Privacy Policy

Last updated: May 17, 2023

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalised have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.
  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
  • Company (referred to as either “the Company”, “Topical”, “Topicalwear”, “We”, “Us” or “Our” in this Agreement) refers to AURA Holdings Pty. Limited, PO BOX 1234, Broadway NSW 2007, Australia.
  • Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
  • Country refers to: New South Wales, Australia
  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
  • Personal Data is any information that relates to an identified or identifiable individual.
  • Service refers to the Website.
  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analysing how the Service is used.
  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  • Website refers to Topicalwear, accessible from https://topicalwear.com.au
  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. The technologies We use may include:

  • Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
  • Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

We use both Session and Persistent Cookies for the purposes set out below:

  • Necessary / Essential Cookies Type: Session Cookies Administered by: Us Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.
  • Cookies Policy / Notice Acceptance Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies identify if users have accepted the use of cookies on the Website.
  • Functionality Cookies Type: Persistent Cookies Administered by: Us Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

Processing of data for web analytics

a) Google Analytics

Our website uses Google Analytics, a web analytics service provided by Google LLC (“Google”). Google uses cookies (see Section 2.1 b), which enable an analysis of your use of our website. The information generated by the cookie about usage is usually transferred to a Google server and stored there. However, due to the activation of IP anonymisation on our website, where applicable, your IP address will first be shortened by Google. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide us with other services relating to website and internet use.

The IP address transmitted by your browser in the context of Google Analytics will not be combined with other data held by Google.

You can prevent the storage of cookies by selecting the appropriate settings in your browser software; however, please note that if you do this you may not be able to use the full functionality of our website. You can also prevent the data generated by the cookie and relating to your use of the website (including your IP address) from being recorded and processed by Google by downloading and installing the browser plug-in available under the following link: https://tools.google.com/dlpage/gaoptout/. Specifically in the case of mobile devices, you can prevent Google Analytics from recording data by clicking here: Disable Google Analytics. This will place an opt-out cookie which prevents recording when you visit our website in future. Please note that if you delete all cookies on your device, this opt-out cookie will also be deleted; in this case, if you still wish to object then you must place the cookie again using the above button. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website.

This website uses Google Analytics with the “_anonymizeIp()” extension. Consequently, IP addresses are further processed in shortened form, so that any personal association with the data subject can be ruled out. As far as the data collected about you relates to you personally, that association is therefore ruled out immediately and the personal data thus erased without delay.

We use Google Analytics to analyse and regularly improve the use of our website. The statistics this yields allow us to improve our website and make it more interesting for you as a user. We also use Google Analytics to share limited aggregated & anonymised data with Shop Owners, including for example the number of visits to their Shop over time, and the referral sources for those visits (e.g., Facebook vs Google search). The legal bases for our use of Google Analytics are your consent and our legitimate interests.

Third-party provider information: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. See also the terms of use (https://www.google.com/analytics/terms/us.html) and privacy overview (https://support.google.com/analytics/answer/6004245? ) for Google Analytics as well as Google’s privacy policy: https://policies.google.com/privacy.

Usage-based online advertising

Our website uses various conversion tracking and retargeting technologies made available by other service providers. We use these technologies to make our website interesting for you. The information also helps us to address users who have already shown an interest in our products with individually tailored advertising on the websites of our partner companies. We assume that the display of personalised, interest-based advertising is generally more interesting for the internet user than advertising that has no such personal relevance. At the same time, we want to avoid inappropriate and intrusive advertising.

a) Use of Google Ads conversion tracking and Google Ads remarketing

We use Google Ads, a service of Google LLC (“Google”), to use ads to draw attention to our offers on external websites. In relation to the data of advertising campaigns, we can identify how successful the individual advertising activities are. In this way we want to show you advertising that is of interest to you, make our website more attractive to you and achieve a fair calculation of advertising costs.

These ads are deployed by Google via ‘ad servers’. For this purpose, we use ad server cookies, which enable the tracking of certain parameters for measuring success, such as the display of ads or clicks by users. If you arrive at our website via a Google ad, Google Ads will store a cookie on your device. These cookies usually expire after 30 days and are not intended to identify you personally. Analysis values usually stored for this cookie are the unique cookie ID, the number of ad impressions per placement (frequency), the last impression (relevant for post-view conversions) and opt-out information (marker showing that the user no longer wishes to be targeted).

These cookies allow Google to recognise your internet browser. If a user visits certain pages of a Google Ads customer’s website (in this case ours) and the cookie stored on their device has not yet expired, Google and the customer can recognise that the user has clicked on the ad and has been redirected to this site. Each Google Ads customer is assigned a different cookie. Cookies cannot therefore be tracked via the websites of Google Ads customers. We do not collect and process any personal data in the aforementioned advertising activities. Google merely provides us with statistical evaluations. On the basis of these evaluations we can identify which of the advertising activities used are particularly effective. We do not receive any further data from the use of ads; in particular we cannot identify users on the basis of this information.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Google server. We have no influence on the extent and further processing of the data collected by Google through the use of this tool and therefore inform you according to what we know: By integrating Google Ads Conversion, Google receives the information that you have retrieved the corresponding part of our website, or that you have clicked on one of our ads. If you are registered with a Google service, Google can associate the visit with your account. Even if you are not registered with Google or have not logged in, it is possible that Google will obtain and store your IP address.

– Google Ads remarketing

Besides Google Ads Conversion, we also use Google’s remarketing feature. This is a process we use in an attempt to contact you again. After visiting our website, this feature makes it possible to show you our ads when you continue to use the internet. This is done by means of cookies stored in your browser, which Google uses to record and evaluate your usage behavior when visiting various websites. This is how Google can determine that you have previously visited our website. According to its own information, Google does not combine the data collected in the context of remarketing with your personal data, which may be processed by Google. Specifically, according to Google, pseudonymisation is used during remarketing.

There are various ways in which you can prevent your participation in this tracking procedure:

  • By setting your browser software accordingly; in particular, disabling cookies from third party providers means that you will not receive any ads from third-party providers;
  • By permanent deactivation in your browser Firefox, Internet Explorer or Google Chrome via the link: https://support.google.com/ads/answer/7395996?hl=en. Please note that by doing this you may not be able to properly use the full functionality of our website.
  • By clicking on the following button: Disable Google Ads. This will place an opt-out cookie which prevents recording when you visit our website in future. Please note that if you delete all cookies on your device, this opt-out cookie will also be deleted; in this case, if you still wish to object then you must place the cookie again using the above button. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website.
  • By disabling interest-based ads from providers who are part of the “YourAdChoices” self-regulation initiative via the link http://optout.aboutads.info/?c=2#!/; please note that this setting will be erased if you erase your cookies.

The legal bases for the processing of your data are your consent and our legitimate interests.

Third-party provider information: Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. For further information about privacy at Google, please refer to: https://policies.google.com/privacy and https://services.google.com/sitestats/en.html. Alternatively, you can visit the website of the Network Advertising Initiative (NAI) at: http://www.networkadvertising.org.

b) Use of Meta Custom Audiences, Website Custom Audiences and Conversion Tracking

– Meta Custom Audiences

Our website also uses the Website Custom Audiences remarketing function of Meta Platforms, Inc. (“Meta”). This allows users of the website to see interest-based ads (“Meta Ads”) when visiting the social network Facebook or other websites (e.g., Instagram) that also use the process. Our intention here is to show you ads that are of interest to you.

Due to the marketing tools used, your browser automatically establishes a direct connection to the Facebook server. We have no influence on the extent and further processing of the data collected by Meta through the use of this tool and therefore inform you according to what we know: By integrating Custom Audiences, Meta receives the information that you have retrieved the corresponding part of our website, or that you have clicked on one of our ads. If you are registered with a Facebook service, Meta can associate the visit with your account. Even if you are not registered with Facebook or have not logged in, it is possible that Meta will obtain and store your IP address and other identifying information.

– Website Custom Audiences

Our website also uses the Meta product “Custom Audiences from your website”. For this purpose, we have integrated remarketing tags (so-called Meta Pixel or web beacon) into our website. The Meta Pixel is a small piece of JavaScript code that provides a range of functionalities for sending application-specific events and user-defined data to Meta. We use the Meta Pixel to track how visitors use our site. The Meta Pixel records and reports to Meta information about the user’s browser session, a hashed version of the Facebook ID, and the URL being viewed. Every Facebook user therefore has a device-independent Facebook ID, which enables us to recognise users across multiple devices on the social network Facebook so that we can use Meta Ads to reach our visitors again for advertising purposes. After 180 days, the user information is deleted until the user returns to our website. No personal information is transmitted to us about individual website visitors, and we can only specifically deploy ads to website custom audiences if the custom audience has reached a critical size. This makes it impossible for us to determine the individual identities of visitors.

– Conversion Tracking

We also use the Meta Pixel on our website to measure the reach of ads. This allows us to track users’ actions after they have seen or clicked on a Meta Ad. The Meta Pixel records and reports to Meta information about the user’s browser session, a hashed version of the Facebook ID, and the URL being viewed. The way it works is comparable to Website Custom Audiences via the Meta Pixel, which is already described above. Using the hashed Facebook ID, we can measure the reach and effectiveness of an ad to find out whether you are actually interested in our advertising. This enables us to measure the effectiveness of Meta Ads for statistical and market research purposes. For us, the data used is not personally identifiable.

You can prevent Meta from recording your data on this website by clicking here: Disable Meta Custom Audiences, Website Custom Audiences and Conversion Tracking. This will place an opt-out cookie which prevents recording when you visit our website in future. The opt-out cookie is set per top-level domain, per browser and per device and only prevents the recording of data for this website. How to prevent the recording of your data on other websites is explained on the respective sites, and if you are a user who has logged in to Facebook, here: https://www.facebook.com/settings/?tab=ads#_.

The legal bases for the processing of data when using the functions specified above are your consent and our legitimate interests. You may revoke your consent anytime as described above (without this affecting the lawfulness of processing up to the point of revocation).

Third-party provider information: Meta Platforms, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. For more information about data processing by Meta, please refer to Facebook’s privacy policy: https://www.facebook.com/about/privacy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.
  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
  • To manage Your requests: To attend and manage Your requests to Us.
  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganisation, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyse the use of our Service, to contact You.
  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of the Company
  • Prevent or investigate possible wrongdoing in connection with the Service
  • Protect the personal safety of Users of the Service or the public
  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: