- make a consumer related enquiry or complaint (including via letters, telephone calls, text messages and emails to our Consumer Experience Centre);
- enter into our competitions and promotions;
- complete our surveys;
- sign up to our newsletters;
- sign up to join our online communities;
- complete registration processes when you purchase a product;
- transact with us; and
- use our website.
- What data do we collect?
Our Company collects the following data:
- Personal identification and contact information, including your name, date of birth, gender, email address, phone number, address and other contact details.
- Information relevant for promotions and competitions.
- Information you may make publicly available online (including, but not limited to, on social media platforms).
- Transaction details, if you make a purchase with us or choose to store details in your online profile.
- Information we require to facilitate or improve our transactions and dealings with you.
- Information that helps us to improve our products and develop new products.
- A record of any enquiries you make.
- If you make a consumer related enquiry or complaint to us, health and other sensitive personal data if needed in connection with your enquiry or complaint.
- How do we collect your data?
You directly provide our Company with most of the data we collect. We collect data and process data when you:
- Contact us, including when you make a consumer related enquiry or complaint to our Consumer Experience Centre via our website, email or telephone, and in subsequent communications with the Consumer Experience Centre.
- Enter our competitions and promotions.
- Voluntarily complete a customer survey or provide feedback via our website, any of our social media pages or email.
- Use or view our website, via your browser’s cookies.
- Use or view our social media pages or use our apps.
- Sign up to our branded newsletters.
- Sign up to join our online communities.
We will always seek your consent to collect any health or other sensitive personal data about you.
Our Company may also receive your data indirectly from the following sources:
- Our agents and contractors in connection with any of our competitions or promotions.
- Our customers if you contact them and we reasonably believe you have authorised them to refer your inquiry to us.
- Third parties if it is not reasonable or practicable to collect the data from you.
- How will we use your data?
Our Company collects your personal data for the purposes of our business and activities, and in our efforts to improve and grow our business. More specifically, the purposes for which we collect your personal data, and the legal basis for processing your personal data under European Union and United Kingdom data protection laws, is set out below:
|Confirm your identity.||This is in our legitimate interest, for example, to ensure we have confirmed the identity of the person making a request to us. We also process this personal data where necessary for us to comply with a legal obligation that we are subject to.|
|Provide products and services to you.||This is in our legitimate interest in order for us to provide products and services to you. In addition, where we have a contract with you, it may be necessary for us to process your personal data in order for us to perform that contract with you.|
|Deal with your consumer related enquiry or complaint.||This is in our legitimate interest in order to respond to your enquiry or complaint.|
|Administer and manage promotions and competitions.||This is in our legitimate interest in order to manage and administer our promotions and competitions. In addition, where we have a contract with you regarding the promotion or competition, it may be necessary for us to process your personal data in order for us to perform that contract with you.|
|Conduct marketing activities as described in Section 7.||We process your personal data in order to send you marketing materials. Where required under applicable data protection laws, this will be on the basis of your consent.|
|Obtain your feedback on our products and services and conduct consumer research.||This is in our legitimate interests in order to conduct research and obtain feedback to improve our products and services.|
|Conduct a business or professional relationship we have with you.||This is in our legitimate interests in order to manage and conduct our relationships with third parties in a business or professional capacity.|
|Personalise and enhance your online experience.||This is in our legitimate interests in order to improve our website and online experience for our customers and visitors.|
Sometimes we extract information from our collected records to produce aggregated data. This aggregated data does not identify individuals. We use the aggregated data for research and product development and may share the data with third parties in connection with those purposes.
You are not required to provide any personal data to us. If you do not, or you inform us that you do not want us to use your personal data to contact you, we may not be able to deal with you effectively for the above or other purposes.
- How will we disclose your data?
Our Company may disclose your data in the following ways:
- If you consent, our Company will share your data with our partner companies so that they may offer you their products and services.
- We may provide your data to third parties that we engage to perform functions on our behalf, such as processing credit card information, mailing information or prizes, data analysis, research, and advertising.
- In certain circumstances, we may disclose your personal data where required or authorised to do so by law, including in emergency situations, for health and safety reasons, and to assist law enforcement agencies.
- If you purchase a product, we may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.
- How do we store your data?
Our Company uses various systems and services to safeguard the personal data we store, as part of our business systems and processes.
Our Company securely stores your data both at an onsite secure server and offsite using trusted third party storage providers. Our staff are required to sign in and use multi-factor password when accessing our secure systems. We provide training for relevant staff to ensure that they are aware of our privacy commitments and our obligations in relation to the collection, use and disclosure of personal data.
Our Company will keep your personal data for as long as it is required for the purposes for which it was collected, or longer if required by applicable laws. Once your personal data is no longer required, we will de-identify or delete your data in our systems, or ensure we are no longer able to access and use it.
- Cross border transfer of personal data
Our Company’s systems and services may involve other entities within The Arnott’s Group and third party service providers located outside the country in which our Company is located.
Your personal data may be held and processed outside the country in which our Company is located by other entities within The Arnott’s Group and our service providers. The Arnott’s Group entities and our service providers are based in various countries, including Australia, New Zealand, Japan, Hong Kong, Malaysia, Indonesia, Singapore, Taiwan, India, the United Kingdom and United States.
When we transfer personal data to others or outside the country in which our Company is located, we will comply with applicable privacy and data protection laws and will take steps to ensure it is treated in the same way that we would treat it. If you are located in the European Union (“EU”), European Economic Area (“EEA”) or the United Kingdom (“UK”), your personal data may be transferred outside of the jurisdiction in which you are located. We may transfer your personal data to jurisdictions that are deemed as adequate for the purposes of EU/EEA and UK data protection laws and, where that is not the case, we will ensure appropriate safeguards are in place under EU/EEA and UK data protection laws, such as standard contractual clauses. For more information or to obtain a copy of the standard contractual clauses that we use, please contact us using details in Section 11.
Our Company would like to send you information about our products and services that we think you might like. This may include updates on special offers, events and rewards, and other communications through our newsletters, online communities and/or loyalty clubs.
We will only do so if you have consented to receive marketing from us. If you have consented to receive marketing from us, you may always opt out at a later date. If we send a marketing offer directly to you, we will provide a way for you to opt out of future marketing offers.
You have the right at any time to stop our Company from contacting you for marketing purposes or giving your data to other members of The Arnott’s Group.
If you no longer wish to be contacted for marketing purposes, please contact us using the details in Section 11. You can also follow the instructions to unsubscribe or opt out that we include in every electronic marketing communication.
- What are your data protection rights?
- Access – You can ask us to confirm whether we hold personal data about you. You have the right to request our Company for copies of your personal data. We will handle and respond to your request in accordance with applicable privacy laws, including if we are unable to provide you with the access you request. We do not impose any charge for a request for access, but where permitted under applicable data protection laws, we may charge you a reasonable fee for our costs associated with retrieval and providing you with access.
- Rectification – You have the right to request that our Company correct any information you believe is inaccurate. You also have the right to request our Company to complete information you believe is incomplete. You should contact us if you believe that any of the personal data we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, and provide us with a statement of the correction that you seek.
- Erasure – You have the right to request that our Company erase your personal data, under certain conditions.
- Restrict processing – You have the right to request that our Company restrict the processing of your personal data, under certain conditions.
- Object to processing – You have the right to object to our Company’s processing of your personal data, under certain conditions. For example, you have the right to object to our processing of your personal data on the basis of our legitimate interests, under certain conditions. You also have the right to object to our processing of your personal data for direct marketing purposes as set out in Section 7
- Data portability – You have the right to request that our Company transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
- Withdrawal of consent – If we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time.
If you make a request, we will use reasonable endeavours to respond to you within a month, and we will inform you if we will need longer to respond to you. If you would like to exercise any of these rights, please contact us using the details in Section 11.
- Privacy policies of other websites
- How to contact us
Email us at: Privacy@arnotts.com
- Australia: 1800 24 24 92 or 1800 66 33 66
- New Zealand: 0800 88 19 66
- Hong Kong: +852 2811 3806
- Indonesia: 0 800 1 80 8000
- Japan: 0120 801639
- Malaysia: +60 3 7787 6288
- Singapore: +65 6273 0889
Or write to us at:
Attention: Privacy Officer
24 George Street, North Strathfield NSW 2137, Australia
- How to contact the appropriate authority
We will inform you of any applicable dispute resolution avenues that you may pursue if you are not satisfied with our response. Should you wish to report a complaint or if you feel that our Company has not addressed your concern in a satisfactory manner, you have the right to contact the relevant authority in your country. These include:
Office of the Australian Information Commissioner
Phone: 1300 363 992
Office of the Privacy Commissioner for Personal Data
Phone: 2827 2827
Personal Information Protection Commission, Japan
Phone: 03 6457 9680
Personal Data Protection Department
Phone: 03 8911 5000
New Zealand Office of the Privacy Commissioner
Phone: 0800 803 909
Information Commissioner’s Office
Phone: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
If you are located in the EU, you may contact the data protection authority in your jurisdiction. A list of contact details for EU data protection authorities is available at https://edpb.europa.eu/about-edpb/about-edpb/members_en
- The Arnott’s Group entities
The Arnott’s Group includes the following entities. If you are located in one of the jurisdictions below, the entity/entities listed are the data controller in respect of your personal data unless otherwise indicated:
· Arnott’s Biscuits Ltd (ABN 44 008 435 729)
· Campbell Australasia Pty Ltd (ABN 28 004 456 937)
· Good Food Partners Pty Ltd (ABN 38 104 048 400)
· Campbell Foods HK Ltd
· PT Arnott’s Indonesia
· Campbell Japan Inc
· Campbell Cheong Chan (Malaysia) Sdn Bhd
· Campbell Soup Southeast Asia Sdn Bhd
· Arnott’s New Zealand Ltd
· 180 Degrees Ltd
· Campbell Foods UK Ltd (data controller: Arnott’s Biscuits Ltd (ABN 44 008 435 729) (Australian company))
All entities in The Arnott’s Group can be contacted using the details in Section 11.