The privacy of your Personal Data is important to Swisse Wellness Pty Ltd. and its related companies and affiliates (referred to collectively as “Swisse Wellness”, “we” or “our”) and we are committed to ensuring that your Personal Data is handled responsibly, in accordance with the applicable Data Protection Legislation.
DATA PROTECTION LEGISLATION
We observe the Privacy Act 1988 (Cth) (“Privacy Act”) including the Australian Privacy Principles (“the APPs”) (hereinafter jointly referred to as the “Australian requirements”).
In addition, we adhere to the European Data Protection Legislation as described below to the extent it applies to the Personal Data we process about you.
“Personal Data” is data relating to you from which you can be reasonably identified. Examples of Personal Data include your full name, postal address, email address and telephone number. We recognise that your Personal Data is valuable and process your information in accordance with the Australian requirements and European Data Protection Legislation (hereinafter jointly referred to as “Data Protection Legislation”).
Swisse Wellness Pty Ltd. is responsible as data controller for the processing of your Personal Data collected on the Swisse Wellness websites under the European Data Protection Legislation and the Australian requirements as applicable.
PERSONAL DATA THAT WE COLLECT AND HOLD
We collect Personal Data to allow us to provide you with services and deliver information on the products and/or services offered by us. We make sure that the Personal Data we collect from you is necessary for and directly related to this purpose.
The type of Personal Data that we collect from you, will vary depending on the circumstances in which we are dealing with you. This information may include:
Credit card information we collect from you will go directly to our processor or bank and no personnel of Swisse will have access to this data. If you choose to purchase a product from us, our third party payment processors will collect your payment information, and none of our personnel will have access to this data.
As a general rule, we do not collect sensitive information about you, such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, physical or mental health or condition, sexual orientation and judicial or criminal records (“Sensitive Information”). However, in circumstances where we require Sensitive Information from you for a lawful purpose, for example for the purpose of providing our services to you, we will seek your consent to collect Sensitive Information prior to collecting it.
We collect such Personal Data from you in a number of ways, including:
We make sure that the way we collect data from and about you is lawful and fair in your circumstances.
We take all practical steps to ensure that you are informed of what data you are obliged to provide us, what data you may voluntarily provide us and what we may do if you do not provide us with data which you are obliged to provide.
PURPOSES FOR WHICH WE USE INFORMATION YOU PROVIDE US
This is information you give us when you enter your personal details on the Swisse Websites (for example during registration or application for products or services) or by contacting us via post, phone, e-mail or otherwise, in the context of your communication with Swisse. We will use your Personal Data to:
When you opt-in to receive communications from us, you are giving your consent for your Personal Data to be used by us to contact you (depending on your selection) by email, direct mail and telephone, and to deliver personalized Website experiences, to share information about relevant products and services, news and events in relation to Swisse’s offering.
We shall not use your Personal Data for marketing communications unless we have received your consent. Your consent may be communicated to us without charge by checking the opt-in / consent box in this Website or by writing to our Data Protection Officer, Aaron Xie at:
aaron.xie [at] hh.global
Data Protection Officer
111 Cambridge Street
If you subsequently decide that you do not want to receive correspondence from us about the services we could provide, you are entitled to withdraw your consent to us contacting you by clicking the “unsubscribe” link provided in a promotional email message, by amending your communication preferences or by contacting our Data Protection Officer at aaron.xie [at] hh.global or by post at 111 Cambridge Street Collingwood, Victoria AUSTRALIA 3066. Withdrawing your consent will not affect our use of the Personal Data prior to you withdrawing that consent but it will mean that we will not be able to contact you about the services we may be able to offer you or your business in the future.
We will let you know where you must provide us with Personal Data in order to perform an agreement with you or your business or to comply with a legal obligation. If you do not provide us with the Personal Data in these circumstances, we may be unable to respond to your enquiry and/or engage in further communications with you.
INFORMATION WE COLLECT FROM THIRD PARTIES
We may use information provided to us by third parties that operate automated tracking technologies on third party websites, information you may have made publicly available or information provided by third party sources, such as marketing opt-in lists or data aggregators.
PURPOSES FOR WHICH WE USE INFORMATION WE AUTOMATICALLY COLLECT FROM YOU
When you visit the Swisse websites, we may automatically collect information such as your IP address and browser type using cookies, log files, and pixel-tags (also called web beacons). This automatic data is primarily used for delivering and optimising services offered by us, such as:
To the extent this information constitutes Personal Data, we use it to ensure that content from the Swisse Websites is presented in the most effective manner for you and your device because it is in our legitimate interest to improve our customers’ online experience in relation to the Swisse websites.
The following information sets out the types of cookies used on the Swisse websites and provides detail about what they are used for. When you use the Swisse websites for the first time, cookies which are essential to make the Swisse websites operate (see those identified as “essential cookies” below) will have been set but other cookies will not have been set unless you agreed to those cookies being set at that time. If you have agreed to accept cookies then the Swisse websites will remember this and continue to set cookies each time you visit. If you do not want cookies to be stored, then you may, via your browser, turn off certain cookies listed below individually or you can select the appropriate options on your web browser to delete some or all cookies. Please note, however, that if you block some or all cookies (including essential cookies) you may not be able to use or access all or parts of the Swisse websites, such as being able to log on to member specific areas.
WHAT TYPES OF COOKIES DO WE USE?
We use a number of different cookies, outlined below:
First party cookies:
Third party cookies:
These cookies serve a function of:
Authentication, Security, Basic Functionality
Advertising, Marketing and Analytics
Microsoft Internet Explorer
CONSEQUENCES FOR YOU IF YOUR PERSONAL DATA IS NOT PROVIDED TO US
If you do not provide us with the Personal Data we ask for or the information provided is incorrect or incomplete, we might not be able to provide you with our products or services.
DISCLOSURES OF PERSONAL DATA TO THIRD PARTIES
However, we may disclose your Personal Data for the purposes listed above or as otherwise permitted by the Data Protection Legislation. By visiting the Swisse Website, you agree to disclosures to the following third parties:
STORAGE AND TRANSFER OF YOUR PERSONAL DATA TO OTHER COUNTRIES
If you provide Personal Data to Swisse, it may be transferred to, processed in, stored at or accessible from a destination outside Australia or the European Economic Area (“EEA”), such as New Zealand, Canada, China, the USA and Switzerland, or any other country in which Swisse Wellness or its service providers maintain facilities. All practical steps are taken to ensure that all data is treated confidentially, kept secure and protected against unauthorised or accidental access, processing, erasure or other use and is maintained and kept no longer that is necessary for the purpose for which it is intended.
Swisse Wellness is located in Australia, which is a territory not currently been deemed to offer adequate data protection by the European Commission. If you provide your Personal Data to us in circumstances where our processing of it is subject to European Data Protection Legislation, please note that you are doing so on the basis that you explicitly consent to the transfer of your data outside the EEA. The potential consequence of you explicitly consenting to this are that there is a risk that your Personal Data will not be protected in a manner that complies with European Data Protection Legislation. You can withdraw your consent for this reason at any time by emailing us at SwisseCustomerService [at] hh.global. Withdrawing your consent will not affect our use of the Personal Data prior to your withdrawing that consent but it will mean that we may not be able to contact you about the services we may be able to offer you in the future.
Where we pass your Personal Data that is subject to European Data Protection Legislation from a location inside the EEA to parties located outside the EEA that do not offer adequate protection as determined by the European Commission, and if they are not subscribed to an approved data protection framework, such as the EU-US Privacy Shield that permits us to transfer the Personal Data to them from the EEA, we will enter into agreements which enable us to transfer Personal Data to them and that enable you to exercise your rights in accordance with the European Data Protection Legislation. A copy of these terms can be obtained by emailing us at aaron.xie [at] hh.global.
HOW PERSONAL DATA IS HELD AND PROTECTED
We will keep a record of the Personal Data that we receive from you in order to answer your query, respond to a request for more information about the services, or in response to an enquiry from one of our existing suppliers. Subject to legal requirements, we will only retain the Personal Data collected from a user for as long as the user’s account is active or has otherwise not been cancelled and the user has not requested that their Personal Data be deleted. We will retain Personal Data to fulfil the purposes for which we have initially collected it, unless otherwise required by law. All Personal Data will be retained only as necessary to comply with our legal obligations.
We will delete our copy of your Personal Data 7 years from the end of our contact with you or when we are no longer required by law to retain it (whichever is later), although we may retain a record of the existence of the relationship, to the extent and for so long as we are required to do so by law. For example, if you have contacted us to ask us for the processing of your Personal Data to be erased, we will retain a record of your request in order to ensure we comply with your wishes.
Your Personal Data may be stored in hard copy documents or in electronic form in our computer systems. In particular, your Personal Data, will be stored in 128 SSL bit encryption on database servers at our data centres or at data centres owned by third party hosting companies.
You should keep in mind that Internet transmissions (including emails) are never completely secure or error-free. As such, you should take steps to protect yourself, especially online and take special care in deciding what information you send to us via e-mail or other transmissions. Moreover, where you use passwords, ID numbers, or other special access features on the Websites, it is your responsibility to safeguard them. You should choose a strong password, do not use the same password that you use on other websites and do not share your password with anyone else. Also remember to sign out of our Websites and close your browser window when you have finished to ensure that others who may have access to your computer cannot access your Personal Information.
ACCESSING AND CORRECTING YOUR INFORMATION
You have a right to access the Personal Data that we hold abut you at any time, subject to certain exemptions under the Privacy Act.
We will take all reasonable steps to ensure that the Personal Data we collect, use or disclose is accurate, complete, up-to-date and relevant to our dealings with you and the nature of our relationship with you.
If you would like to request access to your Personal Data or correction of your Personal Data held by us, you may contact us in writing. The relevant contact details are provided below (see “Contact us”).
PRIVACY COMPLAINTS OR DISPUTES
If you are unhappy with the handling of your complaint you may refer the complaint to the Office of the Australian Information Commissioner (visit www.oaic.gov.au for more information).
Please contact Swisse Wellness Customer Service to exercise these rights or for additional information at SwisseCustomerService [at] hh.global.
In addition to the above, you have the right to review, update, and correct your account information and preferences at any time by managing your account’s Profile page. If there is any information that you are not able to edit or delete, contact our Customer Service to help you make the amendments.
You have the right to request for your account to be terminated and your information to be deleted when there is no longer a legitimate or legal reason for us to keep your Personal Data.
On the other hand, if you wish to change or use other services affiliated to us, you may request for your Personal Data to be transferred or transmitted.
If you wish to contact us about the privacy-related matters described above or find out more information about our privacy practices, please use the contact details below:
PrivacyOfficer [at] swisse.com
Swisse Wellness Pty Ltd
111 Cambridge Street
Data Protection Officer
Aaron.Xie [at] hh.global
Data Protection Officer
111 Cambridge Street