Last updated: April 2021
At Gusto we are committed to ensuring that your personal data is protected and never misused.
Privacy policies can be complicated. We have tried to make ours as clear and as accessible as possible. To help, we have also summarised how we handle your personal data at Gusto in our privacy principles below. These principles demonstrate our commitment to protecting your privacy and handling your personal data in the right way and as you would expect it to be handled.
At Gusto we:
- Will only ask for or collect the personal data we need to provide and improve the service, products and experiences our customers expect.
- Give you control over the personal data we hold about you to ensure it is accurate and reflects your preferences.
- Make sure your personal data is always secure and protected.
- Are fair and transparent about how we use the personal data we hold.
- Only ever use your personal data for the purpose that you trusted us to use it for.
Respect your choices and will inform you if there are important changes that affect your personal data or how we use it.
- Take responsibility for the personal data that we hold about you.
What personal data do we collect?
We are not interested in collecting every personal detail about you. Our main reason for collecting your personal data is to provide and improve the service, products and experiences that you and our customers expect from us.
Personal data is defined slightly differently across the world. To guarantee your privacy and the protection of your information, we define it as any information that could be used to identify you or another individual.
We collect personal data about you in a number of different ways. In this section, we explain the different ways we collect personal data about you and the ways in which that information will be used.
Information you share with us
We collect personal data that you share with us when you contact us or interact with us through our website, apps, email, phone, in person at our stores, stands and events, or otherwise.
For example, you will provide information to us when you contact our customer service teams, place an order, register your warranty, complete a survey, competition or questionnaire, update your preferences and account information, connect through a Gusto app or rate one of our products on our website.
Through these interactions you may share with us: your name, address, e-mail address, contact number and payment information. In some circumstances, we will need that information to be able to provide you with a product or service that you have asked for; for example, we need your payment information when you buy a product, and your address to deliver it to you.
Information from Gusto products
As well as the personal data you share with us about yourself and your Gusto product, we will collect and handle personal data directly from your Gusto connected products. A connected product is a Gusto product that is “smart”, internet enabled or operated through a Gusto app.
We will collect information about your use of our connected products (for example, when they are used and for how long), their responsiveness and any errors (or potential errors) with them.
Some of the information we collect from your use of our connected products and apps will enable us to determine the location of your connected product. In particular, you will need to enable location tracking on your phone (or other device) when you first register your connected product (otherwise, we will not be able to connect it). It is useful for us to know your location so that we can understand the environmental conditions in which your connected product is operating which helps us to optimise the performance of the connected product.
Gusto uses Android location services for connectivity to enable the pairing of a Gusto product with the Gusto Link App through Bluetooth or WiFi. Please note that Gusto does not collect any location data as a result of this connection.
Additionally, our Light Cycle makes use of background location services to:
- Receive product software updates
- To synchronise the time on the product with the time on your connected mobile device
- To load and amend any schedules, preferences and setting changes for your product
- To maintain the right light profile based upon your light’s location.
The Light Cycle’s location data is anonymised within Gusto as the location data relates to the product, and not the user.
Some of our connected products, or specific features of our connected products, will not be able to operate properly without collecting certain information.
Information from your online interactions
We collect and store limited personal data and some anonymous, aggregate statistics from all visitors to our websites and users of our apps, whether you actively provide us with that information or merely browse our websites or use our apps. The information we collect includes the internet protocol (IP) address of the device you are using, the browser software you use, your operating system, the date and time of access, the internet address of the website from which you link through to our website and information on how you use our websites or apps.
We use this information so that we can see how well our websites and apps are working, how they are used and what users look at most.
We also collect and handle information about how you engage with our promotional campaigns and advertising online, outside of our own websites (for example, on Google, YouTube and on social media).
As a user of our products or services, we will send you support communications by e-mail. As long as you are happy for us to do so, we would also like to keep you posted on anything that’s happening at Gusto which we think you might like to know about; whether it’s our latest product announcements, owner offers or upcoming events, we want to make sure you’re happy with the communications you receive from us. You can find out how to update or change whether you would like to hear from us, or stop us contacting you, in the section below titled ‘How can you change the way that we contact you?’
We collect information about how you engage with our e-mails; including whether they are delivered to you, whether you open them, whether you choose to learn more about what’s happening at Gusto (for example, by clicking on a link in our e-mail) and if you ask us not to contact you anymore (by clicking on the unsubscribe option included in all our e-mail correspondence).
We use that information by itself and in combination with your customer record (the information you share with us) to make sure that we stop sending you support or marketing communications when you ask us to. We also use it to make our e-mails as interesting as possible by providing you with content and experiences that we think you will be interested in based on how you have engaged with our previous e-mails; you have the right to object to our use of your information for this purpose (see the section below titled ‘Your controls and choices’).
We love interacting with you on social media. You may use social media to contact us about your Gusto products, or to let people know what you think about your Gusto product. We review publically available social media and online sites to get a better understanding of what people are saying about us, and our products, technology and services and to assist consumers who prefer to contact us through social media.
The information we collect from social media and online sites, including Facebook, YouTube, Twitter, Pinterest, Line and Snapchat, sometimes includes personal data that has been put online and is publicly available. We make sure any information we use is properly credited to its source or is made anonymous.
These online and social media sites typically have their own privacy policies explaining how they use and share your personal data. You should carefully review those privacy policies before you use these sites to make sure that you are happy with how your personal data is being collected and shared.
Information we collect at our stores, stands and events
You may share personal data with us when you visit us in person at our stores, stands and events; such as your name, contact details and payment information (see the section above titled “Information you share with us”).
We will also collect personal data about you through our use of CCTV, filming and photography. CCTV cameras are primarily used for security purposes; in some of our stores, they will also help us to measure traffic (that means, how many people come in and out of our stores). We will film and take photographs at some of our events and exhibitions (such as, when we open a new store); we use film and photographs for our business purposes (for example, to post on our social media pages). We will display notices at those of our stores, stands and events where we use CCTV, or where we intend to film or take photographs, to let you know that we will collect personal data about you.
If you have Wi-Fi or Bluetooth enabled on your phone (or other device) when you visit us at our stores, stands and events, we will also collect limited personal data from your device through beacons installed at these locations. Beacons are small wireless transmitters that connect with nearby smart devices (e.g. smartphones) through Bluetooth.
Information we collect from third party data providers
We only collect information from third parties who have obtained your permission to share your data. This will include aggregated demographic and lifestyle data that provide insights into the relative affluence of households within your neighbourhood, from third party data providers who help us to give you a more relevant owner experience by enabling us to provide offers at the right time, and to give you more relevant services and advice.
How do we use your personal data?
Our main reason for collecting and using your personal data is to provide and improve the service, products and experiences that you expect from us.
Information you share with us
We use the personal data you share with us, or our retail partners, in the following ways:
- To provide, manage and coordinate the purchase, delivery and any required after sales care of your products
- To respond to your queries and requests;
- To communicate with you;
- To provide services and support for our products;
- For customer satisfaction surveys to enable us to identify where service and product improvements can be made and to allow us to improve your experience should you need support from one of our experts;
- To provide updates to you about any changes to Gusto’s policies, terms and conditions and any other matters which we may need to tell you;
- As long as you are happy for us to do so, to tell you about our other products and services;
- To provide you with essential service updates about your Gusto products; and
- To customise and improve the way that you shop with us in the future; for example, by showing you products and offers that we think you might like, both on our websites and apps and on certain third party websites (including on social media platforms);
- To document, monitor and record the lifecycle of our products, including stock management of Gusto products.
Information from your online interactions
We use the personal data from your online interactions, by itself and in combination with other personal data that we collect about you to identify any part of our websites or apps that aren’t working as well as they should be – so that we can fix things and make our websites and apps better for you and other users;
We also want to be able to monitor your use of our websites and apps, and how you engage with our promotional campaigns and advertising online, so that we can:
- Customise and improve the way that you shop with us in future (for example, by showing you products and offers that we think you might like); and
(as long as you are happy for us to do so) send you more relevant and interesting marketing communications;
- Detect and prevent fraud;
- Keep our websites, apps, products and IT systems secure;
- Produce analytics, user profiles, reports and targeted advertising;
- To respond to online queries through the web-enabled chat services on our websites.
Gusto does not take any decisions involving the use of algorithms or profiling that significantly affects you.
Information from your in person interactions
When you visit a Gusto store, or Gusto stand within another retailer, we will sometimes need to process your personal data to:
- Respond to queries;
- Provide support for your existing products;
- Let you know when products or models are next in stock;
- Order, process the payment of, and coordinate the delivery of new products.
To promote our products we often hold Gusto events in a variety of venues, such as Gusto stores or other retailer properties. By attending these events your personal data may be captured:
- As part of photographs or filming for social media, promotional media or archiving purposes;
- By our experts and stylists, with your permission, for sharing on social media or in promotional materials;
- To book an appointment with one of our experts.
From time-to-time, we use your personal data to help you with the Gusto products you own. We do this in various ways, including e-mail, post, SMS, phone and in-app push notifications.
As a user of our products or services, we will send you the following support communications:
- Helpful information about your Gusto product or the Gusto service you use;
- Reminders about how to carry out maintenance on your Gusto product for optimal performance;
- Alerts for recommended app or software updates or upgrades that we think will improve the performance of your product;
- Information about how and where to get help from Gusto experts should you need support;
- Information about your Gusto warranty;
- Alerts regarding any important product safety or recall announcements;
- Requests for your feedback on how we perform after you have used a Gusto product or service; and
- Send invitations to Gusto events that may be of interest to you.
We will send you support communications unless you change your preferences, or tell us that you want to stop receiving support communications from us. Please see the section below about how to do this.
If your details change, please let us know so that we can stay in touch.
Other potential uses of your personal data
We use your personal data:
- To assist in any disputes, claims or investigations relating to your Gusto product or warranty matters;
- To detect and prevent fraudulent transactions;
- To comply with our legal obligations and;
- For profiling and statistical analysis. As part of this activity we combine different categories of personal data that we collect about you. For example, we combine personal data from your online interactions, information you share with us, or information from Gusto products, for the profiling and statistical analysis of product popularity, of your behaviour when you use our website or apps or of how our products are used.
Other purposes include:
- To ensure that our own processes, procedures and systems are as efficient as possible;
- To analyse and enhance the information that we collect;
- To determine the effectiveness of our promotional campaigns and advertising; and
- To customise and improve the way that you shop and engage with us in the future.
You have the right to object to the processing of personal data in this way. For more information on how to exercise your right to object, see the section below titled ‘Your controls and choices’.
What is our justification for handling your personal data in this way?
Data protection and privacy laws in some countries require us to have what’s called a “legal basis” or “lawful ground” for handling personal data. Broadly, that means that we have to have a legal justification for handling your personal data. For the most part, we need to handle your personal data to be able to:
provide you with the products or services that you have asked for; and
for our products, websites and apps to be able to work properly and to do all the things that you expect them to.
Sometimes, our use of your personal data is not strictly necessary for us to be able to provide you with our products and services, or for them to work properly. In those circumstances, we have what’s called a “legitimate interest” in handling your personal data; our “legitimate interest” may be to:
- detect and prevent fraud;
- keep our websites, apps, products and IT systems secure;
- ensure that our own processes, procedures and systems are as efficient as possible;
- analyse and enhance the information that we collect;
- determine the effectiveness of our promotional campaigns and advertising; and
- customise and improve the way that you shop and engage with us in future.
There will be certain personal data that you share with us which we specify as being optional (for example, when you update your account information). We will explain how we use that information and if you choose to provide it to us, you are agreeing to our use of your information in that way. You can ask us to delete that information at any time by contacting Gusto customer service or by e-mailing our privacy team at email@example.com.
Finally, in some, relatively limited circumstances we will need to handle your personal data in a certain way to be able to comply with our legal obligations; for example, if we are requested to disclose your personal data to regulatory bodies or law enforcement authorities.
Ultimately, the reason we handle your personal data in the way we do is so that we can directly or indirectly, improve our products, services and your overall experience of Gusto as a business. Whatever our justification for handling your personal data (whether it is necessary for us to provide you with a certain product, or it is in our “legitimate interests”), we make sure that we take steps to honour our commitment to protect your privacy.
Visitors to Gusto premises
To ensure that we adhere to our security, health and safety, and fire marshalling requirements, we will need to process the personal data of all visitors to our sites.
The level of personal data required may differ by local country requirements, but in general we will be required to process the following:
- Contact details;
- Where required, government issued identification documentation (e.g. identity cards, passports, drivers licences); and
- Where required, photographs.
We use your personal data in the following ways:
- To manage visitor access and notification of arrival;
- To ensure that appropriate security access is provided;
- To log current onsite population for the purposes of health and safety and fire marshalling;
- Where applicable, to provide a required or requested services (e.g. onsite product support); and
- Where required, to complete non-disclosure agreements or other relevant legal documentation.
- Suppliers, Press and Media, Ambassadors, Influencers, and other Third Parties’ personal data
The personal data that we will process includes:
- Contact details;
- Payment information and terms; and
- References and/or background information.
We use your personal data in the following ways:
- To enable Gusto to work with you and make use of your services;
- To monitor your use of any Gusto data or assets;
- To be able to process and fulfil the agreed compensation for your services; and
- To complete our required due diligence process.
Gusto contact promise
We love to keep you posted, whether it’s on our latest product announcements, owner offers, opportunities to test new Gusto products, or upcoming events. We will also occasionally provide you with information about the James Gusto Foundation and the James Gusto Award.
We do this in various ways, including e-mail, post, SMS, in-app and push notifications, via social media platforms and by phone, but only if you are happy for us to do so. Ultimately, we want to make sure you’re happy with the communications you receive from us.
We therefore promise to:
- Only send you marketing communications when you have told us it is ok to do so;
- Only allow another Gusto Group company to send you marketing communications if you have told us it is ok to do so;
- Never pass your personal data to anyone outside the Gusto Group for them to use for their own marketing purposes; and
- Give you the option to stop receiving support or marketing communications at any time.
- How can you change the way that we contact you about our products, services and support?
We will only send you marketing communications when you have told us that you are happy for us to do so.
Changing your preferences
If you have previously said that you would like us to contact you (“opted-in”) but would like to change or update the way that we do so, you can update your preferences by:
- Contacting Gusto customer service and stating that you would like to change or update the way that we contact you; or
- Logging onto your account on our website and changing your preferences and information.
- What personal information does Gusto share with third parties?
Sharing within the Gusto Group
Most of Gusto’s processes, procedures and systems are shared across the Gusto Group, which means that we need to share your personal data between us. We make sure that access to your personal data is limited to those of our staff who need it, and that all staff understand how and why we protect your personal data. Transfers of personal data between Gusto entities (including those outside of the EEA) are governed by Gusto’s Intercompany Agreement.
Third party service providers
- Certain distributors, who help us to sell our products in certain countries;
- Those helping us to deliver products to you;
- Third parties that help us with mailing services, product services and repairs, processing product purchases, financial services, audit services, administrative services, IT technologies (e.g. data storage), security services and insurance claims; and
- Third parties that help us to provide services and responses to you.
Third parties that help us with our advertising and marketing
We want to make sure that our advertising and marketing is relevant and interesting to you and our other customers. That means that we work with third parties to help us to understand how well our online advertising works, or to reach people who are more interested in Gusto products. They do this by setting cookies on our website (more information on this can be found in our cookies policy).
We will also share limited personal data (such as name and contact details) with:
- social media platforms (such as Facebook), who serve our advertising on their platforms and
- third party data providers and analytics companies, who perform data matching and/or data analysis on our behalf.
Other third parties
We will also share your personal data if we are required to do so by law, including in response to a legal process, such as a court order or subpoena, or to comply with other national, state, provincial or local laws.
If you would like more information on how we share your personal data, please email our Privacy Team at firstname.lastname@example.org.
Links to third party websites
We provide links to other websites which are not operated and controlled by Gusto. We have no control over and are not responsible for the content of those sites or how the third parties responsible for them collect and use your personal data. We do not endorse or make any representations about third party websites.
Third party websites usually have their own privacy policies explaining how they use and share your personal data. You should carefully review those privacy policies before you use these websites to make sure that you are happy with how your personal data is being collected and shared.
How long do we keep your personal data?
How do we protect your personal data?
We are committed to protecting your personal data. We use appropriate technical and organisational measures, including encryption, to protect your personal data and privacy, and review those regularly. We protect your personal data using a combination of physical and IT security controls, including access controls that restrict and manage the way in which your personal data and data is processed, managed and handled. We also ensure that our staff are adequately trained in protecting your personal data. Our procedures mean that we may occasionally request proof of identity before we share your personal data with you.
In the unlikely event that we do suffer a security breach which compromises our protection of your personal data and we need to let you know about it, we will do so.
Data transfers, storage and the global handling of your personal data
The relevant Gusto group company or companies will collect personal data from you in the country in which you live. We, and those third parties that we share your personal data with, then host, store and otherwise handle that information in the UK, in the countries within the European Economic Area (EEA) or in any country outside of the EEA, including those listed in the Contacts.
We will make sure that any transfers of your personal data from one country to another comply with those data protection and privacy laws which apply to us. European data protection laws, in particular, include specific rules on transferring personal data outside the EEA. Transfers of personal data between Gusto entities (including those outside of the EEA) are governed by Gusto’s Intercompany Agreement.
When transferring personal data outside the EEA, we will:
- include standard data protection clauses approved by the European Commission for transferring personal data outside the EEA into our contracts with those third parties (these are the clauses approved under Article 46.2 of the General Data Protection Regulation (GDPR)); or
- ensure that the country in which your personal data will be handled has been deemed “adequate” by the European Commission under Article 45 of the GDPR.
If you would like to receive this information in another format or have any questions, comments or concerns about how we use the personal data we hold about you, please contact our Privacy Team.
You can also contact the relevant regulator or authority in your country that is responsible for handling complaints about the use of personal data.
You can contact our Global Privacy Team at any time by email at email@example.com or in writing at:
Gusto Global Industries Pty Ltd
PO Box 1640
KINGSCLIFF NSW 2487