Privacy Policy | The Source FAQ's

Version date: 12 March 2014

Introduction

This Privacy Policy explains how Simplot Australia Pty Ltd manages your personal information. It includes details of how we collect, store, use and disclose your personal information.

We are committed to protecting your privacy and are bound by the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (the Act).

In this Privacy Policy, "personal information" has the meaning set out in the Act. Essentially, your personal information is any information or opinion about you, or from which you are reasonably identifiable.

We will only collect, store, use or disclose your personal information in accordance with the Act and this Privacy Policy.

We may amend this Privacy Policy at any time and for any reason. The latest version will be available on our website at www.simplot.com.au. You should check this Privacy Policy regularly for changes.

How to use this Privacy Policy

See Part A for general information about our information handling practices.

See Part B for more specific information for:

users of our websites;
users of our Consumer Information Service;
people who have entered our promotions or trade incentives;
people who have subscribed to the Food 4 Thought mailing list;
people who have registered as members of the Quorn Club; and
people who have applied for a job with us.

See Part C for information about accessing or correcting your personal information, or lodging a complaint about our handling of your personal information.

Part A General Information

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.

Part B Specific Information

1 Information for our website users

Our websites and social media pages (and other materials we provide to you) may contain links to third party websites. The operators of those websites may have privacy policies and practices which differ from our own. We are not responsible for the content of any external website or the privacy practices of any third party.

Some information that you post to parts of our website or to our social media pages may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.

Some of our websites and services use cookies and other similar technologies to passively collect certain types of usage information such as your IP address, details of your computer system, browser details, geolocation information, pages visited (and for how long), and website functionality accessed. Unless you have consented, we do not combine this usage information with your personal information (which means that we cannot identify you from the usage information that we collect).

We may use this passively collected usage information for a variety of purposes, including customising and improving our websites and services. Certain aspects of our websites and services require this information to function and may not be available if this information is not collected.

2 Information for users of our Consumer Information Service

When you use our Consumer Information Service we may ask for you to provide certain personal information in order for us to respond to your query. For example, we may request your phone number so that we can contact you once we have an answer to your query. Some queries may require us to disclose your personal information to third parties, for example food safety testing labs.

If your query requires us to collect health information or other sensitive information about you, we will only do so if we have your consent and if the sensitive information is reasonably necessary for us to deal with your query. We will only use and disclose this information with your consent, or for other purposes if we are authorised or required to do so by law.

We will handle any health information that we collect about you in accordance with applicable laws.

3 Information for competition, promotion and trade incentive entrants

When you enter a competition, promotion or trade incentive conducted by us, we will use the personal information you provide to us for the purpose of administering the competition, promotion or trade incentive.

We may also store the information that you provide to us for the competition, promotion or trade incentive on our customer information database for use for promotional, marketing and product development purposes in relation to any of our products or services.

4 Information for subscribers to the Food 4 Thought mailing list

The Food 4 Thought program, magazine and mailing list is operated by us, together a number of other businesses. More information about the other businesses that are involved in the Food 4 Thought program can be found on the Food 4 Thought website at www.f4t.com.au.

If you consented to receiving marketing materials when you subscribed to the Food 4 Thought mailing list, we may send you marketing materials (including electronic messages) about our products and services and those of the third party businesses that are involved in the Food 4 Thought program.

We may share personal information that we have collected about you through your membership of the Food 4 Thought program with the third party businesses that are involved in the Food 4 Thought program for direct marketing purposes. The information that we share with those third party businesses may include your name, contact details and product preferences.

You can unsubscribe from receiving these marketing materials and/or the Food 4 Thought mailing list by contacting us using the contact details in Part C of this Privacy Policy.

5 Information for members of the Quorn Club

Marlow Foods Limited is a company incorporated in the United Kingdom. We market and distribute products bearing the Quorn brand in Australia and New Zealand under licence from Marlow Foods Limited.

If you have registered as a member of the Quorn Club (through the www.quorn.com.au website or otherwise), we may share personal information that we have collected about you through your membership of the Quorn Club with Marlow Foods Limited for the purpose of direct marketing and product concept research. The information that we share with Marlow Foods Limited may include your name, contact details and product preferences.

6 Information for job applicants

If you apply for a job with us, we will use the information provided by you to assess your application.

We also may provide assistance to our related companies in relation to their recruitment activities, including:

Top Cut Foods Pty Ltd; and
Simplot New Zealand Limited (which is located in New Zealand).

If you submit an application for a position with one of these companies, we will share information about you (including your application and the supporting documents) with the relevant company for the purpose of assessing your suitability for that position.

As part of the application process, you may be required to undergo certain assessments such as background checks, psychometric screening, aptitude testing, medical testing and human resources management activities. These activities would likely involve the collection of health information and possibly other sensitive information. This information may be used in the assessment of your suitability for the role you have applied for.

We may engage third party service providers to assist us with assessing your application. Those service providers may collect personal information about you on our behalf and we may share personal information about you with these service providers for this purpose.

You may refuse to provide this information to us or our service providers. However, if you refuse to provide any of the information requested by us, or do not consent to the disclosure of the results of your additional assessments, we may be unable to consider your application.

Part C Contacting Us

You can contact us if:

you want to access or correct any personal information that we hold about you;
you want to unsubscribe from our mailing lists; or
you think that we have breached the Australian Privacy Principles and want to make a complaint.

We can be contacted about privacy issues by email sent to privacyofficer@simplot.com.au. Alternatively, you can write to us at Simplot Australia Privacy Officer, Locked Bag 3005, Braeside, Victoria 3005.

When contacting us, please provide as much detail as possible in relation to your query, issue or complaint.

Please note that:

Your complaints are taken seriously and will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner and in accordance with the Act. We request that you cooperate with us during this process and provide us with relevant information we may require. If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner.
If you require access to the personal information that we hold about you, we may charge a fee for providing access to this information and we may refuse access where the Act allows us to do so.