Spotlight Stores Privacy Policy

Spotlight Privacy Policy

Our privacy commitment

Spotlight Stores Sdn Bhd (My COID 1063748-V) (“Spotlight”, “we” us”) is committed to protecting the privacy of your personal information. We manage your personal information in an open and transparent way.

Spotlight will only use your personal information when it is necessary for us to deliver you a service or perform other necessary business functions and activities.

Spotlight will not use or disclose your personal information for purposes unrelated to the services we provide, unless we first obtain your consent.

Our privacy obligations

This privacy policy sets out how we comply with our obligations under the

Personal Data Protection Act 2010 (Malaysia)

Spotlight is bound by the requirements of these laws, which regulates how we may collect, use, disclose and store personal information.  These laws also specify how individuals may access and correct personal information held about them.

“Personal Information” means any information in respect of commercial transactions that relates directly or indirectly to a data subject, who is identified or identifiable from that information, including sensitive personal data (data relating to health, commission or alleged commission of an offence, political opinions or religious beliefs or other similar beliefs) and expressions of opinion. For example, these types of information could include your name, contact details, age and health information.

By visiting our websites and/or providing your personal information or data to us, you consent to the terms and conditions in this Privacy Policy, unless you tell us to the contrary by contacting us.

This privacy policy is effective from June 2014. From time to time, our policies and procedures will be reviewed and, if appropriate, updated.  If any changes are made to this policy these will be posted on our websites.

How and why does Spotlight collect and hold your personal information?

Spotlight will only collect personal information about you by lawful and fair means, and not in an unreasonably intrusive manner.

It is Spotlight’s usual practice to collect personal information directly from you when you:

submit a Spotlight VIP club registration form or amendment form;

submit the Kids Club application form;

register with any of our other loyalty or marketing programs;

place an order via the Shop-At-Home service or complete any online form on one of our websites or online payment gateways;

visit or use a Spotlight website (including any forums);

subscribe to marketing and sales material or communications;

complete an online form on one of our social media channels;

enter a trade promotion or competition;

register a gift card;

complete an online form on one of our online advertisements that is placed on a third party website;

complete a hard copy form or provide information in one of our stores;

complete and return to us a hard copy form that is provided with one of our products;

complete and return to us a wholesale account application form;

request delivery of products;

make a purchase, return or exchange a product where we request you to verify your identity;

speak with us, or one of our representatives directly during a product or sales enquiry; 

contact us directly by telephone, via mail, e-mail or online;

apply for employment with us or respond to a job application;

wish to do business with us.

We may collect personal information about you from a third party or a publicly available source, but only if you have consented to such collection, or would reasonably expect us to collect your personal information in this way. 

Where we can, we will allow you to deal with us anonymously or by using a pseudonym. However, in some circumstances, this may not be possible, and Spotlight may need to collect personal information from you to provide you with a delivery or other service, to consider you for employment or to offer you employment or to engage you as a vendor/supplier. In some cases, if you do not provide the required personal information we will not be able to provide you with a service, offer you employment or consider you for employment or engage you as a vendor/supplier.

What kind of personal information does Spotlight collect and hold?

Any personal information that you provide via our websites or directly is collected and managed by Spotlight.

If you provide your personal information to a third party via a link from a Spotlight website, that information is collected and managed by those third parties. You should familiarise yourself with their privacy policy prior to deciding whether you wish to provide them with your information.

The types of personal information Spotlight may collect includes your:

name;

date of birth;

gender;

marital status and family details;

residential, business and postal address;

email address;

contact telephone numbers;

identification details;

testimonials or opinions;

if you are a job applicant or an employee, information relating to your past and current employment, your resume or CV;

if you are a supplier or vendor, your trading history;

photos of you;

financial information, such as bank accounts and credit card details;

written or verbal contact with Spotlight, including voice recordings of telephone conversations you have had with our employees; and

activities, including but not limited to lifestyle and other interests.

Whilst you may opt not to provide us with your personal information, you should be aware that without this personal information, we may not be able to provide you with some of the services and/or products you are seeking, offer you employment or consider you for employment or engage you as our supplier/vendor. 

If you provide us with information about any third party, you must obtain that person’s permission to give us the information and inform them that you have given the information to us.

How does Spotlight use your personal information?

We use your personal information for a variety of reasons including to:

Customers

contact you in relation to one of our loyalty or marketing programs;

provide services and products to you;

answer your inquiries and deliver customer service to you;

to tell you about other products that we think may be of interest to you;

to enable us to undertake a credit assessment;

maintain and improve customer services;

to manage your gift card balance;

Employees or job applicants

to consider making offers for employment purposes;

to undertake employment, human resource and payroll related functions;

Vendors or suppliers

to manage our business dealings with you;

to enable us to undertake a credit assessment;

Generally

manage and resolve any legal, consumer or commercial complaints and issues;

carry out internal functions including training; 

conduct marketing research and analysis; and

meet our legal obligations;

In what circumstances will Spotlight disclose your personal information?

In the course of conducting our business or providing our products and services to you or employing you or doing business with you, we may disclose your personal information.

We only disclose personal information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or activities.  We do not give it to anyone else unless one of the following applies:

you have consented to the disclosure;

you would reasonably expect, or have been told, that your information is passed to those individuals, businesses or agencies; or

it is otherwise required or authorised by law.

Who do we disclose your personal information to?

We may disclose your personal information to:

another Spotlight business or entity;

to companies that perform services on our behalf, such as delivery companies, data entry service providers, trade promotion or gift card administration and account management providers;

professional advisers (such as lawyers or auditors);

where you are an employee, to human resource and payroll processing providers;

where you are a job applicant or employee, to recruitment consultants; 

payment systems operators and financial institutions;

organisations authorised by Spotlight to conduct promotional, research or marketing activities;

upon lawful request from law enforcement agencies or government authorities; and

any persons acting on your behalf including those persons nominated by you, executors, trustees and legal representatives.

Direct marketing

We are committed to compliance with all laws and requirements relating to the use of your personal information.  We will only use or disclose your personal information for direct marketing purposes if you have provided your information for that purpose (and you would expect us to use the information for that purpose), or if you have provided consent for your information to be used in this way.

From time to time, we may contact you with information about products and services offered by us and our related entities and our business partners, which we think may be of interest to you.  When we contact you it may be by mail, telephone, email, SMS/text message or social media message.

Where we use or disclose your personal information for the purpose of direct marketing, we will:

allow you to request not to receive direct marketing communications (also known as ‘opting-out’); and

comply with your request to ‘opt-out’ of receiving further communications within a reasonable timeframe.

Spotlight will only ever contact you if you have consented to this, and you can ask to be removed from our marketing lists at anytime by contacting us directly. 

If you do not wish to be contacted by Spotlight please e-mail us at privacy@srg.com.au.

Does Spotlight disclose your personal information to overseas recipients?

Your personal information may be disclosed to other Spotlight entities, business partners and service providers in Australia and overseas.

The countries this information may be disclosed to will vary from time to time, but may include Australia, New Zealand, Singapore, Malaysia, Fiji, and the United States of America.

Sometimes we use third party platforms and services to process sales, provide web support, send marketing messages, deliver products or otherwise deliver information. These services are hosted and managed by organisations other than ourselves, and some of these services are hosted overseas. We use products and services maintained in Australia, New Zealand, Singapore, Malaysia, Fiji, and the United States of America.

Your personal information may be stored in a secure and encrypted form overseas (e.g. in data storage and cloud computing facilities operated by us (or by third parties on Spotlight’s behalf).

Use of Government Identifiers

Spotlight will not use Government Identifiers, such as a driver's licence number as its own identifier of individuals.

Website usage

Our websites are professionally hosted and operate in a secure environment. You should however be aware that there is always an inherent risk in transmitting your personal information via the Internet. 

We use secure payment platforms to process online orders. Customers can see their cards being debited in real time, all in an SSL secure environment.

We take website and credit card security extremely seriously, and always endeavour to provide a secure safe platform on which to conduct online transactions, all our websites use 2048 bit SSL with up to 256 bit encryption for capturing personal information and processing transactions. We do not store your credit card details.

To make sure you are accessing a secure server, check for the unbroken key or closed lock symbol located generally either at the bottom left or top right of your browser window. If it appears, then SSL is active. You can double check this by looking at the URL as well. If SSL is active, then the first characters of that line will read ‘https’ rather than just ‘http’. It is important for you to protect against unauthorised access to your password and to your computer.

Ensure you logout when you have finished visiting our websites especially if you accessed them from a shared computer.

Cookies are pieces of information that a website transfers to your computer for record-keeping purposes. The information collected may be used by Spotlight to improve your experience on our website. 

If you visit an area of the website where you are not required to log on, to read, browse or download information, our system will record the date and time of your visit to our site, the pages viewed and any information downloaded.

Any personal information that you submit to us using our website or in an e-mail will only be used in accordance with this privacy policy.

SRG websites use Google Analytics Services, for more information about cookies used, see Google Cookies Policy

Links to third party sites

Whilst links to third party websites may be provided on our website, we are not responsible for the content or practices of these third party websites.

These links are provided for your convenience and do not represent Spotlight's endorsement of any linked third party website. We recommend that you check the privacy policies of these third parties prior to providing them with your personal information.

No links may be made to this website without our prior written consent.

How you can access or correct your personal information

You can request access to the personal information we hold about you at any time, and we will provide you with that information unless we are prevented by law from giving it to you.

If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.

You will not be charged for accessing your information, although we might have to charge the reasonable cost of processing your request, including photocopying, administration and postage. We will advise you of any fee payable before we process your request.

If you believe that your personal information is not accurate, complete or up to date, please contact us via email to privacy@srg.com.au or address your request to The Privacy Officer, Legal Department, Spotlight Retail Group, Level 6, 111 Cecil Street, South Melbourne  Vic  3205, Australia, and we will correct this information. 

How you can notify us of a privacy concern or contact our Privacy Contact Officer

If you:

have queries, concerns or complaints about the manner in which your personal information has been collected or handled by Spotlight; or

would like to request access to or correction of the personal information we hold about you;

please write to:

 

The Privacy Officer
Legal Department
Spotlight Retail Group
Level 6, 111 Cecil Street
South Melbourne  Vic  3205
Australia
Email: privacy@srg.com.au