We recognise the importance of privacy in your personal information. The purpose of this Global Privacy Policy (Policy) is to describe how Australian Wool Innovation Limited, an Australian not-for-profit company, and/or its subsidiaries and affiliates including The Woolmark Company Pty Ltd (collectively AWI) collects, stores, processes, uses and discloses your personal information.
This Policy applies in relation to personal information collected as a result of your use of AWI’s websites and applications, attendance at AWI events, use of any AWI services, participation in AWI competitions or engagement with AWI in relation to its service offerings.
1. WHO ARE WE?
AWI is a not-for-profit company that invests in research, development and marketing along the global supply chain for wool to enhance the profitability, international competitiveness, sustainability and demand for Australian wool. AWI is the owner of The Woolmark Company Pty Ltd and its subsidiaries.
When we refer to ‘AWI’, ‘we’, ‘us’ or ‘our’ in this Policy we are referring collectively to AWI and its subsidiaries and affiliates. You can contact our Privacy Officer/ Data Protection Officer at Australian Wool Innovation Limited, Level 3, 23 York St Sydney, NSW Australia 2000. Phone: +61 2 8295 3100 or email: privacy@wool.com.
For the purposes of applicable EU privacy laws, our EU representative for privacy is Woolmark International Pty Ltd, incorporated in England and Wales under Registration No. 3388909. Registered Office: New Wing, Somerset House, The Strand, London, England, WC2R ILA. Phone: +44 207 845 5888. Email: privacy@wool.com
2. WHAT TYPE OF PERSONAL INFORMATION DO WE COLLECT?
Personal information is information or an opinion which identifies you as an individual or from which your identity can be reasonably ascertained.
For the purposes described in this Policy, AWI may collect the following types of personal information:
- identification and contact information (such as your name, phone number, postal address, e-mail address) when you are willing to provide them, for example when you register on our websites, sign up to receive publications or participate in events;
- business information;
- payment information;
- images, photos or videos of you;
- passwords;
- location or GPS location;
- communication and marketing preferences and interests;
- feedback and survey responses; and
- your opinion on wool-related issues.
- if you complete a financial transaction with us, your credit card details will be requested and shared with our third party financial institution, who will process the financial transaction; and
- personal information about your interactions with us, including any contact we have with you by telephone, email, online or in person.
We may also receive personal information about you from third parties for example sub-contractors, consultants, marketing or advertising agencies. They will generally collect this information when you are participating in, accessing or signing up to an AWI service, event or activity which they are managing for us. The types of personal information that they will provide us will generally be the same as described above.
By providing your personal information you enable AWI (and where applicable its contractors) to provide you with services, information and content. You do not have to provide your personal information to us but, if you do not provide the information requested, we may not be able to provide you with the services, information or content you have requested.
We do not knowingly collect personal information relating to children unless expressly stated.
The list above is not exhaustive, and in certain instances, we may need to collect your additional data for the purposes advised at the time.
AWI also uses cookies (see Cookies section below for further details) and collects IP addresses. An IP address is a number that can uniquely identify a specific computer or other network device on the internet from visitors to our websites.
3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
We generally collect personal information if you choose to provide your details through our various global channels which we own, operate, manage or control including but not necessarily limited to websites, social media sites, apps and e-commerce platforms (Channels). We may also collect personal information from you in person (for example when you attend our trade shows, seminars, events, meetings or otherwise liaise with our employees).
Sometimes, we may collect your personal information from someone else such as our related companies, agents, representatives or service providers or your organisation and representatives. We may also obtain personal information from other sources, both from companies or public documents (for example, our on-farm network partners provide us with lists of people to contact for farm-related events). This Policy also applies to personal information collected by us in this manner.
We also automatically collect certain information when you visit our websites via cookies (see Cookies section below for further details).
During your communications with us you must not provide us with personal information of any other individual unless you have clear consent from that person to do so, let them know that we collect and handle their personal information in accordance with this Policy and provide them with a copy of it or details of where to find it.
Some of the personal information we collect is collected pursuant to applicable laws or contracts. For example, when conducting competitions, we collect names and contact details of entrants to ensure we can meet our obligations under laws about competitions (sometimes called ‘trade promotions’) (for example, the Lotteries and Art Unions Act 1901 (NSW)).
4. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use the personal information described above for a number of purposes specified at the time of collection or hereafter in this Policy based on your consent, or legitimate interest, or performance of contractual obligations, or for compliance with legal obligations, including, but not limited to the following:
- to provide information, materials, services, events, activities, products and content to address and respond to your requests and enquiries;
- to provide you, or permit selected third parties to provide you, with information about our offers, promotions, products, services, activities and events where you have requested to receive this (if you no longer want us to use your information in this way please use the unsubscribe facility in the message or let us know by contacting us at the address in the "Who are we?" section above);
- to analyse and improve the services (and content) we offer and the events and activities we undertake;
- to fulfil our duties to you as a shareholder, levy payer or other stakeholder;
- to personalise the way we engage with you (e.g. by analysing information about your previous interactions with us, we can provide you with more tailored services and content);
- for service administration purposes e.g. to provide you with a password or to notify you that a particular service, event or activity is taking place;
- to contact you about a submission, article or correspondence that you have made or sent;
- to verify, maintain and update information we hold;
- to carry out our obligations arising from contracts entered into between you and us, or to take requested action in anticipation of such a contract;
- for purposes relating to law enforcement and investigations, protecting our lawful interests and acquisition or sale of our business;
- market research purposes;
- to manage any registered accounts you have with us;
- for general research and analysis purposes;
- protecting you and other individuals and maintaining safety, health and welfare (e.g. at an AWI event);
- as required or authorised by applicable law; and
- any other purposes notified to you at the relevant time.
We always try to ensure that we deliver content that you will be most interested in. By developing a better understanding of you through the personal information that you provide us and the transactions you have with us, we can tailor our services and communications to provide you with content, marketing and promotions that you are most likely to be interested in based on your profile.
We use information obtained from cookies so that we can optimise the activities, products and services which we provide to you (see the Cookies section below for more details).
5. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We do not disclose or otherwise share your personal information, except with:
- our related bodies corporate and affiliates entities for the purposes described above;
- third party companies which we may have commercial or non-commercial relationships with for the purpose of marketing, promoting, collaborating on or managing wool related events and products (including prize suppliers for our competitions);
- our agents or service providers who assist us with technical infrastructure solutions, customer contact processes and archival, auditing, accounting, legal, business consulting, banking, payment, delivery, data processing, marketing, insurance, advertising and website or technology services;
- regulatory and law enforcement authorities or parties involved in any legal process (for example, in connection with complaints, claims, investigations, misconduct, criminal activity and security breaches);
- parties involved in any relevant sale or potential of our business, or other corporate transaction;
- any other entities identified at the time of collecting your personal information; and
- when required to do so by law or when it is necessary to comply with applicable laws (for example, we might share some of the above parties are located in countries other than Australia, including the United Kingdom, Italy, Germany, the Netherlands, France, Spain, Turkey, USA, India, China (including Hong Kong), Vietnam, Korea, Japan and Singapore. Where we disclose your personal information to a recipient outside your jurisdiction, we use various safeguards to comply with our obligations in respect of exporting personal information. This may include ensuring the recipient is subject to similar legal requirements or certified under a binding data protection scheme or entering into appropriate contractual arrangements for the protection for your personal information. You can contact us to obtain further details of the safeguards we use. For the avoidance of doubt, you hereby consent to your personal information being transferred overseas as described above. You can contact AWI at any time should you wish to withdraw your consent and if you have any questions in this regard.
For the purpose of Australian privacy law only, note that where your personal information is provided to entities outside Australia, you acknowledge that by agreeing to the disclosure of your personal information to these overseas entities, we will no longer be required to take reasonable steps to ensure the overseas recipient's compliance with the Australian privacy law in relation to your personal information and we will not be liable to you for any breach of the Australian privacy law by these overseas recipients. On this basis, you consent to disclosure of your personal information to these overseas recipients.
6. LINKS TO THIRD PARTY WEBSITES
Our Channels may contain links to other websites some of which may be white-labelled or co-branded with our logos; however, these channels may not be owned, operated, maintained or controlled by us. The inclusion of these links is not intended to indicate that we sponsor, approve or endorse the websites (unless we specifically state otherwise). We are not responsible for the content, availability, useability nor the privacy practices or policies of those websites and recommend that you review their terms of use and privacy policies. Access to these third-party websites is at your own risk.
7. YOUR RIGHTS
If you would like to:
- access, correct or rectify any personal information we hold about you;
- stop receiving marketing communications from us or stop us disclosing your personal information for another entity’s direct marketing;
- withdraw any consent you have provided in relation to the handling of your personal information, subject to any other permitted grounds we may have to continue handling your personal information in some circumstances;
- erase or restrict our handling of your personal information, where the information is no longer needed by us for a permitted purpose (or in certain other circumstances);
- object to our handling of your personal information except in relation to legal claims or where we have a justifiable basis to continue; or
- object to decisions being made based solely on automated processing of your personal information;
- have us provide you or another person with a copy of your personal information in a commonly used machine readable format,
then please contact us via the contact details set out in section 1 above. Note that these rights are not absolute and do not apply in all jurisdictions. For example, rights at dot point 4 and 7 above have limited application outside the European Economic Area. We will seek to deal with your request without undue delay, and in any event within any time period set out by law (subject to any extensions to which we are lawfully entitled). We will provide our reasons if we deny any request made above (e.g. by identifying any relevant exception). Please note that we may keep a record of your communications to help us resolve any issues which you raise.
8. STORAGE AND SECURITY
Your personal information we collect is held in electronic databases and in paper files, both at our own premises and with the assistance of our service providers.
AWI and its infrastructure providers have taken reasonable steps regarding physical and technical access intrusion security measures to protect the personal information we hold against loss, misuse, interference and from unauthorised access, alteration or disclosure. However, if you are considering sending us any personal information through any of our Channels, please be aware that the information may be insecure in transit, particularly where no encryption is used (e.g. email, standard HTTP). You must also take care to protect your usernames and passwords and notify us immediately if you become aware of any security breaches.
We take reasonable steps to destroy or anonymise personal information once we no longer require it for a permitted purpose (being the purpose for which we collected it). This may apply, for example, if we cease to operate our business and do not transfer it to a new owner. Sometimes we are subject to legal obligations to retain particular types of personal information for specific periods.
In the event of any security breach affecting personal information, we will comply with our applicable legal obligations in respect to minimising the impact of the breach, notifying affecting individuals and reporting to relevant authorities.
9. USE OF COOKIES
We may collect from you technical data and other related information about your device, systems, application software, and peripherals. Such information could be your internet protocol address, your operating system and platform details, browser type and version, referrer website as well as information about your preferences, viewed/searched for products and on-site activity. Some of this information may be capable of personally identifying you.
This information will often be collected by using cookies. A cookie is a piece of data that is stored on your digital device so that when you browse the internet your digital device can be recognised at a later time.
In some cases third parties such as Google Analytics may use cookies on our Channels in connection with online services like website analytics, surveys and advertising. This may allow them to collect information about your use of our Channels, which they may store in countries other than Australia. For more about how Google collects and processes data, please see Google’s privacy policy and their information at www.google.com/policies/privacy/partners/.
AWI uses the technical information from cookies to store visitors preferences, record session information, record user-specific information such as what pages users access or visit, alert visitors to new areas that we think might be of interest to them when they return to our site, record past activity at a site in order to provide better service when visitors return to our site, for example customize web page content based on visitors' browser type or other information that the visitor sends.
You can configure your web browser to reject cookies but you may find some parts of our Channels they have limited functionality.
For more information on how we use cookies please refer to our full Cookies Policy at www.woolmark.com/legal/cookies.
10. HOW TO MAKE A COMPLAINT
If you wish to make a complaint about a breach of this Policy or applicable privacy and data protection laws you can contact us using the contact details set out in section 1 above. You will need to provide us with all relevant details of your complaint and any supporting evidence.
We will refer your complaint to our Privacy Officer who will investigate your complaint and determine the steps that we will undertake to resolve it. We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation. If you are not satisfied with our determination, you can contact us to discuss your concerns or contact the applicable privacy or data protection authority.
In Australia, this is the Office of the Australian Information Commissioner, which can be contacted on 1300 363 992 or via www.oaic.gov.au.
In the European Union, the privacy regulators for each Member State are listed (along with contact details) on the following website: http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
11. LEGAL CONDITIONS FOR USING YOUR PERSONAL INFORMATION
If you are located in the European Union, applicable privacy laws provide that there are a number of different ways that we are lawfully able to process your personal information. We have set these out below.
Where using your personal information is in our legitimate interests
We are allowed to use your personal information where it is in our interests to do so, and those interests aren't outweighed by any potential prejudice to you. We believe that our use of your personal information is within a number of our legitimate interests, including, but not limited to:
- providing you with services, events, activities, information and content to deal with your requests and enquiries;
- to provide you, or permit selected third parties to provide you, with information about our services, activities, initiatives and events;
- to analyse and improve the services (and content) we offer and the events and activities we undertake;
- to personalise the way we engage with you (for example, by analysing information about your previous interactions with us, we can provide you with more tailored services and content); and
- verifying, maintaining and updating information we hold.
We don't think that any of the activities set out in this Policy will prejudice you in any way. However, you do have the right to object to us processing your personal information on this basis (as set out in 7 section above).
Where you give us your consent to use your personal information
We are allowed to use your personal information where you have specifically consented. As part of our relationship with you, we may ask you for specific consents to allow us to use your data in certain ways. If we require your consent, we will provide you with sufficient information so that you can decide whether or not you wish to consent.
You have the right to withdraw your consent at any time (as set out in section 7 above).
Where using your personal information is necessary for us to carry out our obligations under our contract with you
We are allowed to use your personal information when it is necessary to do so for the performance of our contract with you. For example, we need to collect your contact details in order to be able to communicate with you and provide you with any products you have requested.
Where processing is necessary for us to carry out our legal obligations
As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with and we are allowed to use your personal information when we need to in order to comply with those other legal obligations.
12. CHANGES TO THIS POLICY
This Policy may change from time to time, so you should check it each time you visit any of our Channels. The date of the most recent revision appears at the bottom of this Policy. If material changes are made to our Policy, we will notify you as required by law. We will post an update copy of an updated Policy on our website(s).
Last updated on September 2018.
