Privacy Policy

This Privacy Policy explains how Raptor Marketing Ltd. (referred to as “we”, “us”, or “our” in this policy) collects, uses, stores, and protects your personal data. This policy is effective as of 18/12/2024 and applies to all data collected through our website and services, including when you sign up, apply for ambassador roles, register for events, or interact with us in any other way.

The purpose of this policy is to clearly state how we intend to meet our obligations under the related laws, including 1) the Australian Privacy Principles (“APPs”) set out in the Privacy Act 1988 (Cth) (“Privacy Act”); and in addition to the extent applicable, 2) the European Union (EU) General Data Protection Regulation (“GDPR”), where we process personal data relating to identifiable individuals to whom the GDPR applies; 3) the Data Protection Act 2018 (UK) (“UK Act”), where we process personal information relating to UK residents; and other laws where applicable.[JA1] [KB2] [JA3] [KB4] 

Our Privacy Policy details the sort of information we may collect about you, how we manage, use and disclose your personal information, sets out some of your privacy rights in relation to personal information and advises how you can contact us with privacy queries. 

By using our website or providing personal data, you acknowledge that you have read, understood and agree to the terms of this Privacy Policy. If you do not agree, please do not use our services or submit any personal information.

1. What information will Raptor collect about me?

We collect personal data that you provide to us through various interactions with our website or services. We aim only to collect personal information that is necessary to carry on our business and to supply you with the services that you have requested us to provide. However, we may also collect information about you to do internal research and to conduct market research for our own purposes.  We may collect the following personal information:

·      Personal Identification Information: Name, email address, postal address, phone number, date of birth, and postcode.

·      Job Applications and Ambassador Roles: When you apply for a role or submit job applications, you provide personal details such as your name, contact information, and other relevant data.

·      Promotions and Competitions: Data collected when signing up for promotions, competitions, or newsletters.

·      Customer Service Interactions: Information from communications with our customer support team, whether via email, phone, or social media (including name, email address, phone number, and social media usernames).

·      Device Information: IP address, browser type, operating system, geographical location of your device, and usage data, which is automatically collected to enhance your experience on our site.

This information may be collected directly by us or through third-party services including any third party services you may be unaware of (e.g., analytics tools, ticketing services).

Before collecting information of a sensitive nature or information relating to an individual’s health, we will seek consent from the individuals concerned.

2. How will you use my Personal Information:

We use the information we collect to provide, improve, and personalize our services, including:

·      Service Delivery: To process your application for ambassador roles, events, and other services you’ve requested.

·      User Experience: To improve and tailor your experience across devices.

·      Marketing and Communication: To send you promotional content, event updates, and newsletters if you’ve opted in.

·      Market Research and Product Development: To analyze trends and improve our services.

·      Legal and Regulatory Compliance: To meet legal obligations and regulatory requirements.

·      Fraud Prevention: To detect and prevent fraudulent activities.

We will only use sensitive information we hold about you for the primary purpose for which it was collected or for a purpose directly related to the primary purpose, and where you would reasonably expect us to use or disclose it for that purpose.

3. What is the lawful basis for processing my Personal Information?

We process your personal data under the following lawful bases:

·      Performance of a Contract: To fulfill the services you’ve requested, such as processing your application or sending event invitations.

·      Consent: Where you’ve given explicit consent, for example, when you sign up for marketing communications or promotions.

·      Legitimate Interests: To send marketing communications, analyse user behaviour for website improvement, and ensure network security.

4. Do you share my Personal Information with anyone else?

We may share your personal data with:

·      Raptor Entities: Within Raptor Marketing Ltd., where staff need to access it for operational purposes.

·      Third-Party Service Providers: We work with trusted partners, such as marketing platforms, SMS services, and ticketing companies. We ensure they comply with this Privacy Policy and use your data only for the specified purposes.

·      Legal Authorities: If required by law, we may disclose your information to law enforcement, regulatory bodies, or other authorities investigating potential illegal activities.

·      Brand Partners and Third Parties (For the Feierstarter Position): As part of the application process for the Feierstarter position, we share your personal data with our brand partners and third-party collaborators who are involved in the selection process. These brand partners are the parent companies of the brands we distribute, market, and sell for, such as MAST-Jägermeister SE. We may share your information with these brand partners and third-party collaborators such as Spirits Platform Pty Ltd for the purpose of reviewing and deciding on your application, as well as for marketing, promoting, advertising, and selling their products and services to you. When we share your information, these brand partners and third-party collaborators agree to use it in a manner consistent with the terms of this Privacy Policy.

We do not sell or distribute your personal data to third parties for their own marketing purposes.

If any such third parties collect your information they will have their own obligations regarding treatment of your information, and if you have any concerns about those parties you should liaise with them directly.

5. Transfer of Information Overseas

Personal information which we collect and hold is stored within cloud-based data servers in the EU/UK and follows ISO/IEC 27001 data protection certification. We utilize some cloud-based service providers for specific functions, such as email and accounts, who may store certain information on our behalf on servers based in Australia, Austria, Brazil, Germany, Hungary, Kenya, Mozambique, South Korea and United Kingdom. These service providers are engaged pursuant to terms of service requiring stringent privacy compliance in respect of this data.

Some of the companies we may disclose your personal information to are located overseas, including Australia, Austria, Brazil, Germany, Hungary, Kenya, Mozambique, South Korea and United Kingdom. In all instances of overseas disclosure, we shall ensure that the transfer of your personal information is carried out in accordance with all applicable privacy and data protection laws.

Such measures may include (without limitation) transferring the data: (i) to a third party in a country that has been identified as providing adequate protection for EU or UK data; or (ii) to a third party which has entered into standard contractual clauses adopted or approved by the European Commission.  Should you require more detailed information with regard to transferring your personal information outside the EU or UK (e.g. the names of the recipients and the exact legal basis for any such transfer), please contact us on the contact details below.

We will not send your personal information outside of Australia unless:

·      It is necessary (including to provide the personal information to a third party) to provide our goods and/or services to you;

·      You have provided your consent; 

·      We believed on reasonable grounds that the organisation involved would only deal with your personal information in a similar manner to the requirements under the APPs, GDPR or UK Act (as applicable); or 

·      Where otherwise allowed by the Privacy Act, GDPR or UK Act (as applicable). 

6. Cookies

The use of cookies and other information is used on our website to optimize the viewing experience, troubleshoot any problems and better serve content. A cookie is a piece of information that our web server may send to your machine when you visit our website. The cookie is stored on your machine, but does not identify you or give us any information about your computer, so is not personally identifiable information under Australian law. A cookie helps us to recognise you when you re-visit our website and to co-ordinate your access to different pages on the website. With most Internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more.[JA9] [KB10] [JA11] 

7. What security measures are in place to protect my “Personal Information”?

We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, loss, or alteration. When we have collected information about you it cannot be seen or modified by anyone other than those authorized to access the information for the purposes stated above.  [JA12] [KB13] We will endeavour to make reasonable efforts to ensure information is stored securely both in electronic and physical forms and to keep this information accurate, up to date, complete and relevant. We ensure only those necessary have access to your personal information.  Physical, electronic and managerial procedures have been put in place to reasonably secure any information collected from misuse, interference or loss, and in order to prevent unauthorized access, modification to or disclosure of that information.  We utilize systems, services and third party platforms to manage and store your personal information that are located outside of your country of residence.

However, no method of data transmission over the internet can be 100% secure. While we strive to protect your data, we cannot guarantee its absolute security. In the event of a data breach, we will notify you and any applicable authorities as required by law.

8. How and where will Raptor store my Personal Information?

We store your personal data securely and limit access to only those who need it to perform their roles. Data is stored in compliance with applicable data protection laws and is protected by appropriate security measures. We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. Any information that we no longer use for the purposes contained in this policy is destroyed. The exception to this may be information required for possible data analysis at a future date, or information we are legally required or advised to hold for specific time periods.

9. Your rights:

You have the following rights regarding your personal data:

·      Right of Access: You can request copies of the personal data we hold about you, except where law allows us to refuse your request, in which case we will provide reasons why we have refused. We may provide you with this information verbally or in writing, as may be appropriate.

·      Right to Rectification: You can ask us to correct any inaccurate or incomplete information. We will take reasonable steps to amend or correct your personal information to keep it accurate and up to date.

·      Right to Erasure: You can request that we delete your personal data in certain circumstances.

·      Right to Restriction of Processing: You can request that we limit the processing of your data under certain conditions.

·      Right to Object: You can object to processing based on legitimate interests or direct marketing. You also have the right to withdraw consent to processing.

·      Right to lodge a complaint: You can file a privacy or personal information related complaint to us. We will treat your complaint confidentially, investigate your complaint and aim to ensure that we contact you and that your complaint is resolved within a reasonable time.

UK and EU residents also have the following additional rights:

·       the right to be informed about how their personal information is being used; and

·       the right to transfer their personal information to another person or entity (right of data portability).

To exercise any of these rights, please contact us at hello@feierstarter.com.

10. How long will Raptor keep my information for?

We will retain your personal information only for as long as necessary for the purposes outlined above or as required by law. After this period, your data will be deleted or anonymized.

11. The use of our service by under 18s

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal data from minors. If you are a parent or guardian and believe your child’s data has been collected, please contact us, and we will take appropriate action.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technology. Any changes will be posted on this page, and the "effective date" at the top of the page will be updated. We recommend reviewing this policy periodically to stay informed. All changes are effective from the date we post the revised Privacy Policy.  In particular, by continuing to use the website after the Privacy Policy has been varied or by otherwise providing your information to us, you agree to be bound by the variation.

13. Links to Other Websites

Our website may contain links to other websites of interest. However, once you have used these links to leave our website, you should note that we do not have any control over that other website.  Remember, this Privacy Policy is strictly limited to our collection, storage and use of personally identifiable information collected via the website or otherwise in the course of our business, and does not apply to any third parties. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such websites and such websites are not governed by this Privacy Policy. You should exercise caution and look at the privacy statement policy applicable to the website in question. 

14. How can I contact Raptor?

If you have any questions about this Privacy Policy or how we handle your personal data, or would like to make a privacy or personal information related complaint, please contact us at:

hello@feierstarter.com

We will endeavour to respond to your query in relation to this Privacy Policy within 30 business days.

If we are unable to satisfactorily resolve your concerns or complaint, you can contact the Office of the Australian Information Commissioner at www.oaic.gov.au or the local regulator in your jurisdiction in the UK or Europe, as applicable.   

Last updated December 2024A1]