Introduction

Metcash Trading Limited ABN 61 000 031 569 and its related bodies corporate (collectively, “Metcash”, “we”, “our” or “us”) are committed to the protection of the privacy and rights of individuals in relation to their personal information. This Privacy Policy tells you how we collect, hold, use and disclose your personal information.

Metcash may update this Privacy Policy from time to time. The most current version will be posted on the Metcash websites and will be effective from the date of posting. A copy of this Privacy Policy is also available by contacting our Privacy Officer by email or at the address detailed below under the heading “10. How to contact us or make a complaint”.

Where we refer to the ‘Privacy Act’ in this Policy we mean, if you are located in Australia, the Privacy Act 1988 (Cth) and if you are located in New Zealand, the Privacy Act 1993 (NZ).

What personal information do we collect and hold?

The types of personal information we collect and hold will vary depending on your dealings with us.

We may collect and hold any or all of the following types of personal information:
• your name, address(es), telephone number(s) and other contact details;
• the name of any company you are employed by or associated with;
• your position, title, profession or occupation, work history and other work-related details;
• your email address(es);
• your bank details;
• details of your assets and credit history;
• your credit card details;
• transaction details relating to your use of our products, services or benefits;
• membership numbers or other personal identifiers related to your access to or use of our services;
• health, medical, criminal background and financial information collected in the context of pre-employment screening/checks;
• your date of birth and driver’s licence number where required (for example, to comply with age restrictions or in order to verify your identity when you apply for credit terms); and
• other personal information you provide to us.

From time to time, you may provide us, and we may collect from you, the personal information of a third party. Where you provide the personal information of third parties, you agree that you will ensure that those persons are aware of this Privacy Policy, understand it and agree to accept it.

How do we collect your personal information?

Metcash generally collects your personal information directly from you, unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect it in the following ways:

• through your access to and use of our websites, or when you email us;
• during conversations with you in person (such as in store or via telephone);
• through security cameras at our premises;
• when you apply for credit terms with us, or complete an application, purchase order, agreement or similar or related paperwork;
• through your participation in our procurement processes;
• when you apply for a job with us, including through pre-employment screening/checks (which may include medical assessments, criminal record checks and bankruptcy checks);
• when you enter into a competition or promotion run or supported by Metcash;
• when you register to use one of our marketing or promotional programs, platforms or portals;
• when you subscribe to receive communications from us;
• when you complete one of our surveys;
• otherwise in the course of us providing you with a requested product, service or benefit; or
• when you have other dealings with us.

We may also collect personal information from third parties including:

• business partners we collaborate with to conduct marketing and promotional activities (including suppliers and retailers, and their service providers);
• in connection with pre-employment screening checks (e.g. medical records and health information may collected from a medical practitioner as part of a pre-employment medical examination);
• third party companies such as credit reporting agencies, law enforcement agencies and government entities; and
• your representatives (including legal representatives).

Why do we collect, hold, use and disclose your personal information?

General

Metcash collects, holds, uses and discloses personal information for a variety of different purposes relating to our functions and activities, which include:

• to establish and maintain our relationship with you, and provide you with information to enable you to remain in contact with Metcash;
• to assess and process your application;
• to provide the products or services you have requested from us, and keep a record of them, and process any payments you make to us;
• to administer our promotions and competitions;
• to provide credit to you, or pay you for products or services you provide to us;
• to provide you with access to protected areas of our websites;
• to respond to your enquiries;
• to process and respond to your complaints;
• to perform our internal and external administrative functions;
• to notify you of, and register you for, our events and promotions;
• to conduct surveys;
• to assess the performance of our websites and to improve the operation of the websites, and for other data analytics purposes;
• to assist us to make our services and products more valuable or useful to you;
• to conduct due diligence;
• to enable us to perform any duties we owe to you;
• to otherwise enable us to perform our business activities and functions;
• any other purposes described to you at or around the time of collection of the information;
• purposes to which you have provided your consent;
• to enforce our legal rights and obtain professional advice;
• to comply with industry standards and our policies; and
• as required or authorised by law or a court or tribunal order.

Direct marketing

Where we have your consent or are otherwise permitted by law to do so, Metcash may also use and disclose your personal information to send direct marketing to you from:

• Metcash Trading Limited and its related bodies corporate; and
• third parties who provide services to us.

The direct marketing may relate to:

• our products and services;
• the products and services of other parties;
• promotions run by us or other parties; or
• other new developments we believe may be of interest to you.

You may opt-out of receiving this direct marketing from Metcash or third parties through the unsubscribe function that will be made available to you with each direct marketing communication.

If personal information is not provided

You do not have to provide us with any personal information however, if you do not do so, this may limit the assistance we are able to provide you. For example, we may not be able to complete a transaction you have entered into, finalise payment for a product or service you have ordered or supplied, consider or process an application you have made, provide a product or service you have requested, grant credit terms, accept or validate your entry in a promotion or contact you in connection with the promotion, tailor, optimise or enhance your use or experience of our websites, respond to your queries or complaints or otherwise handle your enquiries, process your job application or otherwise provide you with the products, services or benefits you have requested.

Who do we disclose your personal information to?

Metcash may disclose your personal information to various third parties who we engage to assist in performing our business activities and functions, including those who help to provide our products and services to you. The third parties we may disclose your personal information to include:

• our personnel;
• manufacturers and suppliers;
• couriers and delivery contractors;
• marketing consultants and promotions companies (some of whom are engaged for the purposes of directly marketing products, services and promotions to you);
• professional advisers such as accountants, solicitors, business advisers and consultants;
• government bodies and regulatory authorities;
• credit reporting agencies or bodies in accordance with our Credit Reporting Data Management Policy; and
• companies that we plan to merge with or be acquired by or who may invest in us;
• payment processors, debt collectors, web hosting providers and IT service providers.

How do we store and protect your personal information?

Metcash stores personal information in a combination of computer storage facilities, paper-based files and other records. In so doing, we have taken reasonable steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification or disclosure.

When we no longer need your personal information, we take reasonable steps to destroy or permanently de-identify the information.

Disclosure of personal information to overseas recipients

Metcash discloses personal information, for some of the purposes described above, to organisations located in other countries, including the United Kingdom, the United States of America and India. We may also make personal information held in Australia, New Zealand or the other countries listed above remotely available for processing by service provider personnel located in other countries, such as China and Thailand.

We take reasonable steps to ensure that overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

How you can access and correct your personal information

Metcash will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up to date. If your personal details change, such as your address or phone number, please contact our Privacy Officer by email or at the address detailed below.

At your request, Metcash will provide you with a copy of any personal information which we hold about you, unless an exception under the Privacy Act applies. We may charge reasonable fees for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information.

We will promptly acknowledge and investigate any complaint about the way we manage personal information.

Digital Technologies

We and third parties may use digital technologies such as cookies, location services, web server logs and web beacons in connection with Metcash’s websites and other online services. Some of these technologies may operate without collecting or using any personal information. Please note this privacy policy applies to our collection, use, disclosure and storage of personal information only.

The Metcash websites use cookies to track user traffic patterns and to better serve you when you revisit a website. A cookie is a small data file that a website may write to your hard drive when you visit it. A cookie file can contain information, such as a Session ID which the website uses to track the pages you have visited. Other technologies we use include web beacons. We allow cookies and other digital technologies to be used:

• so that your preferences for a particular site can be stored;
• to improve your browsing experience; and
• to help tailor advertising and promotions to you.

Information is also generated whenever a page is accessed on a Metcash website that records information such as the time, date and specific page. We collect such information for statistical and maintenance purposes that enables us to continually evaluate our websites’ performance.

In some cases, we and third parties may use cookies and other technologies in connection with Metcash websites and digital marketing initiatives, for example in relation to online behavioural advertising, surveys and website analytics and email campaign tracking. The third party technologies we may use from time to time include Google Analytics, Google AdSense, Google Tag Manager, Facebook tracking, Cretieo, Hot Jar, Clicky and Gigya. You can find more details about these technologies, the data they collect and how you can opt out of certain conduct in the privacy policies and other consumer-facing documentation for those technologies (e.g. via Google’s Ads Preferences Manager). You may need to opt-out separately from each technology. The website www.youronlinechoices.com.au also allows you to opt-out of some online behavioural advertising and provides further information about how online behavioural advertising works. Your browser may also allow you to turn off or disable cookies and certain other technologies. Please be aware, however, that if you turn off or disable these technologies, you may not be able to experience the full functionality of our websites and associated services.

How to contact us or make a complaint

If you have any questions about this Privacy Policy, if you wish to update information we hold about you or if you wish to make a complaint about our collection, use or disclosure of your personal information under this Privacy Policy, please contact:

The Privacy Officer
Metcash Trading Limited
1 Thomas Holt Drive
Macquarie Park NSW 2113
Fax: (02) 9741 3027
E-mail: [email protected]

Metcash will take reasonable steps to remedy any issues resulting from our failure to comply with our privacy obligations. If our response to your complaint does not address your concerns to your satisfaction, you may have the right to make a complaint to a competent regulator (e.g. in Australia, the Office of the Australian Information Commissioner, whose website is located at www.oaic.gov.au).