Privacy Policy

Disclaimer

We utilise this privacy policy for your personal data in all areas of our business including where necessary for the creation and delivery of orders, information, services or any other reason we may advise you of and seek your consent for prior to using your personal data. We may communicate this to you via any of the contact methods you have provided where appropriate and by which we are likely to receive a prompt response. This privacy policy forms part of our Terms and Conditions for which acceptance is required when using our website, any information we may provide and any services we may provide either through the website, phone, written (e-mail or postal) or in person.

Section 1: Who Are We

Primal Desires is a registered business in the state of Queensland and the Commonwealth of Australia in accordance with the Australian Securities and Investments Corporation and the Australian Taxation Office using our Australian Business Number (ABN) 65595474350 and we are the controller of your personal data stored with us. Any references in any policy, statement, document or other information provided by us to “Primal Desires”, “this business”, “our”, “we” or “us” refers to Primal Desires (and includes any subsidiaries, affiliates, individuals directly associated). All references to “our website” is in relation to the website owned and operated by Primal Desires and its registered owner.

Section 2: Who This Policy Applies To

1. all visitors, users and customers; and
2. any individual who chooses to create a profile with us; and
3. any individual who consents to be a recipient of products and or services provided by us. Subject to your relationship with us, we may request to collect and use your personal data in different ways.

With respect to this, you have various rights in how we use and where we store your personal data. These have been set out below in the section “Your Rights”. Specifically, you have the following 3 fundamental rights to be aware of:

1. You may choose to give your personal data where this is required to us to allow us to complete the transaction which you have engaged us in and separately should you wish to provide us with any personal data which may allow us to enhance the products and services we provide to you; and
2. You may request us to stop using and remove your personal data for any reason and that if you exercise this right, we will stop using your personal data for the purpose given provided it does not prevent us from using your personal data under certain exemptions necessary for us to comply with our own legal obligations or as necessary to establish, exercise or defend legal claims in accordance with the appropriate governing laws of Queensland and the Commonwealth of Australia; and
3. You may request us to consider any valid objections you may have regarding the use and storage of your personal data.

Section 3: What You Can Expect

1. Your consent will be requested whenever we feel there is a need to collect any personal information regardless of whether or not it may be personally identifiable. Some of the data we might request (this is not a complete list and additional data maybe requested at a later date or discarded securely) is as follows:
   • Your legal name (Only where it is absolutely necessary)
   • Your e-mail address
   • Any addresses you might provide us for billing and delivery
   • Any phone numbers you might provide
   • Date of Birth (Only if you wish to provide it – we use this for verification of age and for other purposes related to our P D Club membership program)
   • Preferred Gender & Pronouns (optional – We do want to be able to address you correctly)
   • Photo ID (optional – Used for verification of identity and age with the image securely deleted once verification is carried out)
   • Social Media profile names
   • Payment Information (While we do not keep payment data on our systems, we use a special secured token linked to your profile with payment gateways who may store your payment details in accordance with their own privacy policies and terms of use. Please refer to the relevant payment services to review their privacy policies and terms of use.)
   • Technical information such as your IP address, browser type and version, operating system and time zone setting (Collected and recorded automatically as part of our data tracking and does not individually identify you.)
   • Data about your visit and behaviour while using our website including but not limited to the pages and products you click on. This may include the full website address (URL) that you follow to us, through and from our website including the date and time, page response times, errors, interactions such as clicks, mouse-overs, scrolling and form fields that are completed, and also any methods used when leaving our website
2. We will respect your privacy and strive to ensure all strict regulatory requirements are met and if possible, exceeded.
3. We will only provide the data you consent to give to us to a third party when absolutely necessary for your order to reach its intended destination to delivery services and payment gateways. We will not sell or provide any data regardless of the level of sensitivity to any third party unless compelled to do so by a legal authority with a court order or other form of written request by a governing legal body such as courts or police.

Section 4: Use of Your Data

Primal Desires may use this information for a number of purposes however this does not and never will include providing data to a third party beyond what is necessary to complete the order transaction. Other purposes we may use the data for include:

• Direct e-mail marketing if consent is given for such marketing
• Newsletter subscription – We use a secure digital mailing service for processing and distribution of our digital newsletter and only the e-mail address is provided
• Billing and delivery services
• Optional verification of identity and age to minimise the risk of fraud and provision of inappropriate material to minors and/or vulnerable individuals
• Customising our website, products and services to your individual preferences
• For the security of this website and business
• To allow you access and use of our website including access to any protected areas such as your user profile and age restricted material
• To allow us to align our communications and protection of your data when we communicate to you via any social media accounts we operate
• To manage any enquiries or issues you may have including the request of any additional information necessary to complete the enquiry or resolve the issue
• Where you have consented to receive our newsletter or other communications including any order status e-mails and follow-ups, order tracking data, membership and associated subscription information and general and administrative communications which may be necessary from time to time (for example, any changes to our policies, terms and conditions, etc)
• To comply with any procedures, regulations or laws which might be applied to us as a business and as individuals

Section 5: Storage of Your Data

We keep all data collected in relation to this website and for internal uses on secure servers located in Australia and on secured and wholly owned equipment belonging to Primal Desires management. Only data needed to complete transactions is provided to third parties such as payment gateways and delivery services, and this data may be stored on services and equipment in other countries other than Australia. We require all of these third parties to have adequate policies and procedures in place to ensure the protection of your data and your rights as an individual.

Section 6: Protection of Your Data

Primal Desires employs a number of methods to protect your personal data and for the security and integrity of this website.

• Minimal access to stored data by Primal Desires management and associated staff. This includes limiting who has access to what data for the purposes of completing their assigned tasks.
• Password encryption
• Restricting one user profile per e-mail address
• Regular scans and removal of any suspicious profiles
• Automated checks for fraudulent orders which place an order into a holding queue should it reach a prescribed level requiring additional manual checks
• SSL Certificate so that you are aware our website has no insecure data when viewing it
• Payments will appear on your bank statement as “P D Sales”
• Providing only essential data to third parties for the purposes of obtaining payment or delivery services
• Discrete packaging in a plain box or satchel showing only your stated delivery contact name, delivery address, delivery phone contact  and a return address to us
• Our return address will simply be shown as from “P D Sales” with our parcel locker or P.O. box address
• Signature on delivery (or other form of delivery confirmation such as photo of parcel left at intended destination) requested for all orders unless otherwise stated on a per order basis
• Double Opt-in for newsletter subscriptions

Primal Desires and its trusted payment gateway providers follow the Payment Card Industry Data Security Standards (PCI-DSS) in relation to the handling and where requested, storage of customer debit/credit card data providing protection from unauthorized access, disclosure and alteration. With reliable, robust controls over access, encrypting of your data whilst in transit to the payment gateways and when held either temporarily or permanently in storage and combined with protection using AI-driven firewalls, anti-virus and anti-malware software on multiple levels, we work to ensure your personal data is kept safe and secure at all times.

Additional protection may be implemented including optional two factor authentication (2FA), use of strong passwords, double opt-in requirement for creating a profile, challenge questions for password resets and session time-outs. These will be added where possible and necessary to ensure the protection of your personal data and the security of the website. As part of the general maintenance of the website, Primal Desires management make sure that all servers, equipment and any software used to create the website and or store data are kept up to date at all times and instant reporting of all administration logins, unauthorised login attempts, data breach attempts and any actions that may have been taken automatically to prevent breaches and unauthorised access.

Section 7: Your Rights

In accordance with regulations and legislation, Primal Desires does not seek to impede your rights as an individual in relation to your personal data. You have, but not limited to, the following rights in relation to your personal data:

• Right of Access and to be informed
  You have the right to have access to any personal data you provide us and which we currently hold about you. You can request a copy of the personal data, whether we are using your personal data and the purposes and reasons it is being used for, details of protections we have in place should we need to transfer your personal data to any other party as required for the completion of order transactions and for legislated or court ordered requirements.
• Right to Erase
  You have the right to request us to erase your personal data for certain purposes such as marketing and profile data. We will inform you should we need to retain any personal data for the integrity of our internal order data which is kept for a period of time as deemed necessary by any regulation or legislation that might be imposed on us at any given point.
• Right of Objection
  You have the right to object to us continuing to use your personal data for certain purposes without restriction. Should you wish to exercise this right, we will make every effort to immediately stop using your personal data for these purposes.
• Right to Rectify
  You have the right to request us to update your personal data where it is out of date or incorrect. We will provide access to you where possible and consented to, the ability to also update your own personal data without interference from Primal Desires. We may where necessary correct the format of some data to comply with how our systems store your personal data and where we use your data for certain purposes such as delivery addresses being formatted correctly for the destination it is going to and the delivery service being used.
• Right to Portability
  You have the right to request us to provide your personal data only as necessarily required to a third party for the provision of services under specific and certain conditions. This only applies where we use your personal data with your consent or in the performance of a contract such as fulfilling your order whether by automated or manual means. You have the right to know the identity of the third party where we are able to provide this information, how they will use your personal data and the type of personal data they require.

For the intention of clarity, when we provide information to a payment gateway, this may include your full name (or preferred name if a full name is not essential), billing and shipping addresses, contact information (e-mail & phone), payment details and list of order items (if needed – in most cases we only need to provide a product code that does not fully identify the item) and total payable. In relation to delivery services, this may include the delivery contact name (this may be a preferred name if the recipient consents to you using this), delivery address (you must have the recipient’s consent if the delivery address is not your own) and contact information (e-mail address and/or phone number). Where we have doubt about the consent of using data provided, we will either contact you and/or the recipient if the effort to do so is not disproportionate.

Should at any time there be an exception to your rights above or in relation to any other rights you may have, we will advise you when responding to your request and as soon as physically possible (and no later than within 28 days or as stated by an applicable law unless we inform you that an applicable law allows us a longer period). Some personal data may be exempt from such requests under certain circumstances such as the need to keep using/storing information to comply with our own legal obligations or to establish, exercise or defend legal claims under the governing laws of the state of Queensland and Commonwealth of Australia.

Primal Desires reserves the right to refuse or question your request under these rights where we are not reasonably satisfied of your identity either when it was originally provided or when confirming your identity for the purposes of carrying out the request. We may request you provide us with sufficient information necessary to verify your identity before carrying out any request made. We may also use external data and other checks for verification such as data matching and validation to minimise risks such as fraudulent orders and requests to access restricted data including your own personal data where the use of any external sources does not require your personal data to be transmitted to a third party without your prior consent.

Section 8: Cookies and Session Data

Primal Desires only makes use of cookies and session data necessary to carry out any transactions during your visit to our website. The contents of these cookies and session data is not passed to any third parties and we have gone to extreme lengths to ensure even anonymous data is not collected by third parties where we have control of this. Please note that your own web browser and other associated software or devices may collect data whilst you are visiting our website and we have no control over the configuration of your software or devices in this regard.

Section 9: Google and The reCAPTCHA Service

We utilise Google’s reCAPTCHA service on any forms including registration, login, order and contact forms to minimise spam that may be submitted through those forms. Google has its own privacy policy and terms of use in relation to this which can be found at the bottom of the footer of every page and listed here for additional convenience.

Google Privacy Policy & Terms of Service

Section 10: Third Party Website Links

The Primal Desires website and e-mails may contain links to other websites that are not operated by us and therefore not under our control. While these links are provided for your reference and to facilitate convenience in providing you with the most current information available to us at the time, we do not endorse the activities of such third party websites or any association with the owners or operators of these websites and cannot accept any responsibility or liability for the content of these third party websites, their terms and conditions or policies that they may have. We cannot be held responsible for any personal data you may provide to these third party websites or that maybe collected about  and stored by the third parties. These websites and the businesses and individuals that own and operate them will have their own terms and conditions and privacy policies which we encourage you to read carefully before you provide any personal data to them.

Policy Changes

Primal Desires may update this policy and any other policy or terms and conditions we have from time to time. Notification of updates will, where appropriate, be sent to you via e-mail should they directly or indirectly affect how we use and store your personal data. Any changes we make to our policies and terms and conditions will appear on this page or other pages where relevant and a site-wide notification will be shown in the form of an on-screen message that you can dismiss if you choose (it will reappear if you visit and start a new session until we remove the need for it after 3 days) and as a News Update post that can be found on the Latest Updates section of this website located under the News & Blog menu option.

Further Questions and Making a Complaint

Any queries or complaints about how we collect, manage and store your personal data or if you wish to exercise your rights in relation to your personal data, please contact us directly:

E-mail: cs@primaldesires.com.au

or

Phone: (07) 3568 8900 (Australia)  or  +61-73568-8900 (International)

or

Post:
Primal Desires
P.O. Box 107,
Sunnybank, QLD, 4109
Australia