EASTERLY PRIVACY POLICY

Last Updated and Effective: July 2025

1. Collecting Your Personal Data

Beyonda Pty Ltd. d/b/a/ Easterly ("us," "we," or "our") offers and maintains the website(s) located at , including all subdomains and subparts, as well as our social media accounts on Facebook, Instagram, and other platforms (collectively, the “Site”).  When you visit the Site, you may choose to provide us with personal data that identifies you as a specific individual (“Personal Data”).  This Privacy Policy explains how we process and use your Personal Data, and it applies regardless of how you access the Site.  Please take time to read this Privacy Policy carefully.  Please also review our Terms of Use. We will notify you of any additional processing of your Personal Data that is not mentioned in this document.

BY ACCESSING OR USING THIS SITE OR BY CHECKING THE BOX PROMPT BEFORE SUBMITTING PERSONAL DATA TO US, YOU EXPRESSLY CONSENT TO THE COLLECTION, USE, DISCLOSURE, RETENTION, AND DESTRUCTION OF YOUR PERSONAL DATA SUBMITTED TO US IN ACCORDANCE WITH THIS PRIVACY POLICY.

If you have any questions about this policy or would like to withdraw your consent to the processing of your Personal Data, you can email us hello@easterly.co

2. Personal Data We Collect 

When you visit the Site, we collect the following Personal Data:

Provided directly by you

·         Identifiers, including name, alias, or other similar identifiers

·         Contact information, including home address, email address, telephone number, and other contact details

·         Birthday and/or age

·         Content of your interactions with or messages to us, including applications, emails, texts, chats, and communication through social platforms or other feedback

 

Collected automatically with your use of the Site (“Log Data”) or provided by third parties or public sources, such as social media profile information

 

·         Device identifiers and information about or generated by your device, such as IP address, log files, log-information, browser type and browser version

·         Statistics on your activities on the Site (such as the date and time of visits, the pages viewed, time spent at the Site)

·         Information about how you came to the Site

·         Data collected through cookies or other similar technologies discussed in more detail below.

·         Internet or other electronic network activity information and behavioral information, such as your browsing history, search history, and interaction with advertisements

 

 

3. How We Use Your Personal Data

We use your Personal Data for various purposes, depending on our relationship with you

Customer Service

If you are a customer, we use your Personal Data for the purposes for which you provided it, including to:

·         Fulfill your product or service needs;

·         Register your online account;

·         Maintain our own accounts for billing and delivery; 

·         Advise you about products, services, offers, or events that may be of interest to you; and

·         Provide customer service to you. 

 

Internal Business Activities

 

We may also use your Personal Data or Log Data to administer our internal business activities, including to:

·         Design and arrange the Site content and functionality in the most user-friendly manner;

·         Better understand customer trends and requirements and visitors to the Site;

·         Create non-personally identifiable data to be used for marketing;

·         Detect unauthorized activity on the Site;

·         Manage your account;

·         Track, monitor, and comply with legal obligations regarding the safety of our products or services; and

·         Provide a service that is reliable, responsive, and efficient.

 

Analytics

In addition, we may use third-party services and advertising networks, such as Google Display Network or Google Analytics, that collect, monitor, and analyze Log Data to deliver online behavioral advertising that serves ads to you on our behalf on other sites throughout the Internet. 

 

 

4.                  How We Disclose Your Personal Data

 

There are certain circumstances in which we may disclose, transfer, or share your Personal Data with certain third parties after obtaining your consent.  We may also use anonymized versions of your Personal Data for any purpose. By checking the box prompt before submitting your Personal Data to us, you expressly consent to our sharing your Personal Data, as set forth below.

For purposes consistent with this Privacy Policy, we may disclose your Personal Data with: 

Easterly affiliated entities

 

·         our parent companies, subsidiaries, and/or affiliates

Third-parties we engage to perform business-related functions for Easterly or provide services to customers, such as

·         third parties who provide services to our customers or with whom we partner to do business;

·         third parties who assist with our marketing, including chatbot applications, marketing agencies, and analytics companies, such as Google Analytics, that collect, monitor, and analyze Log Data;

·         third party providers of database, software, email, security, backup and disaster recovery services;

·         payment processors;

·         our insurance carriers;

·         professional service providers, such as consultants, attorneys, and accountants;

Third parties to whom we disclose your Personal Data maintain and use it according to their own privacy policies.

 

Social media platforms

·         including Facebook, Instagram, YouTube, Google, Pinterest, TikTok, and X, and application developers who specialize in social commerce

·         so you can connect to us, share your interests, express opinions about products and services, purchase our products, and generate interest in our products and services among members of your social networks

If you use third party social media features available on our Site, we or the third party may collect or share your data, including your Personal Data.  If you do not want us to be able to access information about you, including Personal Data, from Third Party Sites, you must limit data collection and disclosure in the privacy settings on the Third Party Sites.  We reserve the right to remove the Personal Data or other data of any person for any reason we, in our sole discretion, deem appropriate.

 

Successors who acquire your Personal Data

 

·         if we sell, merge, reorganize, dissolve, or similarly change our ownership or corporate structure

Government or third party lawyers

if required to do so by law or in our good faith belief that such action is necessary to:

·         comply with a legal obligation;

·         protect or defend our rights, interests, or property, or that of third parties;

·         prevent or investigate possible wrongdoing in connection with the Site;

·         act in urgent circumstances to protect the personal safety of users of the Site or the public; or

·         protect against legal liability.

 

 

5.                  Your Rights About The Processing Of Your Personal Data

You have the right to consent or withdraw your consent to the collection, use, or disclosure of your Personal Data at any time, subject to exceptions defined by law.  If you change your privacy preferences in the future, that will not limit the lawfulness of any processing performed based on your prior consent.  To withdraw consent, please email us at hello@easterly.co and specify what you would like us to do.   

To stop email communications from us, you can also follow the unsubscribe instructions set forth at the bottom of our promotional e-mail messages. You may also access and correct some of your Personal Data by logging into your online account, if you have one.  If you choose to limit our use of your Personal Data, you may not have access to certain functionality of the Site, such as promotions, product information, or opportunities. 

 

6.                  How We Secure Your Personal Data

 

We use reasonable measures to secure your Personal Data. However, no network, server, database, Internet or e-mail transmission is ever fully secure or error free. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Site. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site. Therefore, you should take special care in deciding what Personal Data you send to us electronically.  For more information on the security of your Personal Data, please email us at hello@easterly.co.

 

7.                  How Long We Keep Your Personal Data

 

Except as otherwise permitted or required by law, we will only retain your Personal Data as long as necessary to carry out the purpose for which we collected it, including maintenance of your account, or to satisfy any accounting or legal requirements.

 

We may anonymize your Personal Data so that it can no longer be associated with you for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

 

You may close your account, unsubscribe to emails, and otherwise limit our use of your Personal Data by contacting us at hello@easterly.co.  However, we may retain your Personal Data for an additional period as is permitted or required under applicable laws. Even if we delete your Personal Data, it may persist on backup or archival media for an additional period of time.

 

8.                  How We Use Cookies

We use cookies on our Site. If you do not want cookies to be placed on your device, you can manage your cookie preferences in our cookie banner.

(a)  What Are Cookies?

A cookie is a piece of information that is placed on your web browser or device when you access or use the Site.  Cookies store text and can later be read back by the Site or third parties. Cookies can remember the information you access on one webpage to simplify your subsequent interactions with the Site or to use the information to streamline your transactions on related webpages.

(b)  Why We Use Cookies

We use cookies to recognize your browser and you as a unique visitor to the Site through an anonymous unique identifier.  We use cookies to:

·         recognize when you are logged in to your account on the Site;

·         monitor and analyze how you use the Site or interact with us;

·         remember your preferences to make your online experience easier and more personalized;

·         route Site traffic to effectively distribute the Site workload across servers;

·         use analytics, such as Google Analytics, to help understand how visitors come to and use the Site, including through combination with third-party cookies of our service providers;

·         provide information to us about which advertisements you see and click or to show you ads on or off the Site; and

·         test new features.

·         support affiliate marketing programs by tracking referral activity, including recognizing when a user visits our Site via a partner's link and attributing sales to that partner. Affiliate tracking cookies may remain active for up to 30 days. 

(c)   How You Can Manage Cookies

You can opt out of and manage the use of cookies in a number of ways, either through our cookie banner, your browser or via the third party placing the cookie. The following pages provide browser specific information:

·         Google Chrome

·         Internet Explorer

·         Safari

·         Mozilla Firefox

Many of the third party technologies that enable targeted banner advertising also allow you to opt out. Such third party service providers include Adroll, Rubicon, Google, Media Math, Perfect Audience, Quantcast, Retargeter, and Yahoo! among others.  You can control your preferences directly with each such third party service provider.

To see how to opt-out of Google Analytics Advertising Features, visit Google Ads Settings, Ad Settings for mobile apps, or any other available means (for example, the NAI's consumer opt-out listed below). Google also provides a Google Analytics opt-out plug-in for the web. 

You can find more information on how Google Analytics works in this Google guide and on Facebook App Events here.

You can learn more about cookies at the following third-party websites:

·         All About Cookies: http://www.allaboutcookies.org/; and

·         Network Advertising Initiative: http://www.networkadvertising.org/.

Note that if you disable, delete, or refuse to accept cookies, you may not be able to use some features of the Site and/or some of our pages might not display properly.

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not currently respond to DNT signals. Therefore, please be advised that third party web analytics companies may collect information about your online activities over time and across our website and other online properties.

9.                  What Data Is Not Covered By The Privacy Policy?

 

The limitations in and requirements of this Privacy Policy do not apply to:

 

·         Third Party Sites:  Any data you disclosed on websites not operated or controlled by us (“Third Party Sites”), even though we may provide links to them on the Site or in our emails. We are not responsible for the policies and practices employed by, or the content of, Third Party Sites. We suggest contacting those sites directly for information about their privacy policies and practices. 

 

·         Non-Personally Identifiable Data: Any non-personally identifiable data we collect, including, without limitation, Log Data, domain names of your Internet Service Provider, your approximate geographic location, a record of your usage of the Site, the time of your usage, and aggregated personally identifiable information, but only to the extent the foregoing cannot be used to specifically identify you.

 

·         Publicly Available Data: Any information that is lawfully made available to the general public by you, from widely distributed media, or by a person to whom you disclosed the information without restricting it to a specific audience, including information you make disclose on social media.

 

10.                  We Do Not Collect The Personal Data of Children

 

We do not intentionally or knowingly collect any Personal Data from children under the age of eighteen (18), nor do we target our emails to them.  Children under the age of eighteen (18) should not submit any Personal Data through the Site.  We encourage parents and legal guardians to monitor their children's use of the Internet and instruct them to never provide Personal Data through the Site.  If you believe a child under the age of eighteen (18) may have provided Personal Data to us through the Site, please contact us at hello@easterly.co, and we will use reasonable efforts to delete it from the Site and our files.

 

11.                  International Privacy Laws

 

If you are visiting the Site from the United States, please be aware that you are sending information (including Personal Data) to Australia where our servers are located. That information may then be transferred back to the United States or out of the United States depending on the type of information and how it is stored by us. We will hold and process your Personal Data in accordance with privacy laws in the United States and this Privacy Policy. Please note that privacy laws in the United States may not be the same as, and in some cases may be less protective than, the privacy laws in Australia, and while in the United States, Personal Data may be subject to lawful access requests by government agencies. 

 

12.                  Changes To This Privacy Policy

 

We may occasionally make changes to this Privacy Policy.  If we wish to use your Personal Data for a new purpose not covered by this Privacy Policy, we will provide you with a new Privacy Policy and notice explaining this new use prior to commencing the processing of your Personal Data pursuant to the new Privacy Policy and setting out the relevant purposes and processing conditions. If we change this Privacy Policy, your checking the box prompt before submitting Personal Data to us, or continued use of the Site after receiving the notice outlined above, will signify your consent to such changes.

 

13.                  How You Can Resolve A Privacy Dispute With Us

If you have a complaint about this Privacy Policy or our privacy practices, we will work with you in an attempt to resolve your complaint.  Please contact us at hello@easterly.co.  Please also refer to the arbitration procedures described in the Dispute Resolution section of the Site’s Terms of Use.  BY SUBMITTING YOUR PERSONAL DATA TO US, WE EACH AGREE TO SETTLE DISPUTES ONLY BY NON-CLASS, INDIVIDUAL ARBITRATION, INSTEAD OF SUING IN COURT (EXCEPT CERTAIN SMALL CLAIMS).  THE RULES IN ARBITRATION ARE DIFFERENT.  THERE IS NO JUDGE OR JURY, BUT AN ARBITRATOR CAN AWARD THE SAME DAMAGES AND RELIEF, AND MUST HONOR THE SAME LIMITATIONS STATED IN THE AGREEMENT, AS A COURT WOULD. 

To initiate an arbitration proceeding, you must send us a notice of your complaint that includes a written statement of your name, address, and contact information, the facts giving rise to your complaint, and the relief you are requesting (the “Dispute Notice”).  The Dispute Notice must be addressed to:  Beyonda Pty Ltd. d/b/a/ Easterly Co, and sent to us at hello@easterly.co.  If we do not reach an agreement to resolve your privacy complaint within sixty (60) days after we receive your Dispute Notice, you may commence an arbitration proceeding under the Dispute Resolution section of the Site’s Terms of Use. Contact Us

 

If you have any questions about this Privacy Policy, our practices, or your dealings with us, or to exercise any and all of your rights, please contact us at hello@easterly.co.