Privacy policy
1. INTRODUCTION
1.1 About this policy
This Privacy Policy (“this Policy”) is the official privacy policy of Christmas Wonder Australia Pty Ltd (Christmas Wonder) ACN 699 109 978 based in Australia and having the registered office 76A Maple Street, Maleny QLD 4552, and any of its wholly owned subsidiaries and business divisions (hereafter collectively referred to as “Christmas Wonder” or “we”, “us”, or “our”) and it applies to all Personal Information about individuals collected by Christmas Wonder. If this Policy has been referenced on a website pertaining by a company or business entity, that company or business entity is a part of Christmas Wonder and this Policy applies to all information collected and used by that entity.
1.2 Relationship with Privacy Act and other Laws
This Policy is intended to comply with the Privacy Act 1988 (Cth) (the “Act”) to ensure Christmas Wonder’s compliance with its obligations under the Act, including the Australian Privacy Principles (the “APPs”), if applicable to Christmas Wonder. This Policy is not otherwise an ‘opt-in’ under section 6EA of the Act.
(a) For the purpose of interpretation of this Policy any terms in this Policy defined in the Act have the same meaning as defined in the Act.
(b) To the extent that Christmas Wonder may from time to time be the subject of privacy laws of nations other than Australia, this Policy extends to information collected by us from overseas entities but does not limit our obligations under any other laws.
1.3 What this Policy provides
(a) In this Policy we explain how and why we collect personal information as defined in the Act (“Personal Information”) about individuals, how we use such information within our business, and what controls individuals have over our collection and use of information about them.
(b) This Policy is relevant to individuals who are current and former customers, as well as other individuals that we deal with in connection with the goods and services we provide or information we collect from customers and other persons.
1.4 Our commitment
We value your privacy and are committed to complying with laws that deal with how businesses may collect, hold and use Personal Information about individuals, and to protecting and safeguarding the privacy of individuals when they deal with us, including the Act and the APPs if applicable.
2. COLLECTION OF INFORMATION
2.1 Type of information collected
(a) Some information provided to us by clients, customers and other parties might be considered private or personal. However, without such information we would not be able to carry on our business activities and provide our services. We will only collect such Personal Information if it is necessary for one of our functions or activities.
(b) The kinds of Personal Information that we may collect and hold in respect of individuals may include:
(i) names;
(ii) contact details;
(iii) identification information;
(iv) location data of where a customer has shopped;
(v) user data including our products and webpages browsed, the customer’s interest trends, and any feedback provided;
(vi) marketing preferences regarding marketing communications;
(vii) financial information, including information about transactions and trading history with us; and
(viii) information about credit history.
2.2 Situations where information is collected
Personal information may be collected in the following situations by Christmas Wonder:
(a) if an individual contacts us, we may keep a record of that communication or correspondence;
(b) if an individual submits an application or curriculum vitae or another form required to be completed by an individual to enable and/or facilitate services and/or employment to be provided by us;
(c) when applying for and/or establishing and/or accessing an account with us or ordering products or services from us;
(d) when conducting certain types of transactions such as cheque or credit card purchases or refunds;
(e) when an individual submits their contact details to be included on our mailing lists; and
(f) when an order is placed with us to purchase goods or services we may require individuals to provide us with contact information including name, address, telephone number or email address and financial information (such as credit card details) for the purposes of processing and fulfilling such an order or providing the service.
2.3 Manner of collection
(a) At or before the time the Personal Information about an individual is collected by us, we will take reasonable steps to ensure that the individual is made aware of who we are, the fact that the individual is able to gain access to the information held about the individual, the purpose of the collection, the type(s) of organisations to which we may usually disclose the information collected about the individual, any laws requiring the collection of the information and the main consequences if all or part of the information is not collected.
(b) We usually collect Personal Information about individuals directly from the individual. However, sometimes we may need to collect Personal Information about individuals from third parties for the purposes described below in this Policy. The circumstances in which we may need to do this include, for example, where we need information from a third party to assist us to process an application or an order (such as to verify information an individual has provided or to assess the individual’s circumstances) or to assist us to locate or communicate with the individual.
2.4 How information may be held
(a) Christmas Wonder may hold Personal Information about an individual in physical form or in electronic form on our systems or the systems of our IT service providers.
(b) The Personal Information that we hold about individuals is protected by physical, electronic, and procedural safeguards and we also require our service providers that hold and process such information on our behalf to follow appropriate standards of security and confidentiality. Any Personal Information we collect from an individual or about an individual is kept securely and held on secure servers in controlled facilities.
(c) Christmas Wonder takes other technical and organisational measures to protect the Personal Information of individuals from misuse, loss or disclosure. These include:
(i) training of staff and others who work for Christmas Wonder on how to handle Personal Information appropriately; and
(ii) restricting of access to what is necessary for specific job functions;
(iii) regularly updating its software and hardware including passwords and permissions; and
(iv) employing the use of firewall and cyber security technology to avoid unauthorised access to our systems and data.
2.5 Period of retention of information
(a) Christmas Wonder may retain Personal Information collected or provided to us including:
(i) client files and order history including individuals’ Personal Information, contact information, financial and transactional information;
(ii) to enable us to verify transactions and customer details and to retain adequate records for legal and accounting purposes.
(b) Christmas Wonder will retain Personal Information collected for such minimum or maximum periods as it is required by law depending on the type of information collected. But for any minimum or maximum periods of retention required by law, we will safely destroy Personal Information once it is no longer required.
3. USE AND DISCLOSURE OF PERSONAL INFORMATION
(a) Christmas Wonder may use or disclose Personal Information held about an individual as permitted by law and for the business purposes for which it is collected (e.g. provision of our services, including administration of our services, notifications about changes to our services, record-keeping following termination of our services and technical maintenance), that is, to carry on our business activities and provide services to our customers.
(b) We may also use such information about individuals for a purpose related to the primary purpose of collection and where the individual would reasonably expect that we would use the information in such a way. This information is only disclosed to persons outside our business in the circumstances set out in this Policy or as otherwise notified at the time of collection of the information.
(c) Christmas Wonder’s business purposes for which Personal Information is collected, used and disclosed may include:
(i) processing an application or product order or service request (including verifying a person's identity for these purposes);
(ii) managing our products and services or other relationships and arrangements, including processing receipts, payments and invoices;
(iii) assessing and monitoring credit worthiness;
(iv) detecting and preventing fraud and other risks to us and our customers;
(v) responding to inquiries about applications, accounts or other products, services or arrangements;
(vi) understanding our customers' needs and developing and offering products and services to meet those needs;
(vii) researching and developing our products and services and maintaining and developing our systems and infrastructure (including undertaking testing);
(viii) ensuring workplace health and safety and productivity of employees at our workplace premises;
(ix) dealing with complaints;
(x) meeting legal and regulatory requirements, for example various Australian laws may expressly require us to collect and/or disclose Personal Information about individuals, or we may need to do so in order to be able to comply with other obligations under those laws; and
(xi) enforcing our rights, including undertaking debt collection activities and legal proceedings.
3.2 Additional disclosure situations
In addition to the above, we are permitted to use or disclose Personal Information held about individuals:
(a) where the individual has consented to the use or disclosure;
(b) where we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious, immediate threat to someone's health or safety or the public's health or safety;
(c) where we reasonably suspect that unlawful activity has been, is being, or may be engaged in, and the use or disclosure is a necessary part of our investigation or in reporting the matter to the relevant authorities;
(d) where such use or disclosure is required under or authorised by law (for example, to comply with a subpoena, a warrant or other order of a court or legal process);
(e) where we reasonably believe that the use or disclosure is necessary for prevention, investigation, prosecution and punishment of crimes or wrongdoings, or the preparation for, and conduct of, proceedings before any court or tribunal or the implementation of the orders of a court or tribunal by or on behalf of an enforcement body; and
(f) where a customer (being the individual or related to the individual) has requested a service to be provided by us and we are required to disclose the information to a third party in order to facilitate the provision of the service. In most, if not all cases, any such disclosure will be with the consent of the individual.
3.3 Third parties to whom information may be disclosed
Third parties to whom we may disclose Personal Information about individuals in accordance with our business purposes set out above may include:
(a) our legal advisors;
(b) our financial and accounting advisors;
(c) our IT service providers;
(d) regulatory bodies in Australia;
(e) participants in financial and payment systems, such as banks, credit providers, and credit card associations;
(f) guarantors and security providers associated with individuals;
(g) debt collectors;
(h) cloud information storage providers; and
(i) other trade suppliers.
3.4 Use of Personal Information by third parties
Christmas Wonder, subject to having complied with its obligations under this Policy, makes no warranty in relation to, and will not be liable for, any misuse or loss of Personal Information by third parties to whom we are authorised to provide Personal Information under this Policy.
4. USE OF AUTOMATED DECISION MAKING TOOLS (ADM)
(a) Christmas Wonder may use computer programs to make decisions using Personal Information of individuals that could reasonably be expected to significantly affect the rights or interests of individuals.
(b) The type of automated decision making tools (“ADM”) that we use, the Personal Information used, and decisions made by ADMs are as follows:
(i) Christmas Wonder uses ADM tools to analyse Personal Information concerning customers’ interactions, preferences and purchasing behaviour to improve the relevance and effectiveness of Christmas Wonder’s products, services, advertising and marketing activities.
5. DIRECT MARKETING
5.1 We may carry out direct marketing
As part of Christmas Wonder’s functions and business activities and to promote the services we can provide to our customers, we may be permitted to use Personal Information about individuals, that individuals have provided to us for the purposes of direct marketing. Direct marketing includes, but is not limited to, sending information to and/or contacting individuals in relation to promotions relating to us.
5.2 Opting out of direct marketing
(a) All recipients, including individuals, can opt out of receiving direct marketing communications by sending an email to our Privacy Officer, at the email address shown in the ‘Contacting us’ section of this Policy.
(b) In any direct marketing communication we remind recipients of their right to opt out of receiving direct marketing communications.
5.3 Third party marketing
Christmas Wonder does not engage in the practice of selling client information for marketing purposes, but does not warrant that third parties who receive Personal Information of its clients will not undertake marketing activities with that information. If you experience harassment or spamming from a third party that we have engaged with, please let us know, and we will endeavour to take such action as is reasonably possible for us to take.
6. ANONYMITY AND PSEUDONYMITY
Individuals would generally have the option of dealing with us anonymously. However, this only applies where it is not impracticable for us to deal with individuals acting anonymously or under a pseudonym. For example, individuals making general enquiries of Christmas Wonder may do so anonymously or under a pseudonym. However, if the dealing with us is for us to supply goods and services and/or to enter into contractual relations (such as a commercial credit account) with a customer that is the individual or is associated with the individual, then it is impractical for such individuals to deal with us on an anonymous basis or under a pseudonym.
7. WEBSITE AND LINKS
7.1 Our websites
(a) Christmas Wonder advertises and carries on business through a number of websites pertaining to our business, including:
https://ChristmasWonder.com.au and any other website that contains a link to this Policy.
7.2 Website terms and conditions
(a) Each of our websites collects Personal Information pursuant to this Policy except as otherwise stated on the website.
(b) A website may display additional terms and conditions for access and use of the website which apply in addition to this Policy.
Christmas Wonder collects information from its websites and software applications using “cookies”.
(a) Cookies are small text files sent by us to your computer or mobile device, which enable features, functionalities and allow the websites or applications, among other things, store and retrieve information about the number of visits, browsing habits of the user or your device and, depending on the information they contain and the way you use your device, can be used to recognize the user.
(b) Some cookies are associated with your account and personal data to remember that you are logged in and which websites you are logged into. Other cookies are not tied to your account but are unique and allow us to carry out analytics and customization, among other similar things.
(c) Christmas Wonder will generally use cookies for the following purposes:
(i) Authentication of your account or browser for safer or faster access or retrieval of your personal information and preferences;
(ii) Security and functionalities including support security features and detect malicious activity;
(iii) Personalisation, preferences, features and services including denoting the language that you prefer, help complete forms more easily and provide customised content; and
(iv) Marketing performance, analytics, and market research to help us understand and improve our products and services and customise them to our customers.
(d) Christmas Wonder may also use social cookies and pixels to enable you to share our content with your friends and networks and to create links between your visit to our website and a third party which may subsequently be used for analytical and advertising purposes.
(e) Not all cookies will come from our websites and can come from external sources, including by partner services such as Google, Meta etc. to follow your activity across our and various other websites and applications.
(f) Cookies may remain active for various durations ranging from:
(i) session cookies - active during the session only and expire when you close your browser; and
(ii) persistent cookies – cookies that remain on your hard drive until you erase your hard drive or your browser does, depending on the cookie’s expiration date.
(g) We will typically ensure our cookies have an expiry date of 12 months and not longer, but please be aware that we may need to retain data from certain cookies for any possible legal claims up to the claim limitation period. Furthermore, when a cookie has expired, we may renew it if you agree to its use once more.
(h) Depending on your consent to the use of certain cookies, the data gathered via cookies may be shared with selected partners and service providers who assist us with various functions, such as website analytics, advertising, and improving user experience. Refer to clause 9 of this Policy concerning transfer of data overseas.
(i) You can stop your browser receiving or accepting cookies at any time, this is typically done by either:
(i) Managing cookie preferences – via the cookie banner or through the settings panel of our website or your browser; or
(ii) Disabling cookies – via your browser. Please refer to your specific browser’s instructions.
(j) However, please note that the use of cookies is in some cases necessary for certain functions on our websites to work properly, and therefore we cannot assure you that you will be able to access and enjoy all functions of our website without the use of cookies.
7.4 Third party links
Our websites may contain links to other websites and those third party websites may collect Personal Information about individuals. We are not responsible for the privacy practices of other businesses or the content of websites that are linked to our websites. We encourage users to be aware when they leave our website and to read the privacy statements of each and every website they frequent.
8. SECURITY AND STORAGE OF INFORMATION
8.1 Our commitment
Christmas Wonder places a great importance on the security of all information associated with our clients and others who deal with us. We have security measures in place to reasonably protect against the loss, misuse, unauthorised access and alteration of Personal Information and other data under our control.
8.2 Security and storage methods
(a) All Personal Information and other data held is kept securely and that which is held electronically is held on secure servers in controlled facilities.
(b) Information stored within our computer systems or by our agents who provide electronic storage facilities can only be accessed by those entrusted with authority and computer network password sanctions.
(c) We consult with IT service providers to implement reasonable levels of firewall, malware detection and data security procedures.
8.3 Electronic transmissions
No data transmission over the internet can be guaranteed to be absolutely secure. As a result, whilst we strive to protect users' Personal Information, we cannot ensure or warrant the security of any information transmitted to it or from it’s online products or services, and users do so at their own risk. Once we receive a transmission, we make every effort to ensure the security of such transmission on our systems.
8.4 Banking information and payment requests
(a) We will never email you or telephone you requesting your credit card or bank account details except in connection with a purchase that you are making by email or telephone.
(b) In all cases, if you receive a communication purported to be from us requesting payment or banking information, we recommend that you separately contact us via our publicly available telephone contact details to verify the authenticity of the request.
8.5 Data breach
Christmas Wonder has developed a data breach response plan which ensures compliance with the mandatory notification requirements of Part IIIC of the Act.
9. TRANSFER OF INFORMATION OVERSEAS
Christmas Wonder may utilise local and overseas cloud services for the purpose of storing information. Your credit information may be disclosed to our cloud service provider for that purpose. While our cloud service providers are located in Australia, the country location of our cloud service providers may periodically change.
9.2 Data transfer to overseas recipients
(a) Some of the third parties to whom we may disclose your Personal Information as outlined in section 3.3 of this Policy may be located overseas. In addition, we may co-operate with overseas entities in the delivery of goods and services for our clients.
(b) Some of the international entities to whom Personal Information may be disclosed include:
(i) Shopify Inc. and its related bodies corporate, being third-party service providers engaged by us to assist in business administration, process transactions in trade, facilitate payment processing, and provide related e-commerce platform services, which may involve the disclosure, storage, and processing of Personal Information in accordance with Shopify's privacy policies and terms of service.
(c) Subject to paragraph (d) below, we take reasonable steps to ensure that overseas recipients of your Personal Information do not breach the Australian Privacy Principles. This is usually done by Christmas Wonder requiring that our overseas recipients comply with the Act and this Policy.
(d) In some cases, we will disclose Personal Information to overseas recipients that we reasonably believe, or which are determined by Government declaration, to be situated in a country or subject to a binding scheme (“Whitelisted Countries and Schemes”):
(i) having the effect of protecting Personal Information about individuals in a way that, overall, is at least substantially similar to the way the Australian Privacy Principles protect the information; and
(ii) having mechanism that the individual can access to take action to enforce protection.
(e) You agree that we may disclose your Personal Information to entities in Whitelisted Countries and Schemes subject to any pre-requisites set by legislation, and in such case we will not be obliged to take reasonable steps to ensure that these overseas recipients comply with the Act and the Australian Privacy Principles.
(f) In any case, by agreeing to this Policy, you agree to the disclosure of your Personal Information to entities outside of Australia including those listed above and that, subject to our compliance with our obligations under the Act, we will not be liable to you for any breach of the Act, including any misuse or loss of your Personal Information by these overseas recipients.
10.1 Products and Services not intended for Children
(a) Christmas Wonder’s products and services are not intended for use by children, and we will not typically collect information from any unsupervised child under the age of 13.
(b) If you are under the age of 13, you may not use our products and services unless your parent/s or guardian has provided us with their express authorisation for your use of our products and services.
11. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
11.1 Our commitment
Christmas Wonder is committed to and takes all reasonable steps in respect of maintaining accurate, timely, relevant, complete and appropriate information about our customers, clients and website users.
11.2 Access to information
(a) Any individual may request access to Personal Information about them held by Christmas Wonder. Such a request for access to Personal Information is to be made to our Privacy Officer, whose details are set out below.
(b) We will respond to any requests for access or correction within a reasonable time of receipt of the request, but by no later than 30 days of the request being received.
(c) Please note that we do require that, as part of any request by an individual for access to Personal Information, the individual verify their identity so that we may be satisfied that the request for access is being made by the individual concerned.
(d) Please note that we are not required to give an individual access to Personal Information in circumstances where:
(i) we reasonably believe that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety; or
(ii) giving access would have an unreasonable impact on the privacy of other individuals; or
(iii) the request for access is frivolous or vexatious; or
(iv) the information relates to existing or anticipated legal proceedings between us and the individual, and would not be accessible by the process of discovery in those proceedings; or
(v) giving access would reveal the intentions of Christmas Wonder in relation to negotiations with the individual in such a way as to prejudice those negotiations; or
(vi) giving access would be unlawful; or
(vii) denying access is required or authorised by or under an Australian law or a court/tribunal order; or
(viii) both of the following apply:
(A) we have reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to our functions or activities has been, is being or may be engaged in;
(B) giving access would be likely to prejudice the taking of appropriate action in relation to the matter; or
(ix) giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
(x) giving access would reveal evaluative information generated within Christmas Wonder in connection with a commercially sensitive decision-making process.
(e) If we refuse to provide an individual with access to their Personal Information or to correct the Personal Information held by us about them, then we will provide reasons for such refusal. Such reasons will set out the grounds for refusal, the mechanisms available to complain about the refusal and any other matters that are required by the Act.
11.3 Correction of Information
(a) Inaccurate information will be corrected upon receiving advice to this effect. To ensure confidentiality, details of an individual’s Personal Information will only be passed on to the individual if we are satisfied that the information relates to the individual.
(b) From time to time, and having regard to the purpose of the collection and use of Personal Information about individuals, we may contact individuals to seek confirmation that the Personal Information provided to us by the individual is accurate, up-to-date and complete.
12. COMPLAINTS
12.1 Making a complaint
If an individual has a complaint about this Policy or our collection, use or safe disposal or destruction of Personal Information about the individual, any complaint should be directed in the first instance to our Privacy Officer at the contact details set out in the ‘Contacting us’ section of this Policy.
12.2 Handling of complaints
(a) Christmas Wonder will generally manage complaints in the following manner:
(i) we will acknowledge receipt of a complaint within 5 working days of receipt;
(ii) we aim to resolve complaints within 30 days of receipt; and
(iii) if a complainant is not satisfied with the outcome of our internal complaints procedure in respect of our privacy practices, then the complainant may refer their complaint to the Office of the Australian Information Commissioner (“OAIC”). The website for the OAIC is: www.oaic.gov.au.
13. CHANGES TO POLICY
If we decide to, or are required to change this Policy, we will notify you of any such amendments on our websites and post changes on our Privacy Policy webpage so that users may always be aware of what information is collected by us, how it is used, and the way in which information may be disclosed. As a result, please refer back to this Policy regularly to review any amendments. This Policy is current as of August 2026.
14. CONTACTING US
14.1 Contacting us
For concerns, complaints or further information regarding this Policy and our policies and procedures regarding privacy and data security, or any other general queries please contact us at the following address:
The Privacy Officer – Christmas Wonder
Address for postage: PO Box 238, Hervey Bay QLD 4655
Email: elf@ChristmasWonder.com.au
We will respond to your enquiry as soon as possible.
14.2 Contacting the OAIC
If you are not satisfied with our response to your enquiry and for more information on privacy legislation, please visit the website of the Office of the Australian Information Commissioner at www.oaic.gov.au.