Last Updated 1 March 2018
BHC abides by the Australian Privacy Principles (“APPs”) under the Australian Privacy Act 1988 (Cth) (“Australian Privacy Act”) and by the Privacy Principles under the New Zealand Privacy Act 1993 (”NZ Privacy Act”)
In Australia, you can obtain information about the APPs and your privacy rights at the website of the Office of the Australian Information Commissioner at http://www.oaic.gov.au/privacy/privacy-news. In New Zealand, you can obtain information about the NZ Privacy Act and your privacy rights at the website of the Office of the Privacy Commissioner at https://www.privacy.org.nz/.
References to “websites” in this policy include any website controlled by BHC, including the following:
1 What type of personal information do we collect and what happens if we do not receive the information requested?
BHC collects personal information that is necessary to review employment applications, maintain our relationships with our business customers, administer any award program, promotion or competition we may run, market our products, and deal with enquiries and complaints regarding those products.
The personal information we collect for promotional and business purposes is often limited to contact details (name, address, email address, phone no.). We may collect date of birth details if a person is required to be above a certain age to take part in a promotion. We may also collect personal information submitted to us as part of a promotional activity which may include photographs, video images and other material.
If you apply for a job at BHC, we will collect information related to your employment history and ask you to undertake a basic medical examination. You consent to our use of this medical information for the purposes of assessing your employment application.
If you lodge a complaint with us about a product, we will record details of the complaint including which particular BHC products you have used and the nature of the complaint (which may include in appropriate circumstances health information). You consent to our use of this health information for the purposes of dealing with your complaint.
If you apply for credit for product purchases with BHC, we will collect your contact details and may collect information in relation to your business, assets and credit history for the purposes of considering your application.
If you do not wish to give us personal information as requested, then our ability to meet our obligations to you or provide services or information to you may be adversely affected.
2 How do we collect and hold personal information?
We usually collect personal information directly from the individual to whom the information relates. We collect personal information about individuals in a number of ways, including where you:
(i) take part in our competitions or other activities to promote our products;
(ii) are nominated in any award program we may promote; or
(iii) lodge a complaint/inquiry about our products.
However there are some instances when we collect personal information from someone else. For example, we collect personal information about prospective employees from the resumes they provide but this personal information will sometimes be provided by a recruitment agency. Also, we may collect personal information from a medical professional carrying out medical examinations that are part of the interview process.
In some circumstances we may receive personal information (such as an email address or an image of a person) from someone who takes part in one of our promotions and sends to us their own personal information and also that of other people. Other circumstances when personal information may be collected by someone else include information collected through our agencies running competitions, through other providers of consumer analysis services, through Facebook, Twitter and other forms of social media.We will endeavour to inform anyone whose personal information we collect from a third party that we have collected that information as soon as practicable. Otherwise, we will take steps to try to ensure the third party who provided this information to us has done so.
Personal information about our business customers is usually collected from direct contact between those customers and our sales representatives.
We collect information either electronically (eg. in an e-mail), where you send it to us as a hard copy document or where you provide it verbally (over the phone or in person).
We hold personal information in electronic and hard copy files.
Collection of information from our websites
When using our websites you may voluntarily disclose personal information to us. Our servers may automatically record details such as your internet address, domain name if applicable, and the date and time of your visit to one of our websites. This information is used for internal purposes only, including statistical purposes.
We will not try to identify users or their browsing activities except as necessary to investigate or report any suspected unlawful activity, as required or authorised by law or as reasonably necessary for the activity of an enforcement body.
You can prevent Google from detecting a cookie that is generated because of and related to your usage of this website (including your IP address) as well as processing of these data by downloading and installing this browser plugin: http://tools.google.com/dlpage/gaoptout?hl=en.
Use of remarketing tools
Google remarketing, Facebook remarketing, pixel tags, web beacons, clear GIFs or other similar technologies will be used on occasion to record details and collect information of your visit to any one of our websites and deliver specific advertisements to you about our products and services based on the pages visited and the way in which you access the website. These advertisements may be delivered by our third party vendors when you visit our websites or other internet websites. These vendors may use pixel tags, web beacons, clear GIFs or other similar technologies to obtain information which will be used to deliver advertisements about goods and services that may be of interest to you.
3 How your personal information will be managed
BHC will take reasonable commercial steps to ensure that all information we collect, use or disclose is accurate, complete, up to date and relevant and protected from misuse, interference and loss and from unauthorised access, modification or disclosure. We will also take reasonable steps to ensure that all personal information is stored in a secure environment accessed only by authorised persons.
If any of your details change, please let us know as soon as possible by using the contact details below so we can maintain the accuracy of your personal information.
We will, where permitted by law, destroy or permanently de-identify personal information that is no longer needed.
4 How your personal information will be used
BHC will use the personal information provided to us for one or more of the following purposes (depending on the circumstances):
• review employment applications;
• maintain and develop our business relationships with our business customers;
• respond to, and analyse, complaints and enquiries regarding BHC products;
• administer award programs, promotions and competitions we may run from time to time;
• participate in customer research, marketing campaigns and promotions run by other companies that may promote and/or supply our products;
• notify you from time to time of alternative or additional products and services BHC may provide; and
• fulfil all legal and regulatory requirements of BHC.
Information provided to us may be held on a server operated by any of our related companies overseas (BHC Companies). This information may also be held by any company overseas that is engaged by a BHC Company to host, maintain or update any of our websites or databases. The countries in which your personal information may be held include Germany, the United States, Canada and India. Your use of any BHC web site constitutes consent to the storage of your information by the BHC Companies and their contractors providing hosting or other web site or database related services.
If we wish to use your personal information for direct marketing, such as by adding you to a marketing database, we will first seek your consent.
If you have given consent and no longer wish to receive information about additional products and services offered by BHC, you may opt out at any time by replying to the email using the unsubscribe facility or by sending our Privacy Officer a message by post, fax or e-mail at our addresses set out below.
5 Will my personal information be disclosed to a third party?
The personal information BHC collects is kept confidential. We will not disclose that information to any third parties other than:
• related bodies corporate of BHC;
• organisations with which we run or organise promotions, competitions or award programs or which supply a prize or reward;
• retailers and other customers of BHC, and suppliers of BHC, for the purpose of promotions they may run relating to BHC products;
• retailers, service providers and other customers of BHC for the purpose of obtaining consumer research services;
• any contractor BHC arranges to provide fulfilment or delivery services;
• any contractor BHC engages for web-hosting or other website related services;
• as we may be required or permitted to do by law;
• or otherwise with your consent.
The disclosure of information to the parties listed above may involve the disclosure of your personal information to a recipient in a foreign country, including in Germany, Canada, India and the United States.
We have an obligation ("the Obligation") to take reasonable steps, in the circumstances, before disclosing personal information to an overseas recipient to ensure that the overseas recipient does not breach privacy laws in relation to that information. However should we obtain your consent to disclose your personal information to an overseas recipient, the Obligation does not apply. In obtaining your consent, we will not be accountable and you will not be able to seek redress against us under the Privacy Act if the overseas recipient handles your personal information in breach of the APPs under the Privacy Act and/or the Privacy Principles under the NZ Privacy Act. In providing your consent, you acknowledge and agree to the risks associated with the disclosure of your personal information overseas. These risks may include:
• the overseas recipient not being subject to any privacy obligations or privacy principles similar to the APPs and Privacy Principles ; and
• the overseas recipient being subject to foreign law that could compel the disclosure of your personal information to a third party, such as an overseas authority.
6 How you can access your personal information
On request, you may have access to your personal information held by BHC, except in circumstances where access may be denied under the Australian Privacy Act, the NZ Privacy Act or other law in Australia or New Zealand. Examples of these circumstances are:
• where providing access will pose an unreasonable impact on the privacy of another individual;
• where providing access would be unlawful, would pose a threat to the life or health of an individual, may prejudice an investigation of possible unlawful activity, may prejudice enforcement of laws or denying access is specifically authorised by law.
To make a request for your personal information, please contact our Privacy Officer (contact details below). We will endeavour to acknowledge a request for personal information within 10 days and notify you of our acceptance or denial of your request within 20 days.
If personal information is provided to you as the result of a request, you may be charged a fee for costs incurred in providing that information such as photocopying, administration and postage.
If access is denied we will provide you with reasons for our refusal in writing except if, having regard to the grounds for refusal, it would be unreasonable to do so.
7 How you can correct your personal information
If you believe that the personal information we hold about you is inaccurate, incomplete, out-of-date, irrelevant or misleading, please let us know. Provided we agree with you, we will correct it.
If we do not agree with you, we will:
• give you reasons for the refusal in writing (except to the extent that it would be unreasonable to do so) and how you may complain of the refusal; and
• upon request from you, place a statement of what you allege is incorrect where that information is kept and accessed so that it will be apparent to users of the information.
8 Links to other websites
Our links to the linked websites should in no way be construed as an endorsement, approval or recommendation by us of the owners or operators of the linked website or of the content, products or services contained on or referred to by the linked websites.
10 Queries or Complaints
If you have any queries or complaints in regard to our collection, use or management of your personal information, please contact us. Any complaints will be considered within 30 days and responded to. We will always endeavour to resolve any complaint to your satisfaction, however, if you are unhappy with our response, you are entitled to contact the Office of the Australian Information Commissioner (OAIC) (Tel: 1300 363 992 or email: firstname.lastname@example.org), which may investigate your complaint further in Australia, or the Office of the Privacy Commissioner in New Zealand (Tel: 0800 803 909 or email: email@example.com).
Our contact details are:
Beiersdorf Health Care Australia Pty Ltd
4 Khartoum Road
North Ryde NSW 2113
Phone: +61 2 9888 0977
Fax: +61 2 9888 0971
BHC internal use only:
Last update March 2018: Copy BDF from 011017 JWS DocID 72596956.1 | File with KL.