Privacy Policy
Introduction
Ridley Corporation Limited and its related bodies corporate (as defined in the Corporations Act 2001 (Cth) (Ridley, we, our or us) seek to comply with the Australian Privacy Principles and are committed to the protection of personal privacy in accordance with the Privacy Act 1988 (the Act).
This policy sets out how we collect, use, disclose, manage and store Personal Information.
Scope
This Policy applies to Ridley and all employees and contractors of Ridley.
Protecting your privacy
You agree to the collection, holding, use and disclosure of personal information in accordance with this Policy (which may change from time to time) until you tell us otherwise by contacting the Privacy Officer.
What is Personal Information?
Personal Information is any information or an opinion about an identified individual or an individual who can be reasonably identified from the information or opinion. Information or an opinion may be Personal Information regardless of whether it is true.
What Personal Information do we collect and why do we need it?
We collect Personal Information to enable us to conduct various aspects of our business and to run our operations. We sometimes need to collect contact information and other Personal Information about customers, shareholders, suppliers, third party advisers, potential employees and other persons who deal with us.
The kinds of Personal Information that we collect and hold about you, and the purposes for which we may use your Personal Information, will depend on the circumstances and purposes of collection. For example, we use:
- customer information to provide products and services, for payment and credit control and to facilitate competitions and promotions;
- supplier information to initiate and facilitate transactions and reconcile accounts;
- shareholder/investor information to administer our share register and comply with our legal obligations;
- information concerning potential employees to assess their applications for employment.
Generally, we collect, hold and use your Personal Information so that we can:
(a) provide, offer or communicate with you about products and services, and manage our relationship with you;
(b) contact you, for example, to respond to your queries, feedback or complaints, or if we need to tell you something important;
(c) fulfil administrative functions associated with our business, such as order processing, billing, debt recovery, entering into contracts, managing relationships, planning, managing and monitoring our activities, products and services, training staff, contractors and other workers, risk management and management of legal liabilities and claims, obtaining advice from consultants and other professional advisers;
(d) comply with our legal obligations and assist government and law enforcement agencies or regulators;
(e) develop, improve and market our products and services; and
(f) any purposes for which it was requested and any secondary purposes to which you have consented or for which we are lawfully allowed to use your information.
In addition to the uses above, we may use your Personal Information for marketing purposes, to identify and tell you about other products or services that we think may be of interest to you. That may include marketing activities run in collaboration with other relevant businesses.
We will not use your Personal Information for marketing purposes if you ask us not to and if, at any time, you no longer wish to receive marketing material from us, please let us know. You can tell us using the opt out process described in the marketing material you receive or the contact details at the bottom of this policy, and your details will be removed from our marketing database.
We may use your Personal Information for any other purposes required or authorised by or under law, including purposes for which you have provided your consent. That consent may be written, verbal or implied from your conduct.
If we do not collect your Personal Information, we may not be able to provide you with the services or assistance you have requested or do business with you or the organisation with which you are connected.
We will only collect your sensitive Personal Information if you have consented to the collection and the information is reasonably necessary for, or directly related to, one of our functions or activities or we are otherwise legally permitted to collect the information.
We also collect certain technical information each time a person visits our website. Unless we suspect misuse of the website or illegal activity, this information is kept in a de-identified form and is not traceable to any individual.
How do we collect Personal Information?
We may collect your Personal Information in person, in writing, by telephone, through our website and by other electronic communication channels, and from publicly available sources of information. We collect this Personal Information through our staff and through our contracted agents.
Where reasonable and practicable, we will ask you for your Personal Information directly. However, we may need to collect Personal Information from others such as employers, business associates, bankers, credit reference agencies and referees. We will take reasonable steps to notify you if this is the case.
If you provide us with Personal Information about another person, please make sure that you tell them about this privacy policy.
Who will see or have access to your Personal Information?
Unless we are required to provide your Personal Information to others by law, by court order or to investigate suspected fraud or other unlawful activity, your Personal Information will generally only be seen or used by persons working in or for Ridley. These people will include our staff and contracted agents and service providers engaged to help us carry out our operations.
Some Personal Information may be stored and processed by service providers on servers located in countries outside Australia. Where this occurs, we will take reasonable steps to protect your information.
We may also disclose your Personal Information to third parties for purposes authorised by or under law, including purposes for which you have provided your consent. That consent may be written, verbal or may be reasonably inferred from your conduct or the circumstances in which you provided us with your information.
Where you have ordered goods or services from us that necessarily involve a third party contractor, such as a delivery contractor, you acknowledge that we will provide your Personal Information to the relevant third party and that third party may hold and use your information in accordance with its own privacy policy.
If the ownership or control of all or part of our business changes, we may transfer your Personal Information to the new owner.
How do we hold your Personal Information?
We may store your information in hardcopy and/or in electronic form.
We will take reasonable steps to protect the Personal Information we hold from misuse, interference and loss, and from unauthorised access, modification or disclosure.
We will take reasonable steps to de-identify or destroy Personal Information when it is no longer required for one of our business functions or activities or for legal requirements.
Collection of information via our website
On our website we provide a form for visitors to provide their Personal Information if they wish to contact us or to facilitate a purchase of our products and, on occasion, we may collect Personal Information in relation to promotional competitions and similar activities. We do not otherwise routinely collect Personal Information via our website.
Like most companies, our website does use “cookie” technology. When you visit our website a small packet of files, known as cookies, are written to your hard drive. We also use tools, such as Google Analytics. We may use cookies and data from analytics tools to log information about the use of our website. The type of information logged may include technical information, such as the type of browser, language, device and operating system used, and the date and time of the visit. We may also log the site from which you came to our site, the documents downloaded, the pages visited and the subsequent site visited.
Neither cookies nor the analytical tools used are able to read information from your hard drive. Although these tools do not personally identify website users, they do identify a user’s Internet Service Provider (ISP). You can configure your browser to reject some or all cookies, to notify you when a cookie is sent or to limit the information available to analytics tools. Please refer to your browser instructions to learn more about those functions. We may use persistent cookies (which remain on your computer even after you close your browser) to store information that may speed up your use of our website for any of your future visits. We may also use session cookies (which no longer remain after you end your browsing session) to help manage the display and presentation of information on the website. Please note that if you do configure your browser to reject our cookies, you may not be able to use the full functionality of the website.
What if you want to check or correct the Personal Information we hold about you?
Subject to some exceptions permitted by law, we will provide you with access to the Personal Information we hold about you if you request it in writing.
Generally, there is no charge for accessing your Personal Information, but if your request is particularly complex or requires detailed searching of our records, we may require that you pay our reasonable costs of providing access (such as photocopying costs or costs for time spent on collating large amounts of material). Any request for access should be made via the contact details provided below.
If you believe there are errors in our records about you, please let us know (using the detail below) and we will investigate and take reasonable steps to correct any inaccuracies.
Employee Records Exemption
Notwithstanding this Policy, we rely on the “employee records exemption” in the Act and any other applicable exemptions in the Act or other relevant legislation. The employee records exemption means that in many cases, we are not bound by the requirements of the Act in relation to personal information we hold about current or former employees (relating to their employment).
Further information and complaints
If you would like further information on our privacy policy, if you have any concerns over the protection of the Personal Information you have given to us or that we have collected from others, or if you have a complaint about the way we have handled a privacy issue, please contact our Privacy Officer:
Address: Privacy Officer, Ridley Corporation Limited, Level 4, 565 Bourke Street, VIC 3000
Phone: (03) 8624 6501 (and ask to speak to the Privacy Officer)
We will investigate any complaint and respond to you in writing. If you are not satisfied with our response, you can contact us to discuss your concerns further or contact the Office of the Australian Information Commissioner (OAIC) (www.oaic.gov.au) for guidance on alternative courses of action which may be available.
Changes to this policy
From time to time, we may change our policy on how we handle Personal Information or the types of Personal Information which we hold. Any changes to our policy will be published on our website. You may obtain a copy of our current policy from our website or by contacting us at the contact details above.
VERSION CONTROL
Last approved by the Board: 23 November 2022
Last reviewed by Management: 28 October 2022
