies by selecting the appropriate settings on your browser. You can opt out of third-party vendor cookies by visiting your Google’s Ad settings or http://www.networkadvertising.org/managing/opt_out.asp. Please note that the website may not work as well for you if you disable cookies.

                    You can also opt out of information collecting for advertising targeting by visiting www.aboutads.info/choices.

                    10. Changes to this policy

                      If we decide to change our Privacy Policy, we'll let you know by posting such changes on our website.

                      11. Contact details

                        For any questions or notice, please contact us using these details:

                        Kate Cashman

                        E: hello@tinkleco.com.au

                        This Privacy Policy was last updated: 5 March 2019