The privacy of your Personal Data is important to PILLAR Performance PTY LTD. and its affiliates (referred to collectively as “PILLAR”, “we” or “our”) and we are committed to ensuring that your personal data is handled responsibly, in accordance with the applicable 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”).
“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.
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:
Personal details about you such as your name, gender, date of birth, residential and business addresses, telephone numbers, email and other electronic addresses; If you have registered on our website, we may collect any information from your browser and our servers that may be connected to the contact details you gave when you registered, such as username, password, profession, company, etc. Other details relating to your relationship and dealings with us. Information that you voluntarily provide to us through your responses to competitions, surveys, search functions, questionnaires, feedback, ratings and reviews.
Credit card information we collect from you will go directly to our processor or bank and no personnel of PILLAR 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.
We collect such Personal Data from you in a number of ways, including:
Directly from you, such as when you enter your personal details on our websites (for example during registration or application for products and services), when you provide information by phone or in documents such as an application form;
from our affiliated companies; from your representatives; from our agents or service providers when engaged by us to do so or by other third parties, such as from referees, to verify the information you have provided us or to assist us to locate or communicate with you from sources where you’ve made your information publicly available. 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 pillar performance.com.au (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 PILLAR. We will use your Personal Data to:
- Identify you. We do this because it is in our legitimate interest to make sure that your enquiry is genuine and is not being made for fraudulent reasons or is spam. We may also do this because we may be subject to legal obligations which require us to confirm the details that you provide us with before entering into a relationship with you.
- Create an account when you register with us. We will do this because it is in our legitimate interest to use your Personal Data to communicate with you, to respond to your requests and to develop the relationship between us in the context of establishing and operating your account. If you submit Personal Data comprising an email address to PILLAR, we may send you product and/or service related emails (e.g. transactional emails, service and policy updates in respect of matters related to or arising from the use of this Website) because it is in our legitimate interests to keep you informed of your account activities or service changes. It may also be necessary for us to: use your Personal Data to perform an agreement with you, where we would be unable to provide those services without that information; use your Personal Data to comply with a legal obligation relating to how we manage our relationship with you.
- Provide, administer and manage services and carry out obligations arising from any contracts entered into between us, such as but not limited to online purchases. In these circumstances, we will use your Personal Data to perform an agreement with you because we would be unable to provide those services without that information;
- Monitor your use of the Website to ensure that content from our Website is presented into the most effective manner, to view given your device and to help the further development of the Website by compiling aggregate statistics about our users to analyse Website usage. We do this because it is in our legitimate interests to understand user behaviour so that we can ensure that we present information on the Website that is of most interest to users and to ensure that information is displayed to you correctly and in a user friendly way.
- To enable PILLAR to conduct research and/or analysis and gather feedback and reviews on the use of its Website and to evaluate and improve our products and/or services. We do this because it is in our legitimate interests to understand the trends in the use and consumer tastes and the popularity of our products and services so that we can adapt existing and offer new services based on this research and analysis.
- Conduct communications between you and PILLAR and respond to feedback with regard to your needs and expectations of services and/or products we offer. We will do this because it is in our legitimate interest to use your Personal Data to communicate with you, to respond to your requests about the services and facilities you require and to develop the relationship between us in the context of your use of our Website.
- Comply with various Australian laws, which may either expressly or in effect, require us to collect your Personal Data. Such laws include the Commonwealth Taxation Administration Act, Income Tax Assessment Act and other taxation laws (for example, to comply with information requests issued by the Federal Commissioner of Taxation) and employment laws (for example the Fair Work Act).
- Provide you with information related to PILLAR including the products, services, news, events and other privileges, benefits and other advantages from time to time offered by Swisse, where you have opted in to receive this information.
- 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 personalised Website experiences, to share information about relevant products and services, news and events in relation to PILLAR.
We shall not use your Personal Data for marketing communications unless we have received your consent.
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. 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 pillarperformance.com.au, we may automatically collect information such as your IP address and browser type using cookies, log files, and pixel-tags. This automatic data is primarily used for delivering and optimising services offered by us, such as:
- authenticating your identity and confirming whether you are currently logged in as you move through the Website. Your browser allows us to place some information (e.g., session based IDs and/or persistent cookies) on your computer’s hard drive that identifies the computer you are using.
- tracking your usage across our Website in order to provide you with relevant, personalised content;
- improving our services, whereby we may occasionally display different versions of content to you and measure your usage of our web site pages.
To the extent this information constitutes Personal Data, we use it to ensure that content from pillarperformance.com.au 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.
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 pillarperformance.com.au you agree to disclosures to the following third parties:
- related entities, commercial partners (including parties with whom we have various types of commercial arrangements) and affiliates;
- service providers;
- other companies and individuals which we employ to provide you promotional and informational offers on behalf of PILLAR, such as email marketing services (e.g. analysing customer lists, deliverability statistics, opens and clicks), marketing assistance or consulting services. These third parties may have access to information needed to perform their function but can not use that information for any other purpose;
- advertisers, which may collect aggregated statistics from the Swisse websites;
- payment processors who will collect your payment information if you choose to purchase a product from us;
- credit reporting agencies and other financial institutions including our own bankers, service providers; our professional advisers, such as our accountants, auditors and lawyers, insurers and industry groups having a legitimate reason to receive such information.
- other persons that we need to deal with in connection with engagement of staff (such as training or medical providers, insurers, next-of-kin, referees); and
- other persons and entities as permitted under the Privacy Act (such as insurers).
STORAGE AND TRANSFER OF YOUR PERSONAL DATA TO OTHER COUNTRIES
If you provide Personal Data to PILLAR, it may be transferred to, processed in, stored at or accessible from a destination outside Australia. 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.
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.
ACCESSING AND CORRECTING YOUR INFORMATION
You have a right to access the Personal Data that we hold about 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.