AS AT APRIL 2014
Spiral Foods Pty Ltd (ACN 006 292 780) (”Spiral Foods”) is committed to protecting and respecting your privacy, and takes its obligations under the Privacy Act 1988 (Cth) seriously. As a result, Spiral Foods has implemented practices, procedures and systems to comply with its legal obligations and, in particular, to:
By “personal information”, we mean information or an opinion about an identified individual, or about an individual who is reasonably identifiable from the information. Those individuals include customers, potential customers, agents, suppliers, distributors, contractors and other business associates.
What personal information does Spiral Foods collect and hold?
The kinds of personal information we may collect and hold are:
Also, when you visit our site, we may collect information about your computer, including (where available) your IP address, operating system and browser type.
We do not keep files containing all of the above information on all people who contact us, or with whom we deal. In many cases, we may have only one or two pieces of data relating to any particular person.
Why does Spiral Foods collect and hold personal information?
We collect and hold personal information for a variety of purposes – and different kinds of personal information are used for different purposes.
In each case, however, the personal information we collect and hold is reasonably necessary for our functions and activities, including so we can provide you with services you would expect from us. These purposes are:
From time to time, when collecting information from you, we may also ask you to “opt-in” to consent to us using or disclosing your personal information other than in accordance with this policy or any applicable law. As part of our commitment to protecting your privacy, however, you will also be given the opportunity to “opt out” from receiving communications from us or from third parties that send communications to you in accordance with this policy or in accordance with any additional consent you give, and we will comply with your decision. (You will be able to “opt out”, for example, by clicking on an “unsubscribe” link at the end of an email, or by contacting our Privacy Officer.)
How does Spiral Foods get the personal information it collects and holds?
Spiral Foods only collects personal information by fair and lawful means, when people:
We prefer to obtain any personal information we collect directly from you. In some cases, however, it may be unreasonable or impracticable to obtain personal information directly, and we may obtain that information from someone else. Spiral Foods does not, however, purchase mailing lists. If you are concerned about what personal information we may hold about you, please see below for information on how you can access and (if necessary) correct that information.
Can I interact with Spiral Foods anonymously or under a pseudonym?
In many cases, you will need to provide your real name when interacting with us. This will particularly be the case if you are (for example) purchasing an item or claiming a prize in a competition.
You may however – wherever lawful and practicable – use a pseudonym (or simply not identify yourself) when dealing with us. For example, if you have a complaint or concern about our site, or a general question about any of our products or services, you are welcome to contact us without identifying yourself. In some cases, however, if you do not provide us with information, we may not be able to provide you with our products or services, or we may not otherwise be able to respond adequately to you.
For clarification on when you must identify yourself, please contact our Privacy Officer. (You may use a pseudonym – or simply not identify yourself – when making such an enquiry.)
Who has access to my personal information?
Generally, only our staff will access your personal information, and then only on a “need to know” basis.
We may, however, also disclose your personal information:
Please also note that the transmission of information (including over the internet and by post) is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information – particularly while it is being transmitted to us – so any transmission is at your own risk and we cannot accept responsibility for misuse or loss of, or unauthorised access to, your personal information where the security of information is not within our control.
If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.
How can I access (and, if necessary, correct) personal information that Spiral Foods collects and holds about me?
If you want to review (and, if necessary, correct) personal information that Spiral Foods may have collected and holds on you, please contact our Privacy Officer.
We will respond to your requests to access and to correct your personal information as soon as possible (but in any case within a reasonable period).
How can I complain about Spiral Foods if it breaches any of applicable privacy principles or any registered code that binds it?
Contact our Privacy Officer if you have any complaints about breaches by Spiral Foods of any applicable privacy principles or of any registered code that binds it.
How will Spiral Foods deal with complaints I might have about breaches of applicable privacy legislation or any relevant registered code?
We will treat any complaint about a breach of privacy legislation or any relevant registered code seriously, and will investigate any breach of which we become aware – including how it occurred and how best to prevent such a breach occurring again.
What steps does Spiral Foods take to secure personal information?
We take reasonable steps to ensure that your personal information is treated securely and in accordance with this policy and is not subject to misuse, interference or loss, or unauthorised access, modification or disclosure. For example, apart from using secure servers, we implement firewalls and password access and, where relevant, we impose limits on who can access personal information.
If we have given you (or where you have chosen) a password which enables you to access our services or parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Does Spiral Foods disclose personal information to people or organisations outside Australia?
We will not, however, transfer your personal information to any country that is not subject to a comparable privacy scheme unless the organisation to which we disclose that information implements privacy policies at least comparable to the obligations that apply in Australia.
Who do I contact at Spiral Foods about privacy issues?
Contact our Privacy Officer on webadmin [at] spiralfoods [dot] com [dot] au or on +61 2 8231 4404 if you have any concerns about privacy issues, including how Spiral Foods is dealing with or holding your personal information.
Please also contact our Privacy Officer if you want to review and/or correct any personal information we hold about you, or if you receive communications purporting to be connected with Spiral Foods or our services that you believe have been sent other than in accordance with this policy or in breach of any law.