Stratuum Privacy Policy

This Privacy Policy explains how Neemon Investments Pty Ltd trading as Stratuum (“we”, “us” or “our”) handles personal information when you visit stratuum.com.au, purchase a product, start or manage a subscription, contact us or interact with our advertising.

• Legal entity: Neemon Investments Pty Ltd
• ABN: 36 498 582 441
• Address: Return address provided with your return or on request via our contact form.
• Privacy contact: hello@stratuum.com.au
• Customer support: hello@stratuum.com.au

We aim to handle personal information transparently and in accordance with applicable Australian privacy law. We follow privacy-by-design practices even where a particular legal requirement may not apply to us because of our size or circumstances.

1. Personal information we collect

The information we collect depends on how you interact with us.

Information you provide

• your name
• email address
• telephone number, where needed for delivery or support
• delivery and billing addresses
• order, return, refund and subscription information
• communications you send to us
• marketing preferences and consent choices
• information reasonably required to investigate a product-quality or safety concern, such as an order number, batch number and a factual description of what occurred

Payment information

Payments are processed by Stripe. We do not intend to receive or store your full payment-card number or card security code. Stripe may provide us with limited payment information, such as payment status, card type, expiry details, billing country and a transaction reference.

Information collected when you use the website

Depending on your privacy choices, we may collect:

• IP address and general location derived from it
• browser, device and operating-system information
• pages viewed and interactions with the website
• referring website or advertising campaign
• UTM campaign parameters
• cookie and similar identifiers
• Meta click and browser identifiers, such as _fbc and _fbp, where applicable
• checkout, purchase and subscription events
• diagnostic, security and error information

Sensitive and health information

Stratuum is an online cosmetics retailer. We do not ask you to provide a diagnosis, medical history, procedure details, photographs of a skin condition or other sensitive health information through ordinary website forms.

Please do not include medical information, clinical photographs or urgent health concerns in our contact form. If we receive unsolicited sensitive information that we do not need and are not permitted to retain, we will take reasonable steps to delete or de-identify it.

2. How we collect information

We may collect personal information:

• directly from you when you place an order, subscribe, contact us or make a privacy choice
• automatically through essential website technology
• through optional analytics and advertising technology where you have permitted it
• from Stripe in connection with a payment or subscription
• from delivery, fulfilment, email, hosting and customer-support providers
• from Meta or another advertising platform in connection with a campaign, subject to your privacy choices and the platform’s settings
• when another person purchases a product for delivery to you

Where practical, we collect information directly from the person concerned.

3. Why we collect, use and disclose information

We may handle personal information to:

• provide the website and maintain its security
• process and deliver orders
• create and manage subscriptions
• process payments, refunds and charge disputes
• provide receipts, order updates and customer support
• manage returns, product-quality enquiries and safety reports
• prevent fraud, misuse and unauthorised transactions
• maintain accounting, tax and business records
• improve website reliability, usability and conversion performance
• measure advertising performance where you have allowed advertising technology
• send marketing communications where we have consent or another lawful basis to do so
• comply with legal obligations and exercise or defend legal rights
• conduct aggregated or de-identified analysis

We do not sell personal information as a standalone product. We do not intend to trade in health information.

4. Cookies, analytics and advertising technology

Essential technology

Essential cookies and similar technology support functions such as:

• secure checkout
• fraud prevention
• load balancing and website security
• remembering your privacy choices
• maintaining a temporary shopping selection

These functions are necessary for the website and payment flow to operate.

Optional analytics and advertising technology

With your permission, we may use analytics and advertising technology to understand how visitors reach and use the website, measure campaigns and help show relevant advertising.

This may include the Meta Pixel and Meta Conversions API. Where enabled, events such as viewing Cohesion, selecting an offer, beginning checkout or completing a purchase may be shared with Meta together with limited identifiers used for measurement and matching.

We configure tracking to minimise personal information and avoid sending contact-form text, skin concerns, medical details, photographs or other sensitive information to advertising platforms.

Your choices

On your first visit, you can choose:

• Allow all — permits optional analytics and advertising technology
• Essential only — uses only technology needed to operate the website and checkout
• Manage choices — lets you control available categories

You can change your selection at any time through the Privacy choices link in the website footer.

Browser controls, ad-platform settings and privacy tools may provide additional choices. Blocking essential technology may prevent checkout or other website functions from working correctly.

Do Not Track and similar signals

Browser signals are not implemented consistently across services. We will honour supported consent and opt-out mechanisms described on this website and will review emerging technical standards.

5. Direct marketing

We may send product news, education or promotional messages where you have expressly subscribed or where otherwise permitted by law.

• Marketing consent is separate from placing an order.
• Marketing boxes are not pre-selected.
• Each marketing email will identify the sender and include a clear unsubscribe option.
• You may also withdraw consent by contacting us.
• We will action unsubscribe requests as required by applicable law.

Transactional messages about an order, payment, delivery, subscription, recall, safety issue or customer-service request are not marketing messages and may still be sent where necessary.

6. Who we disclose information to

We may disclose personal information to service providers and other parties where reasonably necessary, including:

• Stripe, for payment, billing, fraud prevention and subscription management
• website hosting, content-delivery, database and security providers
• email and transactional-message providers
• fulfilment partners, warehouses and delivery carriers
• Meta and other advertising or analytics providers, where you have permitted the relevant technology
• professional advisers, insurers, accountants and auditors
• regulators, courts, law-enforcement bodies or other parties where required or authorised by law
• a purchaser or adviser in connection with a genuine proposed sale, restructure or transfer of the business, subject to appropriate confidentiality and legal safeguards

We require providers to handle information only for authorised purposes and to apply appropriate safeguards.

7. Overseas processing and disclosure

Some providers may store or process personal information outside Australia. At launch, our principal providers and likely processing locations are expected to include Stripe, Meta, our website host, database provider, email provider and support or fulfilment provider. Before publishing this policy, we will replace the placeholders with locations that are reasonably practicable to identify and maintain a current internal register of processors.

Where Australian privacy law applies, we take reasonable steps in the circumstances to address the privacy handling of overseas recipients. However, overseas recipients may also be subject to the laws of their country.

8. Data quality

We take reasonable steps to keep personal information accurate, complete and current. You can ask us to correct your information by contacting hello@stratuum.com.au. Customers are responsible for checking delivery details before submitting an order.

9. Security

We use administrative, technical and physical safeguards appropriate to the information and our operations. No internet transmission or storage system is completely secure. If a data incident occurs, we will investigate and take steps required by applicable law.

10. Retention and deletion

We retain personal information only for as long as reasonably needed for the purposes described in this policy, including legal, tax, accounting, fraud-prevention, dispute and product-safety purposes. When information is no longer needed and no legal exception applies, we take reasonable steps to delete or de-identify it.

11–16. Access, withdrawal, children, links, complaints and changes

You may request access to or correction of personal information, withdraw consent, or complain to the Office of the Australian Information Commissioner (oaic.gov.au) if dissatisfied. We do not knowingly seek personal information from children. The website may link to third-party services governed by their own notices. We may update this policy when our services, providers or legal obligations change; the current version will be published here with its effective date.

Send privacy questions or requests to hello@stratuum.com.au.

Contact

Privacy Officer
Neemon Investments Pty Ltd trading as Stratuum
Return address provided with your return or on request via our contact form.
hello@stratuum.com.au

This is an implementation draft, not a substitute for legal advice. Replace every placeholder, verify the data processor list and overseas locations, and obtain Australian legal review before publication.