Asaleo Care Limited is committed to protecting your personal information in accordance with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (in Australia), the New Zealand Privacy Principles (NZPPs) in the Privacy Act 1993 (in New Zealand), and any other applicable privacy or health records laws.
Contact details for Asaleo Care's Privacy Officer
Telephone: +61 3 9258 0555
Asaleo Care Privacy Officer
PO Box 117
Box Hill Victoria 3128
1. What is "Personal Information"
1.1 "Personal information" is any information or opinion about an identified person, or a person who is reasonably identifiable, whether true or not and whether recorded in a material form or not.
1.2 In Australia "sensitive information" is a subset of personal information that is generally afforded a higher level of protection by privacy laws. It includes your health information as well as information about your racial or ethnic origin, political opinions, membership of political, professional or trade associations or trade unions, religious beliefs, sexual orientation or practices and criminal record. There is no equivalent of this definition in New Zealand legislation, although in general Asaleo Care would expect to take a similar approach to information of this type in New Zealand as it does in Australia.
2. What personal information do we collect?
2.1 Asaleo Care collects personal information (which may, because of the context or nature of the service or product, include health or other sensitive information) from its customers, potential customers, website users, contractors and job applicants and other individuals with whom we may interact. This information may include:
- your name, contact, delivery and company details;
- your credit card, banking and other payment details;
- details of the products or services that you have purchased;
- responses to or your participation in one of our surveys, promotions or competitions;
- information posted on our websites or provided through the social media platforms we use;
- records of our communications with you, including any complaints, requests or queries; and
- information provided by you and third parties when you apply for a job with Asaleo Care (depending on the role this may also include government related identifiers and criminal record information through police or Ministry of Justice checks).
2.2 We may collect this information when you:
- visit, register on or use one of our websites or social media pages;
- download and use one of our apps;
- purchase our products or use our services;
- submit a form requesting information on Asaleo Care, our brands, products or services;
- enter a competition or participate in a promotion run by or on behalf of Asaleo Care;
- complete a survey for Asaleo Care;
- submit a job application for a position with Asaleo Care; and/or
- contact us by telephone, email, mail, one of our websites or via our social media pages.
2.3 In some circumstances, Asaleo Care may also collect personal information about you from third parties if that is appropriate, for example, through recruitment consultants and employment referees and when we purchase mailing lists with your name and contact details from third parties for direct marketing purposes. Asaleo Care will have obtained your consent to collect this information from these third parties and/or these third parties will have obtained your consent to disclose this information to us and, where applicable, for us to use this information for the purpose of direct marketing to you. We may also collect your personal information from individuals acting on your behalf, such as a parent, guardian or other family member.
2.4 We may generally only collect your sensitive information such as your health information from you or third parties if we have your consent, which may be implied because of the circumstances in which you have chosen to provide this information to us.
2.5 Where practical and lawful, you can interact with Asaleo Care anonymously or using a pseudonym. However, in many instances we need to identify you in our interaction with you, for example, to enable us to provide you with products or services, respond to your enquiries or complaints, or assess your job application. If you do not provide us with all of the personal information we request, we may not be able to do these things.
3. Information collected via our apps or web-based platforms
3.1 Asaleo Care may collect personal information about you, including health information, either from you personally or from your health care provider, when you use one of our apps or web platforms. We will only use that health information to provide you and/or your health care provider with the relevant service. We will not use your health information for any marketing related purposes.
4. Information collected via our websites
4.1 Asaleo Care operates the following websites to which this policy applies:
- LoveLibra.com.au / .co.nz
- Tork.com.au / tork.co.nz
- TCMS-online.com / TCMSonline.com.au
- Beautyofnormal.com.au / .co.nz
- Iamfearless.com.au/ .co.nz
Click stream data
4.3 When you visit and browse one of our websites, Asaleo Care’s website host will collect personal information for statistical, reporting and maintenance purposes. This information may include:
- the number of users visiting this website and the number of pages viewed;
- the date, time and duration of a visit; and/or
- the path taken through this website.
Asaleo Care will not take any active steps to use this information to identify you. Asaleo Care’s website host uses this information to administer and improve the performance of our websites.
4.4 To be able to administer our websites in an efficient and secure manner, we collect and store IP addresses for a limited period of time. The IP address is a unique number which makes it possible to identify a visitor's connection to the internet and it is automatically reported by your web browser each time you view a website.
4.5 Cookies are small text files that are transferred to and stored on a user's computer by a website for the purpose of storing information about a user's identity, browser type or website visiting and usage patterns to improve functionality. If you access one of our websites, a cookie is downloaded onto your computer when you first log onto the website. You can accept or reject cookies by changing the relevant settings in your browser. However, if you decline cookies, you may be unable to access certain parts or features of our websites.
4.6 Web beacons are images that originate from a third party site to track visitor activities. Asaleo Care currently use web beacons to track the visiting patterns of individuals accessing our websites.
5. Our social media pages: platform providers
Asaleo Care uses a number of social media platforms to interact with our customers, including Facebook, YouTube and Pinterest. When you visit one of our social media pages, the platform providers may also collect your personal information. Asaleo Care does not have any control over these platform providers. How they collect and handle your personal information will be governed by their own terms and conditions, including their privacy policies. Please refer to their websites for more information.
6. What Asaleo Care uses and discloses your personal information for
6.1 Asaleo Care uses and discloses the information it collects about you generally for the following purposes:
- to provide you with information, products or services you have requested;
- to personalise, customise and improve your experience with our applications and websites;
- to help Asaleo Care research the needs of its users and customers in order to improve and market its products, services and make offers according to their needs and interests;
- to process your job application;
- to communicate with you by various means;
- to comply with our legal obligations; and
- for any other purposes related to the above purposes which you would reasonably expect, which we inform you of when we collect your personal information, or which we otherwise obtain your consent for.
7. Who we disclose your personal information to
7.1 Asaleo Care may disclose the information about users of our websites to our related companies (including related companies located overseas), to third parties that provide us with services, fulfilment houses and distributors, and other third parties such as your employment referees.
7.2 Asaleo Care may also disclose your personal information to our website host or software application provider in certain limited circumstances, for example, when an application or website experiences a technical problem or to ensure that they operate in an effective and secure manner.
8. Direct marketing and opting out
Asaleo Care may use and disclose your personal information to tell you via various means (eg email, telephone, mail) about Asaleo Care or about its services and products. If you do not wish to receive direct marketing communications from us (or sent to you on our behalf) by a particular method or at all, you can contact our Privacy Officer on the details at the top of this policy at any stage and we will remove your name from our marketing lists as soon as it is practicable for us to do so.
9. Storage and security of personal information held by Asaleo Care
9.1 Asaleo Care takes reasonable steps to keep your personal information secure and to protect it from unauthorised access, modification and disclosure and from misuse, interference and loss. Any personal information that is collected through one of our websites or which is held on Asaleo Care's computer systems is protected by technical and procedural safeguards, including (for example) encryption protocols, firewalls, information security audit programs, intrusion prevention and detection systems and incident management procedures.
9.3 When we decide that we have no further need or legal obligation to keep your personal information we will take reasonable steps to either destroy the information or to ensure it is de-identified.
10. Accessing your personal information held by Asaleo Care
10.1 You are entitled to access personal information that Asaleo Care holds about you by contacting our Privacy Officer on the details at the top of this policy. If you request access to your personal information, we will need to verify your identity and will then grant your request within a reasonable period, except in certain circumstances provided for in the APPs and NZPPs, such as where providing you with access would unreasonably impact upon the privacy of others (or would involve the unwarranted disclosure of another individual’s affairs). If Asaleo Care refuses your access request, we will give you written notice of our decision, including our reasons and how to complain if you are not satisfied with our decision.
10.2 We may need to charge you for our reasonable costs of providing access.
11. Quality and correction of your personal information
11.1 Asaleo Care takes reasonable steps to ensure that the personal information it collects about you is accurate, up-to-date and complete and also, when using and disclosing it, that it is relevant for the purposes for which it has been collected. If we are satisfied that any of the information should be corrected, having regard to the purposes for which it is being held, Asaleo Care will also take reasonable steps to correct the information.
11.2 If you believe that the personal information which Asaleo Care holds about you is inaccurate, incomplete, out-of-date, irrelevant or misleading, please let us know by contacting our Privacy Officer on the details at the top of this policy or, where applicable, by changing that information via our websites through any logins you have. Asaleo Care welcomes your assistance to keep our records up-to-date so please let us know if your details change.
11.3 If we do not agree that your information needs correcting in response to your correction request, we will give you written notice of our decision and reasons and tell you how to complain if you are not satisfied with our decision. In this type of situation you can also ask us to associate a statement with the personal information which explains that you believe it is incorrect.
11.4 You will not be charged for making a correction request or requesting us to associate a statement with your information.
12. Privacy questions, problems or complaints
12.2 We will investigate and respond to your complaint within a reasonable period and generally within 30 days. We may need to request more information from you and we may propose a resolution to your complaint.
12.3 If you are not satisfied that Asaleo Care has resolved your complaint, in Australia you can contact the Office of the Australian Information Commissioner (OAIC), or in New Zealand you can contact the Office of the Privacy Commissioner (OPC). To raise a query concerning your privacy rights, or to lodge a complaint with either the OAIC or OPC about how we have handled your personal information, contact:
12.4 The OAIC and OPC have the power to investigate your complaint and also to take certain other actions.
Approved by: Executive General Manager, Human Resources
Date: 20 July 2015