Jalna Dairy Foods Pty. Ltd. ACN 005 363 664 (Jalna, we, us, our) and its related entities is committed to complying with
applicable privacy laws in relation to the personal information that we collect in the course of running our business.
obligations and your rights in respect of our dealings with your personal information.
employees. Section 10 explains the position of employees.
Where applicable privacy laws provide for exceptions or exemptions, we may rely on those exceptions or exemptions in
our information handling practices.
In this document:
- “APPs” means the Australia Privacy Principles set out in the Privacy Act;
- “personal information” has the meaning set out in the Privacy Act, and (in summary) means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether true or otherwise;
- “Privacy Act” means the Privacy Act 1988 (Cth); and
- “sensitive information” has the meaning set out in the Privacy Act, and includes certain specific types of personal information such as health information, and information about a person’s racial or ethnic origin, sexual orientation or practices, criminal record, religious beliefs or affiliations, political opinions, membership of a political, professional or trade association, and biometric and genetic information.
- How we collect your personal information
We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect the personal information you directly give us through some of the following means:
- when you contact us or make an inquiry about our products or via our Website, from correspondence (whether in writing or electronically), forms or when you contact us via telephone, social media platforms or other means;
- when you enter into contracts with us for our products;
- in administering and performing any contracts with service providers;
- when you apply for a role with us;
- when you upload content to or interact (in an identifiable manner) with our Website or our social media pages;
- while conducting customer satisfaction and market research surveys;
- if you attend any of our premises, we may record certain contact details so that we can comply with applicable laws, and we may also record your image and/or voice if we have surveillance systems operating at those premises; and
- as otherwise required to manage our business.
However, in certain cases we may collect personal information indirectly, such as from publically available sources and third parties, such as our service providers, suppliers, retailers that sell our products, your employers or representatives, our related companies, recruitment agencies, referees, government bodies and credit reporting bodies (in accordance with our credit policies).
If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information.
- Types of personal information we collect
The types of personal information we collect about you depends on the circumstances in which the information is collected. Typically, the types of personal information we may collect can include (but is not limited to) your name, address, email address, phone numbers and .
If we enter into contracts with you, request or receive products from us or have any other commercial dealings with us, we may also collect your signature, occupation, current and previous addresses, date of birth, credit card and/or banking details and driver’s licence number.
If you are an individual contractor to us or apply for a role with us, we may also collect information relevant to your engagement with us including qualifications, length of engagement, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment (e.g. phones, computers and vehicles).
If you attend a premises we operate or manage, we may:
- collect certain contact details that you provide to us (which may be via digital check-in apps), including the date and time of attendance, including so that we can comply with applicable laws (such as public health directives). If we collect such information to comply with a particular law, we will only use and disclose it in accordance with applicable laws; and
- record your image and/or voice through the use of Closed-Circuit Television (CCTV) systems footage of you via our CCTV devices, for the purposes of managing security of the premises and health and safety of occupants and the public generally.
If you call us via telephone, we may monitor and in some cases record such telephone conversations for staff training, quality assurance and record-keeping purposes.
If you access our Website, we may utilise cookies to collect additional information about your use of our Website. Please see the cookies section below for further details. If when you are on our Website and you have provided us with permission to access your device location, we may collect information about your geographical location.
If we communicates with you by email, we may use technology to identify you so that it will be in position to know when you have opened the email or clicked on a link in the email.
We only collect sensitive information about you with your consent, or otherwise in accordance with the Privacy Act. The main types of sensitive information we may collect include:
- details of injuries (i.e. health information) that may occur on our premises or arising through the consumption of our products; and
- details of disabilities or allergies (i.e. health information) you notify us of so we can accommodate any special requirements when you attend our premises.
If you do provide sensitive information to us for any reason (for example, if you provide us with information about a disability you have), you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.
In addition to the types of personal information identified above, we may collect personal information as otherwise permitted or required by law.
Where you do not wish to provide us with your personal information, we may not be able to provide you with requested products or otherwise action your request.
- Our purposes for handling your personal information
As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.
We may use or disclose your personal information:
- for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
- for other purposes to which you have consented; and
- as otherwise authorised or required by law.
In general we collect, use and disclose your personal information so that we can do business together and for purposes connected with our business operations.
Some of the specific purposes for which we collect, hold, use and disclose personal information are as follows:
- to provide you with our products or to direct you to a retailer that sells our products;
- if you are a supplier or service provider, to receive goods or services from you;
- to consider you for a job (whether as an employee or contractor) or other relationships with us;
- to provide you with tax invoices for our products and dispatch and tracking information;
- to operate, monitor, develop and improve our Website, business operations and products (including research and development of new products);
- to maintain our customer and employee databases;
- to confirm your identity;
- to optimise and customise the user experience (including content and advertising) for users of the Website;
- to facilitate communications via our Website and social media channels, including communications with us via direct messaging;
- where you have provided us with access to your geographical location via our Website, we may send you push notifications and other electronic communications (including SMS) for purposes including to notify you of where the closest retailer is that sells our products;
- conduct appropriate checks for credit-worthiness (in accordance with our credit policies) and to implement anti-fraud measures;
- to facilitate your entry and participation in a competition or trade promotion;
- to contact you (directly or through our service providers and marketing research agencies) to obtain your feedback and to find out your level of satisfaction with our products;
- to comply with our legal and regulatory obligations;
- to protect the security and safety of our premises, facilities, personnel and visitors;
- to address any issues or complaints that we or you have regarding our relationship; and
- to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.
- Who we disclose your personal information to
- our suppliers, service providers, contractors and organisations that provide us with technical and support services or who manage some of our business functions, including without limitation:
- mailing houses;
- IT service providers; and
- marketing and telemarketing service providers;
- our related entities (who may use and disclose the information in the same manner we can);
- our accountants, insurers, lawyers, auditors and other professional advisers, organisations involved in managing our corporate risk and funding functions (e.g. securitisation) and credit providers;
- any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees or your authorised representatives or legal advisers);
- government and regulatory authorities and other organisations, as required or authorised by law;
- if our assets or business (including accounts and trade receivables) may be transferred, acquired or considered for transfer or acquisition by a third party, that third party and its advisors;
- credit reporting bodies (in accordance with our credit policies); and
- debt collection agencies.
We may also disclose your personal information in accordance with any consent you give or where disclosure is authorised, compelled or permitted by law.
If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.
If you post information to certain public parts of our Website or to our social media pages, you acknowledge that such information may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.
- Protection of personal information
We will hold personal information as either secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third party servers, which may be located overseas. We use a range of security measures to protect the personal information we hold, including by implementing IT security tools to protect our electronic databases.
We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.
- Direct marketing
Like most businesses, marketing is important to our continued success. We therefore like to stay in touch with customers and let them know about new offers and opportunities. We may provide you with information about products, services and promotions either from us, or from third parties which may be of interest to you, where:
- you have consented to us doing so; or
- it is otherwise permitted by law.
You may opt out at any time if you no longer wish to receive direct marketing messages from us. You can make this request by contacting our Privacy Officer.
We may use third party vendors to show our ads on sites on the Internet and serve these ads based on a user’s prior visits to our Website and other internet activity. We may also use analytics data supplied by these vendors to inform and optimise our ad campaigns based on your prior visits to our Website.
- Accessing and correcting your personal information
You may contact our Privacy Officer (see section 12) to request access to the personal information that we hold about you and/or to make corrections to that information, at any time. On the rare occasions when we refuse access (which we will only do in accordance with applicable laws), we will provide you with a written notice stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to the personal information we hold about you.
We are not obliged to correct any of your personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will provide you with a written notice stating our reasons for refusing.
We will respond to all requests for access to or correction of personal information within a reasonable time.
- Overseas transfers of personal information
We do not generally disclose personal information to recipients based outside Australia.
We collect information in relation to employees as part of their application and during the course of their employment, either from them or in some cases from third parties such as recruitment agencies, referees, government bodies (e.g. police checks, if required) and academic and professional bodies (e.g. to validate details and currency of qualifications). Such information may include contact details, qualifications, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records and logs of your usage of our equipment (e.g. phones, computers and vehicles).
Under the Privacy Act, personal information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship. We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.
- Resolving personal information concerns
When contacting us please provide as much detail as possible in relation to your question, concern or complaint.
We take all complaints seriously, and will respond to your complaint in accordance with any applicable timeframes imposed by law and otherwise within a reasonable period. We request that you cooperate with us during this process and provide us with any relevant information that we may need.
If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218, Sydney NSW 2001
Telephone: 1300 363 992
- Contact details of Privacy Officer
The contact details for our Privacy Officer are as follows:
Postal address: PO Box 169, Bundoora VIC 3083
Telephone: (03) 9474 3900 Email: firstname.lastname@example.org
Our Website may contain links to other websites operated by third parties such as our retailers. We make no representations or warranties in relation to privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices and procedures.