Safeguarding Your Personal Privacy
PHE International takes your personal privacy extremely seriously.
We take extra care to safeguard your privacy from the second you land on our homepage to the moment your order arrives at your front door. Here is just a few of our special measures:
Strong Computer Defences
PHE International has comprehensive, companywide standards for maintaining the privacy and safety of your personal and billing information. While we can’t go into explicit details, our safeguards include multi-layered firewalls and virus scans, secured servers, mandatory password changes, and the very latest in computer encryption.
All of our products are shipped as anonymously as possible. Depending on your order, you might receive a plain box or a satchel lined with bubble wrap.
Our efforts to ensure your privacy even extends to your credit card statement. Our name will never appear in your billing statement. Instead, your order will be listed simply as 'PHE International Pty Ltd'.
Effective 31 October 2020
PHE International Pty Ltd is the owner of Excite Online Services, Wild Secrets, Fantasy Lingerie, FGMO, Linspree & Sharing Secrets (referred to later as "PHE International" "we," "us" or "our") and fully understands the need to protect your personal information while online.
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.
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
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.
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.
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These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.
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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.
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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.
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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:
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.
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.
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).
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:
- 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
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.
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:
PO Box 350
ABBOTSFORD VIC 3067
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:
PO Box 350
ABBOTSFORD VIC 3067
Making Sure Your Order is Secure
PHE International makes every possible effort to protect your credit card information and personal data by following some of the strictest security standards in the industry to prevent hacking. All communication to thec website is upgraded to be encrypted using current encryption protocols. This works by creating a secure link between your computer and ours so only PHE International can decode your personal information. Look for https or the lock icon in your browser’s address bar.
We follow the Payment Card Industry Data Security Standards (PCI-DSS) when handling customer’s credit card data and work hard to protect you and your information from unauthorized access, alteration, disclosure, or destruction. We have several layers of security measures in place, including, but not limited to:
• Encryption for both data at rest and during transmission
• Robust access controls
• Multi-layered defences
• Vulnerability management, intrusion detection, monitoring, and continuous testing
• A mature InfoSec policy
As an extra level of security, PHE International employs outside companies to regularly test our site and examine our security policies to make sure we’re doing all we can to protect your personal information. Unfortunately, no system can be guaranteed to be 100% secure. You provide all such information at your own risk, but please remember that these risks can be minimized by using responsible browsing habits such as the use of anti-virus software and similar protection measures.
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 email@example.com, quoting “PHE International Pty Ltd.” in the subject line, or
372 Old Street
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
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: firstname.lastname@example.org 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.
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