Privacy Policy

Privacy Policy

This Privacy Policy relates to San Remo Macaroni Company Pty Ltd ACN 000 228 713 and to its related entities that are deemed, for the purposes of the Privacy Act 1988 (Cth) (“Privacy Act”), to be APP entities (“we”). We are committed to protecting your privacy and complying with the Privacy Act by ensuring we act in accordance with the Australian Privacy Principles for the collection, holding, use and disclosure of personal information.  The Australian Privacy Principles are available at www.oaic.gov.au/individuals/privacy-fact-sheets/general/privacy-fact-sheet-17-australian-privacy-principles.

This Privacy Policy is current as at 1 January 2019. From time to time we may find it necessary to change this Privacy Policy to reflect changes in the law or our commercial activities. You can obtain the latest version of our Privacy Policy by contacting our Privacy Officer or visiting our website at www.sanremo.com.au/privacy-policy.

This Privacy Policy contains the following information:

• the kinds of personal information that we collect and hold;
• how we collect and hold personal information;
• the purposes for which we collect, hold, use and disclose personal information;
• how you can access your personal information that is held by us and seek the correction of such information;
• how you can complain about a breach of the Privacy Act, the Australian Privacy Principles, or a registered APP Code (if any) that binds us, and how we will deal with such a complaint; and
• whether we are likely to disclose personal information to overseas recipients.

This Privacy Policy applies to an individual, which has the meaning of a “natural person” only. Examples of personal information this Privacy Policy applies to include:

• full name;
• any alias or previous name;
• date of birth;
• sex;
• current / last known address and two previous addresses;
• phone number;
• e-mail address;
• credit card details;
• name of current and any last known employer;
• driver’s licence number (if applicable).

Collection and Use

You’re important to us, so we may collect personal information to assist us in responding to your queries, as part of the recruitment and selection process, to provide you with the products and services you require and in relation to competitions that we run from time to time. The information collected is only that which is reasonably necessary for us to provide you with our products and services or undertake our other functions or activities. If you do not wish to disclose your personal information to us, then we may not be able to respond satisfactorily to your query or request.

We collect information about your use of our website by recording your IP address, country, pages downloaded, date / time of visit and the type of browser used.  This information is stored in a secure location which cannot be accessed from our website. This information is analysed for statistics on the popularity of our website and no attempt is made to identify users except where required by law.

We may also collect your full name, employer’s name, phone number, address, e-mail address and other similar types of personal information if you send us an email or provide us with this information via online forms or submissions or place an order for our products. We will only hold, use and disclose this personal information in accordance with the Privacy Act and this Privacy Policy.

We try to ensure that any personal information that we hold is accurate, complete, up to date, relevant and not misleading. One way we do this is by collecting information about a person as much as possible from the person.

If we hold your personal information, we shall only use that information for the primary purpose for which it was collected or, if allowable, for the purpose of direct marketing, unless:

• you consent to the use or disclosure of that information;
• we within reasonable expectations use the information for a related secondary purpose;
• it is required to be disclosed by law;
• it is reasonably required by a law enforcement agency or body, including any court or tribunal; or
• another exception applies, such as a permitted general situation or permitted health situation as set out in the Privacy Act.

Should we use or disclose the information for a secondary purpose we will maintain a written note of its use or disclosure.

Direct Marketing

We may, within reasonable expectations or with your consent, also use your personal information so we can provide you with direct marketing information which may be of interest to you. We will not disclose that information to others unless you have consented, or we are required to disclose it by law. We will give you the opportunity not to receive this marketing information when we collect your details or on occasions when we send such material to you. We continue to be bound by the SPAM Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth) when we undertake direct marketing and we comply with the provisions of these Acts.

AdWords Remarketing

Our website may use the Google AdWords remarketing service to advertise on third party websites (including Google) to previous visitors to our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an enquiry. This could be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to our website. Of course, any data collected will be used in accordance with this Privacy Policy and Google’s Privacy Policy.

You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

Web Site Cookies

We may use remarketing and other audiences’ features to reach people who have previously visited our website. The purpose is to help match interests relevant to you. This means we or third parties may show ads across our site. It is possible to opt out of these advertising cookies. For more information visit http://optout.networkadvertising.org/#! or other relevant sites.

Anonymity and Pseudonymity

You may wish to deal with us anonymously or using a pseudonym (a false name that is not your actual name), for example, if you wish to make an enquiry about the availability or price of a particular product. In these circumstances we will respond to your query without seeking to collect personal information about you. However, in those circumstances where it is impracticable for us to deal with you if you do not identify yourself, then we are not obliged to give you the option of anonymity or of using a pseudonym. We will inform you if we believe that such a situation exists. If you choose not to provide us with personal information then we may not be able to provide you with the good or service that you seek.

Disclosure

We do not sell or disclose the personal information that we hold to any person outside our organisation for direct marketing by that other person. Personal information that we hold may be exchanged between different businesses within our group of companies. This disclosure is permitted by the Privacy Act. Personal information that we hold may be disclosed to agents or contractors who act on our behalf to collect debts or recover goods and to service contractors and companies that provide support to our customers. We may also disclose personal information to our solicitors and accountants. The identity of these people may change from time to time.

We are not likely to disclose your personal information to overseas recipients.

Any unsolicited personal information we receive, that could not have been collected if we had solicited it ourselves, will be destroyed unless, after notifying you, we are advised we may hold the information. If we determine that we could have collected the personal information if we had solicited it ourselves or you advise we may hold it, the personal information will then be stored and managed in compliance with the remainder of this Privacy Policy.

If the personal information is sensitive information we will only disclose it with your express consent.

Security

We shall take reasonable steps to protect personal or sensitive information we hold from misuse, interference, loss, unauthorised access, modification or disclosure.

Where personal or sensitive information is stored (either electronically or by other means), information will be identified as being “confidential” and access shall be restricted through either lockable storage or electronic password.

We have strict internal computer access policies and procedures that require staff to follow the Australia Privacy Principles, including specifically, security of personal information.

Where identifiers are used, they shall not use an individual’s tax file number or other number which has been assigned by a government agent or agency.

Destruction

Personal or sensitive information which is collected shall be destroyed or de-identified once it is no longer required by us for any allowable purpose, including information collected as part of the recruitment process.

Documents will be destroyed either through the use of a shredding device, or disposed of in a secured bin for collection by an approved document management organisation.

Electronic files containing personal or confidential information shall be erased. We have strict internal computer access policies and procedures that require staff to follow the Australia Privacy Principles, including specifically, when advised, the requirement to suitably and efficiently destroy personal information.

Access and Correction

We shall provide you with access to personal information we hold about you except to the extent that:

• providing access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;
• providing access would have an unreasonable impact on the privacy of other individuals;
• the request for access is frivolous or vexatious;
• providing access would be unlawful;
• providing access would reveal commercially sensitive information; or
• another exclusion as provided for or required by the Australian Privacy Principles applies.

Where we are not required to provide you with access to the information, we may if reasonable, consider the use of a mutually agreed intermediary to have access to the information; or provide you with a reason for the denial of access.

You may be charged a fee for accessing your personal information and will need to establish your identity and right to that information. Requests for access should be directed to our Privacy Officer.

We will correct your personal information if we are satisfied that it is incorrect and you request us to do so.  Requests for correction to your personal information should be directed to our Privacy Officer (details below).

Making a Complaint

If you wish to make a complaint because you believe that we have breached your privacy, the Privacy Act, the Australian Privacy Principles, or a registered APP Code that binds us, please contact our Privacy Officer (details below).

Our Privacy Officer will investigate the matter and attempt to resolve it in a timely way. Our Privacy Officer may need to discuss your complaint with our employees, agents, service providers or solicitors. We will inform you in writing about the outcome of the investigation.

The Privacy Act requires that you first make your complaint to us in writing and that we are then given a reasonable time to respond to you (usually 30 days). While we hope that we will be able to resolve any complaint without needing to involve third parties, if you are not satisfied with the response that you receive, you can then make a complaint to the Australian Information Commissioner, whose contact details are:

The Office of the Australian Information Commissioner

GPO Box 5218
Sydney NSW 2001
Phone: 1300 363 992
Email: enquiries@oaic.gov.au

Fax: (02) 9284 9666
Website: www.oaic.gov.au

If you wish to obtain more information about our Privacy Policy, or obtain a hard copy of this Privacy Policy (or a copy in any other format) then you may contact our Privacy Officer at:

The Privacy Officer
San Remo Macaroni Company Pty Ltd
4 Boden Court
Windsor Gardens SA 5087
Telephone: (08) 8334 8200
Fax: (08) 8344 8231
Email: privacy.officer@sanremo.com.au