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Safeguarding Your Personal Privacy

Adam & Eve’s Privacy Policy

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California Consumer Privacy Act

Making Sure Your Order is Secure

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UK Data Protection Act and EU General Data Protection Regulation

Safeguarding Your Personal Privacy

Adam & Eve’s Privacy Policy

Effective 31 October 2020

PHE International Pty Ltd is the authorised operator of adameve.com.au (referred to later as "PHE International" "we," "us" or "our") and fully understands the need to protect your personal information while online.

The purpose of our Privacy Policy (referred to later as "Policy") is to inform you how we gather and process your personal information throughout our websites (referred to later as the "Site"). It provides you with the necessary information regarding your rights and our obligations. It also explains how, why, and when we process your personal data and has been developed to safeguard your data in accordance with relevant regulations and laws.

By using the Site or obtaining any product or service through this Site, you agree to the limited collection and use of information as outlined in this Policy. If you do not agree to this Policy, please do not use the Site.

Emails from our Site or its business partners, may contain links to other Internet websites, including sites that may or may not be owned or operated by PHE International. Unless otherwise explicitly stated, we are not responsible for the privacy practices or the content of such websites, including their use of any information (such as IP number, browser type or operating system) collected when email recipients or Site visitors click through links to those sites. If you visit such websites, we encourage you to become familiar with the privacy practices of the sites to ensure a safe browsing experience.

We may from time to time update this Policy to reflect changing technology and other factors. We will notify you of changes to the Policy by posting the updated Policy on this page in our discretion. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy on this page and by continuing to use our Site, you hereby agree to be bound by the terms of the amended Privacy Policy. If you do not agree with the terms of this Privacy Policy, in whole or part, you must terminate your use of the Site.

Information That We Collect
We process your personal information to meet our legal, statutory, and contractual obligations and to provide you with our products and services. We will never collect any unnecessary personal data from you and do not process your information in any way other than as specified in this Policy.

The Site collects two basic types of information during your visit:

non-personally identifiable information
personally identifiable information

Non-personally identifiable information is general information that cannot be traced to individuals and contains no personalized data, think of it as a simple census form. When visitors come to our Site, we collect and aggregate information indicating, among other things, which pages of the Site were visited, the order in which they were visited and which links on the site were clicked. Collecting such information involves logging the IP addresses, operating system and browser software used by each visitor to the Site. Although such information is not personally identifiable, it may be possible to determine from an IP address a visitor’s Internet Service Provider and the general geographic location of the visitor’s point of connectivity. We then use this information in making modifications and improvements to the site to provide users with a smoother and more efficient shopping experience.

Personally identifiable information is needed to provide you with requested services and to process your orders. This information is provided directly by you, such as when you complete the account sign-up form, order form, or email marketing opt-in form and/or when you provide information over the telephone or chat. The personally identifiable information you provide may include the following information, which we use as indicated below:

Name — used for order fulfilment and marketing
Date of Birth — used to ensure that you are a legal adult
Mailing, Shipping and/or Billing Addresses — used for order fulfilment and marketing
Email Address — used for order status communication and marketing
Telephone Number(s) — used for order status communication

Please note, we do not directly collect or store your credit or debit card details used for payment of orders. Your card details will be processed directly by our third-party payment processor(s) in accordance with their privacy policy and terms of use.

Cookie Settings
Like many online services, this site uses cookies and related technologies for site operation, analytics, and third party advertising purposes as described in this policy. We also use non-invasive "cookies" and other tracking technologies to collect information. Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your Web browser. These cookies do not track other websites you might visit and they do not plant malware on your computer. These cookies allow us to recognize your browser so we can personalise your return visits to the Site and save you time during checkout.

If you are uncomfortable with cookies on your computer, you can always remove them by accessing the options menu of your browser. Please refer to your browser’s help menu for more specific directions if needed.

Cookie List
A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

Strictly Necessary Cookies

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.

Name	Scope	Domain	Category
UserKey	First Party	.adameve.com.au	Necessary
ssUserId	First Party	.adameve.com.au	Necessary
_isuid	First Party	.adameve.com.au	Necessary
tfcsr	First Party	.adameve.com.au	Necessary
wishlist	First Party	.adameve.com.au	Necessary
ssSessionIdNamespace	First Party	.adameve.com.au	Necessary
ssShopperId	First Party	.adameve.com.au	Necessary
ksi	First Party	.adameve.com.au	Necessary
lastViewedProducts	First Party	.adameve.com.au	Necessary
Recent	First Party	.adameve.com.au	Necessary
ssViewedProducts	First Party	.adameve.com.au	Necessary
CCtr	First Party	.adameve.com.au	Necessary
ssCartProducts	First Party	.adameve.com.au	Necessary
CCtr	First Party	www.adameve.com.au	Necessary
ksi	First Party	www.adameve.com.au	Necessary

Functional Cookies

These cookies enable the website to provide enhanced functionality and personalisation. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Name	Scope	Domain	Category
AKA_A2	First Party	.adameve.com.au	Functional
RT	First Party	.adameve.com.au	Functional
ak_bmsc	Third Party	.worldpay.com	Functional
bm_sv	Third Party	.worldpay.com	Functional
enforce_policy	Third Party	.paypal.com	Functional
ts_c	Third Party	.paypal.com	Functional
ts	Third Party	.paypal.com	Functional
ANID	Third Party	.google.com	Functional
__cf_bm	Third Party	.afterpay.com	Functional
_cfuvid	Third Party	.afterpay.com	Functional
ak_bmsc	Third Party	.chimpstatic.com	Functional
_hjSessionUser_2717319	Third Party	.useinsider.com	Functional
_hjSessionUser_2411481	Third Party	.useinsider.com	Functional
cookie_check	Third Party	.paypal.com	Functional
d_id	Third Party	.paypal.com	Functional
cookie_prefs	Third Party	.paypal.com	Functional
login_email	Third Party	.paypal.com	Functional
ui_experience	Third Party	.paypal.com	Functional
_BEAMER_LAST_UPDATE_qSaVNPWs22800	Third Party	.useinsider.com	Functional

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Name	Scope	Domain	Category
_fbp	First Party	.adameve.com.au	Marketing/Targeting
__Secure-3PSID	Third Party	.google.com	Marketing/Targeting
__Secure-3PAPISID	Third Party	.google.com	Marketing/Targeting
NID	Third Party	.google.com	Marketing/Targeting
__Secure-1PSIDTS	Third Party	.google.com	Marketing/Targeting
__Secure-3PSIDTS	Third Party	.google.com	Marketing/Targeting
__Secure-3PSIDCC	Third Party	.google.com	Marketing/Targeting
_BEAMER_USER_ID_qSaVNPWs22800	Third Party	.useinsider.com	Marketing/Targeting
_BEAMER_FIRST_VISIT_qSaVNPWs22800	Third Party	.useinsider.com	Marketing/Targeting
_BEAMER_DATE_qSaVNPWs22800	Third Party	.useinsider.com	Marketing/Targeting
ar_debug	Third Party	.google-Performance.com	Marketing/Targeting

How We Use Your Personal Data

PHE International takes your privacy very seriously and will never sell your personal data to anyone. We only use your data for the purpose(s) specified in this Policy. Where you have consented to us providing you with promotional offers and marketing, you are free to withdraw this consent at any time.

Non-personally identifiable information, such as your IP address and the pages that you visit on our Site, is used to help diagnose problems with our servers and to administer our Site and improve Site-related services and features. Your IP address and other non-personally identifiable information also may be used to gather broad demographic information and to recognize customer traffic patterns and Site usage trends. This information aids us in merchandising and in developing the design and layout of the Site.

We also might share aggregated statistical data and other non-personally identifiable information with our current and potential business partners and with our service providers to help them provide similar services.

The Site sometimes administers online surveys in which we ask you for demographic information and opinions. We do not ask you for personally identifiable information as part of a survey. We use the collected survey data on an aggregated basis to better understand the needs of all of our customers.

The Site uses personally identifiable information collected from you to complete transactions initiated by you, particularly the sale and delivery of products and services. Your personally identifiable information is also used to get in touch with you when necessary to provide updates about your order and answer any questions you might have.

We may also use personally identifiable information to contact you to make sure you are satisfied with our goods and services or to find out how we can serve you better. Your decision to participate in any survey or questionnaire about this is completely voluntary. Further, we may use personally identifiable information to conduct in-depth marketing research regarding our customers and potential customers.

Financial information (credit card numbers, credit card expiration dates, billing address, and so forth) is used solely to bill you for products and services and we make every effort to keep your information secure from theft or fraud.

The Site may also use your personally identifiable information to "pre-populate" forms that are used by the Site to facilitate transactions with us and save you from entering every data field on the checkout.

The Site may also send you periodic announcements regarding your order, status updates, service changes concerning the Site and other administrative matters.

You may also, from time to time, receive information from us regarding new features, new products and services and special offers we think you'll find valuable. If you'd like to opt out of receiving promotional communications from us, please follow the procedure outlined in the Opt-Out section below.

There are some special instances when we might use or disclose personally identifiable information:

Service Providers
As described in this Privacy Policy, we work with third parties who provide services, including but not limited to website hosting, order processing and fulfilment, age verification, credit card clearance, e-commerce affiliation, data analysis, emailing, marketing, targeting and other services. Some of these third parties may be given access to some or all of the information that you provide to us and may use cookies or other tracking technologies in connection with providing their services. To the extent that we provide your personally identifiable information to such third parties, we restrict their ability to use such information for their own marketing purposes to the best of our abilities. However, we cannot be responsible for the privacy policies or practices of such third parties.

Related Companies
We may share personal information we collect about you with related companies for purposes consistent with this Policy.

As Required By Law
Subject to applicable law, we reserve the right to release information concerning any Site visitor where such visitor is believed to be in violation of his or her obligations to us, is partaking (or is suspected of partaking) in any illegal activity, in response to civil subpoenas, court orders and/or discovery requests, to protect the interests of PHE international, our customers or others, and as otherwise permitted or required by law as regards to these special cases.

Sharing and Disclosing Your Personal Information
Except as provided in this Policy, we do not share or disclose any of your personal information without your consent.

PHE International uses third parties to provide certain services and business functions and may share your personal information with service providers for purposes such as order and payment processing, website functionality and the marketing of products. Keep in mind that, while we encourage all third parties involved in running our business to adhere to our policies regarding the privacy of our visitors and to handle personally identifiable information in a responsible manner, we cannot and do not assume any responsibility for any actions or omissions of third parties, including the manner in which they use information received either from the Site or independently.

Opting Out
At any time, you can opt-out of our marketing emails. To opt-out, simply click the “No Longer want to receive this?” link on the bottom of the email.

Safeguarding Measures

California Consumer Privacy Act

California residents have certain rights regarding our collection and use of personal information under the California Consumer Privacy Act of 2018 (“CCPA”). If you are a California resident and you wish to know more about your rights under the CCPA, please view our CCPA Disclosure below. Please note that the CCPA Disclosure controls as to California residents in the event of any conflict between the CCPA Disclosure and any other provision of this Policy.

PHE International California Consumer Privacy Act (CCPA) Disclosure

California residents may:

Request that we delete their personal information.
Request information about:

the categories and specific pieces of personal information we have collected about the you;
the categories of sources from which we have collected your personal information;
the business or commercial purpose for collecting or selling your personal information;
the categories of personal information we have sold about your; and
the categories of third parties with whom we have shared, disclosed for a business purpose, or sold your personal information, and which categories of personal information we have sold to which categories of third parties.

We will not discriminate against you for exercising their rights under the CCPA.

NOTE: While under the CCPA you may request that we do not sell your personal information, there is no need to opt out of sales because we do not sell your personal information.

Exercising Your Rights

Requests for Information
If you are a California resident, you may request that we provide certain information about our use of your personal information, as specified above. Upon receiving a request from you, we will take reasonable steps to verify your identity. We will respond to a verified request from you by: (a) providing the requested information; or (b) explaining to you why the Act does not require us to provide the requested information.

We will respond to requests for information within 45 days. If a response requires additional time, we will notify you of the basis for the delay and may extend our response period up to an additional 90 days. If the Act requires us to provide the information requested to you, we will provide the information covering the 12 months preceding the request, free of charge, and in a readily useable portable format. We have no obligation to provide personal information to you more than twice in a 12-month period. If a request or series of requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the request(s), or may refuse to process the request(s).

Requests to Delete
California residents may request that we delete their personal information. Upon receiving a request from you, we will take reasonable steps to verify your identity. We will respond to a verified request from you by: (a) deleting your personal information and, if applicable, directing our service providers to delete your personal information; or (ii) explaining to you why the Act does not require us to delete your personal information.

If a request or series of requests are manifestly unfounded or excessive, we may charge a reasonable fee for processing the request(s), or may refuse to process the request(s).

Minors
We do not sell to or obtain personal information from persons under 18 years of age.

Personal Information We Have Collected, Sold, or Disclosed
In the preceding 12 months, we have collected the following categories of personal information about California residents:

Name
Date of Birth
Postal address
Billing address
Shipping address
Credit or debit card information
E-mail address
Telephone number(s)
Records of products/services purchased
Internet Protocol address and geolocation
Analytics regarding interaction with our website
Device information (e.g. device model, operating system, device date/time, unique device identifiers, network information)

We do not sell, and have not in the prior 12 months sold, any personal information of California consumers.

In the preceding 12 months, we have shared for a business purpose the following categories of personal information about California Users:

Identifiers: such as your name, Internet Protocol address, email address, and similar identifiers.
Payment information: some personal information included in this category, such as your address, may overlap with other categories.
Internet or other electronic network activity information: such as browsing history, search history, or information on interaction with a website or advertisement
Geolocation data. In some cases, we may collect your physical location to provide you location-related services
Inferences drawn from any of the above information

According to California law, personal information does not include (i) publicly available information from government records or (ii) de-identified or aggregated consumer information.

California Shine the Light
If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of personal information we have shared with third parties for the third parties’ direct marketing purposes during the preceding calendar year. To request a notice, please submit your request to:

PHE International Pty Ltd.
PO Box 350
ABBOTSFORD VIC 3067
AUSTRALIA
Attention: Shine the Light.
Please allow 30 days for a response.

Transfers Outside of Australia
PHE International is located in Australia and processes Personal Data in multiple countries including but not limited to; Australia, New Zealand, United Kingdom, Ireland, United States of America. This list is not exhaustive and Personal data may be processed in other countries or jurisdictions depending on the nature of the services. Personal data in the European Union is protected by the General Data Protection Regulation (GDPR).

Personal Data transferred outside of Australia, we will comply with Applicable Laws in doing so.

Google Analytics & Google Optimize

In accordance with this policy, Google Analytics may use your browsing behavior to connect it with other data that has previously been provided by you.

PHE International also uses some Google Analytics functions including but not limited to: Google Optimize, Remarketing, Google Display Network Impression Reporting, DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. PHE International may also remarket with Google Analytics to advertise online. Third-party vendors, including Google, may show our ads across various internet sites. These third-party vendors use first-party cookies or related technologies that serve ads based on your previous visits to our Site. They will also report on the ad impressions, interactions and visits with our site.

Social Media
We run a number of pages across various social media platforms. By accessing and interacting with these pages, you agree to the terms and Privacy Policy of those platforms.

Consequences of Not Providing Your Data
You are not obligated to provide your personal information to PHE International however, this information is required for us to provide you with our services and deliver your products. We will not be able to offer some or all of our services without it.

How Long We Keep Your Data
PHE International only retains personal information for as long as is necessary to serve the purposes described in this Policy. We will also retain and use your personal data for as long as necessary to comply with legal, regulatory, accounting or reporting obligations, to resolve disputes, and to enforce our agreements.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

Special Categories Data
Owing to the products, services or treatments that we offer, PHE International sometimes needs to process sensitive personal information (known as special category data) about you, as a consequence of the type of products we sell. Where we collect such information, we will only request and process the minimum necessary for the specified purpose and identify a compliant legal basis for doing so.

Where we rely on your consent for processing special category data, we will obtain your explicit consent through a checkbox on our website. You can modify or withdraw consent at any time, which we will act on immediately, unless there is a legitimate or legal reason for not doing so.

Lodging A Question or Complaint
PHE International only processes your personal information in compliance with this privacy notice and in accordance with the relevant data protection laws. If, however, you have a question about this Policy, the data collection and usage practices of this Site or your dealings with this site, you can click this link: Contact Us or mail us at:

Customer Service
PO Box 350
ABBOTSFORD VIC 3067
AUSTRALIA
Attention: Privacy

If you wish to report a complaint regarding the processing of your personal data or are unsatisfied with how we have handled your information, you contact the supervisory authority by mail at:

PHE International
GDPR
PO Box 350
ABBOTSFORD VIC 3067
AUSTRALIA
Attention: Privacy

Making Sure Your Order is Secure

UK Data Protection Act

We have appointed DPR Group as our UK representative under the UK Data Protection Act 2018, as amended.

If you are based in the UK, you may contact our UK Representative using the following details: Sending an email to datainquiry@dpr.eu.com, quoting “PHE International Pty Ltd.” in the subject line, or

Mailing Inquiries:

DPR Group

BPM 335368

372 Old Street

EC1V 9AU

London, United Kingdom

Note that the EU General Data Protection Regulation provisions set forth below in this Policy also apply to our UK based customers.

EU General Data Protection Regulation

This section of the Privacy Policy applies if you are a customer in the European Union (EU). For these purposes, reference to the EU also includes the European Economic Area countries of Iceland, Liechtenstein and Norway and, to the extent applicable, Switzerland. To the extent that provisions in this section contradict other provisions of this Privacy Policy, the provisions in this Section prevail for EU residents.

In compliance with the EU General Data Protection Regulation, PHE International has appointed DPR Group as their Data Protection Representative in the EU so that you can contact them directly in your home country. DPR Group has locations in each of the 28 EU countries, so that our customers in the EU can always raise the questions they want with them.

If you are based in the EU and want to raise a question with us or otherwise exercise your rights in respect of your personal data, you may do so using one of these three methods:

sending an email to DPR Group at: datainquiry@dpr.eu.com quoting “PHE International Pty Ltd.” in the subject line or,

contacting us on our online webform at https://www.dpr.eu.com/datarequest or,

mailing your inquiry to DPR Group at the most convenient of the addresses listed in the table below.

PLEASE NOTE: when mailing inquiries, it is ESSENTIAL that you mark your letters for ‘DPR Group’. Please refer clearly to PHE International Pty Ltd in your correspondence. On receiving your correspondence, we may request evidence of your identity to ensure your personal data and information connected with it are not provided to anyone other than you. If you have any concerns over how DPR Group will handle the personal data we will require to undertake our services, please refer to our privacy notice at https://www.dpr.eu.com/legal-privacy.

Country Address

Austria DPR Group, City Tower, Brückenkopfgasse 1/6. Stock, Graz, 8020, Austria

Belgium DPR Group, Place de L'Université 16, Louvain-La-Neuve, Waals Brabant, 1348, Belgium

Bulgaria DPR Group, 132 Mimi Balkanska Str., Sofia, 1540, Bulgaria

Croatia DPR Group, Ground & 9th Floor, Hoto Tower, Savska cesta 32, Zagreb, 10000, Croatia

Cyprus DPR Group, Victory House, 205 Archbishop Makarios Avenue, Limassol, 3030, Cyprus

Czech Republic DPR Group, IQ Ostrava Ground floor, 28. rijna 3346/91, Ostrava-mesto, Moravska, Ostrava, Czech Republic

Denmark DPR Group, Lautruphøj 1-3, Ballerup, 2750, Denmark

Estonia DPR Group, 2nd Floor, Tornimae 5, Tallinn, 10145, Estonia

Finland DPR Group, Luna House, 5.krs, Mannerheimintie 12 B, Helsinki, 00100, Finland

France DPR Group, 72 rue de Lessard, Rouen, 76100, France

Germany DPR Group, 3rd and 4th floor, Altmarkt 10 B/D, Dresden, 01067, Germany

Greece DPR Group, 24 Lagoumitzi str, Athens, 17671, Greece

Hungary DPR Group, Kálmán Imre utca 1, Budapest, 1054, Hungary

Ireland DPR Group, Phoenix House, Monahan Road, Cork, T12 H1XY, Republic of Ireland

Italy DPR Group, BPM 335368, Via Roma 12, 10073 , Turin, Italy

Latvia DPR Group, 4th & 5th floors, 14 Terbatas Street, Riga, LV-1011, Latvia

Lithuania DPR Group, 44A Gedimino Avenue, 01110 Vilnius, Lithuania

Luxembourg DPR Group, BPM 335368, Banzelt 4 A, 6921, Roodt-sur-Syre, Luxembourg

Malta DPR Group, Tower Business Centre, 2nd floor, Tower Street, Swatar, BKR4013, Malta

Netherlands DPR Group, Cuserstraat 93, Floor 2 and 3, Amsterdam, 1081 CN, Netherlands

Poland DPR Group, Budynek Fronton ul Kamienna 21, Krakow, 31-403, Poland

Portugal DPR Group, Torre de Monsanto, Rua Afonso Praça 30, 7th floor, Algès, Lisbon, 1495-061, Portugal

Romania DPR Group, 15 Piata Charles do Gaulle, nr. 1-T, Bucharest, Sectorul 1 011857, Romania

Slovakia DPR Group, Apollo Business Centre II, Block E / 9th floor, 4D Prievozska, Bratislava, 821 09, Slovakia

Slovenia DPR Group, Trg. Republike 3, Floor 3, Ljubljana, 1000, Slovenia

Spain DataRep, BPM 335368, Avd. Castilla La Mancha Nº 70-1 (Nave A), 45270, Mocejon-Toledo, Spain

Sweden DPR Group, S:t Johannesgatan 2, 4th floor, Malmo, SE - 211 46, Sweden

Other country websites

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