The Trustee for After Eight Unit Trust

1. Overview

Thank you for using Romy operating under The Trustee for After Eight Unit Trust (“Romy”).

Romy recognises the importance of safeguarding your information. This Privacy Policy therefore sets out how we handle your information in accordance with the Privacy Act 1988 (Cth) (Privacy Act), which includes the Australian Privacy Principles (APPs) and any related privacy codes.

This Policy outlines how we collect, use, disclose and store your personal information and lets you know how you can access that information. This Policy applies to our obligations when handling information in Australia.

If you have any queries regarding this Policy or our use of your information please contact us using the details set out below. 


2. Consent

As you interact with us, we will collect your information in several ways. Often you will provide this information directly to us, but in other cases it may be collected automatically through technical means, such as cookies. By providing personal information, you consent to us collecting, using, storing and disclosing your personal information in accordance with this Policy or as required or permitted by law. 

If you continue using our services, then we will treat your use as your consent to us handling your personal information in accordance with this Policy.


3. What kinds of personal information do we collect and hold?

If you contact us through our website, by email, or by social media, or purchase items from our store, we will collect the following information:

a. your name

b. your postal address

c. your email address

d. your phone number

e. financial or payment information, such as credit card details (if you have made a purchase)

f. information provided in communications we have with you.

    We also collect the following information about you automatically, through technical means such as cookies, when you browse our store:

    g. internet Protocol (IP) address

    h. your device ID, device type and information, geo-location information about your access and use of our website, including browser session data, device and network information, statistics on page views, acquisition sources, search queries, browsing behaviour and information gathered through internet cookies. If you are a prospective employee or independent contractor applying to work with us at Romy, please refer to Appendix A.

    We may collect some sensitive information from individuals. This includes information that could be inferred due to a result of a working with children check or police check.

    If you consent to providing us with this information, we will only use it for the following purposes relating to our provision of services and to enable you to use our website.

    If you choose not to provide information as requested, we may not be able to service your needs. For example, it will not be possible for us to provide you with our service if you want to remain anonymous or use a pseudonym.

    We sometimes receive unsolicited personal information. In circumstances where we receive unsolicited personal information we will usually destroy or de-identify the information as soon as practicable if it is lawful and reasonable to do so unless the unsolicited personal information is reasonably necessary for, or directly related to, our functions or activities.


    4. Why do we collect your personal information?

    We collect your personal information primarily to provide our online retail and styling services. Some ways we use your personal information are:

    a. for the purpose for which the personal information was originally collected, including complete a purchase or create a wish list through our online store;

    b. to fulfil orders

    c. to analyse and improve our business and website and online store

    d. to identify and interact with you;

    e. to perform administrative and operational functions;

    f. to comply with any legal requirements, including any purpose authorised or required by an Australian law, court or tribunal; and

    for any other purpose for which you give your consent, such as marketing updates or product and service emails.

      If you are a prospective employee or independent contractor applying to work with us at Romy, please refer to Appendix A to understand why we collect personal information.


      5. How we collect your personal information?

      You give it to us We collect personal information directly from you when you:

      a. use our services;

      b. set up an account with us;

      c. interact or share personal information with us via the Romy website and social media; and communicate with us.

        We collect it We may also collect your personal information from third parties including:

        a. service providers;
        b. referrals who may have referred you to us; and
        c. organisations with whom we have an agreement to share information with.

          We will generally obtain consent from the owner of personal information to collect their personal information. Consent will usually be provided in writing; however, sometimes it may be provided orally or may be implied through a person’s conduct. We endeavour to only ask for your personal information if it is reasonably necessary for the activities that you are seeking to be involved in.


          6. Disclosing your personal information?

          Where Romy uses third parties, we may disclose to them your personal information. However, they will only use your information to the extent necessary to allow them to perform the service on our behalf.

          Romy will share your information with the following categories of service providers:

          a. third parties providing payment gateways or who process payments on our behalf such as Stripe and AfterPay.

          b. Google Adwords: Google AdWords is an online advertising service developed by Google, where advertisers pay to display brief advertising copy, product listings, and video content within the Google ad network to web users. Google AdWords’ system is based partly on cookies and partly on keywords determined by advertisers. Google uses these characteristics to place advertising copy on pages where they think it might be relevant. Advertisers pay when users divert their browsing to click on the advertising copy.

          c. Google Analytics: Google Analytics is a freemium web analytics service offered by Google that tracks and reports website traffic. Google launched the service in November 2005 after acquiring Urchin. Google Analytics is now the most widely used web analytics service on the Internet.

          d. Facebook and Instagram: Facebook is an American online social media and social networking service company based in Menlo Park, California.

          e. WooCommerce: WooCommerce is a customizable, open-source eCommerce platform built on WordPress.

          f. to our business or commercial partners; Willow & Blake and Online Business Development Pty Ltd.

          g. to our professional advisers, dealers and agents.

          h. any third parties authorised by you to receive information held by us.

            We may also disclose your personal information if we are required, authorised or permitted by law.

            We may send information to third parties that are located outside of Australia. These third parties are located in the USA and UK, although this list may change from time to time. Disclosure is made to the extent that it is necessary to perform our functions or activities.


            7. Using your personal information for direct marketing?

            From time to time, and in support of our future development and growth, we may use your personal information to contact you to promote and market our products and services. 

            You can opt-out from being contacted for direct marketing purposes by contacting us at or by using the unsubscribe facility included in each direct marketing communication we send. Once we receive a request to opt out from receiving marketing information, we will stop sending such information within a reasonable amount of time.


            8. Security

            We take all reasonable steps to protect personal information under our control from misuse, interference and loss and from unauthorised access, modification or disclosure. 

            If you provide us with your credit card information, the sensitive information will be handled and protected directly by our payment gateway partners, Stripe and Afterpay. We will not be storing it on our website

            While we take reasonable steps to ensure your personal information is protected from loss, misuse and unauthorised access, modification or disclosure, security measures over the internet can never be guaranteed. 

            We encourage you to play an important role in keeping your personal information secure, by maintaining the confidentiality of any passwords and account details used on our website.


            9. Accessing or correcting your personal information

            If you would like to access your personal information, please contact us using the details below. In certain circumstances, we may not be able to give you access to your personal information in which case we will write to you to explain why we cannot comply with your request.

            We try to ensure any personal information we hold about you is accurate, up-to-date, complete, and relevant. If you believe the personal information we hold about you should be updated, please contact us using the details below and we will take reasonable steps to ensure it is corrected, if appropriate. 


            10. Destroying or de-identifying personal information

            We destroy or de-identify personal information when we no longer need it, unless we are otherwise required or authorised by law to retain the information. 


            11. Making a complaint

            If you believe your privacy has been breached or you have a complaint about our handling of your personal information, please contact us using the details below.

            We take privacy complaints seriously. If you make a complaint, we aim to respond within 5 business days to acknowledge your complaint. We will try to resolve your complaint within 30 days. When this is not reasonably possible, we will contact you within that time to let you know how long we will take to resolve your complaint.

            We will investigate your complaint and write to you to explain our decision as soon as practicable.

            If you are not satisfied with our decision, you can refer your complaint to the Office of the Australian Information Commissioner by phone on 1300 363 992 or online at 


            12. Changes

            We may, from time to time, amend this Policy. Any changes to this Policy will be effective immediately upon the posting of the revised Policy on our website. By continuing to use the services following any changes, you will be deemed to have agreed to such changes.


            13. Contact us

            All questions or queries about this Policy and complaints should be directed to: 

                 Privacy Compliance Officer



            This Policy was last updated in March 2023. 

            Appendix A: Prospective employees and independent contractors

            If you are a prospective employee or independent contractor that would like to work or currently works with Romy, the following section sets out how we handle your personal information.

            What information we collect

            If you are a prospective employee or independent contractor applying to work with us at Romy, we may collect the following information:

            a. your name, address and contact details;

            b. business registration details, such as your Australian Business Number or business registration number;

            c. your employment details and qualifications;

            d. financial, billing or payment information; or

            e. information you provide to us as part of the recruitment process.

              Why we collect personal information

              In relation to the personal information of independent contractors or prospective staff members seeking employment at Romy, we collect personal information to allow us to:

              a. carry out our recruitment functions;

              b. correspond with you;

              c. fulfil the terms of any contractual relationship; and

              d. ensure that you can perform your duties.