PRIVACY POLICY

Last updated: 10 March 2026

1. Introduction

Welcome to VASJA’s Privacy Policy.
VASJA (“VASJA”) are firmly committed to protecting your privacy. This Privacy Policy (“Policy”) sets out how VASJA uses and protects your personal information when you access, visit and use this website or our Services (regardless of where you visit it from) to the extent VASJA is the data controller of your personal information. Please use the Glossary to understand the meaning of some of the terms used in this Policy.
This Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

2. Important information and who we are

2.1 Purpose of this Policy
This Policy aims to give you information on how VASJA collects and processes your personal data through your use of this website, including any data you may provide through this website when you purchase a product or service or take part in a competition. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how
and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them.
2.2 Controller
2.2.1 VASJA is the controller and responsible for your personal data (collectively referred to as VASJA) "we", "us" or "our" in this Policy).

2.3 Contact details
2.3.1 If you have any questions about this Policy or our privacy practices, please contact our data privacy manager in the following ways:

VASJA (Australian Business Number: 83 823 130 962)
info@vasja.com.au

2.3.2 Australia: If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach
an independent adviser or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au)
for guidance on alternative courses of action that may be available.
2.3.3 United Kingdom: You have the right to make a complaint at any time to the Information Commissioners Office
(ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to
deal with your concerns before you approach the ICO so please contact us in the first instance.
2.4 Changes to the Policy and your duty to inform us of changes
2.4.1 We keep our Policy under regular review. The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2.4.2 VASJA may occasionally update this Policy. When it does, VASJA will also revise the Effective Date at the top of this Policy. VASJA encourages you to periodically review this Policy to stay informed about VASJA’s collection, use, and disclosure of personal information. VASJA reserves the right, at its discretion, to change, modify, add, or remove portions of the Policy at any time.

2.5 Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

 

3. The data we collect about you

3.1 Personal data, or personal information (used interchangeably), means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
3.2 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  •  Identity Data includes first name, maiden name, last name, username or similar identifier, and title.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products and
    services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version,
    time zone setting and location, browser plug-in types and versions, operating system and platform,
    and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your
    interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and
    our third parties and your communication preferences.

3.3 We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
3.4 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal
convictions and offences.
3.5 If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to
provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

4. How is your personal data collected?

4.1 We use different methods to collect data from and about you including through:
4.1.1 Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • apply for our products or services;
  • create an account on our website;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us.

4.1.2 Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
4.1.3 Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below:

5. How we use your personal data

  • 5.1 We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

5.2 Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the
right to withdraw consent to marketing at any time by contacting us.
5.3 Purposes for which we will use your personal data
5.3.1 Marketing
5.3.2 We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
5.3.4 Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
5.3.5 Third-party marketing 
We will get your express opt-in consent before we share your personal data with any third party for marketing
purposes.
5.4 Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase.
5.5 Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see VASJA ’s Cookie Policy.
5.6 Change of purpose
5.6.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
5.6.2 If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5.6.3 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

6.1 We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

  • Internal Third Parties as set out in the Glossary
    External Third Parties as set out in the Glossary.
  • Specific third parties listed in the table Purposes for which we will use your personal data above.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.
6.2 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

7.1 VASJA is a global business headquartered in Australia. Personal information collected by VASJA worldwide (including in Europe) may be transferred to the United States or anywhere else where our affiliates, third party service providers and partners operate. However, VASJA has taken appropriate safeguards to ensure that your personal information remains protected in accordance with this Policy and applicable data protection law. This includes implementing the European Commission’s Standard Contractual Clauses for transfers of personal information to our affiliates, third-party service providers and partners.
7.2 If transfers outside of the UK occur: we ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK.
7.3 Whenever we transfer your personal data out of the UK, we ensure a high degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
14. Entering into SCCs
14. Intracompany transfer agreements
14. Data Protection Impact Assessments are completed annually
14. Technical measures which include encryption, access control, and logical separation of data
14. Confidentiality agreements and background checks to ensure the reliability of staff
14. A process for ensuring data cannot be accessed by third-party governments
14. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
14. Where we use certain service providers, we may use specific contracts approved for use in the UK or EEA which give personal data the same protection it has in the UK and EU.

8. Data security

9.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
9.2 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9.3 We take reasonable precautions to protect your personal information from loss, misuse and unauthorised access, disclosure, alteration, and destruction. No method of transmission over the Internet, or method of electronic storage is
100% secure, however. Therefore, VASJA cannot guarantee its absolute security. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

10.1 How long will you use my personal data for?
10.1.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
10.1.2 To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means,
and the applicable legal, regulatory, tax, accounting or other requirements.
10.1.3 By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
10.1.4 In some circumstances you can ask us to delete your data.
10.1.5 In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
10.1.6 When VASJA has no ongoing legitimate business need to process personal information, we will either delete or anonymise/de-identify it or, if this is not possible (for example, because the data has been stored in backup archives), VASJA will securely store the personal information and isolate it from any further processing until deletion is possible.
10.2 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10.3 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Links to other websites

VASJA does not control and cannot be responsible for third-party websites’ content, operation, or privacy policies and other terms of service. VASJA is not responsible for the protection and privacy of any information which you provide while visiting such websites and such websites are not governed by this Policy.

11. Children’s Privacy

Our Services and Sites are not intended for use by anyone under the age of 16. VASJA does not knowingly collect personal data from anyone under the age of 16. If you are under 16, you may not attempt to register for our Services or send any information about yourself to us, including your name, address, telephone number, or email address. If we
become aware that we have collected personal data from someone under the age of 16 without verification of parental consent, we will delete that information promptly. If you are a parent or legal guardian of a child under 16 and believe that a child has provided us with their personal data, please contact us at the email or mailing address provided at the end of this Policy.

12. Your legal rights

13.1 Under certain circumstances, you may have the following rights under data protection laws in relation to your
personal data.

  • To request access to your personal data.
  • To request correction of your personal data.
  • To request erasure of your personal data.
  • To object to processing of your personal data.
  • To request restriction of processing your personal data.
  • To request transfer of your personal data.
  • To withdraw consent.

13.2 If you wish to exercise any of the rights set out above, please contact the privacy manager at info@vasja.com.au and we will respond to your request promptly.
13.3 No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
13.4 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
13.5 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.