At TRILOGY™ we recognise that the privacy of your personal information is important to you. TRILOGY™ is a related body corporate of Real Pet Food Company ACN 618 564 257. This policy sets out how the Real Pet Food Company and its related bodies corporate in Australia (together referred to as RPFC) collect, use, disclose and secure your personal information. It also sets out your rights to access and correct your personal information.
At RPFC, we take our privacy obligations seriously and are committed to ensuring that we handle personal information in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Privacy Act).
This policy covers all of our activities, including the operation of this website and our other websites and our social media accounts including any RPFC Facebook pages, Instagram pages or other social media accounts (RPFC Social Media).
2. WHAT IS PERSONAL INFORMATION?
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
3. COLLECTION OF YOUR PERSONAL INFORMATION
We collect personal information relating to our customers and suppliers for our business purposes, which are detailed generally on our websites.
RPFC may collect personal information including (but not limited to) the following: your title, name, job title, address, email address, telephone numbers, birthdate, occupation, purchase preferences and other information reasonably necessary for us to provide our services to you or which is otherwise reasonably necessary for us to carry out our functions and activities.
RPFC generally collects personal information directly from you when you communicate with us. For example, when we receive an email from you, we are collecting your personal information. However, there may be circumstances where we collect information about you from third parties or via other methods. For example, we may receive personal information about you from a business that we deal with in the context of providing services to them. RPFC may also collect information that individuals publish on social and other media, for example when you engage with RPFC Social Media.
If you send an email to any of our staff, we will record your email address. We will use your email address for the purpose for which it was provided, and for any other purpose for which you would reasonably expect us to use it. In particular, we may include your email address on our mailing list. We will not use your email address for any other purpose without your express consent.
If we require you to provide personal information when you complete an electronic form on the websites, we will collect that information to assist us in responding to your request.
RPFC will not collect personal information in a way that would be unlawful or where such information is unnecessary or unrelated to our functions, activities or business.
4. USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
We use the personal information we collect for our business purposes (including as described on our websites), to fulfil our legal obligations and to keep our suppliers and customers informed of our activities and the services that we provide. Our business purposes are generally to provide products and related services to our customers, to administer our relationships with our customers and potential customers, and with suppliers, corporate partners and others, and to operate our websites and the RPFC Social Media.
RPFC will only use or disclose your personal information for the purpose for which it was collected, for another, related purpose for which you would reasonably expect us to use it, or for any other purpose with your consent (whether express or implied). For example, we may use your personal information to analyse data obtained on our websites to determine the websites’ effectiveness and to modify it to improve its functionality and the service it provides to suppliers and customers.
RPFC may from time to time send you marketing material that we consider may be useful to you, including information about our business and activities. If you do not wish to receive this information, you can let us know and we will not send it to you. You may choose to restrict the collection or use of your personal information in the following ways:
(a) whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do or do not want the information to be used for direct marketing purposes; and
(b) if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by emailing us at email@example.com.
We will not sell, distribute or lease your personal information to third parties for marketing purposes unless we have your permission. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
Depending on the purpose of collection, your personal information may be disclosed to:
(c) external service providers (on a confidential basis and in circumstances where those service providers may only use your information for the purpose of RPFC’s activities), including specialist advisers that RPFC have engaged to provide us with legal, accounting, administrative, financial, insurance, research, marketing or other services; and
(d) any other person authorised and specified by you.
In addition, RPFC may use or disclose your personal information:
(a) where required or authorised by or under an Australian law (including the Privacy Act) or an order of a court or tribunal;
(b) in accordance with the Privacy Act, including where we hold a reasonable belief that the use or disclosure is required for certain enforcement or health and safety purposes, or that use or disclosure is necessary in relation to certain suspected unlawful activity or misconduct; or
(c) if reasonably necessary for the establishment, exercise or defence of a legal or equitable claim or for the purposes of confidential alternative dispute resolution.
RPFC may at other times notify you about our disclosure practices in respect of specific services that we provide in relation to our activities.
4.2 You may, in some circumstances, have the option of not identifying yourself or using a pseudonym when you deal with RPFC, such as if you are making a general enquiry about our services. However, if you choose not to provide your personal information we may not be able to provide you with a service you request.
5. COOKIES AND ANALYTICS
A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs and preferences by collecting and remembering information about you.
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie does not give us access to your computer or any information about you, other than the data you provide to us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. This may, however, prevent you from using the full capabilities of the website.
We may also use third-party analytics tools, including those provided by Facebook and Google to improve your experience and to provide us with information about how you use our website. These analytics tools may place or access cookies on your device, which allow them to monitor your web browsing activity. More information regarding the services provided by Facebook and Google, including their privacy policies and information about opting out is available on their websites:
6. STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
RPFC may hold your personal information in a number of different formats, including software programs (located both onsite and offsite, including in the cloud), databases, filing systems and in offsite backup storage. Personal information held by RPFC may be stored in email accounts that are accessible through mobile devices.
If reasonably required for the purpose for which you have disclosed your personal information, we may send your personal information overseas, for example to an associated entity, or to other companies acting on Real Pet Food’s behalf in other countries. Such countries include, without limitation, New Zealand, Canada, the United States, United Kingdom, Greater China, and countries within South East Asia. Your personal information is more likely to be disclosed overseas if you are a customer residing outside of Australia.
RPFC is committed to ensuring that the information you provide is secure and we take all reasonable steps to protect your personal information from loss, unauthorised access, modification, disclosure or misuse. However, we cannot ensure the security of any information that you transmit to us over the internet and you do so at your own risk.
7. SENSITIVE INFORMATION
RPFC does not generally collect any sensitive information such as information relating to your racial or ethnic origin, membership of political bodies, religion or trade unions, sexual preferences or activities, criminal record, state of health or medical history. If RPFC holds any sensitive information about you that information will only be used and disclosed by RPFC for the purpose for which it was provided by you, or otherwise in accordance with the Privacy Act.
8. ACCESS TO YOUR PERSONAL INFORMATION
At any time, you may request access to personal information about you that RPFC holds by contacting our Privacy Officer using the details below. RPFC will process your request within a reasonable time. We will generally give you access to your personal information, and if we do not we will take reasonable steps to meet your needs (for example by letting you know generally the kind of information we hold about you). We will also give you the reasons why your request has been refused and advise you on avenues to make a complaint.
9. CORRECTION OF YOUR PERSONAL INFORMATION
You should promptly notify RPFC if there are any changes to your personal information. You may ask RPFC at any time to correct personal information we hold about you by contacting our Privacy Officer.
Please notify our Privacy Officer if you have any complaints relating to RPFC’s handling of your personal information. RPFC will investigate all complaints and respond to you within a reasonable time and in accordance with its legal obligations.
11. CHANGES TO THIS POLICY
This policy was last updated on 17th February 2020.
RPFC may amend this policy by publishing a revised policy on our websites. Any changes will be effective as of the date they are published.
12. LINKS TO OTHER WEBSITES
13. CONTACT DETAILS AND FURTHER INFORMATION
If you have any questions in relation to privacy or you wish to access or correct your personal information, please contact us directly by email at firstname.lastname@example.org, or write to us at Privacy Queries, Real Pet Food Company, 39 Albany St, Crows Nest, NSW, 2065, Australia.
For further information about privacy issues, see the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.