Holt Seafood Company Pty Ltd ABN: [Insert ABN]

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1. Introduction

Holt Seafood Company Pty Ltd (“Holt Seafood”, “we”, “us”, or “our”) is committed to protecting the privacy of individuals who visit our website at holtseafood.com (the “Website”) and who interact with our business.

This Privacy Policy explains how we collect, use, store, disclose, and protect your personal information in accordance with the Australian Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs), and the European Union General Data Protection Regulation (GDPR) where applicable.

By using our Website, you acknowledge that you have read and understood this Privacy Policy.

2. Who We Are

Holt Seafood Company Pty Ltd is an international seafood import and export company headquartered in Sydney, Australia, with operations in Barcelona, Spain.

Registered Address: PO Box 1042 Lane Cove, NSW 1595 Australia

Email: [email protected] Phone: +61 (2) 9418 6966

For the purposes of the GDPR, Holt Seafood Company Pty Ltd is the data controller responsible for your personal information.

3. Information We Collect

We collect limited personal information through our Website. The types of personal information we may collect include:

Information you provide directly:

• Your name, email address, and the content of any message you submit through our Website contact form.
• Any other information you voluntarily provide when communicating with us via email or phone.

Information collected automatically:

• Technical data such as your IP address, browser type and version, operating system, referring website, pages visited, time and date of your visit, and time spent on pages.
• This information is collected through Google Analytics and standard web server logs.

We do not collect sensitive information (such as health data, racial or ethnic origin, or political opinions) through this Website.

4. How We Use Your Information

We use your personal information for the following purposes:

• Responding to enquiries: To respond to messages and enquiries you submit through our contact form or via email.
• Business communications: To communicate with you about our products, services, and business operations where relevant to your enquiry.
• Website analytics: To understand how visitors use our Website so we can improve its content, functionality, and user experience.
• Legal compliance: To comply with our legal obligations under Australian law and, where applicable, EU law.
• Protecting our interests: To protect our legal rights and enforce our Terms and Conditions where necessary.

We do not use your personal information for automated decision-making or profiling.

5. Legal Basis for Processing (GDPR)

For visitors located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we process your personal information on the following legal bases:

• Legitimate interests: We process technical data collected through analytics to understand Website usage and improve our services. Our legitimate interest is maintaining and improving our Website and business operations.
• Consent: Where you submit information through our contact form, you consent to us processing that information to respond to your enquiry.
• Legal obligation: We may process your information where necessary to comply with a legal obligation to which we are subject.

You may withdraw your consent at any time by contacting us at [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

6. Google Analytics

We use Google Analytics to collect anonymised data about how visitors interact with our Website. Google Analytics uses cookies to gather information such as the pages you visit, how long you spend on the site, and how you arrived at the site.

This data is aggregated and anonymised, meaning it does not personally identify you. Google Analytics data is processed by Google LLC in accordance with their privacy policy.

You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout.

For more information about how Google uses data, visit https://policies.google.com/privacy.

7. Cookies

Our Website uses cookies — small text files placed on your device — to facilitate the operation of the Website and to support analytics.

Types of cookies we use:

• Essential cookies: Required for the basic functionality of the Website, such as navigation and access to secure areas.
• Analytics cookies: Used by Google Analytics to collect anonymised information about how you use the Website.

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies or alert you when cookies are being sent. Please note that disabling cookies may affect the functionality of the Website.

8. Disclosure of Your Information

We do not sell, rent, or trade your personal information to third parties.

We may share your personal information in the following limited circumstances:

• Service providers: With trusted third-party service providers who assist us in operating our Website and conducting our business (such as website hosting providers and Google Analytics). These providers are contractually obligated to protect your information and may only use it for the specific services they provide to us.
• Legal requirements: Where we are required to do so by law, regulation, legal process, or enforceable governmental request.
• Business transfers: In connection with a merger, acquisition, or sale of all or a portion of our business assets, in which case your personal information may be transferred to the acquiring entity.
• Protection of rights: Where necessary to protect the rights, property, or safety of Holt Seafood, our users, or the public.

9. International Data Transfers

As we operate in both Australia and Spain, your personal information may be transferred between these countries. Additionally, data collected through Google Analytics may be processed by Google in various countries, including the United States.

Where personal information is transferred outside the EEA, we ensure that appropriate safeguards are in place, including Standard Contractual Clauses approved by the European Commission, or reliance on the recipient’s participation in recognised data protection frameworks.

For transfers of personal information outside Australia, we take reasonable steps to ensure that the overseas recipient handles your information in accordance with the Australian Privacy Principles.

10. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

• Contact form submissions: Retained for up to 2 years from the date of your last communication with us, unless an ongoing business relationship requires longer retention.
• Analytics data: Retained in accordance with our Google Analytics settings, currently set to 14 months.

When personal information is no longer required, we will securely delete or anonymise it.

11. Your Rights

Under Australian Privacy Law

If you are located in Australia, you have the right to:

• Access the personal information we hold about you.
• Request correction of any inaccurate or incomplete personal information.
• Complain to the Office of the Australian Information Commissioner (OAIC) if you believe we have breached the Australian Privacy Principles. You can contact the OAIC at www.oaic.gov.au.

Under the GDPR (EEA, UK, and Switzerland)

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following additional rights:

• Right of access: To request a copy of the personal information we hold about you.
• Right to rectification: To request correction of inaccurate or incomplete personal information.
• Right to erasure: To request deletion of your personal information where there is no compelling reason for its continued processing.
• Right to restrict processing: To request that we limit the processing of your personal information in certain circumstances.
• Right to data portability: To request that we provide your personal information in a structured, commonly used, and machine-readable format.
• Right to object: To object to the processing of your personal information based on our legitimate interests.
• Right to withdraw consent: To withdraw consent at any time where processing is based on your consent.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days (or within the timeframe required by applicable law).

If you are located in the EEA and believe that our processing of your personal information infringes the GDPR, you have the right to lodge a complaint with your local data protection supervisory authority.

12. Data Security

We take reasonable technical and organisational measures to protect your personal information from unauthorised access, loss, misuse, or alteration. These measures include secure hosting environments, access controls, and encryption where appropriate.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

13. Children’s Privacy

Our Website is not directed at children under the age of 16, and we do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child under 16, we will take steps to delete that information promptly. If you believe a child has provided us with personal information, please contact us at [email protected].

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Any updates will be posted on this page with a revised “Last updated” date.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way we handle your personal information, please contact us:

Holt Seafood Company Pty Ltd PO Box 1042 Lane Cove, NSW 1595 Australia

Email: [email protected] Phone: +61 (2) 9418 6966

For privacy-related complaints in Australia, you may also contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.