In this policy “we”, “us’ and “our” means Respring Pty Limited, its subsidiaries and affiliated companies. Please read this policy carefully as it describes the way in which we collect and handle your personal information. We may update or revise this policy from time to time. If we elect to update or revise this policy, we will post the date on which that revision takes effect at the end of this policy. Please be aware that you have no obligation to provide any personal information requested by us. However, if you choose to withhold your personal information, we may not be able to provide you with the services or products that depend on the collection and use of that information.
1. Our privacy commitment
We recognise the importance of, and are committed to, managing any personal information that we collect in compliance with the Privacy Act 1988 (Cth), which includes the Australian Privacy Principles, and other Australian privacy laws (together, “Privacy Laws”).
Where possible, we collect your personal information directly from you. This collection includes through your
- entry into promotions or competitions;
- answers to surveys;
- signing up to newsletters and other notifications from our brands;
- registration to attend events;
- provision of express permission when accessing applications sitting on Farmbuy.com brand social media accounts;
- application for an internship or employment with us;
- communications with us such as telephone calls and emails regarding services and products;
- registration for our loyalty clubs; and
- download and use of our mobile applications (“apps”).
In some circumstances, however, we may also collect your personal information from third parties or public agencies where it is unreasonable or impracticable for us to collect the personal information directly from you. Where we collect personal information from third parties, we will ensure that the collection is conducted in a fair and lawful manner and the information is reasonably necessary for our functions or activities.
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. Generally, we collect the following types of personal information:
- name and address;
- telephone/e-mail contact details; and
- bank account/credit card numbers and associated details as reasonably required in relation to processing payments at your request.
However, 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. We generally do not collect sensitive information that is associated with an identifiable individual.
If you provide us with sensitive information on an unsolicited basis, we assess whether such information is reasonably necessary for one or more of our functions or activities. The unsolicited sensitive information you disclose to us may be used and disclosed for the purpose for which you provided such information or, where you would reasonably expect us to, we may use the information for a directly related secondary purpose. We may also disclose or use the information for other purposes with your consent or if required to by law.
4. Why do we collect and use your personal information?
We will collect your personal information if it is reasonably necessary for the performance of our business activities and functions, which includes providing a range of products and services to you, some of which are listed below.
4.1 Sales Promotions, Competitions, Surveys and registration to attend our events We 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.
4.2 Our mobile apps We, or a service provider, may collect information through our apps to assist us in understanding how you use our apps, how the apps are performing across different handsets and to assist us in the selection of advertisements for groups of individuals.
4.3 Registration for our loyalty clubs We collect personal information when you sign up to join one of our loyalty clubs. By providing this personal information we are able to keep you updated on special offers and events that you may be interested in and to reward your commitment to the brands.
4.4 Employment or internship We collect personal information from applicants who are seeking employment or an internship with us as part of the recruitment process. In circumstances where you do not provide the mandatory personal information, we will be unable to consider you for a position with us.
5. Who do we disclose your personal information to?
We provide your personal information to third parties in order to carry out our business activities and functions. This may include:
- organisations who are sponsoring or otherwise involved with or participating in a promotion, offer, competition or survey;
- other companies or individuals we engage to perform functions on our behalf, processing credit card information, mailing information or prizes, data analysis, telemarketing, research and advertising; and
- with your specific and prior consent, to other companies or individuals for the purposes you have consented to.
We ensure that any organisation which we disclose your personal information to is subject to appropriate contractual obligations to safeguard and protect your personal information and comply with all Privacy Laws.
In certain circumstances, we may disclose your personal information where required or authorised to do so by law, including in emergency situations and to assist law enforcement agencies. We will always ensure that those to whom we disclose your personal information have the legal right to receive it.
6. How is your personal information secured?
We understand that the security of your personal information is important. As such, we take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. We store information with trusted third party storage providers. We undertake regular training of our staff to ensure that they are aware of our privacy commitments and our obligations in the collection, use and disclosure of personal information.
7. Access to and correction of personal information
In certain circumstances where you have a sign in to your customer details and/or you can access your own personal information via your membership you will be required to follow prompts to access, correct or update your personal information. If this option is available to you directly, we will clearly mark it for ease of access.
You can access or correct your personal information by contacting us using the ‘Contact Details’ set out. 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 costs of providing that information to you. We will inform you of 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 collect is accurate, complete and up-to-date including updating personal information when we are advised by you that your personal information has changed.
If you wish to delete the personal information we hold about you, please let us know by contacting us using the ‘Contact Details’ set out below and we will take reasonable steps to delete the information, unless we are required to retain it for legal reasons.
We, and our service providers, use the information collected from cookies for a number of reasons:
- for statistical purposes in order to track how many users we have and how often they visit our website or apps;
- to provide you with a more personalised, convenient and interactive experience on our websites or apps;
- to track who has viewed an advertisement or clicked-through an advertisement; and
- to provide you with a more targeted advertising experience both on and off our websites or apps, allowing us to impose restrictions where appropriate and monitor how effective an advertising campaign has been.
We engage various analytic programs, including Google Analytics to analyse the performance of our websites and apps and to provide us with reports that contain aggregated, de-identified benchmark information that assists us to understand when, and how many times, you have used our websites or apps. The anonymous information assists us in the selection of advertisements for groups of individuals.
We may also use Google Analytics features (including Google Remarketing, Google Display Network Impressions Reporting, the Double Click Campaign Manager and Google Analytics Demographics and Interest Reporting) on our websites and apps. Google Analytics uses both first party and third party cookies to record standard internet traffic information such as when, and how many times, you have visited our websites or apps. We, and some third parties (including Google), also use the information to optimise advertising selection for groups of individuals based on demographic information. The cookies allow us and other third parties (including Google) to evaluate your interactions with advertising services on our websites and apps and serve targeted advertising on those websites and apps and across the Internet. We have enabled Google Analytics for Display Advertising, which allows Google and other third parties to advertise to you on our websites and apps and across the Internet.
9. Third party websites
10. 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.
11. How to make a complaint
If you wish to make a complaint about the way in which we handle your personal information, please contact us using the contact details set out below. We undertake to 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 Australian Information (Privacy) Commissioner (see www.oaic.gov.au).
12. Contact Details