AS AT OCTOBER 2016
Spiral Foods Pty Ltd (ACN 006 292 780) (”Spiral Foods”) is committed to protecting and respecting your privacy, and takes its obligations under the Privacy Act 1988 (Cth) seriously. As a result, Spiral Foods has implemented practices, procedures and systems to comply with its legal obligations and, in particular, to:
- maintain the confidentiality and security of personal information it collects and holds; and
- manage its systems, practices and procedures in an open and transparent way.
By “personal information”, we mean information or an opinion about an identified individual, or about an individual who is reasonably identifiable from the information. Those individuals include customers, potential customers, agents, suppliers, distributors, contractors and other business associates.
What personal information does Spiral Foods collect and hold?
The kinds of personal information we may collect and hold are:
- contact details (including email addresses);
- dates of birth;
- details of your visits to our sites (including traffic and location information, which pages you visit, weblogs and other communication information);
- details of transactions you carry out through our site; and details concerning your orders; and
- financial information (including credit card information).
Also, when you visit our site, we may collect information about your computer, including (where available) your IP address, operating system and browser type.
We do not keep files containing all of the above information on all people who contact us, or with whom we deal. In many cases, we may have only one or two pieces of data relating to any particular person.
Why does Spiral Foods collect and hold personal information?
We collect and hold personal information for a variety of purposes – and different kinds of personal information are used for different purposes.
In each case, however, the personal information we collect and hold is reasonably necessary for our functions and activities, including so we can provide you with services you would expect from us. These purposes are:
- to provide you with products or services, news or information, that you request from us or which we believe may interest you;
- for purposes necessary or incidental to providing you with goods and services that you have ordered or requested from us (including through our sites);
- to personalise and customise your experience when using our sites (including so that our sites are presented in the most effective manner for you and for your computer);
- to communicate with you (including by email, mail or telephone, and including in relation to changes to our products and services);
- to manage and enhance our products and services;
- to conduct competitions and promotions (both on our own behalf and in conjunction with Spiral Foods’ affiliates and selected third parties);
- for system administration and for network analysis and security (by ourselves and our IT contractors);
- to report aggregate information to our affiliates and advertisers;
- to allow you to participate in interactive features of our sites that may be available;
- to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and
- as required or permitted by any law (including privacy legislation).
From time to time, when collecting information from you, we may also ask you to “opt-in” to consent to us using or disclosing your personal information other than in accordance with this policy or any applicable law. As part of our commitment to protecting your privacy, however, you will also be given the opportunity to “opt out” from receiving communications from us or from third parties that send communications to you in accordance with this policy or in accordance with any additional consent you give, and we will comply with your decision. (You will be able to “opt out”, for example, by clicking on an “unsubscribe” link at the end of an email, or by contacting our Privacy Officer.)
How does Spiral Foods get the personal information it collects and holds?
Spiral Foods only collects personal information by fair and lawful means, when people:
- contact us through our sites;
- enter any of our competitions or promotions;
- browse our sites;
- post material to our sites or to social media that we use (such as Facebook, Twitter, Pinterest and Instagram);
- contact us for assistance or with questions, or report problems with our sites or with a product; and
- contact us other than through our sites or social media (for example, if you email us directly, or send us a fax or letter).
We prefer to obtain any personal information we collect directly from you. In some cases, however, it may be unreasonable or impracticable to obtain personal information directly, and we may obtain that information from someone else. Spiral Foods does not, however, purchase mailing lists. If you are concerned about what personal information we may hold about you, please see below for information on how you can access and (if necessary) correct that information.
Can I interact with Spiral Foods anonymously or under a pseudonym?
In many cases, you will need to provide your real name when interacting with us. This will particularly be the case if you are (for example) purchasing an item or claiming a prize in a competition.
You may however – wherever lawful and practicable – use a pseudonym (or simply not identify yourself) when dealing with us. For example, if you have a complaint or concern about our site, or a general question about any of our products or services, you are welcome to contact us without identifying yourself. In some cases, however, if you do not provide us with information, we may not be able to provide you with our products or services, or we may not otherwise be able to respond adequately to you.
For clarification on when you must identify yourself, please contact our Privacy Officer. (You may use a pseudonym – or simply not identify yourself – when making such an enquiry.)
Who has access to my personal information?
Generally, only our staff will access your personal information, and then only on a “need to know” basis.
We may, however, also disclose your personal information:
- to people who work for us or for one of our suppliers, or on our behalf, and who may be engaged in, among other things, filling and delivering orders, processing payments and mail-outs, marketing, research and providing support and IT services;
- to protect the rights, property, health or safety of Spiral Foods or its staff, customers or others (including exchanging information with other companies and organisations to protect against fraud and to reduce credit risk);
- to our agents, legal advisers, business partners, joint venture entities and other partners, including any holding company or subsidiary, our ultimate holding company, and its holding companies and subsidiaries, as defined in section 50 of the Corporations Act 2001 (Cth);
- to sponsors and promoters of any competition that we may conduct or promote;
- as part of a sale (or proposed sale) of all or part of our business;
- to anyone else that you specifically authorise us to receive information held by us; and/or
- as otherwise required or permitted by law (including under privacy legislation).
Please also note that the transmission of information (including over the internet and by post) is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information – particularly while it is being transmitted to us – so any transmission is at your own risk and we cannot accept responsibility for misuse or loss of, or unauthorised access to, your personal information where the security of information is not within our control.
If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.
How can I access (and, if necessary, correct) personal information that Spiral Foods collects and holds about me?
If you want to review (and, if necessary, correct) personal information that Spiral Foods may have collected and holds on you, please contact our Privacy Officer.
We will respond to your requests to access and to correct your personal information as soon as possible (but in any case within a reasonable period).
How can I complain about Spiral Foods if it breaches any of applicable privacy principles or any registered code that binds it?
Contact our Privacy Officer if you have any complaints about breaches by Spiral Foods of any applicable privacy principles or of any registered code that binds it.
How will Spiral Foods deal with complaints I might have about breaches of applicable privacy legislation or any relevant registered code?
We will treat any complaint about a breach of privacy legislation or any relevant registered code seriously, and will investigate any breach of which we become aware – including how it occurred and how best to prevent such a breach occurring again.
What steps does Spiral Foods take to secure personal information?
We take reasonable steps to ensure that your personal information is treated securely and in accordance with this policy and is not subject to misuse, interference or loss, or unauthorised access, modification or disclosure. For example, apart from using secure servers, we implement firewalls and password access and, where relevant, we impose limits on who can access personal information.
If we have given you (or where you have chosen) a password which enables you to access our services or parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Does Spiral Foods disclose personal information to people or organisations outside Australia?
- Spiral Foods holds personal information securely both in its offices and on secure servers, all of which are located in Australia.
We will not, however, transfer your personal information to any country that is not subject to a comparable privacy scheme unless the organisation to which we disclose that information implements privacy policies at least comparable to the obligations that apply in Australia.
Who do I contact at Spiral Foods about privacy issues?
Contact our Privacy Officer on firstname.lastname@example.org or on +61 2 8231 4404 if you have any concerns about privacy issues, including how Spiral Foods is dealing with or holding your personal information.
Please also contact our Privacy Officer if you want to review and/or correct any personal information we hold about you, or if you receive communications purporting to be connected with Spiral Foods or our services that you believe have been sent other than in accordance with this policy or in breach of any law.