Church & Dwight (Australia) Pty Ltd and its associated companies (C&D) acknowledges and respects the privacy of individuals. This Policy explains how we collect, use, disclose, retain and manage your personal information (Personal Information) in the course of our business. C&D is committed to complying with the Privacy Act 1988 (Cth) (Privacy Act).
You are not obligated to provide your Personal Information to us, however, if you do not provide us with the Personal Information we require, or where Personal Information provided is inaccurate or irrelevant, we may not be able to engage with you, may not be able to fulfil your orders (where C&D allows you to place orders) or may be limited in our ability to engage with you and provide you access to our services or products.
Collection of your Personal Information
Personal Information is information or an opinion about an identified, or reasonably identifiable, individual.
C&D engages with various individuals, including but not limited to customers, visitors of the Websites and employees. During the provision of C&D’s services, the types of Personal Information that C&D collects will depend on the service requested by you or orders placed by you. Generally, the kinds of Personal Information C&D collects include:
- contact and identification details (e.g. name, addresses, email address and phone number);
- gender and date of birth;
- financial information (e.g. credit card details); and
- other information relevant in the circumstances.
C&D collects your Personal Information in various ways including when you:
- visit the Websites (or any application managed by us);
- place orders for any products on the Toppik Website;
- create a customer account on the Toppik Website;
- interact with our advertisements;
- register to receive marketing communications;
- interact or follow our social media pages or profiles;
- enter into a competition or promotion through any medium;
- participate in a survey or other market research activities;
- request information from us or submit any feedback or query;
- submit job applications or other forms; and
- otherwise provide us with Personal Information in person or via telephone, email, fax, post or other means.
We will, in most cases, collect Personal Information directly from you through written and verbal communication. There may be other occasions when we collect your Personal Information from other sources such as internet service providers, publicly maintained records, including records publicly available through social media, or other third parties. Generally, we will only collect your Personal Information from sources other than you if it is unreasonable or impracticable to collect your Personal Information from you, or if those sources are authorised to do so.
Sensitive information is Personal Information about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional/trade association or trade union, sexual preferences or practices, criminal record, and health or genetic information. It is not our general practice to collect sensitive information unless you have consented or the collection is required under law or for the establishment, exercise or defence of a legal or equitable claim.
Each time you visit the Websites, our server passively collects certain information using various technologies such as cookies, internet tags, web beacons, and navigational data collection methods (log files, server logs, clickstream). This passive information is collected for statistical and marketing purposes, and to help us improve our services. This information can include the type of browser and system you are using, whether you have interacted with any advertisements or links, the address of the Websites you have come from and move to after your visit, the date and time of your visit and your server’s Internet Protocol (IP) address. You can set your browser to accept or reject all cookies, or to notify you whenever cookies are offered so that you can decide each time whether to accept them. Should you reject all cookies, your ability to use the Websites may be limited as certain features may not function correctly.
Use and Disclosure of Your Personal Information
We use your Personal Information for the purposes for which it is provided to us, other related purposes and as permitted or required by law. Generally, we will collect, use and hold your Personal Information if it is reasonably necessary for or directly related to the performance of our functions and for the purposes of:
- confirming your identity;
- facilitating payment for our services;
- fulfilling your orders for our products;
- providing you with access to and maintaining your customer account on the Toppik Website;
- communicating with you;
- monitoring, auditing and evaluating our products and services;
- providing you with marketing information about other products or services that we, our related entities and other organisations that we have affiliations with, offer that may be of interest to you;
- facilitating our internal business operations (including the management and improvement of services, analysing future client needs, modelling data, maintaining our relationship with you, data testing and security);
- complying with any legal or regulatory requirements;
- dealing with any complaints or enquiries;
- assessing your application (i.e. employment);
- informing you of future activities or events and to facilitate improvements to the services provided to you;
- identifying users to prepare customised web pages; and
- any other purposes where consent has been provided.
For any of the above purposes we may contact you by electronic or other means.
Personal Information you provide is considered a company asset and may be included among transferred assets if we merge, combine or divest part of our business unless prohibited from doing so by law.
Generally, the particular purpose for which Personal Information is collected is either specified or reasonably apparent at the time the Personal Information is collected.
Generally, we will only disclose your Personal Information for the purposes listed above. This may include disclosing your Personal Information to:
- our related entities to facilitate our and their internal business processes;
- third party service providers, who assist us in operating our business (including delivery providers, payment processing providers, professional advisors, financial advisors and dealers, and technology service providers); C&D’s contractors and suppliers, including IT contractors and database designers;
- any other third parties engaged to perform functions or activities on our behalf, including direct marketing;
- any other entity, with your consent, or to whom disclosure is required or authorised by law; and
- any other third parties engaged to perform administrative or other services.
This disclosure is done on a confidential basis or otherwise in accordance with the law. If we engage a third party contractor to perform services which involves handling your Personal Information, the contractor will be subject to the same privacy obligations as we are to protect your Personal Information.
However, you should note that other third parties may collect, hold, use and disclose your Personal Information in accordance with their own privacy policies and procedures and these may be different from our own.
We may disclose your Personal Information to our related entities in the United States of America and the United Kingdom. Our third party services providers may also disclose your Personal Information to overseas recipients. In circumstances where the provision of your Personal Information to an overseas recipient may be deemed use rather than disclosure, we will instead comply with our use policy as outlined above.
We may collect, hold, 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 us via the contact details set out below or through any opt-out mechanism contained in a marketing communication to you.
We do not provide your Personal Information to other organisations for the purposes of direct marketing.
C&D stores and holds Personal Information electronically and/or in hard copy. We will take reasonable steps to store and hold Personal Information in a secure and restricted manner and to protect Personal Information from misuse, loss and unauthorised access, modification or disclosure. Access to your Personal Information is limited to those individuals who require such access in order to perform their duties and responsibilities. Any Personal Information held by a third party storage provider is done so under a contractual obligation of confidentiality and non-disclosure.
While we have implemented a number of protection mechanisms, you should be vigilant and note that there are inherent risks associated with transmitting Personal Information via the internet.
This means we cannot guarantee that data transmission will be 100% secure or safe from attack from unauthorised intruders and no data protection or security measure is completely secure, particularly in relation to online transmissions. You must take care to ensure you protect your Personal Information and you must notify us as soon as possible after you become aware of any security breaches.
Your Personal Information, where not stored electronically, is stored in our secure office premises with restricted access or with an offsite secure storage facility. If we no longer require the use of your Personal Information, we will take reasonable steps to destroy or permanently de-identify it.
Access and Accuracy of Your Personal Information
We will take reasonable steps to ensure that the Personal Information we collect is accurate, up to date and complete. You have a right to access, and request the correction of, any of your Personal Information at any time. Any such requests should be made to the Privacy Officer. C&D 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 Information where necessary and appropriate. There may be circumstances in which we cannot provide you with access or make a correction. We will advise you of the reasons if we deny you access or do not correct your Information.
Third Party Links
How to Contact Us
If you have any queries or wish to make a complaint about a breach of this Policy, the Privacy Act or a privacy code that applies to us, you can contact or lodge a complaint to our Privacy Officer using the contact details below. You will need to provide sufficient details regarding your complaint as well as any supporting evidence and/or information.
Our Privacy Officer will respond to your query, or if a complaint has been made, investigate your complaint and determine the steps that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing (which includes electronic communication via email or fax) of the relevant determination. If you are not satisfied with the determination, you can contact us to discuss your concerns or complain to the Australian Privacy Commissioner via www.oaic.gov.au.
The Privacy Officer
Church & Dwight (Australia) Pty Ltd
PO Box 6369
Frenchs Forest NSW 2086
Phone (Australia): 1800 222 099