1. When do we collect personal information?
We only collect personal information when it is reasonably necessary for our business activities.
The types of personal information we collect from you will depend on the circumstances in which the information is collected, and may include information such as:
- name and contact details (including your postal address, email address and phone numbers);
- demographic information (including your age, gender, State or Territory of residence, occupation and product preferences);
- information used to verify your identity (including your date of birth and driver’s licence number);
- records of questions that you ask us;
- answers you provide to questions we ask; and
- other information about your dealings with us.
- We do not generally require you to provide us with any sensitive information about yourself. In limited circumstances, we may require you to provide us with certain health information (for example, when you apply for a job with us or use our Consumer Information Service). See Part C of this Privacy Policy for further details.
If you do provide sensitive information to us for any reason (for example, if you provide us with information about your allergies, dietary requirements or other health related information), you consent to us collecting that information and to us using and disclosing that information for the reason that you provided it to us and as permitted by the Act.
You may notify us that you wish to deal with us by not identifying yourself or using a pseudonym. However, if we are not able to collect personal information about you we may not be able to provide you with the products, services, information or assistance you require.
2. How do we collect personal information?
We collect personal information in a number of ways.
We may collect your personal information directly from you, when you provide it to our staff or to our agents or contractors. For example, when you:
- provide information to our sales staff;
- request a brochure, join a mailing list or request information from us;
- enter a competition, respond to a survey or provide your details to us through one of our websites;
- apply for a job with us; or
- conduct business with us.
- We may also collect personal information about you from publicly available sources, from our related companies or from third parties (for example, from referees if you apply for a job with us).
3. Why do we collect personal information and how do we use it?
How we use your personal information will generally depend on why we collected it and the nature of your relationship with us.
We may use or disclose your personal information:
for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
for other purposes to which you have consented; and
as otherwise authorised or required by law.
Generally, we will only use and disclose the personal information that we collect about you so that we can do business together and for purposes connected with our business operations. These purposes may include:
- verifying your identity;
- contacting you (including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner);
- facilitating your entry and participation in competitions, promotions and trade incentive programs;
- assessing your suitability for employment or other relationships with us (including the provision of credit);
- improving our products or services;
- providing goods or services to you or receiving goods or services from you;
- addressing any issues or complaints that we or you have regarding our relationship; and
- developing and improving our business.
- We also sometimes use personal information for marketing purposes, as described in section 6 below.
4. Who else will have access to my personal information?
We may disclose and provide access to your personal information to third parties in connection with the purposes described in section 3 above and in Part B below.
This may include disclosing your personal information to the following types of third parties:
- any third parties to whom you have directed us to disclose your personal information (e.g. referees);
- our related companies;
- our contractors (such as mailing houses, prize providers, marketing agencies, insurance providers, website and data hosting providers and other IT suppliers) and others persons who provide services to us;
- companies who may use your personal information in order to tailor electronic advertising to you (e.g. on a webpage) in relation to our products and services;
- our accountants, insurers, lawyers, auditors and other professional advisers;
- owners of trade marks who grant us a licence to use those trade marks;
- in the event that we or our assets are or may be acquired by a third party, that third party and their advisors;
- in certain circumstances, third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
- otherwise as permitted or required by law.
- Where we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that such third parties protect your personal information in a manner consistent with this privacy policy.
5. Will my personal information leave Australia?
Some of the third parties to whom we disclose your personal information may be located outside of Australia.
For example, we may disclose your personal information to:
- our related companies overseas (including New Zealand);
- parties who license their trade marks to us, including Marlow Foods Limited in the United Kingdom; and
- overseas service providers that provide us with services including data storage, information and data aggregation and processing, remote access, back up and scanning, email filtering, and virus scanning.
- The countries in which these third parties are located will depend on the circumstances. However, in the course of our ordinary business operations some personal information that we hold is sent to facilities in Japan for processing and storage.
When we disclose your personal information to third party recipients located outside of Australia we will use reasonable commercial efforts to ensure that these third parties protect this personal information in a manner consistent with this Privacy Policy.
6. Do we use personal information for direct marketing?
We may use and disclose your personal information for the purpose of direct marketing where:
- you have consented to us doing so; or
- it is otherwise permitted by law.
- Direct marketing involves communicating directly with you for the purpose of promoting the sale of goods and services. Depending on the nature of our relationship with you, these may be our goods and services or the goods and services of carefully selected third parties (for example, if you are a subscriber to the Food 4 Thought mailing list, our Food 4 Thought partners). Direct marketing can be delivered by a range of methods including mail, telephone, email or SMS.
You can unsubscribe from receiving direct marketing materials from us at any time by contacting us (see Part C of this Privacy Policy).
7. Storage and security of your personal information
We may store personal information on computer databases and/or in hard copy, and we employ reasonable commercial physical and electronic security measures to protect any records that we hold which contain your personal information.
We may also engage third party service providers to assist in storing and processing certain types of personal information for us. Some of these service providers may be located overseas, or use facilities located overseas to provide us with services.
We will take reasonable steps to keep any personal information that we hold about you secure from misuse, interference and loss, and from unauthorised access, modification or disclosure as required by the Act.
However, except to the extent that liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to your personal information. Please notify us immediately if you become aware of any breach of security.
8. Is the personal information you have about me complete and accurate?
We take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. To ensure your personal information is accurate, please notify us of any errors or changes to your personal information using the contact details in Part C of this Privacy Policy and we will take appropriate steps to update or correct such information in our possession.