Last Updated 18 September 2017
Mun abides by the Australian Privacy Principles (“APPs”) under the Australian Privacy Act 1988 (Cth) (“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 Mun, including the following:
1. REASONS FOR COLLECTING YOUR PERSONAL INFORMATION
Mun 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 Mun, we will collect information related to your employment history. You consent to our use of this 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 Mun 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 a credit account for product purchases with Mun, 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. WAYS OF COLLECTING AND HOLDING YOUR PERSONAL INFORMATION
We usually collect personal information directly from the individual to whom the information relates. We collect personal information about customers in a number of ways, including where you:
- take part in our competitions or other activities to promote our products;
- are nominated in any award program we may promote;
- lodge a complaint/inquiry about our products;
- take part in a product evaluation or product trial to assess our products suitability;
- request further company or product information at a conference or event;
- request further company or product information through an inbound or outbound phone call.
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.
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. The security of your personal information is important to Mun and we take reasonable steps to protect it from misuse, interference, loss, unauthorised access, modification or disclosure. Some of the ways we do this include implementing security access procedures to databases, confidentiality agreements for our employees and only allowing access to personal information to individuals once Mun is satisfied as identification requirements.
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. MANAGEMENT OF YOUR PERSONAL INFORMATION
Mun 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. USE OF YOUR PERSONAL INFORMATION
Mun 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;
- assess any applications for credit
- to process and complete any purchase orders
- respond to, and analyse, complaints and enquiries regarding Mun 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 Mun may provide; and
- fulfil all legal and regulatory requirements of Mun.
Information provided to us may be held on a server operated by any of our related companies overseas (Hartalega Companies) This information may also be held by any company overseas that is engaged by a Hartalega Company to host, maintain or update any of our websites or databases. The countries in which your personal information may be held include Malaysia, the United States, China and India. Your use of any Mun website constitutes consent to the storage of your information by the Hartalega Companies and their contractors providing hosting or other website or database related services.
In Australia, if we intend to use your personal information for direct marketing, such as by adding you to a marketing database and you have not already consented to this use, we will notify you and will provide you with an opportunity to opt out.
In New Zealand, 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 Mun, 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. DISCLOSURE OF YOUR PERSONAL INFORMATION TO THIRD PARTIES
The personal information Mun collects is kept confidential. We will not disclose that information to any third parties other than:
- related bodies corporate of Mun;
- credit providers, credit reporting bodies and guarantors to assist in assessing any applications for credit;
- third party suppliers involved in administering any credit account with Mun and to which personal information is usually disclosed such as debt collectors, legal advisors and trade insurers;
- third party suppliers involved in processing and delivering any order placed with Mun such as transporters, warehouses, financial institutions, merchants and payment organisations;
- third party suppliers involved in reviewing, maintaining and upgrading Mun’s business systems;
- organisations with which we run or organise promotions, competitions or award programs or which supply a prize or reward;
- distributors, retailers and other customers of Mun, and suppliers of Mun, for the purpose of promotions they may run relating to Mun products;
- distributors, retailers, service providers and other customers of Mun for the purpose of obtaining consumer research services;
- any contractor Mun arranges to provide mailing services;
- any contractor Mun engages for web-hosting or other website related services.
Mun may also disclose information where:
- You have provided your consent;
- We are required to answer a subpoena;
- We believe it is necessary to assist in lessening or preventing a serious threat to life, health or safety of any individual, or to public health; and
- We believe it is reasonably necessary in taking action in relation to suspected unlawful activity, serious misconduct, locating a missing person or as is required or authorised under Australian law or a court/tribunal order.
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 Malaysia, China, 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. ACCESS TO YOUR PERSONAL INFORMATION
On request, you may have access to your personal information held by Mun, except in circumstances where access may be denied under the 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. CORRECTING 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.
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).
Contact details for Mun’s privacy officer are:
Mun (Australia) Pty Ltd
Suite 305, 51 Rawson Street
Epping NSW 2121
Phone: +61 2 9868 7708
Fax: +61 2 9868 7738