Privacy Policy

CW Marketing Pty Ltd (ACN 39 004 890 715)

Privacy Policy

Last updated June 2026
Applies to All personal information collected by CWM via our websites, warehouse shop, Zendesk, social media, and any other channel
Legislation Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs), as amended by the Privacy and Other Legislation Amendment Act 2024 (Cth)

1. About This Policy

CW Marketing Pty Ltd (ACN 39 004 890 715) and its related entities (collectively ‘CWM’, ‘we’, ‘us’, or ‘our’) is committed to protecting your personal information and handling it in an open and transparent way.

CWM manufactures, imports, markets, distributes and sells homeware, glassware and ceramic products throughout Australia and New Zealand under brands including Ecology, Porto, Symphony, Degree, Esque, Pasabahce and Ocean Glass.

This Privacy Policy explains how we collect, hold, use and disclose your personal information, and how you can access, correct or raise concerns about your personal information. It applies to all personal information collected by CWM through our websites, warehouse shop, Zendesk, social media pages, and any other means.

By accessing or using any of CWM’s digital channels or providing us with your personal information, you accept the terms of this Privacy Policy.

This Privacy Policy is reviewed annually. If we make material changes, we will update this page and note the revision date above.

2. Personal Information We Collect

‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not the information is true and whether or not the information is recorded in a material form.

We collect personal information that is reasonably necessary for our business functions and activities. The type of information we collect depends on how you interact with us, but may include:

  • Name, residential, billing, postal and delivery addresses

  • Contact details including telephone numbers and email addresses

  • Date of birth or age (where relevant to a transaction or promotion)

  • Transaction and purchase history, including products ordered and payment method details

  • Account login credentials (username; we do not store passwords in plain text)

  • Communications you send us, including enquiries, complaints, and customer service messages

  • Information you provide when participating in surveys, competitions or promotions

  • Device and browser information, IP address, and online identifiers collected via cookies and similar technologies — see Section 3

How We Collect It

Where possible, we collect personal information directly from you. We may also collect personal information from:

  • Third parties such as logistics or fulfilment providers, in the course of delivering your order

  • Publicly available sources, where relevant to our business functions

  • Automated means such as cookies and web analytics tools when you visit our website

We will only collect personal information by lawful and fair means. If we receive unsolicited personal information that we could not have collected ourselves, we will destroy or de-identify it, subject to any legal requirements.

You may visit our website anonymously. However, if you choose not to provide certain personal information, we may not be able to fulfil your order, respond to your enquiry, or provide certain features of our website.

Sensitive Information

Sensitive information is a subset of personal information that includes health information, racial or ethnic origin, political opinions, religious beliefs, criminal records, and biometric data. It is afforded a higher level of protection under the Privacy Act.

CWM does not routinely collect sensitive information. If sensitive information is required in connection with a specific product complaint, warranty claim, or legal matter (for example, health information relevant to a product safety enquiry), we will only collect it with your express consent and where it is reasonably necessary for that purpose. We will not use or disclose sensitive information for any other purpose.

Pseudonyms and Anonymity

Where practicable, you may interact with CWM anonymously or using a pseudonym. However, for most of our services this is not feasible — for example, we require your name and address to deliver an order, and contact details to respond to an enquiry. If you deal with us anonymously or by pseudonym where identification is required, we may not be able to provide the relevant product or service to you.

Consequences of Not Providing Personal Information

If you choose not to provide personal information we have requested, some or all of the following may occur:

  • We may be unable to process or fulfil your order

  • We may be unable to respond to your enquiry, feedback, or customer service request

  • We may be unable to provide certain features of our website or online store

  • We may be unable to provide you with information about products and services you have purchased or expressed interest in

3. Cookies and Tracking Technologies

When you visit CWM’s website, we and our service providers may use cookies, web beacons, and similar tracking technologies to:

  • Recognise your browser and remember your preferences

  • Analyse website traffic and understand how visitors use our site (e.g. via Google Analytics)

  • Support the operation of our online store, including shopping cart functionality

  • Deliver relevant content and measure the effectiveness of our marketing

Cookies do not typically identify you personally — they collect anonymous information about your browsing behaviour. However, in some cases, cookies may be linked to personal information you have provided to us.

You can configure your browser to refuse cookies or to alert you when cookies are being sent. If you disable cookies, some parts of our website and store may not function correctly.

We do not use cookies or tracking technologies to make fully automated decisions about you that have legal or similarly significant effects.

4. How We Use Your Personal Information

We use your personal information only for the primary purpose for which it was collected, or for a related secondary purpose you would reasonably expect. This includes:

  • Processing and fulfilling your orders, including arranging delivery

  • Setting up and managing your customer account

  • Responding to your enquiries, feedback, and customer service requests

  • Sending you order confirmations, delivery updates, and transactional communications

  • Sending you direct marketing communications about our products, services, and promotions — see Section 5

  • Improving our website, products, and services through analytics and customer research

  • Complying with our legal obligations, including fraud prevention and detection

  • Administering competitions, surveys, or promotions you have entered

We will not use your personal information for a purpose other than the primary purpose of collection unless you have consented, or it is required or permitted by law.

5. Direct Marketing

We may use your personal information to send you marketing communications about CWM products, services, promotions and events where you would reasonably expect us to do so, or where you have consented. We will not provide your personal information to third parties for their own marketing purposes.

All marketing emails and messages we send will:

  • Clearly identify CWM as the sender

  • Include our business address

  • Provide a clear and easy mechanism to opt out of future marketing

  • Honour unsubscribe requests promptly — within 5 business days

To unsubscribe from marketing communications, use the unsubscribe link in any email or contact us at the details in Section 10. Once you have unsubscribed, we will not send you further marketing material unless it is necessary to continue providing our services.

Transactional communications — such as order confirmations and shipping notifications — are not marketing and will continue to be sent regardless of your marketing preferences.

6. Disclosure to Third Parties

CWM may disclose your personal information to third parties in the following circumstances:

Service Providers

We share personal information with trusted third-party service providers who assist us in operating our business. These include:

  • Logistics and delivery providers (to fulfil and track your orders)

  • Payment processors and banks (to facilitate secure payment transactions)

  • Customer service platforms (Zendesk)

  • Website and e-commerce platforms (Squarespace)

  • Email marketing service providers

  • IT service providers, including cloud hosting and security vendors

These providers are required to handle your personal information only for the purpose we have engaged them, and to protect it in accordance with applicable privacy laws.

Legal Requirements

We may disclose your personal information to government or regulatory authorities, law enforcement bodies, or courts where required or authorised by law, including in response to a subpoena, court order, or other legal process.

Business Transfers

If CWM is involved in a merger, acquisition, or sale of all or part of its business, your personal information may be transferred as part of that transaction. We will notify you if your personal information is subject to a materially different privacy policy as a result.

7. Overseas Disclosure

Before we disclose personal information to an overseas recipient, we take reasonable steps to ensure they handle it in accordance with the Australian Privacy Principles. CWM remains accountable for how your personal information is handled by overseas recipients.

Some of our service providers are located outside Australia. This may include cloud hosting providers, e-commerce platforms, and business support services. Your personal information may be accessed from, or processed in, countries other than Australia as a result of these arrangements.

We also engage contractors and workers who are located overseas. Where such workers access personal information held by CWM — including via remote access to Australian-hosted systems — this constitutes a cross-border disclosure under Australian Privacy Principle 8 (APP 8). We address this through contractual obligations, access controls, and technical security measures.

Where we disclose personal information to overseas recipients, we take reasonable steps to ensure they comply with obligations equivalent to the Australian Privacy Principles. We remain accountable under Australian law for how that information is handled.

8. Security of Personal Information

CWM takes reasonable technical and organisational measures to protect your personal information from loss, misuse, unauthorised access, modification, disclosure, or destruction. Our security measures include:

  • Multi-factor authentication (MFA) on systems that process personal information

  • Role-based access controls, limiting access to personal information to staff and contractors who require it for their role

  • Endpoint security software on all devices used to access CWM systems

  • Encrypted transmission of data (HTTPS) across our website and customer-facing platforms

  • VPN access required for remote access to CWM internal systems

  • Physical security controls at our premises

  • Staff training on privacy obligations and phishing awareness

Despite these measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of your personal information transmitted via the internet, and any such transmission is at your own risk.

We take reasonable steps to securely destroy or de-identify personal information when it is no longer required for the purpose for which it was collected, or as required by law.

9. Data Breaches

CWM is subject to the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988 (Cth). If we become aware of reasonable grounds to believe that an eligible data breach has occurred — that is, a breach that is likely to result in serious harm to any affected individual — we will:

  • Take immediate steps to contain the breach and assess the risk of harm

  • Notify the Office of the Australian Information Commissioner (OAIC) as soon as practicable

  • Notify affected individuals, with information about the breach and steps they can take to protect themselves

We maintain an internal incident response process to identify, assess, and respond to suspected data breaches promptly.

10. Accuracy, Access and Correction

We take reasonable steps to ensure that the personal information we hold about you is accurate, complete, and up to date. If your details change, please let us know so we can update our records.

You have the right to request access to the personal information CWM holds about you, and to request correction of information that is inaccurate, out of date, incomplete, irrelevant, or misleading. To make a request, contact us using the details in Section 11.

We will respond to access and correction requests within 30 days. There is no charge for making a request, though we may charge a reasonable fee if significant resources are required to locate and compile the information.

In some limited circumstances we may decline to provide access — for example, where doing so would unreasonably prejudice the privacy of another individual, where the information relates to anticipated legal proceedings, or where disclosure is restricted by law. If we decline, we will tell you why.

11. How to Contact Us — Privacy Enquiries and Complaints

If you have any questions about this Privacy Policy, wish to access or correct your personal information, or believe CWM has not complied with this Privacy Policy or the Australian Privacy Principles, please contact our Privacy Officer:

Privacy Officer CFO
Organisation CW Marketing Pty Ltd
Postal address PO Box 2369, Rowville VIC 3178
Telephone 03 9765 5700
Email privacy@cwmhomewares.com.au

We will acknowledge your enquiry or complaint within 5 business days and aim to resolve it within 30 days. If we are unable to resolve your complaint to your satisfaction, you may refer it to the Office of the Australian Information Commissioner (OAIC):

12. Your Privacy Rights

Under Australian privacy law, you have the right to:

  • Know what personal information CWM holds about you

  • Request access to your personal information

  • Request correction of inaccurate, incomplete, or out-of-date information

  • Opt out of receiving direct marketing communications at any time

  • Make a complaint about how your personal information has been handled

  • Seek a remedy through the OAIC or, for serious invasions of privacy, through the courts under the statutory tort introduced in June 2025

We are also preparing for additional individual rights that are expected to be introduced under the second tranche of Australian privacy law reform, including a right to erasure (deletion) and a right to object to certain uses of your data. We will update this policy when those changes come into effect.

13. Links to Other Websites

Our website may contain links to third-party websites. This Privacy Policy applies only to CWM’s own websites and digital channels. We are not responsible for the privacy practices of third-party websites and encourage you to review their privacy policies before providing any personal information.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our business, technology, or legal obligations. The most current version will always be available at www.cwmhomewares.com.au. Material changes will be noted with a revised date at the top of this page.

This policy supersedes all previous versions of CWM’s Privacy Policy, including the version dated March 2018.

CW Marketing Pty Ltd  |  ABN/ACN 39 004 890 715  |  Last updated: June 2026  |  Enquiries: privacy@cwmhomewares.com.au