Effective date: 27th February 2022


RPG Ventures Pte Ltd (Co. Reg 201712179C) trading as Bottoms Lab and our related entities (“RPG”, “we”, “us” or “our”) respects your privacy and is committed to protecting your Personal Information. This policy together with our website terms of service and our Cookies Policy, will inform you as to how we collect and process your Personal Information through your use of and access to our websites (together the “Sites”). These Sites are aimed at Australian residents. These other documents are automatically incorporated into this Privacy Policy and form part of it. This Privacy Policy also explains the rights that you have to access your Personal Information that is held by us (see “Your Rights” below).

Personal Information means any information or an opinion about an individual from which that person can be identified. It does not include information where the identity of the individual has been removed or otherwise de-identified (“Personal Information”).


Any changes we may make to our Privacy Policy will be posted on our Sites or, where appropriate, we will communicate the changes to you by email or other means.

The version of this Privacy Policy is current as at the date set out above. All communications, transactions and dealings with us will be subject to the latest version of this Privacy Policy in force at the time.


Our Sites may include links to other websites, plug-ins and applications provided by others, including those acting on our behalf. Clicking on those links or enabling those connections may allow third parties to collect or share data about you, and have their own privacy policies. We do not control third party websites and are not responsible for their privacy policies or actions. When you leave our Sites, we encourage you to read the privacy policy and terms of use of every website you visit.


We may collect, use, store and process Personal Information about you, including:

  • identity information, including name, title, company name, job title, gender and date of birth;
  • contact information, including billing address, delivery address, email address, telephone number(s);
  • purchase and transaction information, including details about your orders, deliveries, exchanges, returns and payments to and from you and other details of products you have purchased from us, bank account and credit card details, vouchers and gift cards;
  • profile information, including your username and password, your interests, preferences and feedback;
  • customer account name and passwords;
  • photos or CCTV images (possibly including recordings on video and audio surveillance devices in our premises);
  • customer service information including any photos you send us, your products reviews, testimonials, options, customer service enquiries, comments and voice recordings of telephone conversations you have had with us;
  • social media names or other details or public information which you have shared via a public platform (such as Twitter feed or public Facebook page) where you have contacts us via the platform, tagged us or used our hashtags or otherwise taken part in our social media promotions;
  • details of your engagement with us such as entering into competitions;
  • demographic information from third parties and publicly available information which we may combine with information we hold about you;
  • technical and usage information, being details of your visits to our Sites, the individual web pages or products that you view, what websites or search terms referred you to the Sites, and information about how you interact with the Sites, including your IP address, times zone, traffic data, location data, website usage and other communication information. Please also refer to our Cookies Policy, for more information about how cookies collect data about you.


We use different methods to collect information from and about you including:

  • when you shop or complete a form you complete on any of our Sites or other third party online or in store stockists, or by corresponding with us of them by post, telephone, email or otherwise. This includes information you provide when you:
    • create an account on our Sites ;
    • participate in our customer activities and promotions;
    • subscribe to our newsletters or join our mailing list;
    • enter a competition, promotion or survey;
    • request marketing to be sent to you or respond to it;
    • give us feedback;
    • submit payments via our Sites
  • through persons who have referred you to us through a refer a friend campaign or promotion;
  • through your interactions and use of our Sites, such as your location data, website usage and other communication data using cookies, log files, web beacons, tags and pixels. For more information please see our Cookies Policy;
  • from third parties and publicly available sources.


We collect and use your Personal Information for any of the following purposes:
  • to register you as a new customer;
  • to process, manage, deliver and contact you about your orders, or otherwise fulfil our obligations arising from any contracts entered into between you and us;
  • to manage our relationship with you, including notifying you about changes to our terms of use, Cookies Policy or Privacy Policy;
  • to enable you to participate in competitions or promotions sponsored by us, or complete a survey, and to offer those to you;
  • to administer and protect our business and our Sites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
  • to conduct and analyse market research;
  • to use data analytics to improve our Sites, products/services, marketing, customer relationships and experiences;
  • to screen our orders for potential risk or fraud;
  • to monitor any user generated content submitted to us or posted to our Sites for compliance with our website terms of use;
  • to monitor delivery and viewing of our newsletters to facilitate the improvement and optimisation of the delivery of the newsletter to you;
  • to combine information from third parties including demographic information and information that’s publicly available to enhance and personalise your shopping experience with us;
  • to make suggestions and recommendations to you about goods, services and offers that may be of interest to you where you have opted in to receive such marketing information.


If you choose not to provide the Personal Information as requested, we may not be able to supply you with our products or services.


Unless we have another lawful means for processing your Personal Information, we will obtain your opt-in consent before we share your Personal Information with any company outside of RPG or its related group companies for promotional and marketing purposes.


The information we collect from you may be transferred to, and stored at or accessed from our locations in Singapore, Malaysia, the United States of America and China (service location).

We takes steps to have security measures, which aim to prevent your Personal Information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we endeavour to limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. We ask them to only process your Personal Information on our instructions and they are subject to a duty of confidentiality.


We may share your Personal Information with the persons set out below:

  • any member of the RPG Group, which means our investors, subsidiaries, our ultimate holding company and its subsidiaries;
  • professional advisers, including lawyers, bankers, auditors, audit assessors, credit assessors and insurers who provide consultancy, banking, legal, insurance or accounting services;
  • our third party service providers so that they can provide their services including website administration, payment processing, data hosting, data analysis, market research, marketing support, customer profiling, lead generation, customer service and other customer interaction;
  • third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Privacy Policy;
  • third parties, including authorities, where we are legally obliged to disclose your Personal Information to them.

Some of the information collected by, or disclosed to, our third party service providers who are acting on our behalf may be transferred to, and stored at, a location outside Australia including those listed in Section 9 above (9. Storage and security of your Personal Information and overseas transfers). In these cases, we impose obligations on those service providers to manage your personal data in a way that would comply with applicable privacy laws. By using our Sites, you agree to that transfer, storing or processing of your personal information outside of Australia or your home jurisdiction.


You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Sites may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

Some of our cookies are provided by third parties, such as Google Inc., and are subject to their privacy policies. For more information about their privacy policies, please visit their respective websites. The information these third parties collect may be transferred to, and stored at, a location outside Australia or your home jurisdiction. By accepting cookies, you agree to this transfer, storing or processing of your Personal Information.


We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.


As a Australian resident, you have the right:

  • to complain to the Office of the Australian Information Commissioner, who may be contacted on 1300 363 992 or online using the forms provided at https://www.oaic.gov.au/about-us/contact-us.
  • to access or correct your Personal Information that we hold about you;
  • to withdraw your consent to use or process your Personal Information for the purpose of direct marketing.

If you withdraw your consent, you should be aware that we may in some circumstances be required to continue to hold and process your Personal Information to fulfil our legal obligations.

If you wish to exercise any of the rights to access or correct your Personal Information or to withdraw your consent set out above, please contact us as set out below in section 14.

    13.1. No fee usually required

    You will not have to pay a fee to access your Personal Information (or to exercise any of your other rights) under applicable law. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

      13.2. What we may need from you

      We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to help speed up our response.

        13.3. Time limit to respond

        We will try to respond to all legitimate written requests by you regarding your Personal Information within 30 days after receiving them. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will let you know and keep you updated.

        14. CONTACT

        If you have any questions, concerns or complaints about how we handle Personal Information, or wish to exercise your rights as set out in this Privacy Policy or under applicable law, please contact us as follows: