Under the Privacy Act, “personal information” means information which identifies you as an individual or from which your identity can be reasonably ascertained (and regardless of the form of the information, and regardless of whether it is true or not). In this Policy “credit-related information” means credit information, credit eligibility information (as those terms are defined in the Privacy Act) and similar information relating to credit worthiness. Credit-related information includes (but is not limited to) information regarding identification, information regarding your application with us, and credit reporting information that we obtain from credit reporting bodies or which we derive from such reporting information.
2. What types of personal information do we collect?
We only collect personal information if it is necessary for one of our functions or activities. The types of personal information we collect will depend on the reason for collection. Generally, the information we collect about customers includes name; home, delivery or business address; demographic information like gender and age; contact/phone number; payment, bank account, credit and billing information; e-mail addresses records of communications with us, details regarding participation in any of our loyalty or rewards campaigns from time to time and, on occasion, drivers licence number (for identity verification purposes) and agronomic information relating to paddocks and farms. Financial information that is collected via our website is used by us to bill you for products and services. Any bank account and credit card numbers that are collected are collected for the purpose of transaction approval and funds transfer and are securely held.
We may not be able to provide our products or services, or make offers to you without your personal information. Sometimes, customers can purchase goods from us without disclosing personal information, but in this situation we may not be able to provide you with the full range of services available.
In addition we collect personal information relating to:
- people involved in or through organisations that we support or sponsor;
- our distributors, agents, suppliers, partners and their employees. This information is collected for business-related purposes but contains some limited personal information contact details of the people that we deal with;
- people who correspond with us, including through our website, in which case we may keep a copy of that correspondence and relevant contact details;
- job applicants: employment and academic histories, the names of their referees and, in some cases, limited health information based on testing undertaken by or for us. We will collect this information directly, from organisations that provide recruitment related services to us, and from third parties who provide job applicants with professional or personal references.
When you visit our websites and mobile/ tablet applications we collect information using cookies, server logs and Google Analytics (including the Google Analytics Advertising remarketing feature). Our website and mobile/ tablet applications will record/log your IP address (the address which identifies your computer on the internet and which is automatically recognised by our web server), date and time of visits to our sites/applications, the pages viewed and any information downloaded. This information (and our cookies and the third party cookies referred to above) will be used for the purpose of site/application analysis, to help us offer an improved online service and to enable advertisements for our goods and services to be placed when our website and certain third party websites are visited by users who have previously visited our website.
Our site may contain links to other sites. We are not responsible for the privacy practices or policies of those sites and recommend that you review their privacy policies.
When you view our electronic direct mail, information is also collected for the purpose of analysis and to help us offer you improved communication. Data collected includes information such as opening times, opening rates, location, click throughs and device used for viewing of the email.
3. How we collect and hold personal information
We collect personal information in a number of ways from individual persons in different situations.
In particular, we collect personal information from when:
- website users fill out an on-line registration form or send an e-mail;
- people fill out a credit application form or a guarantee form;
- people contact one of our customer service centres;
- people enter competitions run by us;
- people enter into an agreement or fill out an order form for goods or services (whether through our websites or otherwise);
- people interact with us on social media in a manner which identifies them.
Where it is reasonable and practicable to do so, we collect your personal information directly from you when you correspond or register your details with us, enter into arrangements with us, or provide feedback to us. Depending on the nature of our interaction with you, we may collect personal information from third parties – for instance, information regarding our customers provided to us by fertiliser selling agents or distributors, or our agronomic data or precision agriculture service partners. We will also, from time to time, collect personal information from our related companies, credit insurers, credit reporting bodies or (where you consent) your accountants and professional advisers.
We hold personal information electronically and, in some cases, hard copy form, both at our own secure premises and with the assistance of our service providers. We take all reasonable steps to ensure that the personal information that we hold is protected from loss, misuse, unauthorised access by ensuring that this information is held on secure servers in controlled facilities and that information stored within our computer systems can only be accessed by those entrusted with authority and computer network password sanctions.
4. Why we collect, hold and use personal information
We may use personal information for the primary purpose for which it is collected (eg. provision of our services, including administration of our services), or for purposes related to the primary purpose where it would reasonably be expected that we would use the information in such a way, or in other limited circumstances set out in the Privacy Act.
We collect, hold and use personal information to:
- provide, deliver, source, administer, improve and personalise products or services to you and to process transactions, applications, credit applications, credit checks, and collect monies owing to us;
- administer your account
- better understand and evaluate the needs of our customers; develop new products and services and tell you about changes to our products and services
- conduct product and market research, personalise and improve our service and to provide offers that are of greater interest or benefit to you
- undertake and administer promotions, competitions, database compilation, analysis of trends and demographics and other marketing or promotional activities;
- send you marketing and direct marketing communications about our products and services (whether by phone, email, SMS, post), offers and opportunities (including competitions) that we believe that you may be of benefit to you or that you may be interested in (even if you are no longer purchasing goods or services from us), unless you inform us that you do not wish to receive such direct marketing communications;
- to communicate with customers and suppliers and to operate the customer service centre
- source products for sale, transport products, and ensure our suppliers comply with our sourcing policies
- recruit and assess potential employees;
- maintain and update our records;
- enable third party service providers to provide us and our related companies with services such as information technology, credit checking and debt collection, marketing, auditing, legal advice, printing and mailing services;
- investigate feedback and complaints;
- correspond with people who have contacted us, and deal with feedback;
- where required or permitted by law, or where we think it is required as part of an investigation, on health or safety grounds.
When we request your information we may give more specific details about the way we use or disclose your information.
5. Why we disclose personal information
We do not disclose personal information to third parties unless we are permitted to do so by law or we have obtained consent to do so. We may disclose personal information for the primary purpose for which it is collected or for purposes related to the primary purpose where it would reasonably be expected that we would use the information in such a way. Also, we are permitted to disclose personal information in circumstances set out in the Privacy Act (including but not limited to disclosures to our related companies).
Third parties we may disclose personal information to include:
- our related companies
- our service providers and professional advisors including IT service providers, auditors, legal advisors, print and mail houses, advertising agencies, transport contractors, marketing research advisors, credit reporting bodies, mapping & analysis service providers, mercantile agents and debt collectors
- our fertiliser distributors and agents who you deal with;
- agronomists and agricultural consultants that you deal with;
- our credit insurers;
- financial institutions; and
- regulatory or government agencies.
We take steps to ensure that our service providers are obliged to protect the privacy and security of personal information and use it only for the purpose for which it is disclosed.
The third parties to whom we disclose personal information may be located in Australia and other countries including USA. Examples of overseas disclosures are where it is necessary for making international payments, in complying with foreign legal or regulatory requirements (especially in countries we deliver chemicals to), or in providing data to relevant software owners in circumstances disclosed to you. We may use cloud computing solutions or data storage located overseas in which case information may be stored, under our control, on computer servers located outside of Australia.
6. Credit reporting and credit information privacy
The way in which we collect, hold, store and use credit-related information about you is similar to the ways in which we collect, hold, store and use other personal information. The types of credit – related information that we collect about you is detailed in Sections 1 and 2 of this Policy, in addition (where you are a commercial customer or guarantor) we may sometimes seek information about assets that you hold and information about your business trading position and history.
- either collect that information from you directly, or we will obtain it through third parties or the credit reporting system as set out in Section 3 of this Policy;
- use that information for several purposes, including establishing your account with us to enable us to provide you with goods and services and collect monies owing to us; and
- disclose that information for several purposes and to several people including legal advisors, print and mail houses, marketing research advisors, credit reporting bodies, credit insurers, mercantile agents, debt collectors and (where you give your consent) people guaranteeing the payment of your account.
We participate in the credit reporting system. If you apply for credit with us, we may request a credit report about you from a credit reporting body. These credit reports contain information about you which assists us to assess your application, including information about your credit history with other credit providers.
Credit reporting bodies can provide credit providers with credit reports in certain circumstances, including when an individual makes an application for credit, or when a credit provider is seeking to help an individual avoid defaulting on their credit. Credit reports are designed to assist credit providers to accurately assess an individual’s ability to repay credit.
To request a credit report, we will provide information to the credit reporting body that identifies you, as well as information about your application – including the type and amount of credit you are applying for.
We will often combine the information obtained from a credit reporting body with information that we already hold about you. For example, when we assess your application for credit, we may combine the information you provide on your application with the information contained in your credit report obtained from a credit reporting body to calculate a rating or score. This will determine whether you qualify for the credit you are applying for.
Some information about the credit you hold with us may be disclosed to a credit reporting body so it can be included in your credit report and shared with other credit providers that request a report from that credit reporting body.
We note that:
- Credit reporting bodies may include the information in reports provided to credit providers to assist them to assess your credit worthiness;
- If you believe (on reasonable grounds) that you have been, or are likely to be a victim of fraud, you have a right to request credit reporting bodies not to use or disclose your credit reports they hold about you. You can do this by contacting them directly. If you make such a request, a credit reporting body will not disclose information about you for 21 days. You can request an extension to this period if you believe you are still, or still likely to be, a victim of fraud;
- you may request that credit reporting bodies not use your credit reporting information for the purposes of pre-screening for direct marketing by a credit provider.
7. Accessing and correcting your personal information, and complaints and questions
You can request access to your personal information held by us, or request that it be corrected, by contacting us at the address below. To ensure confidentiality, details of your personal information will be passed on to you only if we are satisfied that the information relates to you. A fee will not be charged for an access request, but you may be charged the reasonable expenses we incur (such as search and copying costs). If we refuse to provide you with access or correct the personal information held about you by us (in accordance with the Privacy Act), then we will provide reasons for such refusal.
If you wish to make a formal complaint, please make your complaint in writing to our Privacy Officer. We will consider your complaint promptly and contact you to seek to resolve the matter. If we have not responded to you within a reasonable time or if your concerns are not resolved to your satisfaction, you are entitled under the Privacy Act to make a complaint to the Office of the Australian Information Commissioner.
CSBP Privacy Officer
PO Box 345
Kwinana WA 6966
Telephone: (08) 9411 8777
Office of the Australian Information Commissioner Website: www.oaic.gov.au
Phone: 1300 363 992
CSBP Limited ABN 81 008 668 37