Last updated November 2019
1. Purpose of this policy
Kruger ANZ Pty Ltd (ABN 91132340302) and its related entities (we, us, our) is committed to protecting your personal information in accordance with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act) as well as other applicable legislation, such as the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).
2. The types of personal information we collect
We collect personal information in order to provide you with our products or services. If you are one of our customers, this is usually collected through information provided by you on your client information form which you need to fill in to place an order with us.
‘personal information’ is information or an opinion about an individual which is reasonably capable of identifying that individual.
This information may include:
- your name, gender and contact information (including your email address, telephone and fax number, residential, business and postal addresses); and
- if you are a customer:
- information about your preference for products or services we offer
- your payment details for products
- information on the products we have provided to you; and
- other information you have provided to us, including our records of any communications or interactions we have with you.
We will only collect other personal information, including sensitive information, in accordance with the Privacy Act.
3. How we collect personal information
a) Collection of personal information from individuals
We may collect personal information directly from you when you:
- purchase a product or service from us online;
- participate in promotional activities;
- contact us directly via email, phone, or our website;
- contact our third-party suppliers via e-mail, phone or the internet; or
- register online account information.
b) Collection of personal information through websites and Apps
4. How personal information is used and disclosed
a) Main purposes
The main purposes for which we collect, hold, use and disclose personal information are to provide you with our products and services, and to support the operation of our business, which may include:
- processing transactions online and delivering products and services;
- to provide any associated loyalty program;
- promoting us and our products and services, including through direct marketing, events and competitions, public relations and social media;
- performing research and statistical analysis, including for customer satisfaction and product and service improvement purposes (this may include matching information we collect against other information held by third parties, noting we may use and disclose de-identified data for these purposes);
- helping us tailor existing or develop new products, services or offers, and to help us selectively target promotional offers and opportunities;
- developing or seeking to deliver new ranges of products;
- protecting the security of our staff, clients, suppliers and merchandise (including theft and fraud prevention); and
- answering queries, resolving complaints and responding to inquiries through social media.
We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or which are required or are authorised by law, and/or for which you have provided consent.
5. Direct marketing
By providing your address, email address and telephone numbers to us, you consent to us contacting you for the purposes set out in section 4. We may send this information in a variety of ways, including by mail, email, social media, SMS and telephone.
6. Email and mobile communication
If you provide us with an email address or phone number, you consent to electronic communication such as notices or reminders being sent to you via that address or number. You may prefer to provide us with your personal email address or phone number rather than, for example, an email address accessible by your work colleagues.
7. Opting out
Where it is lawful and practicable to do so, individuals may transact business with us without providing personal information or by providing information under a pseudonym.
You may also opt not to have us collect your personal information or, if you are a customer or user of the website, request that we de-identify any personal information we hold about you. This may prevent us from offering you some or all of our products and services.
To opt out, please contact us using the contact details in section 13. Also, if you believe that you have received information from us that you did not wish to receive or if you no longer wish to receive marketing calls, please contact us.
8. Who we may share your personal information with
We may share your personal information with third parties where appropriate for the purposes set out in section 4, including:
- financial institutions for payment processing;
- our contracted service providers or partners, including: overseas and local agents, delivery and shipping providers, information technology service providers, venues and event organisers, marketing and communications agencies, research and statistical analysis providers, call centres, hard copy and electronic mail houses, manufacturers and suppliers and external business advisers (such as recruitment advisors, auditors and lawyers); or
- regulatory, investigative or government bodies to comply with laws.
We may ask one of these third parties to contact you directly for a specific purpose, and provide us with information collected from you in the course of providing the relevant products or services. Those companies will be permitted to obtain only the personal information necessary to deliver their services. We take reasonable steps to ensure that these organisations are bound by privacy obligations to protect personal information otherwise we will seek your consent before sharing personal information with these parties.
9. Cross border disclosure
We may disclose personal information to overseas recipients, who are located in places such as Germany, Switzerland, Hong Kong, India, the Philippines and other countries or jurisdictions depending on the nature of the services those recipients provide to us (for example storing data via a cloud service, or where our customer relationship management system is hosted on servers located overseas, or where delivery address information for online orders is managed via a third party located overseas).
10. Data quality and security
We hold personal information in a number of ways, including in printed documents, electronic databases and email contact lists. Printed documents may be held at our head office, or archived in boxes and stored in secure offsite facilities. We take reasonable steps to:
- ensure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
- protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and
You can help us keep your information up to date by letting us know about changes to your details using the contact details in section 13.
We will take reasonable precautions to protect your personal information from unauthorised access or disclosure, or misuse or loss. The steps we take to secure personal information may include website protection measures and security restrictions on access to our computer systems. While we endeavour to protect the personal information of users of our website, we cannot guarantee the security of information you disclose online: you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us using the contact details set out in section 13. If you become aware of any security breach, please let us know as soon as possible.
11. Third party sites
12. Access and correction
Please contact our head office using the contact details in section 13 if you would like to access or correct the personal information that we hold about you. We may ask you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.
We will generally provide you with access to your personal information within 30 days of your request, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (e.g. by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may, however, charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading. If we correct personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, we will take reasonable steps to do so, unless this would be impracticable or unlawful.
13. Complaints or Questions
Mail: Privacy at Kruger ANZ Head Office, Ground Level, 620 High Street, Kew, Victoria 3101
Telephone: 1800 469 373
All complaints received will be dealt with fairly and in a timely manner considering all the circumstances of the complaint. In most cases, we expect that complaints will be investigated and a response provided within 30 days of receipt of the complaint. If the matter is more complex and our investigation may take longer, we will contact you and tell you when we expect to provide our response.
14. Changes to this Policy