Sara Lee Holdings Pty Ltd (ACN 650 567 641) and its related bodies corporate (Sara Lee, us, we, our) take privacy very seriously and we are committed to handling your personal information in a responsible manner.
We aim to comply with applicable obligations under the Privacy Act 1988 (Cth) (Privacy Act). Where applicable, we also aim to comply with applicable obligations under the Privacy Act 2020 (New Zealand).
What is personal information?
“Personal information” has the meaning given to in the Privacy Act. Generally, personal information is information, including a fact or opinion, about an individual who is identified or reasonably identifiable.
“Sensitive information” has the meaning given to in the Privacy Act. Certain types of personal information are classified as sensitive information and subject to additional protection under the Privacy Act. Information about an individual’s health is an example of sensitive information.
What types of personal information do we collect?
The personal information that we collect about you will vary, depending on your relationship with us and the purpose of its collection. This may include the following:
- if you purchase products through our online store – your name, email address, telephone number, shipping address and payment information (including credit card information) and order details;
- if you create an account on our online store, your name, email address, password and any other information which we require to create and maintain your account;
- if you have consented to receive our email newsletters or other marketing materials – your name, date of birth (optional), email address, and telephone number;
- if you participate in our loyalty programmes or trade promotions (including contests or sweepstakes) – any information which you must provide in order to participate the loyalty programme or trade promotion, including your name, age, email address, and telephone number;
- if you interact with our social media accounts or upload content on to our social media pages or websites (including Facebook, Twitter and similar platforms) – we may collect material which you upload to these locations or any personal information which is displayed on those social media platforms;
- if you apply for a permanent or temporary position with us as an employee, contractor, volunteer, agent or temporary worker – information contained in your application, your CV or résumé, information recorded during any interview or obtained through any pre-employment checks or tests and government-issued identifiers (such as tax file numbers), and any health information relating to our management of the COVID-19 pandemic or other health-related issues in our workplaces as required by law;
- if you visit our premises – your name, residential address, phone number, email address, vehicle plate number and images and videos of you using our CCTV surveillance system;
- if you are a current or prospective supplier, service provider or a B2B customer – any information which we require to establish and manage our commercial relationship with you or your business, including your name, postal or business address, email address, telephone number, job title, payment details (including bank account information) and any other information you provide to us through any online portal which we make available to you;
- if you are an applicant for trade credit – information pertaining to your credit worthiness, including your credit information, information on your credit eligibility, bank account information, operational and trading information and trade referees; and
- if you contact us for any other reason, including to provide feedback or submit a complaint or enquiry – your name, postal or residential address, email address, telephone number and any other information which you voluntarily provide to us.
Generally, we will not collect sensitive information about you. However, in certain circumstances, we may need to collect limited sensitive information. For example, if you visit our premises we may collect information about your health to ensure your safety and well-being (e.g. in case you have any food allergies).
If you access our websites, we will collect your computer’s internet protocol (IP) address and other technical information about how you access and use our websites.
How do we collect personal information?
We collect your personal information directly from you, including when you:
- access or interact with our websites, online store or social media pages;
- order and purchase products from us;
- create or login to your account or any online portal which we make available to you;
- consent to receive email newsletters and other marketing materials;
- participate in our loyalty programmes or promotions;
- apply for a permanent or temporary position with us as an employee, contractor, volunteer, agent or temporary worker;
- visit our premises;
- supply us with goods or services;
- make or receive payments from us; and
- contact us for any other reason.
We will endeavour to only collect personal information about you from you direct, and not from third parties. In limited circumstances, we may collect personal information about you from publicly available sources (such as the Internet) and from third parties (for example, in the course of conducting market research).
If you apply for trade credit from us, we may collect information pertaining to your credit worthiness from credit reporting bodies in order to consider your application.
Can you choose not to disclose your personal information?
When you contact us to make a general enquiry about our business or products, you are not required to identify yourself or provide any personal information to us. In these circumstances, you may inform us that you wish to deal with us using a pseudonym.
However, if we are not able to collect personal information about you, we may not be able to provide you with the assistance, information or products that you have requested. For example, we cannot send you any information in response to a request if you have not provided us with your contact details (for example, an email address).
How do we use your personal information?
Generally, we use your personal information to conduct our business.
By way of example, we use your personal information for the following specific purposes:
- to provide you with our products;
- to operate our websites, online store and social media pages;
- to conduct our loyalty programmes and trade promotions;
- to verify your identity (for example, if you request access your personal information);
- to consider your application for a permanent or temporary position with us as an employee, contractor, volunteer, agent or temporary worker;
- to ensure your health, safety and well-being when you visit our premises;
- to establish and maintain relationships with suppliers, service providers or B2B customers;
- for direct marketing purposes (see the “Direct marketing” section below);
- to respond to your communications to us;
- to consider your application for trade credit; and
- to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.
We may also use or disclose your personal information for internal administrative, research and development purposes, to protect our intellectual property, to provide you with customer service, to resolve legal disputes and for other purposes to which you have consented, or as otherwise permitted or required by law.
Technical information and general analytics are used for monitoring visitor traffic, trends and delivering personalised content to you when you access and use our websites, and to improve our websites and our products and your customer experience.
Where permitted by law, we may rely on the employee records exemption under the Privacy Act and other applicable exemptions under relevant laws.
To whom do we disclose personal information?
We may disclose your personal information to third parties in connection with the purposes described above, including to:
- our related companies;
- our service providers and suppliers, including our third party data service providers, advertising partners and organisations which conduct research or trade promotions on our behalf;
- any potential third party acquirer of our business or assets, and advisers to that third party;
- our professional advisers (such as lawyers, accountants or auditors) and insurers, including to defend or establish legal claims;
- our employees, contractors and volunteers who assist us in performing our functions and activities;
- any person to whom you have authorised us to disclose your information (e.g. referees); and
- any other person as required or permitted by law, including law enforcement agencies, regulators and other government bodies.
We will use reasonable commercial efforts to ensure that any third parties to whom we disclose your personal information only use that information as reasonably required for the purpose of disclosure and in accordance with applicable laws. For example, where commercially practical, we will include appropriate privacy and confidentiality clauses in our agreements with third parties.
Direct marketing communications
We will only send you direct marketing communications (such as through mail, SMS or email), including newsletters, special offers, news and promotions, where you have provided consent for us to do so.
You may opt-out of receiving direct marketing communications at any time by contacting us or by using opt-out facilities provided in the direct marketing communications.
Does personal information leave Australia?
We store personal information in servers located in Australia, including personal information stored through our service providers Kronos and Sage Micropay. We may disclose your personal information to overseas recipients, including to our related bodies corporate (such as our parent company) and our service providers (such as our auditors). Our parent company and our auditors are located in New Zealand.
Except where an exception applies under the Privacy Act or other relevant legislation, we will take commercially reasonable steps to ensure that overseas recipients to whom we disclose personal information comply with the Australian Privacy Principles stated in the Privacy Act in relation to such information.
How do we protect your personal information?
We implement reasonable measures to protect and safeguard your personal information from misuse, loss, theft and unauthorised access, modification or disclosure. However, as the Internet is inherently insecure, we cannot guarantee the security of transmission of personal information disclosed to us online. Accordingly, you transmit your personal information to us online at your own risk. Please notify us immediately if you know or reasonably suspect that your personal information has been subject to any data breach, breach of security or other unauthorised activity.
How long do we keep your personal information?
We have internal data and retention policies and procedures which govern our approach to retention of personal information.
Generally, we will keep your personal information as long as necessary for the purpose(s) for which the relevant information was collected, unless we are required to keep the relevant information for longer by applicable law.
How can I access and correct my personal information?
You can make a request to access or correct your personal information using the details set out under “Contact us” below. Subject to applicable exceptions under the Privacy Act, we will provide you with access to, or we will correct your personal information.
In limited circumstances, we may charge a fee to provide you with access to the requested information. We will provide you with prior notice of any such fee.
What is the process for complaining about a breach of privacy?
We will investigate any complaint and you will be notified of the outcome of the complaint as soon as reasonably practical.
If you are unsatisfied with the outcome of the investigation, we will advise you on next steps, including lodging a complaint with the Office of the Australian Information Commissioner.
Sara Lee Holdings Pty Ltd
Attention: Privacy Officer
Last updated: 23 February 2022