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Privacy Policy and Collection Statement

Privacy Policy

(Last updated: 5 February 2015)


Introduction

Heinemann Australia Pty. Ltd. (ACN 159 521 338) ("Heinemann" or "we") recognises and values the importance of protecting the privacy of our customers.

This Privacy Policy informs you of how we collect, hold, use and disclose any of your personal information in connection with the operation of our online store at www.heinemanndutyfree.com.au (the "Webshop”). This Privacy Policy is broken into a number of sections and includes information on how we manage personal information as well as answers to commonly asked questions.


What is personal information?

In Australia, the collection, storage, use and disclosure of "personal information" is regulated by the Privacy Act 1988 (Cth) (the "Act"). The Act defines “personal information” as:

…information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable

The definition of “personal information” is therefore extremely broad, but good examples would include your full name and your address.

Schedule 1 of the Act also sets out thirteen Australian Privacy Principles (the "APPs") which comprehensively cover the protection of personal information. You can feel confident that we will always collect, hold, use and disclose any of your personal information in accordance with the Act, the APPs and this Privacy Policy.


Why do we need to collect your personal information?

The Webshop is more complicated than a traditional “real world” shop, because you can’t simply walk in off the street and anonymously purchase goods using cash. The Webshop is also more complicated than other online shops that you may use, in that we:

  • don’t deliver goods to your home address, but instead require you to pick up those goods at the Airport
  • are required to verify your identity when you pick up those goods, as you will have paid for them in advance
  • must also verify your entitlement to specific goods (including your entitlement to a specific quantity of such goods and/or particular pricing for such goods), because such goods are duty free and, in some cases, age restricted and/or specially discounted
  • need to be able to contact you, for example if you don’t collect your purchased goods within a reasonable period of the agreed collection date
For the above reasons, we need to collect, store, use and disclose your personal information as part of the normal operation and functioning of our Webshop business.

Because your identity is fundamental to the transactions between us at the Webshop, it is not practicable for you to transact with us anonymously or using a pseudonym. However we will always endeavour to collect the minimum amount of your personal information that is practicable in the circumstances.


Collection, use and disclosure

How will we collect your personal information?

We will always interact with you in an open and transparent manner, including by informing you:

  • when we collect your personal information
  • how we will manage your personal information
At the time of collection of your personal information, we will provide you with a copy of our collection statement which will also refer to this Privacy Policy.


What personal information will we collect?

In order to operate the Webshop, we need to collect a sufficient amount of your personal information to allow us to undertake our functions, and to allow any transactions between us to take place efficiently and securely.

You will be able to browse the products in our Webshop anonymously, although we may request you to confirm your age before viewing certain products. However, in order to purchase goods via the Webshop you will need to create an account with us. When creating an account, we will request that you provide us with the following personal information:

  • your full name and prefix (e.g. Mr or Mrs), so that we can identify you
  • your primary telephone number, so that we can contact you if there is a problem
  • your email address, so that we can correspond with you electronically and administer your account (e.g. password resets)
  • your date of birth, so that we can verify both your identity (for example if you have a relatively common name such as "John Smith") and your entitlement to particular goods such as tobacco or alcohol
  • the type of identification you will use on collection, such as your passport or other proof of entitlement (such as an airline staff ID) so that we can:

  • - identify you when you collect your goods
    - verify your entitlement to purchase particular goods (including your entitlement to a particular quantity of goods and/or particular pricing for such goods)

  • your nationality as stated on such identification, for example your passport
  • your flight number (including your airline and your international travel destination) and your dates of arrival and departure (as relevant) so that we can:

  • - verify your entitlement to purchase particular goods (including your entitlement to a particular quantity of goods and/or particular pricing for such goods)
    - determine when you are likely to physically collect your purchased goods at the Airport
We will never collect “sensitive” information about you. Sensitive information includes certain kinds of information about you, such as your political opinions or your racial or ethnic origin.


What will we do with your personal information?

We will use your personal information for a number of purposes associated with the operation of the Webshop or as otherwise required or authorised by law.

The primary purposes for which we will use your personal information are to allow us to:

  • provide you with functional access to the Webshop, including the ability to purchase goods, use the shopping cart and maintain a user account with us
  • verify your entitlement to particular goods (including an entitlement to a particular quantity of goods and/or particular pricing for such goods), for example age-restricted goods such as tobacco or alcohol or specially discounted goods
  • contact you in respect of the Webshop, for example if you fail to collect your goods within a reasonable period of the agreed collection date or if you have lodged a complaint
  • determine the date and location where you are likely to collect the purchased goods
You will be able to browse the Webshop without providing us with any personal information, although we may ask you to verify your age before viewing certain goods. However, if you do not provide us with the requested personal information and agree to us using it for the above primary purposes, you will regrettably not be able to purchase goods via the Webshop. We would be happy to assist you to purchase such goods at any of our physical “real world” outlets at Sydney Airport.

In order to collect your purchased goods at one of our collection points, we will require you to show your passport or the other ID you used at the time of purchase which we will use to confirm the information you have previously provided to us. We may update your registered account details at this time, for example if you have provided us with an incorrect date of birth when creating a user account. We may also scan your passport and boarding pass for the purposes of reporting to Sydney Airport Corporation Limited, however such any such information will be anonymous and aggregated in nature only.

The secondary purpose for which we will use your personal information is to allow us and our selected partners to send you direct marketing in relation to our respective goods and services. If you do not agree to us using your personal information for this secondary purpose, you should just notify us of this at the time you create a user account. You can also change your mind at a later date.


Who will we disclose your personal information to?

We are part of an international group of companies with a head office in Germany, which is located within the European Union, and local operations in Singapore. We will disclose your personal information to members of our corporate group located in Germany and Singapore for the purposes set out above, however we will take such steps as are reasonable to ensure that such recipients continue to hold your personal information in accordance with the Act, the APPs and this Privacy Policy. From time to time, the Webshop (or certain aspects of the Webshop) may also be hosted on servers located in either or both of Germany and Singapore, and your personal information will necessarily be transferred between Australia and those countries in connection with the operation of the Webshop.

We will also disclose your personal information: (a) to our suppliers in Australia, to the extent necessary for any orders you place via the Webshop to be fulfilled, (b) as otherwise required or authorised by law.

Finally, we are also required to provide certain information to Sydney Airport Corporation Limited where our physical stores and collection points are located. However, in most cases such information will be anonymised and aggregated in nature, and it will not be possible for you to be identified from this.

We will never sell your personal information.


Direct Marketing

Direct marketing is where we or our partners contact you directly to offer you goods and services, using the personal information you have supplied to us.

We will only engage in direct marketing if you have agreed to this at the time of registration for the Webshop and you may change your mind at any time. When registering, you will be asked whether you wish to receive direct marketing materials from us and our partners. You do not need to agree to this to use our Webshop and you will only receive such materials if you have ‘opted-in’.

If you initially agree to receive direct marketing materials but subsequently change your mind, there are a number of ways by which you can unsubscribe or ‘opt-out’. Firstly, you can log on to your user account at the Webshop and change your preferences and settings. Secondly, you can in many cases unsubscribe via the marketing materials themselves. For example, any direct marketing emails we send to you will contain a functional “unsubscribe” feature which will always be valid for at least 30 days from the date of the communication. Finally, you can always change your marketing preferences by contacting our Customer Service Centre on the contact details below.

We will never use or disclose your personal information for the purpose of sending you spam, that is, unsolicited commercial messages which offer or advertise goods or services.


Security

General tips on security

We urge you to take your own privacy seriously and to take steps to protect it. We recommend that you never share your account details or password with anyone, as they are both unique to you.

You should always remember to close your browser window when you have finished communicating with us, especially when you share the computer or device with others.


How will we hold your personal information?

We are committed to storing your personal information as securely as possible.

We will take all reasonable to steps to protect your personal information from misuse, loss, interference and unauthorised access, modification or disclosure, using the most modern technology. In particular, we will store and protect your personal information using a Secure Socket Layer (SSL), which is an encryption method widely used throughout the World Wide Web. All personal information will be encrypted and secured during transmission through the Internet. You will recognise the symbol (a closed padlock) in the lower bar of your browser window, which indicates that you are in a secure area at that time.

We regularly review and monitor the adequacy of our security measures, and would welcome any feedback you may have.


Why do we use cookies?

The use of cookies is extremely important to the smooth functioning of online stores such as the Webshop. Cookies are small text files that many websites place on your computer or device. Most often, cookies are used to recognise repeat users of websites and to remember their user preferences.

We use cookies to allow you to remain permanently signed into the Webshop and to allow you to continue to browse for goods while selected items are waiting in your shopping cart.

Most browsers are automatically set up to accept cookies. The storage of cookies can be deactivated or the browser can be configured in such a way that it sends a notification when cookies are sent. You are always free to decline our cookies, however doing so may significantly interfere with your use of the Webshop.

We will never use cookies for the purpose of "online behaviour advertising".


Access, complaints and corrections

Access to your personal information

You are entitled to access the personal information we hold about you, on request, subject to a limited number of exceptions. If for some reason we are unable to provide you with access to your personal information, we will provide you with our reasons in writing as well as your further options for complaint.

You may make an access request via the contact details below and we will respond to your request within a reasonable period. Ordinarily, we will require you to attend our office to access your personal information in secure circumstances, however we will give reasonable consideration to any other access procedure you may suggest in writing where it is practicable to do so (in whole or in part). We will not ordinarily charge you for gaining access to your personal information.


What if your personal information is wrong?

We will take reasonable steps to ensure that the personal information we hold, use and disclose is accurate, up to date and complete. However, we will not take any administrative steps to verify the accuracy or completeness of the information you provide to us at the time of collection (for example, if you make a mistake when typing in your details).

If you suspect or believe that the personal information we have is not accurate, complete or up to date, please contact us at the details below and we will respond to your request within a reasonable period. When responding, we will take reasonable steps to correct that information and to ensure that it remains accurate, complete and up to date in the future. If for some reason we are unable to correct your personal information, we will provide you with our reasons in writing and your further options for complaint. We will not ordinarily charge you for requesting the correction of your personal information.


How long will we keep your personal information?

We will also take such steps as are reasonable to destroy or anonymise/de-identity any personal information we hold about you where we no longer need that personal information for the purposes for which it was disclosed. Particularly where you have purchased goods from us, we will need to keep your personal information for a relatively significant period of time (for example, in respect of your warranty entitlements).


Complaints

If you believe that there has been a breach of the APPs, you may lodge a complaint with us via the contact details below. We will review your complaint and gather any relevant paperwork or documentation before responding which will ordinarily be within 30 days of receipt of your complaint. When we respond, we will give you written reasons for our decision. If you remain dissatisfied with our response or the reasons given, you may lodge a formal complaint via the Office of the Australian Information Commissioner at www.oaic.gov.au.


How do you contact us?

If you would like further information about how we manage your personal information, or if you have any queries relating to our Privacy Policy or would like to make a complaint, please contact our Privacy Officer at:

Mail:
Heinemann Australia Pty Ltd
PO Box 3027
Sydney International Airport
Mascot NSW 2020


Telephone:
Australian toll-free Service Hotline:
1800 46 46 66

International calls:
+61 2 9667 6800

E-Mail: privacy@heinemanndutyfree.com.au


Changes to this Policy

From time to time, we may amend this Privacy Policy and will publish the amended version via the Webshop.
You may also request a physical copy of the Privacy Policy by contacting our Customer Service Centre on +61 2 9667 6800.



Collection statement

(required under APP 5)

(Last updated: 5 February 2015)

Heinemann Australia Pty. Ltd.(ACN 159 521 338) ("Heinemann" or "we") are collecting your personal information in connection with the operation of our online store at www.heinemanndutyfree.com.au (the "Webshop”).

Our Privacy Policy, which can be found at Privacy Policy provides you with further information on how we collect, store, use and disclose your personal information. It also explains what “personal information” is and the nature of the Australian Privacy Principles (which can be found at www.oaic.gov.au).


Collection and use of personal information

We will collect your personal information in connection with the operation of the Webshop, including to allow us to provide you with functional access to many of its features. Functional access includes the ability to purchase goods, use the shopping cart and maintain a user account with us.

We will also use your personal information to verify your entitlement to particular goods (including an entitlement to particular quantities of goods and/or particular pricing for such goods), to contact you in respect of the Webshop (for example if you fail to collect your purchased goods) and to determine the date and location where you are likely to collect the purchased goods. If you do not provide us with the requested personal information and agree to us using it for the above purposes, you will regrettably not be able to purchase goods via the Webshop.

We may also use your personal information for the related purpose of allowing us and our selected partners to send you direct marking materials. If you do not agree to us using your personal information for this purpose, you should simply notify us of this and you will not receive (or no longer receive) such materials. There are no other consequences of you so notifying us.

We will always collect your personal information directly from you (including via the registration form at the Webshop) and will never collect your personal information from anyone else.


Disclosure of your personal information

We are part of an international group of companies and, as such, we may disclose your personal information overseas in accordance with our Privacy Policy. Such recipients are likely to be located in Germany and Singapore, where our head office and Asia-Pacific operations are respectively located.

We will also disclose your personal information to Sydney Airport Corporation Limited (where our physical stores and collection points are located) and to our suppliers within Australia (to the extent necessary for any orders you place via the Webshop to be fulfilled). Our disclosures to Sydney Airport Corporation Limited may also include anonymised, aggregated data about your transactions with us.

We will never sell your personal information.


Further information

Our Privacy Policy sets out how you may seek to access or correct the personal information that we hold on you.

It also contains our contact details and sets out how you can complain if you believe that there has been a breach of the APPs, and how we will deal with such a complaint.