1. Types of personal information we collect and hold
The types of personal information we collect and hold depends on your dealings with us and the services and benefits we (or our agents, contractors and third parties) provide to you, or a request you make in relation to such products, services and benefits. The personal information we collect includes:
• Telephone number(s);
We do not actively collect sensitive information and where you provide us with sensitive information on an unsolicited basis (such as health information) you consent to our collection of such information.
2. Website cookies
A “cookie” is a small text file that is placed on your computer’s hard drive by a web page server. Cookies store information about your use of our website. The cookies only collect information in aggregate, non-identifiable form. Most web browsers default setting is to accept cookies, but you can disable this functionality. Please note that if you do not accept cookies, not all functionality on our websites may be available to you.
For more information on how Google Analytics operates, see “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/).
3. How we collect and hold personal information
We collect personal information directly from you through our website, transactions, competitions and trade promotions. We do not collect your personal information from any third parties. Your personal information is stored on our behalf by a trusted third party, 303 Mullen Lowe Group, which is a digital agency located in Australia. 303 Mullen Lowe Group takes such steps as are reasonable to secure your personal information from misuse, interference, unauthorised access, modification or disclosure. We are likely to also transfer your personal information to AWS (Amazon Web Services) in Singapore but only for the limited purpose of hosting your personal information.
4. How we use and disclose personal information
Generally, we use your personal information for two purposes:
• to keep you informed of any products, services and benefits that we consider will be of interest to you in the future; and
• to distribute product samples to your home or work address.
As part of the distribution of product samples, we share your personal information with a trusted third party, ANO, which is an Australian distributor who we engage to affix your name and address to parcels that contain free product sample(s) that ANO sends to you on our behalf.
When we collect your personal information we will notify you of the purpose for which it will be used and we will request your permission to contact you regarding any future promotions of products or services. If you do not wish to receive direct marketing information from us, please use the contact details below to update your preferences, or use the unsubscribe feature on our electronic marketing communications. We may disclose your personal information to law enforcement agencies where required or authorised by law to do so or for any purposes connected to a fraud, crime prevention or impropriety investigation.
5. Overseas disclosure of personal information
We are likely to disclose your personal information to AWS (Amazon Web Services) in Singapore for the limited purpose of hosting such information.
6. Access to and correction of personal information
We will take reasonable steps to ensure that the personal information we collect, hold, use or disclose is accurate, complete, up to date, relevant and is not misleading. You have a right to request access and/or the correction of any of your personal information we hold or control. Requests for access or correction are to be directed to Edgewell Customer Service on 1800 761 186. We may ask you to answer a simple question, such as providing your address, to confirm we are providing access to the correct individual. We endeavour to respond to any request within a reasonable time period.
Please provide us with as much detail as you can about the particular information you wish to access or correct, in order to help us retrieve it. We may charge you an access fee to cover our costs of sending the information to you. We will inform you of applicable fees before they are incurred. In certain circumstances, such as where giving you access would have an unreasonable impact on the privacy of other individuals, we may refuse to provide you access to your personal information. If we refuse to provide you access, we will provide you with a written notice that sets out the reasons for the refusal except to the extent it would be unreasonable to do so.
Where we correct personal information we hold about you, you have a right to request that we notify any other third parties to which we disclosed the inaccurate information. We will provide such notice to any third parties where it is practical and lawful for us to do so. In the unlikely event that we refuse to correct your personal information as requested by you, we will provide you with reasons for the refusal except to the extent that it is unreasonable to do so.
7. Anonymous and pseudonyms
You may request to remain anonymous, or seek to use a pseudonym, in your dealings with us. We will honour any such request to stay anonymous or use a pseudonym where it is lawful and practicable to do so.
8. Making a complaint
If you would like to make a complaint about the manner in which we have handled your personal information, please contact Edgewell Customer Service on 1800 761 186. We will promptly investigate your complaint and provide you a response with our findings within a reasonable period of time. If you are dissatisfied with our response, you may complain to the Australian Information Commissioner on 1300 363 992 or, if outside Australia, +61 2 9284 9749 (www.oaic.com.au).
Last updated: 27th October 2014.