A. Clouet (Australia) Pty Limited (ABN 38 085 458 635) and its related bodies corporate trading under the Ayam™ and under other brands from time to time ("we", "us" or "our") recognizes the importance of your privacy and appreciate that your personal information is very important to you. Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable. We are committed to complying with our obligations under the Australian Privacy Principles ("Privacy Principles") set out in the Privacy Act 1988 (Cth).
- The kinds of personal information we collect and hold;
- How we collect and hold it;
- The purposes for which we collect, hold, use and disclose it;
- Your right to access and seek correction of it;
- How you may complain about privacy matters; and
- Our sharing of your personal information overseas.
We may collect personal information from you in a variety of ways, including without limitation, when you:
(a) register your details on our website;
(b) make an enquiry with us or communicate with us online;
(c) request information from us;
(d) submit comments to us;
(e) enter or participate in our trade promotions, competitions, testimonials, surveys and focus groups; or
(f) participate in our surveys, marketing, profiling, product development or research campaigns.
We mainly collect information about your contact details (such as your name, address, email, and phone and mobile numbers). However, there may be circumstances where we may require other personal information from you such as:
- Your hobbies and interests. If you provide us with that information, we may use that information to make offers or invite you to participate in events or trade promotions which we think could be of interest to you.
- Demographic information about your age, gender and occupation. That information may be used in an aggregate form to help improve our products and services, and to better promote and market our products and services.
- Whether you have taken up some of our offerings, promotions or loyalty programs;
- Whether you have a connection with others whose personal information we may collect or hold, for example family members;
- What, how and when you buy from us or have expressed an interest in buying from us; and
- Your stated or likely preferences, for example whether you may be interested in particular products or promotions.
We collect your personal information to ensure we deliver quality products and services to our customers and potential customers. To achieve this, we may use your personal information for a number of purposes including:
- to respond to your enquiries, questions and information requests, and investigate your complaints and enquiries;
- to provide you with access to certain areas or features of our website;
- to communicate with you about our or certain third parties' products, services, promotions and offers;
- to process certain sales orders;
- to provide you with necessary support or customer services;
- for product development, market research, and other marketing and promotional activities;
- to learn of your likely preferences so that we may promote goods and services to you in a way which may be of interest to you. This may include the products and services of our trusted partners who offer products and services that may be of interest to you;
- to carry out our legal compliance obligations, such as to conduct a product safety recall where necessary;
- in connection with legal proceedings or for exercising, defending or establishing our legal rights; and
- for any other purposes set out in any document, material or medium through which your information is collected.
We may use your personal information for the primary purpose for which it is collected. For example to respond to your enquiries about our products and services or to contact you if you are a winner of a trade promotion. We may also use your personal information (with the exception of sensitive information) for related secondary purposes that you would reasonably expect or that you consent to, such as sending you mail or emails with details of new products, services, special offers or promotions that may be of interest to you. You can contact us at any time if you do not wish to receive marketing communications from us.
We may anonymise and aggregate your personal information. We may do this for use and disclosure of the anonymous data to determine preferences and shopping patterns. We share this anonymised data with our trusted partners to assist them in marketing, and selling our products and services to you that are likely to be relevant to your interests and preferences.
We and our retailers may share personal information, so we may disclose your personal information to our retailers and vice versa. We may also disclose your personal information to our employees, officers, contractors, agents, related bodies corporate, product manufacturers, affiliated companies, and service providers who need to work closely with our database to complete their work for us (such as mailing houses for bulk mailing of letters, printing companies, merchandise deliverers, IT, and data storage and processing service providers, and customer service, data analysis and marketing service providers). We are likely to disclose your personal information to overseas recipients such as related bodies corporate and affiliated companies within the Denis Asia Pacific Group located in Singapore, and service providers outside of Australia (because services commonly involve diverse geographic locations which change from time to time for reasons which include data protection and processing efficiency it is not practical to notify you of which country your personal information may be located in). Although general privacy compliance procedures are implemented within the Denis Asia Pacific Group of companies. The overseas recipients may not be subject to the Privacy Principles in relation to your personal information. We will ask our service providers to keep your personal information confidential and not to use or disclose it for any purpose other than the purpose of performing their work for us. Your provision to us, our agents, retailers, or service providers of your personal information will constitute your consent for us to disclose this information to our employees, officers, contractors, agents, related bodies corporate and affiliated companies within the Denis Asia Pacific group of companies located in Singapore, and service providers located outside of Australia, We may also disclose your personal information where allowed or required by law. If we intend to use or disclose your personal information in a manner which is not compliant with this policy, we will seek your consent to do so.
4. Storage and Security and Data Breach
Security of your personal information is important to us and we will take all reasonable steps to protect your personal information from misuse, interference, loss, unauthorized access, modification or disclosure. Your personal information is stored within secured premises by the Denis Asia Pacific Group of companies and these secure premises may be outside of Australia. All reasonable safeguards are implemented to protect your personal information from misuse, interference, loss, unauthorized access, modification or disclosure.
If you transmit your personal information to us over the internet, we may use encryption technology to ensure your information is protected when being transmitted. However, we cannot guarantee the security of your personal information during internet transmissions, and you do so at your own risk. However, once we receive your personal information, we will take reasonable steps to protect your personal information.
We accept our obligation to keep personal information safe and is open and transparent in how data is handled. In the event that personal data systems are breached, data is misused or lost, then we will take all reasonable and practicable means to contact individuals whose personal information is involved. We will advise such individuals of the extent of the data breach (if known) and advise individuals of the most appropriate means of regaining control of their information, in an effort to limit the personal impact of the breach. If appropriate, we will also report any breach of data to the Office of the Australian Information Commissioner (OAIC).
5. Access and correction
You may seek access to your personal information which we hold about you and we will provide you with access in accordance with the Privacy Principles. We may require that you provide suitable identification for security purposes before allowing you to access your personal information. We may also charge an access fee to cover the reasonable cost of retrieving the information and supplying it to you. Access to your personal information may be refused in a number of circumstances, such as where access poses a health or safety risk, the information relates to anticipated legal proceedings or the request for access is frivolous or vexatious. If we deny or restrict your access, we will give you reasons why.
We rely on the personal information we hold in conducting our business. Therefore, it is very important that the personal information we hold about you is accurate, complete and up to date. If you become aware that any personal information we hold about you is incorrect, misleading, irrelevant, incomplete or not up to date, please contact us using our contact details below to seek access to, correct or update your personal information.
6. Third party websites
Our website may contain links to websites owned or operated by third parties, including websites owned or operated by our related bodies corporate or affiliated companies. In addition, other websites may also link to our website. We take no responsibility for the privacy practices, content or policies of third party websites, or any contractual or legal obligations of the operators of third party websites. These third party websites may contain their own privacy policies and their owners or operators are responsible for informing you about their security and privacy practices. We recommend that you thoroughly read the privacy policies of these third party websites.
8. Enquiries and Complaints
If you have any concerns or questions about the way your personal information is managed or used by us, or are concerned that a Privacy Principle or the privacy laws have been breached in relation to your personal information, please feel free to contact our Privacy Officer. We take our privacy obligations seriously. We will ensure that your complaint is registered with us, and may request that you provide the complaint to us in writing. The Privacy Officer will ensure that the complaint is referred to the right persons within the organisation to investigate and respond to the complaint. Any response or action will be notified to you as soon as practicable.
9. Additional Information
This is a policy. There may be additional privacy notices and terms relevant to you depending on the nature of your dealings with us and on our particular businesses. This policy does not apply to the personal information of our employees in their capacity as such. More information about privacy law and privacy principles is available from the Privacy Commissioner. The Privacy Commissioner may be contacted at www.oaic.gov.au (email- firstname.lastname@example.org) (Australia)
10. Contact details
Our contact details are set out below:
Attention: Privacy Officer
Address: 11 Melissa Place, Kings Park NSW 2148
Phone: (02) 8814 8086
Fax: (02) 9678 9508
Last Updated 19 December 2019