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TINITRADER PTY LTD Privacy Policy Last Updated 21 November 2018

Version 2.1

We at TiniTrader Pty Ltd (also referred to as “we or” “our” or “us or “Tinitrader””) know that our users (“you,” “your,” or “yourself”) know privacy and data protection is important to you (“users”, “you”, or “your”) and we take your privacy seriously. We deal with personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”). The APPs govern how we can collect, use, hold and disclose your personal information, as well as ensuring the quality and security of your personal information. A copy of the APPs may be obtained from the website of The Office of the Australian Information Commissioner (“OAIC”) at https://www.oaic.gov.au.

Tinitrader enables you advertise and/or purchase all things new or pre-loved products for you, your baby, toddler or kids from the best range of prams, cots, bassinets, toys, clothes, car seats, kids furniture too everything for your children. By visiting or using the website located at [http://www.tinitrader.com.au[(http://www.tinitrader.com.au), our mobile applications, and any other services that we offer from time to time in connection with any of the foregoing (collectively, the “Site”), you agree to the practices and policies set forth in this Privacy Policy, and you hereby acknowledge and consent to Tinitrader collecting, using, holding and disclosing your personal information as described in this Privacy Policy.

Capitalised terms that are not defined in this Privacy Policy have the meaning given to them in our Terms and Conditions accessible at https://www.tinitrader.com.au/article/terms-conditions.

  1. WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy sets out how we manage your personal information that we collect or you provide to us when you access or use the Site. Any external links on the Site to other websites are clearly identifiable as such, and we are not responsible for the practices, content or the privacy policies of these other websites. 1.1 Persons under 18 years of age We do not knowingly collect or solicit personal information from or knowingly allow individuals under the age of 18 to register for the Site. If you are under 18, and wish to use the Site, you must provide us with documentary evidence that you have your parent’s or guardian’s consent to access and use the Site. If we learn that we have collected personal information from a person under the age of 18 without verification of parental consent, we will delete that personal information as quickly as possible. If you are a parent or guardian and you believe that we have collected the personal information of a person under 18 years of age, please contact us using the contact information in section 11 below.

  1. WHAT INFORMATION DO WE COLLECT?

2.1 Members We collect the personal information that you provide to us when you register to set up an account and become a member of the Site (“Members”), including any updated information you provide, such as your name, username, phone number, credit card, other billing information, email address, shipping address, your third-party account credentials (for example, your Facebook log-in) and information regarding your personal preferences and interests. We also collect personal information that you provide about someone else, for example, when you complete a transaction on the Site or when you share content from the Site with other individuals. 2.2 Non-Members We may also receive or collect personal information from individuals who are not Members (“Non-Members”), for example, so that: • Non-Members can subscribe to our e-newsletter; • a Member may invite a Non-Member to visit the Site; or • a Non-Member may engage in a transaction using the Site. Non-Members’ personal information is used only for the purpose for which it was originally submitted to or collected by us. A Non-Member can contact us using the contact information in section 11 below and request that we delete their personal information. 2.3 Third parties If you provide personal information about other individuals, you must ensure that you are authorised to disclose that personal information. You must also take reasonable steps to ensure that those individuals consent to their personal information being collected and stored in accordance with this Privacy Policy. 2.4 Information collected automatically Whenever you interact with our Site, we automatically receive and record information on our server logs from your browser including your Internet Protocol (“IP”) address, “cookie” information, and the page you requested.

Tracking technologies, cookies and web beacons.

We use cookies and web beacons to improve the functionality of our Site.

“Cookies” are small text files that we transfer to your browser or device that allow us to recognise your browser or device and tell us how and when pages on our Site are visited and by how many users. You can change the preferences on your browser or device to stop your browser or device accepting cookies, but doing so may prevent you from taking advantage of the features of our Site. Our advertising partners may transmit cookies to your browser or device when you click on ads that appear on our Site.

When we collect usage information (such as the number and frequency of visitors to our Site and pages visited within the Site), we only use such data in aggregate form and in a manner that assures your anonymity. We may provide this aggregate usage information to our partners who may use this information to understand how often and in what ways users access and use our Site, so that our partners can endeavour to provide users with a better online experience. For example, we may place a cookie on your device or browser that records what products have been accessed on our Site by your browser or device, and then we may provide that information, in de-identified form, to a third party website, to allow that website to serve ads to your browser or device for similar or related products that are available from us or from third parties . We may also deliver a file to your browser or device (“web beacon”) through the Site from an advertising network we have contracted with. Web beacons allow advertising networks to provide anonymised, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to your browser or device when your browser or device visits other websites. These web beacons may, for example, log that you have viewed a certain product on our Site using your browser or device, and then show you an ad for similar or related products when you access another website using your device. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can set, view or edit their own cookies, just as if your browser or device had requested a web page from their site

Many ad networks participate in the Network Advertising Initiative (“NAI”), a cooperative of online marketing and analytics companies committed to building consumer awareness and establishing responsible business and data management practices and standards. Such NAI members may allow you to opt-out of cookies or web beacons they deliver. Again, we do not control the policies of any third parties, including advertising networks.

We do not honour “do-not-track” signals from internet browsers or other consumer choice mechanisms regarding the collection of behavioural tracking data.

For more information about how we use cookies and other tracking technologies please see our Cookie Policy accessible here insert hyperlink to cookie policy here

2.5 E-mail and other communications With your consent, we may contact you, by email or other means. For example, if you have opted in to receiving email communications from us, we may send you promotional offers from us or on behalf of other businesses. We may also communicate with you by email about your use of the Site. Also, we may receive a confirmation when you open an email from us.

  1. HOW DO WE USE YOUR PERSONAL INFORMATION

We use, hold and disclose your personal information to: • personalise and improve the Site; • allow you to set up a user account and profile; • contact you; • allow you to transact on the Site; • fulfil your requests; • analyse how you utilise the Site; and • as otherwise set forth in this Privacy Policy. We may disclose your personal information to third parties (as described in this Section 3 and in Section 4 below).

  1. HOW DO WE DISCLOSE YOUR PERSONAL INFORMATION?

We neither rent nor sell your personal information to anyone. We disclose your personal information with third parties in the following ways including: • in connection with and to facilitate the ways we use, hold and disclose your personal information described in section 3 above; and • as described below in this section 4.

4.1 Affiliated Businesses and third party websites we do not control In certain situations, businesses affiliated with us (“Affiliated Businesses”) may advertise and sell products or offer to provide or provide services to you through the Site (either alone or jointly with us). You can recognise when an Affiliated Business is associated with such a transaction or service, and we will disclose your personal information to that Affiliated Businesses only to the extent that it is necessary and related to the Site or the Service, for example, to automatically transmit information from your account to an account on a third party website or service, such as Facebook. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, and any transaction or service relating to a third party will be governed by any applicable terms of use and privacy policy of that third party. 4.2 Agents We employ other companies and people (“Agents”) in order for us to administer and operate the Site and we disclose your personal information to these Agents and our Affiliated Businesses in connection with the Site. Unless we inform you otherwise, our Agents do not have any right to use your personal information that we disclose to them beyond what is necessary to provide you with access to the Site. 4.3 Sharing of anonymised or de-identified information We may anonymise your personal information so that it no longer allows you to be reasonably identified and provide that anonymised information to our partners. For example, we allow advertisers to choose the demographic information of users who will see their advertisements and you agree that we may use any of the information we have collected from you in non-personally identifiable form to allow our advertisers to select the appropriate audience for those advertisements. We might use the fact you have purchased or inquired about a certain brand of apparel, for instance, to show you advertisements for the company that sells that brand, but we will not disclose your identity to that company. 4.4 Other user’s personal information As part of the buying and selling process that takes place on the Site, we will facilitate the sharing of personal information between the seller and the buyer involved in the transaction. As part of the buying or selling process, you may obtain another user’s email address, shipping address, payment information, and/or other information. As described in our Terms and Conditions, you have a limited licence to use this information only for transaction-related communications. We have not granted you a licence to use the information for any other purpose including for example for unsolicited commercial messages, unauthorised transactions or transactions outside of the Site. Without express consent from that user, you must not use any personal information in any way, for example, you must not add this personal information to your email or physical mailing list or store or use any payment information or other personal information. 4.5 User profiles and content Certain user profile information, including without limitation, a user’s username and the image content that a user has uploaded to the Site, may be displayed to other users to facilitate user interaction within the Site. Any content you upload to your public user profile, along with any personal information or content that you voluntarily disclose online in a manner other users can view (on discussion boards, in messages and chat areas, etc.) may become publicly available, and can be collected and used by others. Your username may also be displayed to other users if and when you post comments or upload images through the Site and other users can contact you through such comments. 4.6 Business transfers We may choose to buy or sell business assets. In these types of transactions, information (which may include your personal information) is one of the business assets that is transferred. Also, if we (or substantially all of our assets) are acquired, or we take on investors, or if we go out of business or enter liquidation, personal information would be one of the business assets transferred to or acquired by a purchaser as result of the sale of these business assets. 4.7 Protection of Tinitrader and others We may disclose personal information if we believe in good faith that disclosure is necessary for any of the following reasons: • to notify the OAIC or another regulator about a data breach or report a matter for investigation; • to comply with laws; • to enforce our terms and conditions and/or other commercial agreements or relationships; or • to protect the rights, property, or safety of us, our employees, our users, or others. We may exchange your personal information with other companies and organisations (including governmental authorities) for fraud protection and credit risk reduction. 4.8 With your consent Except as set forth in this Privacy Policy, we will always seek your consent to disclose your personal information to third parties. 4.9 Overseas disclosure In order to provide you with access to the Site, Tinitrader may disclose your personal information to companies associated with us who are located including in USA, United Kingdom, Ireland, Germany We take reasonable steps to ensure that the recipient complies with the APPs in relation to that information.

  1. IS PERSONAL INFORMATION ABOUT ME SECURE?

Your account is protected by a password for your privacy and security. You need to prevent unauthorised access to your account and personal information by selecting an appropriately complex password, and protecting your password (or other sign-on protections) and setting appropriate access controls on your computer or device, for example, by using a passcode. We take reasonable care to protect personal information that we collect and hold from misuse, loss, unauthorised access, unauthorised modification or unauthorised disclosure. We seek to protect personal information by implementing reasonable and up to date security measures as well as policies, practices and procedures to govern the protection of personal information.

  1. WHAT ARE MY RIGHTS?

You can always elect not to disclose personal information to us. However, please keep in mind that we may need some personal information to allow you to register with us to have an account and be a Member or to take advantage of some or all of the features of the Site and if you choose not to provide that information, your ability to use our Site may be limited. 6.1 Right to access your personal information You have the right to access your personal information that we hold. Through your account settings, you may access, and, in some cases, edit or delete the following information you have provided to us: • name and password; • email address; • billing information; and • information in relation to your user profile information and content, including images you have uploaded to the Site. The information you can view and update may change as the Site changes. When you update or delete personal information or delete your account there may be some latency in our systems and it may take some time for the changes to be reflected across all of our systems and in all of the copies of your personal information that we hold. We may use any aggregated data derived from or incorporating your personal information, but we will not use that information in a manner that would identify you personally. 6.2 Request updates and corrections to your personal information If you believe that your personal information that we hold is inaccurate, or incomplete, you can contact us to request that we change, amend, update, correct or delete your personal information. If you have any questions about viewing or updating information we have on file about you, please contact us using the contact information in section 11 below. 6.3 Opting out of communications If you do not want to receive email or other communications from us, please change your account settings accordingly. You can also choose to opt out of receiving email correspondence from us by following the instructions to opt-out in our emails or by contacting us using the contact information in section 11 below.

  1. HOW DOES TINITRADER RETAIN YOUR PERSONAL INFORMATION?

We will retain your personal information only for as long as your account is active or as needed to provide You with access to the Site. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements in connection with the Site.

  1. EUROPEAN UNION GENERAL DATA PROTECTION REGULATION (EU GDPR)

If you are located in the European Union (EU), the EU GDPR may apply to our processing of your personal data. As well as the other matters covered in this Privacy Policy, the following matters in this section 8 may apply. 8.1 Data protection officer Our data protection officer can be reached at info@tinitrader.com.au
8.2 Lawful purpose for processing Our processing (including collection, storage, use and disclosure) of your personal data is justified on the following lawful basis as: • the processing is necessary in order for us to perform our contract with you and/or provide services to you, or for us to take steps to enter into a contract with you and at your request; • the processing is necessary for us to be able to comply with our legal obligations; or • you have provided your consent to the processing of your personal data. 8.3 Rights under EU GDPR If you are located in the EU, and if the EU GDPR applies to our processing of your personal data, you have the right to request the following: • access to your personal data that we hold; • that we correct or rectify inaccurate personal data that we hold; • that we erase all copies of your personal information that we hold; • that we restrict the way that we process your personal data; and • to receive your personal data provided to us, or request that this data be provided to another controller.

You can contact us at any time you to withdraw your consent to our processing of your personal information.

Please contact is if you believe the EU GDPR applies to you and you would like to exercise your rights under the EU GDPR. We will respond to your request within 30 days.

You have the right to make a complaint to data protection supervisory authorities about how we have processed your personal data. You can access a list of data protection authorities by EU member state here: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

The European Data Protection Supervisor Postal address: Rue Wiertz 60, B-1047 Brussels Office address: Rue Montoyer 30, B-1000 Brussels Telephone: +32 2 283 19 00 Email: edps@edps.europa.eu Website: www.edps.europa.eu

8.4 Transfers of personal data Where we are in receipt of personal data of EU residents, the transfer of this personal data is subject to an adequate level of data protection. These transfers are made under contracts that contain EU standard contractual clauses governing the transfer of personal data to processors established in third countries.

  1. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use your personal information, we will notify you by posting an announcement on our Site or contacting you directly via email or other means. You are bound by any changes to the Privacy Policy when you use the Site after such changes have been first posted.

  1. QUESTIONS OR CONCERNS

If you have any questions or concerns regarding our privacy policy or how we have handled your personal information, or if you would like to make a complaint please contact us using the contact details in section 11 below. We will endeavour to respond to you within 30 days. If you believe that we have not adequately dealt with your enquiry or complaint you can contact the regulator in your jurisdiction. If you would like any further information about your rights to privacy, please contact or visit the regulator in your jurisdiction: Office of the Australian Information Commissioner GPO Box 5218 Sydney NSW 2001 Tel: 1300 363 992 Web: www.oaic.gov.au

  1. CONTACT US Tinitrader Pty Ltd 134 Buckhurst St South Melbourne VIC 3205 Email: info@tinitrader.com.au

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