Privacy Policy

Privacy Policy Date Effective: 5/12/2018 Current Version: 2.0

Policy Statement

Impeach Pty Ltd ACN 008 143 959 as trustee for Foodland Promotions Unit Trust, trading as Foodland Promotions (ABN 85 528 062 001) and its related bodies corporate (“we”, “our” or “us”) are committed to the protection of personal privacy within the scope of the applicable law. This Privacy Policy covers our treatment of personal information that we collect, use and disclose.

In this policy, ‘personal information’ means information or an opinion about an identified individual or an individual who is reasonably identifiable (whether true or not and whether it is recorded in a material form or not).

Types of personal information collected
The types of personal information that we collect and hold will vary depending on your dealings with us. The information may include any or all of the following:
* name, address(es), telephone number(s) and other contact details;
* email address(es);
* payment information (such as credit card or bank details);
* standard employment information for recruitment purposes;
* other personal information we require to provide our services; and
* transaction details relating to your purchase and use of our products, services or benefits.

We will also collect your date of birth (and driver’s licence number) where required (e.g. to comply with any legal requirements).

We may collect sensitive information (which is a subset of personal information, and includes things such as your membership of any trade union or professional association), but only if you agree to provide it to us and it is reasonably necessary for one of our functions or activities, or if we are otherwise authorised or required by law to collect such information.

You do not have to provide us with any personal information, however if you do not do so, we may not be able to deal with you or provide you with the products, services or benefits you have requested.

How we collect personal information
Generally, we collect personal information directly from you, such as:
* when you submit information through our website;
* when you submit information via our social media sites and smartphone applications;
* in person;
* when you enter into a promotion conducted by us or a third party;
* when you complete a survey or provide feedback;
* when you order goods or services;
* in the course of us providing you with a requested product, service or benefit; or
* when you have other dealings with us.

We may also collect your personal information through:
* our related bodies corporate;
* our business partners (such as an operator of a Foodland supermarket);
* third parties who supply services to us (such as our logistics or marketing service providers);

* a person who provides us with information on your behalf (such as someone filling out an order on your behalf).

Note:  If you provide us with personal information about an individual (for example, for delivery purposes), you must ensure that the relevant individual is made aware of this Privacy Policy and has agreed to us handling their personal information in accordance with this Privacy Policy.

Why we collect, use and disclose personal information
We will use and disclose the personal information we collect for the primary purpose(s) for which we collected it, including but not limited to those purposes disclosed at or before the time of collection, or as otherwise set out in this Privacy Policy. We will not use or disclose your personal information for any other purpose without first seeking your consent, or where authorised or required by the law.

Examples of the primary purposes for which we collect and use personal information are:
* if we collect the information from you:  to establish and maintain your relationship with us and answer any enquiries you make;
* if we collect the information in the course of providing you with goods or services:

–         to provide the goods or services to you;

–         to assist us to make our goods and services more valuable or useful to you;

* if we collect the information in the course of acquiring goods or services from you:  to manage our acquisition of goods or services from you;
* if we collect the information for an event or promotion:  to register you for such event or promotion and allow us to run the event or promotion;
* if we collect the information when you apply for a job with us:  to assess your suitability for such job;

* if we collect your personal information for any purpose, we also collect it in order to conduct our ordinary internal business functions and activities (such as collating data, analysing trends, formulating strategy, raising finance, selling our business or complying with our legal or reporting requirements).

We may disclose your personal information to third parties for the purposes referred to above. These third parties include persons such as:
* manufacturers and suppliers of our goods or services;
* our marketing consultants and promotions companies who assist us to run our business; and
* our consultants and professional advisers;

* government authorities or other persons we are required to disclose such information to at law.

Direct Marketing
We will also use and disclose your personal information to send direct marketing to you from:
* us;
* our related bodies corporate.

The direct marketing may relate to:
* our products and services;
* the products and services of other parties;
* promotions run by us or other parties; or
* new developments we believe may be of interest to you.

You may opt-out of receiving direct marketing through the unsubscribe function that will be made available to you with each direct marketing communication.

How we store and protect personal information
We store personal information in a combination of computer storage facilities, paper-based files and other records. In doing so, we have taken numerous steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification or disclose. Additionally, we take reasonable steps to destroy or permanently de-identify personal information when we no longer need it.
The internet is not a secure method of transmitting information. Accordingly, we cannot and do not accept responsibility for the security of information transmitted over or stored on internet services, or for any unauthorised access or use of that information. You should take steps to ensure any devices you use to transmit personal information are secure.

Do we send personal information overseas?
We are not likely to disclose your personal information to a person who is not in Australia.

How you can access your personal information
We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up to date. If your personal details change, such as your address or phone number, please contact our Privacy Officer at the details below.
At your request, we will provide you with a copy of any personal information which we hold about you, unless an exception under the Privacy Act 1988 applies. We may charge a fee for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information.
We will promptly acknowledge and investigate any complaint about the way we manage personal information.

Our website may use cookies to track user traffic patterns and to better serve you when you revisit a website. A cookie is a small data file that a website may write to your hard drive when you visit it. A cookie can contain information, such as a user ID which the website uses to track the pages you have visited. You can refuse all cookies by turning them off in your browser. However, full functionality for our website requires the use of cookies. Information is also generated whenever a page is accessed on our website that records information such as the time, date and specific page. We may collect such information for statistical and maintenance purposes that enables us to continually evaluate our website performance.

How to contact us or make a complaint
If you have any questions about this Privacy Policy, if you wish to update information we hold about you or if you wish to make a complaint about our collection, use or disclosure of your personal information under this Privacy Policy, please contact:

Foodland Supermarkets Support Office
Level 1, 191 Flinders Street
Adelaide SA 50
(08) 8351 9233

We will take reasonable steps to remedy any issue resulting from our failure to comply with our privacy obligations.

This policy will be reviewed from time to time to take account of new laws and technology, and changes to our operations and practices. The most current version of the policy is located on our website and can be obtained by contacting our Privacy Officer.