1. Your rights in relation to privacy
Almo Milk Pty Ltd ACN 604 082 117 (Almo Milk) understands the importance of protecting the privacy of an individual’s personal information. This policy sets out how Almo Milk aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Almo Milk and the way Almo Milk collects, holds, uses and discloses your personal information.
In handling your personal information, Almo Milk complies with the Privacy Act 1988 (Cth) (Privacy Act), the 13 Australian Privacy Principles in the Privacy Act and all relevant Australian privacy laws.
This policy may be updated from time to time.
2. What kinds of personal information does Almo Milk collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of its products and/or services, Almo Milk may collect your personal information.
Generally, the kinds of personal information Almo Milk collects are:
- contact and identification information such as your name, address, telephone number and email address;
- where you are acting on behalf of another entity (whether as an employee, director or other representative), details of that entity and your relationship with it;
- banking details and financial information as required for Almo Milk’s functions and activities, for example, in respect of the sale of products to customers and engagement of contractors by Almo Milk;
- sensitive information, including health information, where you are applying for a position with Almo Milk and the information is relevant to the recruitment process through which you must progress; and
- other information required for Almo Milk’s functions and activities.
In some circumstances Almo Milk may also hold other personal information provided by you.
3. How does Almo Milk collect personal information?
Generally, Almo Milk collects your personal information directly from you, through the completion of an online form, an interaction or exchange in person or by way of telephone, email, post or through the use of the Almo Milk website.
There may be occasions when Almo Milk collects your personal information from other sources such as from:
- an entity you represent (including but not limited to your employer or a company of which you are a director), where necessary for Almo Milk to provide its products or services to that entity through you or where necessary for that entity to supply products or services to Almo Milk;
- an information services provider;
- a publicly maintained record or other publicly available sources of information including social media and similar websites, such as Instagram, Facebook and LinkedIn;
- trade references;
- if for recruitment purposes, an external recruitment, labour hire, or background screening services provider or third parties with whom you have previously worked;
- a government agency, such as Austrade.
Generally, Almo Milk will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.
4. Why does Almo Milk need your personal information?
Almo Milk collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:
- providing the products you have requested, ordered or purchased from Almo Milk including:
- to process transactions relating to products you purchase;
- for invoicing purposes;
- to deliver the products to you or the organisation you represent, including to enable export permits to be obtained for international transactions;
- to respond to any inquiries, feedback or complaints made by you;
- providing Almo Milk’s services (including contracting out manufacturing facilities to third parties) to you or the organisation you represent and all associated purposes;
- enabling Almo Milk to promote its products and services to you;
- assisting Almo Milk to improve its products and services;
- processing and assessing employment applications for current and future positions;
- accounting, billing and other internal administrative purposes;
- understanding a supplier’s capacity to service Almo Milk’s needs;
- emailing newsletter registration;
- handling supplier enquiries;
- gaining an understanding of whether suppliers, and other organisations Almo Milk partners with:
- can effectively manage Almo Milk’s account;
- have sufficient accreditation levels to be an effective trade partner with Almo Milk;
- have appropriate levels of service;
- pose risks to Almo Milk based on the organisation’s past performance, management team, manufacturing machinery, and internal processes;
- otherwise managing Almo Milk’s internal business operations and processes; and
- any other legal requirements.
Almo Milk may also use your personal information for purposes related to the above purposes and for which you would reasonably expect Almo Milk to do so in the circumstances, or where you have consented, or the use is otherwise in accordance with law.
The principal legal grounds for Almo Milk’s use and disclosure of your personal information are as follows:
- Consent: where you have consented to Almo Milk’s use or disclosure of your personal information.
- Contract performance: where Almo Milk is required to collect and handle your personal information in order to provide you (or the organisation you represent) with the products and services that Almo Milk has contractually agreed to provide to you, or where Almo Milk is required to collect and handle your personal information to give effect to supplier arrangements.
- Legal obligation: where Almo Milk needs to use or disclose your personal information to comply with its legal obligations.
Where personal information is used or disclosed, Almo Milk takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Almo Milk. However, without certain information from you, Almo Milk may not be able to provide its products and/or services to you.
5. To whom does Almo Milk disclose your personal information?
Almo Milk discloses your personal information for the purpose for which Almo Milk collects it. That is, generally, Almo Milk will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to:
- third parties engaged to perform administrative or other business management functions, including debtor management, delivery and courier companies, shipping agents, mailing houses, financial institutions, mercantile agents, and web-hosting organisations;
- people or entities considering acquiring an interest in Almo Milk’s enterprise or assets;
- Almo Milk’s professional advisors, agents, contractors, consultants and related bodies corporate;
- insurance providers;
- recruitment and labour hire agencies (as required); and
- regulatory bodies.
Almo Milk’s disclosures of your personal information to third parties are on a confidential basis and/or otherwise in accordance with law. Almo Milk may also disclose your personal information with your consent or if disclosure is required or authorised by law.
6. Overseas disclosures
Almo Milk may disclose personal information to overseas recipients in order to provide its products and/or services and for administrative, data storage or other business management purposes.
Recipients of such disclosures are located in European Union and may also be located in the United States.
Overseas recipients may have different privacy and data protection standards. However, before disclosing any personal information to an overseas recipient, Almo Milk will take steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law.
If you have any queries or objections to such disclosures, please contact Almo Milk’s Privacy Compliance Officer on the details set out in paragraph 12.
7. Direct marketing
Almo Milk may use and disclose your personal information in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting Almo Milk via the contact details set out in paragraph 12 or through any opt-out mechanism contained in a marketing communication to you.
8. Security of your personal information
Almo Milk takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference, and loss and from unauthorised access, modification, or disclosure. Almo Milk holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.
Almo Milk will destroy or de-identify personal information in circumstances where it is no longer required, unless Almo Milk is otherwise required or authorised by law to retain the information.
9. Can you access and correct the personal information that Almo Milk holds about you?
Almo Milk takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your personal information that is collected and held by Almo Milk. If at any time you would like to access or correct the personal information that Almo Milk holds about you, or you would like more information on Almo Milk’s approach to privacy, please contact Almo Milk’s Privacy Compliance Officer on the details set out in paragraph 12 below.
Almo Milk will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
- you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
- Almo Milk requests that you be reasonably specific about the information you require; and
- Almo Milk may charge you a reasonable administration fee, which reflects the cost to Almo Milk for providing access in accordance with your request.
Almo Milk will endeavour to respond to your request to access or correct your personal information within 30 days from your request.
Almo Milk’s website may, from time to time, contain links to the websites of other organisations which may be of interest to you. Such links are provided as a convenience to you and should not in any way be interpreted as an endorsement of any company, content or product that may be linked. Any access to a third party website that is linked to Almo Milk’s website is at your own risk and Almo Milk has no control over and is not responsible for the accuracy, validity or ownership of any content of a linked site and the privacy practices of those linked websites. You should check those websites for their respective Privacy Policies.
Almo Milk’s website uses ‘cookies’ which are small pieces of information sent from the website and stored by your browser on your computer’s hard drive. Cookies that Almo Milk uses enable its systems to provide features of its services and allow you to visit its website without re-entering your username and/or password, personalize and improve your experience, and to improve the functionality and user-friendliness of its services and monitor how its website is used through your computer.
This information is used by Almo Milk to improve and tailor its website functionality and better understand how you interact with Almo Milk’s services and to monitor aggregate usage and web traffic routing on its website. You can modify your browser setting by editing your browser options to reject Almo Milk’s cookies or to prompt you before accepting a cookie. However, if a browser does not accept cookies or if you reject a cookie, some portions of Almo Milk’s online services may not function properly.
12. How to contact us
For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications, please contact Almo Milk’s Privacy Compliance Officer at:
Post: Level 4, 80 Market Street
South Melbourne Victoria 3205
13. Privacy complaints
Please direct all privacy complaints to Almo Milk’s Privacy Compliance Officer. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and Almo Milk.
Almo Milk’s Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.