THE a2 MILK COMPANY LIMITED
The a2 Milk Company Limited (ABN 97 769 415 292) PO Box 1564, North Sydney NSW 2059 (‘a2MC’, ‘we’, ‘us’ and ‘our’) recognises the importance of your privacy. We abide by the Privacy Act 1988 (Cth) (the ‘Privacy Act’), including the 13 Australian Privacy Principles in the Privacy Act.
- the way we collect, store, use, disclose and otherwise handle (together, ‘process’) your personal information (as defined under the Privacy Act);
- how we aim to protect the privacy of your personal information; and
- your rights in relation to your personal information.
1) Information we collect
- From time to time, we may collect your personal information such as your name, address, phone number, email address, age, date of birth, gender, bank account details, your authorised signatories, tax file number (TFN) and identity documents for verification purposes. In some instances we may also collect other information such as device information, location information, log-on information, and other information you might provide when enquiring about, or purchasing our products and services, investing in a2MC (including any employee incentive plan), or through the course of other interactions you may have with a2MC or our related bodies corporate.
- We may collect your personal information:
- when you give it to us directly;
- when you purchase and use our products and services;
- when you purchase or acquire security holdings including through any employee incentive plan;
- when your financial advisor, broker or authorised representative communicates with us on your behalf; and
- when you knowingly give us information by contacting us via our website, email or telephone.
- We use social media platforms and other interactive online forums through which we communicate, promote, and/or provide our goods and services. We may process personal information you disclose through such forums. However, such information may also be read, collected and used by other users whose actions we cannot control and for which we take no responsibility.
2) Why we collect and how we use information
2.1 We collect your personal information where it is reasonably necessary for the purposes of carrying out our business and operations, including in order to:
(a) respond to your queries;
(b) provide and improve our products and services;
(c) use the information for our internal business and marketing purposes and those of our related bodies corporate;
(d) conduct any promotions you participate in;
(e) keep a record of our dealings with you;
(f) develop a data profile to enable us to tailor our services to you;
(g) create aggregate anonymised data (which does not identify you) to provide to our related bodies corporate and potential stakeholders;
(h) inform you of products and services that may be of interest to you;
(i) comply with our record-keeping, reporting, audit and tax obligations;
(j) for quality assurance and training purposes;
(k) to prevent fraud;
(l) to administer investments in a2MC (including any employee incentive plans), maintain the register of securities, facilitate payments and other associated corporate actions and communications; and
(m) to prepare and distribute statements regarding your security holdings and information relating to your investments in a2MC (including any employee incentive plans).
In the event you do not wish to receive such communications, you may opt-out by contacting us via our contact details in section 5.2 or through the opt-out mechanism contained in the communication.
2.2 Our ability to provide you with products, services, information and administer any investment you make in a2MC may be adversely affected if you choose not to provide us with your personal information (e.g. we may not be able to respond to your request, provide you with specific products or services or administer your investment). Where possible (and to the extent permitted by law), you may have the option of not identifying yourself or of using a pseudonym.
2.3 By giving us your personal information, you consent to your personal information being processed for the purposes described in section 2.1 above.
2.4 We will process your personal information only:
(a) if you have provided consent;
(b) for the purpose for which it was collected, or purposes reasonably related to that purpose, and even then, only if you would reasonably expect us to use it for those purposes; and
(c) in law enforcement, public health, public safety or regulatory circumstances, where authorised or required by law.
3) How we disclose your information
- 1 We will not disclose your personal information, except:
(a) in law enforcement, public health, public safety or regulatory circumstances, where permitted or required by law;
(c) to our related bodies corporate for the purposes listed above who will treat your personal information in accordance with the Privacy Act and their respective privacy policies; or
(d) with your consent or when your consent can be reasonably inferred from the circumstances (including to your financial advisors or representative where relevant authorisations are provided).
3.2 Some of the recipients we disclose your personal information to may be located in other countries, including Australia, New Zealand, China, the United Kingdom, the United States, and any other country in which our related bodies corporates do business. Before disclosing any personal information to an overseas recipient, we take reasonable steps to ensure that recipient complies with the Privacy Act or is bound by a substantially similar privacy scheme. However, please note we cannot guarantee that all overseas recipients will comply with Australian law.
4) Security and confidentiality
4.1 We take all reasonable steps to ensure that all personal information we process is accurate, complete and up-to-date.
4.2 We take all reasonable steps, including by maintaining organisational and technical measures, to protect your personal information from misuse, interference and loss and from unauthorised access, modification and disclosure.
4.4 We will destroy or de-identify your personal information in a secure manner if we no longer need it for the purposes for which it was collected, unless we are otherwise required or authorised by law to retain the information.
5) Your rights
5.1 Upon your request, we will inform you of what personal information we store about you and you may request the deletion or correction of that information.
5.2 If you:
(a) wish to access, correct, remove or modify your personal information;
(b) consider that there may have been a breach of your privacy;
(c) would like to opt-out of receiving promotional communications from us; or
(d) are unhappy with any aspect of the way we process your personal information,
please contact our Privacy Officer by email at firstname.lastname@example.org, or in writing to PO Box 1564, North Sydney NSW 2059.
5.3 When contacting the Privacy Officer, you will be required to provide proof of your identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected. We may charge you a reasonable administration fee reflecting the costs to us for providing access in accordance with your request. Where you have raised a concern or complaint regarding your privacy, we will endeavour to respond within 30 days of receiving your request. If we refuse to provide access to, or allow correction of your personal information, we will notify you in writing setting out a written explanation of the reasons for the refusal (unless unreasonable to do so) and inform you of the mechanisms to complain about the refusal.
5.4 In the event you are dissatisfied with the outcome of your request, or if you still have any concerns about your privacy, you may contact the Office of the Australian Information Commissioner .