We are subject to a range of laws which protect your privacy including Australia’s Privacy Act 1988 (Cth) (the "Privacy Act"). In some cases, exemptions under these laws may apply, in which case we may rely on those exemptions. For example, the Privacy Act includes an exemption for the handling of employee records in some circumstances.
1. COLLECTION OF PERSONAL INFORMATION
We only collect personal information to the extent that this is reasonably necessary for one or more of our functions or activities. We collect personal information about our customers, clients (and their staff), suppliers (and their staff), job applicants, consultants, representatives of regulatory bodies and other individuals who interact with us. For example, we may collect personal information about you when you contact us, place an order with us or apply for a position with us.
The types of personal information we collect include current and historical information about your name, contact details (including address, email address and phone details), identification, organisation, employment, positions held, forms submitted, order history, payment and bank account details, insurance details, interests, preferences, opinions and enquiry/complaint details.
We also collect personal information about your dealings and interactions with us, including any contact you have with us or our service providers by telephone, email or online. We may monitor and record your communications with us (including email and telephone) and operate video and audio surveillance devices in our premises for purposes including security, training and record-keeping.
Job applicants and employees
The personal information we collect about you in connection with our recruitment processes may include your name, contact details, identification details, forms submitted, employment and education history, skills, achievements, character, extra-curricular activities, screening checks (including reference, background, health, cognitive ability, directorship, identity, eligibility to work, criminal record, financial probity, psychometric testing results, drugs/alcohol and vocational suitability checks) and enquiry/complaint details.
In accordance with the Privacy Act, this policy does not apply to our acts and practices directly related to a current or former employment relationship between us and an employee, and an employee record held by us relating to the employee.
For our customers, the personal information we collect about you in connection with our purchase order processes may include your name, contact details, shipping/delivery address, order history, payment details, information about financial standing, your IP address, device identifiers and information about how you use our website (including your setting preferences, browser type, operating system, website visited immediately before coming to our site, and other information).
Collection of information from third parties
We do not typically collect sensitive information about individuals in the course of performing our services. If we do need to collect sensitive information about you, we will seek your consent where required under the Privacy Act. "Sensitive information" includes information about a person's racial or ethnic origin, political or philosophical beliefs or affiliations, trade or professional affiliations, sexual preferences or practices or criminal record and health information.
2. WHY WE COLLECT PERSONAL INFORMATION
We collect, hold, use and disclose personal information to provide you with products and services, operate our global business and to comply with applicable laws. Other purposes for which we may collect, use or disclose your personal information include (but not limited to):
· providing our products and services
· maintaining and updating our records
· verifying information
· communicating information about our business, products and services (including for direct marketing in accordance with legal requirements)
· managing our relationships with stakeholders including our staff and business contacts representing clients, suppliers and others
· recruiting, vetting, training and managing staff and job applicants
· performing our legal obligations (e.g. under contracts or in relation to statutory reporting)
· protecting our lawful interests
· facilitating acquisitions or divestments of businesses.
We may not be able to do these things without your personal information. For example, we may not be able to fulfil an order or consider your application for employment. In relation to staff, we may in some cases take appropriate disciplinary action if you refuse to provide certain information.
We may use and disclose your personal information for the primary purpose for which we collected that information, for related (or directly related, for sensitive information) secondary purposes within your reasonable expectations, where permitted under the Privacy Act and where otherwise required or authorised by law.
3. HOW WE DISCLOSE PERSONAL INFORMATION
We may exchange your personal information with our related bodies corporate, your representatives, your current and previous employers, and with our service providers that assist us with archival, data storage, auditing, accounting, contact centre, legal, business consulting, banking, payment, debt collection, delivery, data processing, data analysis, document management, information broking, research, investigation, insurance, website, technology, marketing, sales, recruitment, vetting, payroll, superannuation, staff benefits, surveillance and training services. We may exchange your information with a law enforcement body to the extent that information is requested from us.
For job applicants including applicants who commence an employment relationship with ABP or one of its related bodies corporate, we may also exchange your personal information with academic institutions, health service providers, professional and trade associations and referees.
ABP is owned by Ixom, and is a part of the Ixom group of companies. Ixom operates globally. Ixom and ABP's related companies and other third parties or service providers described above may be located in Australia/Pacific, North America, Asia and Europe, among others. It is not practicable for us to specify in advance the location of each party with whom we deal. See www.ixom.com for further details of Ixom's global locations.
4. DIRECT MARKETING
We may use and disclose your personal information in order to communicate information about our business, products and services and offers in accordance with legal requirements. These communications may be sent in various forms, including mail, SMS, various Social Media platforms and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). When you sign up to one of our mailing lists or other communication channels, you may consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.
Please note that even if you request not to receive further direct marketing communications, we may continue to provide information to you about certain information, such as changes to our terms and conditions as permitted under applicable laws.
We do not use sensitive information for direct marketing and, except for our service providers, we do not provide your personal information to other organisations for the purposes of direct marketing.
5. SECURITY AND STORAGE OF PERSONAL INFORMATION
We are committed to safeguarding and protecting personal information and will take such steps as are reasonable in the circumstances to protect the personal information we hold from misuse or loss and from unauthorised access, modification or disclosure. We implement a range of measures to protect the security of personal information. Depending on the circumstances, these may include firewalls, encryption, passwords and locked areas. We note that no data transmission over the Internet can be guaranteed as totally secure. While we strive to protect such information, we cannot warrant the security of any information that is provided to us over the Internet, and you provide such information to us at your own risk. We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers.
6. OUR WEBSITES
7. YOUR RIGHTS
We will take such steps as are reasonable in the circumstances to ensure that the personal information which we collect remains accurate, up to date and complete.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal. There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in actually providing you with access.
If you consider that the information which we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps, consistent with our obligations under the Privacy Act and other applicable laws, to correct that information if you so request.
We are bound by the Australian Privacy Principles set out in the Privacy Act.
If you remain unsatisfied with the way in which we have handled a privacy issue, we suggest you approach an independent advisor or contact the Office of the Australian Information Commissioner for guidance on alternative courses of action which may be available. We will provide our full cooperation in the event that you elect to pursue this course of action.
10. CONTACT US
You can contact our Privacy Officer Nik Andersen via one of the means below:
Telephone: 1300 559 262
Post Ixom Operations, Att: Privacy Officer, Level 8, 1 Nicholson St., East Melbourne, Victoria, 3002, Australia
Issued by Australian Botanical Products Pty Ltd ACN 006 782 529 (ABP) ABP is a subsidiary of Ixom Holdings Pty Ltd ACN 131 367 112 (Ixom).