You have no obligation to provide any personal information requested by us. However, if you choose not to, we may not be able to provide you with some of our services or products or access to some functionality of our Digital Platforms.
1. OUR PRIVACY COMMITMENT
We recognise the importance of, and are committed to, managing any personal information (including health information) that we collect in compliance with all applicable laws, including the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (set out in Schedule 1 of the Privacy Act).
2. HOW DO WE COLLECT PERSONAL INFORMATION?
Where possible, we will collect your personal information directly from you. This collection includes when:
- you communicate with us via email, LiveChat, telephone (including our Careline or Customer Service line), SMS or social media;
- you interact with us on our Digital Platforms, including when you register for an account on the Digital Platform, or send or post queries or comments;
- you place an order, or request certain products, samples or services from us;
- you fill in one of our forms, such as a customer registration form, credit or employment application;
- you participate in research activity, promotional activity, or competitions;
- you sign up for our marketing communications; or
- you otherwise correspond with us.
- The information collected by us may also include personal information:
- collected by us through tracking your use of the Digital Platforms, as further detailed at 7 below; and
- collected by us through other tracking technology, as set out at 8 below.
We may monitor and record phone calls for quality control, fraud prevention, or staff training purposes and other purposes related to the purpose for your call. We will let you know at the time of the call if a call is to be recorded.
You may provide information to be published or displayed (“posted”) on public areas of the Digital Platforms or transmitted to other users of the Digital Platforms or third parties (collectively “User Contributions”). If you use any discussion forum feature on the Digital Platforms, be aware that any personally identifiable information you submit there can be viewed and used by other Digital Platforms users. Your User Contributions are posted on and transmitted to others at your own risk. We cannot control the actions of those with whom you may choose to share your User Contributions.
In the event that we collect sensitive information as defined the Privacy Act (such as health information), we will only do so with your consent or in accordance with and as permitted under the Privacy Act. Generally, we will not collect sensitive information about an individual unless the individual consents to the collection of the information and the information is reasonably necessary for one or more of our functions or activities.
Children’s personal information
We have no intention of collecting any personal information directly from minors, although parents or guardians may voluntarily provide us with information relating to their children. A parent or guardian may contact us at any time if they have any questions or would like to make a request in relation to personal information we hold about their child.
3. WHAT PERSONAL INFORMATION DO WE COLLECT?
The personal information we collect varies depending upon the purpose of the collection and the product or service we are providing you. You should assume that when you provide us with information that we will retain it, unless we explicitly advise you otherwise. Generally, we collect the following types of personal information from you:
- contact information, such as name and surname, email address, address and phone numbers;
- demographic information, such as your date of birth and gender, or age/s and gender of your child/ children;
- pregnancy information, such as due date and date of conception;
- information to support the processing and delivery of product and/or service orders;
- access information, such as IP address;
- any other information you voluntarily provide to us (this may include health information);
- credit-related information (such as your credit history, trade references, credit reports, any credit rating or credit assessment derived from a credit report); and
- other records of your dealings with us.
Additionally, for certain purposes, such as where you apply for employment with us, we will collect additional personal information such as your employment history, educational history and employment references.
4. WHY DO WE COLLECT, HOLD, USE AND DISCLOSE YOUR PERSONAL INFORMATION?
We will collect your personal information, so we can provide you with the best advice and to provide you with a high quality of customer service. Your personal information may be used by us for any purpose which is stated to you at the time of collection, or that you otherwise authorise, and for the following purposes:
- to communicate with you and respond to information that you have requested or have registered for;
- to verify your identity when you communicate with us regarding your account or for use of our Digital Platforms, and to assist you if you forget your username or password for any of the services we provide to you via the Digital Platforms;
- to place and process your order, to process your payment, provide you with your order status, and deliver your products;
- to conduct address verification or credit checks for invoicing and billing purposes;
- to provide you with further information about us or other Digital platforms or goods or services offered by us or third parties which we consider may be of interest to you;
- to keep the Digital Platforms relevant and of interest to users;
- to customise the Digital Platforms to your preferences and to show you advertising and information that is most relevant to you and your interests based on the information you have provided to us or we have otherwise collected;
- to develop and improve our products, services, communication methods and the functionality of our Digital Platforms;
- to carry out marketing, promotional and publicity purposes including direct marketing, market research and surveys;
- to assist in providing better services to you by tailoring them to meet your needs;
- to deal with your enquiries and requests; and
- to assess and handle any complaints or for general customer care purposes.
Sales Promotions, Competitions, Surveys and registration to attend our events:
- we may collect personal information when you respond to one of our promotions, competitions or surveys or when you register to attend an event in order to inform you if you have won a prize, to place you on a guest-list to the event, and to help us better understand what products and services you would like to receive information about in the future. Entry to a promotion or competition is usually conditional on providing the requested information. If the information is not fully supplied the entry may be void.
Credit assessment. reporting and debt collection purposes:
- we may collect personal information about you and your credit arrangements in order to assess your credit application (including to decide whether or not to accept you as a personal guarantor of a business to which we may supply our products on credit). We may also use your personal information to collect payments and debts, including to exercise a guarantee if there has been a credit default. We may obtain and disclose your personal information to, and from, credit reporters and debt collection agencies in order to, obtain or assist with, their credit reporting and debt collection services and for our credit assessment and debt collection purposes. In applying for credit, you agree and authorise that we can do so.
Administration and legal purposes:
- we also collect personal information for internal record-keeping, accounting, IT and administration purposes and as required or authorised by law or a court / tribunal order, and to protect our legal rights.
If you provide information to us for a specific purpose, for example to apply for employment, we will use the information for that purpose.
Please note that only de-identified information/data (data where you cannot be personally identified) will be utilised for the purposes of market research, marketing planning, analysis, profiling and statistics.
5. WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?
- to our employees, related group companies, contractors or service providers that perform specific services or functions on our behalf, for the purposes of operating our Digital Platforms or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, credit reporting providers, data management platforms, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and archivists;
- to suppliers and other third parties with whom we have commercial relationships (including outsourced and cloud service providers), for business, marketing, maintenance, distribution of our products, and related purposes;
- to referees whose details are provided to us by job applicants;
- to professional advisors such as accountants, solicitors, insurers, lawyers, auditors, business advisors and consultants on a confidential basis;
- to any other third parties notified to you at or around the time we collect your personal information;
- to other third parties for the purposes you have consented to;
- to third parties where we believe it is necessary or appropriate to comply with any applicable law, regulation, government request or to facilitate court proceedings; or
As a company with international links, we may disclose your personal information outside Australia to Nutricia affiliated entities and overseas third-party service providers, including in New Zealand, Singapore, France, Ireland, United Kingdom and the Netherlands. We take reasonable steps to ensure that any organisations which we disclose your personal information to, whether local or overseas, are subject to appropriate contractual obligations to safeguard and protect your personal information and comply with all applicable privacy laws.
6. CUSTOMER MEMBERSHIP PROGRAMMES
Should you wish to participate in one of our customer membership programmes, we will collect (as part of the registration process) your name, surname, address, email, phone number and other information applicable to the type of membership (for example due date, date of birth of your child, or number of children in your family). This is used to present products and services that may suit your needs and interests. As a member, we may send you an email to inform you about news, activities and services. You will be asked whether or not you wish to opt into such communications.
Where this feature is available, members may amend, update, and adjust personal information by personally using their username and password anytime they wish. If you forget your login name and password, you may go to the main page or member registration page and click on “Forgotten Password.” The program will bring you to the “Forgotten Password” page. You will need to type in the email address or phone number used in registration, and the program will send your login name and password to your registered email address or phone number automatically.
7. AUTOMATIC DATA COLLECTION TECHNOLOGIES
- Digital Platform related traffic data, location data, logs and other communication data;
- data related to your use of the Digital Platforms. This includes the pages you visit, the resources and services that you access; the time you spend on each page, the date and time of your visit, referring pages (pages you came from or go to) and statistical and other aggregated data derived from your use of the Digital Platforms;
- information about your device, computer and network connection, including your IP address, operating system, hardware version and browser type; and
- if you allow our Digital Platforms to deliver content based on your location (for example by enabling this feature on your mobile device) we may collect location data (such as through GPS, Bluetooth, or WiFi signals) including for the automated delivery of relevant content and advertising to you.
8. OTHER TRACKING TECHNOLOGIES
We advertise in a number of ways, including online through managed social media presences, and on other unaffiliated sites and mobile applications. To understand how our advertising campaigns are performing, and better understand the visitors to our Digital Platforms, we may collect certain information via our Digital Platforms through our advertising service providers. We or our vendors use several common online tracking tools to collect information about our users, such as browser cookies, web beacons, and other similar technologies. The information we collect includes IP addresses, the number of page visits, pages viewed via our Digital Platforms, search engine referrals, browsing activities over time and across other websites following your visit to one of our Digital Platforms or applications, and responses to advertisements and promotions on the websites and applications where we advertise.
9. THIRD PARTIES, ADVERTISING AND THIRD-PARTY LINKS
We may allow third-party companies to collect information when you visit our Digital Platforms. This may include information that will not identify you personally (such as browsing behavior, browser type, time and date) and other information such as precise geographical location and user device identification. This information is collected to provide advertisements about goods and services likely to be of greater interest to you.
10. SOCIAL MEDIA AND APIs
Our Digital Platforms may include social media features such as the Facebook like button, Twitter and widgets, share button or interactive programs that run on our site. These features may collect your IP address, which pages you visit on our site, and how long for. If you’re a member of a social media site, the interfaces may allow the social media site to connect your visits to this site with other personal information. Social media features and widgets are either hosted by a third party or hosted directly on our Digital Platform. Your interactions with these features are governed by the privacy notice of the third party providing it and to the maximum extent permitted by law we accept no responsibility for the actions of those third parties.
We may provide an application programming interface (API) to enable third party applications to interface with our Digital Platforms. Some applications enable you to interact with us through the API in a way that requires you to log in. To do this, most of these applications will direct you through a process where you are able to let the application connect to your account.
If you allow an application to connect to your account on our Digital Platforms, including if you set up your account on our Digital Platform using an API with a third party social media platform, that application will be able to access information that you can see when you are logged in to our Digital Platforms. You should only allow applications you trust to access your account on our Digital Platforms.
If you set up your account on our Digital Platforms using an API with a third party social media platform, you also consent to us obtaining and using your information from such platform.
11. HOW IS YOUR PERSONAL INFORMATION HELD AND SECURED?
Any personal information that you provide to us will be collected and held by us electronically or in paper form. We understand that the security of your personal information is important. We will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. We maintain physical and electronic security over our paper and electronic data storage. We also maintain computer and network security. For example, we use firewalls (security measures for the Internet) and other systems such as user identifiers and passwords to control access to computer systems.
If the personal information we collect is no longer needed for any purposes and we are not required by law to retain it, we will take reasonable steps to either destroy it (in a manner that ensures its confidentiality) or permanently anonymise it.
12. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
Under the Privacy Act you have certain rights of access to and correction of personal information that we hold. It is important to us that the personal information we hold about you is accurate, up to date, complete, relevant and not misleading.
Please provide us with as much detail as you can about the particular information you wish to access or correct, in order to help us retrieve it. We may charge you an access fee to cover our reasonable costs of providing that information to you. We will inform you of any applicable fees before they are incurred.
In certain circumstances, we may refuse your request to access, or correct, your personal information. If that is the case, we will provide you with reasons for that decision unless it is unreasonable for us to do so. We take reasonable steps to make sure that the personal information we use is accurate, complete and up-to-date including updating personal information when we are advised by you that your personal information has changed. We will respond to all requests for access and/or correction within a reasonable time.
13. DIRECT MARKETING
By providing us with your electronic contact details (including mobile number and email address) you agree that we, and our related companies, may send you commercial electronic messages for any of the purposes set out in this Policy or otherwise disclosed to you. We will generally ask you to opt in to receiving commercial electronic messages from us.
We may use your personal information to send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth.
You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us using the ‘Contact Details’ set out here
or by using the opt-out facilities provided in the marketing communications, and we will then ensure that your name is removed from our mailing list.
We may also disclose your personal information to our related bodies corporate, our other business partners and our service providers to give you information and offers about products and services offered by us or these companies that may be of interest to you. Again, we will generally ask you to opt in to receiving any such commercial electronic messages.
By opting out of receiving marketing communications, you may still receive communications from us (such as invoices and notices) in relation to the products and services you have purchased from us. This form of communication is not regarded as “direct marketing” under the Privacy Act and the Australian Privacy Principles or a “commercial electronic message” under the Spam Act 2003 (Cth).
14. ANONYMITY AND USE OF A PSEUDONYM
You may request at any time that you remain anonymous, or choose a pseudonym, when dealing with us. To the extent that it is lawful and practicable for us to enable you to do so, we will grant such a request. However, where you choose to remain anonymous, or choose a pseudonym, we may not be able to provide you with some services or products.
Aside from the use of a pseudonym, all material that you post on our Digital Platforms or otherwise provide to us must be true and correct in all respects.
15. BUSINESS TRANSITIONS
16. HOW TO MAKE A COMPLAINT
If you wish to make a complaint about the way in which we handle your personal information, please contact our Privacy Officer using the ‘Contact Details’ set out below. We will acknowledge and investigate any complaint promptly and will respond to written complaints within a reasonable time from the date of receipt.
If you are dissatisfied with our response, you may refer the matter to the Office of the Australian Information Commissioner for guidance on alternative courses of action that may be available (see https://www.oaic.gov.au/).
17. CHANGES TO THIS POLICY
18. CONTACT DETAILS
The Privacy Officer,
Nutricia Australia Pty Limited,
Level 4 Building D, 12-24 Talavera Road, Macquarie Park, NSW 2113.
Alternatively, you can send an email to our Privacy Officer at firstname.lastname@example.org.