Bubs Australia Ltd
ACN 060 094 742

  

1. Commitment to Privacy

Bubs Australia Ltd and its group companies (“we”, “us” and “Bubs”), are bound by laws and regulations applying to privacy and data protection in Australia, including the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) (Privacy Laws). The object of the Privacy Laws is to protect the confidentiality of Personal Information and the privacy of individuals by regulating the way in which that personal information is managed.

“Personal Information” means information or an opinion about an identified individual or from which an individual can be reasonably identified.  It includes “Health Information” which is information about an individual’s physical or mental health, a health service provided to an individual, as well as details of what medicines they use. 

Bubs is committed to protecting the Personal Information it collects and regularly monitors its systems and procedures to ensure compliance with Privacy Laws and this Policy. This Policy outlines the way in which Bubs deals with the Personal Information it collects in Australia.

 

 2. Collection

Bubs collects Personal Information that is reasonably necessary for or directly related to our functions and activities as a provider of infant nutrition.   In some cases we may be required by law to collect Personal Information in order to comply with our regulatory obligations such as responding to safety concerns about our products.

Bubs may collect Personal Information about you through our interactions with you. Personal Information may be collected by Bubs in the course of:

1. Responding to product queries and providing technical assistance about our products
2. Purchasing products via the Bubs e-store or follow-up meetings with our sales or customer service representatives
3. Signing up for the Bubs e-news letter
4. Participation in Bubs sponsored programs, including marketing events and educational programs
5. Using our customer or information services

The Personal Information we collect may include:

1. Your name
2. Your address
3. Your date of birth
4. Your email address
5. Your phone number

 

3. Use and Disclosure

We will inform you about the purpose and use of collected Personal Information.

Bubs will use or disclose your Personal Information for the primary purpose for which it is collected, which generally includes the following purposes:

1. In the course of the sale, distribution or provision of Bubs branded products
2. Administering training programs or marketing activities in which you agree to be involved
3. Compliance with regulatory requirements, such as maintaining a record of complaints, adverse events and recalls relating to our products.

We may also use your Personal Information to:

1. Provide you with updated product or safety information if necessary
2. Send you material on our activities and products or developments in infant nutrition that Bubs believes may be of interest to you
3. Manage, plan and arrange meetings between you and Bubs representatives
4. Generate customer lists for the purposes of market research
5. Manage accounts and ensure that we receive payment for our products

We will only use or disclose your Personal Information for a purpose that was not the primary purpose for which we collected it if you would reasonably expect us to do so or if we have your permission.  We may also use or disclose Personal Information if we are required or authorised by law to do so.

If you do not wish to receive information or materials about Bubs products and updates, you may request not to receive these marketing materials by sending us an “Opt Out Notice”. The Opt Out Notice should be addressed to:

The Privacy Officer (General Counsel)

Email: info@bubsaustralia.com

Address:  23-29 Nina Link, Dandenong South. VIC 3175 Australia. 

Once Bubs receives your request, we will add your name to a no contact list for marketing purposes. 

When dealing with particularly sensitive Personal Information, such as your Health Information for a purpose that is not directly linked to the primary purpose of collection, Bubs will generally seek your consent before using the Health Information.  In only very limited circumstances, such as where required by law to disclose information or in the event of a serious threat to your life or health, will we disclose your Health Information without your consent.

 

4. Cross Border Data Disclosure

As part of a group of companies, we may disclose some Personal Information to another Bubs company or third party IT provider that maintains Bubs’ secure databases from an overseas location.  In disclosing data offshore, Bubs ensures that the use and disclosure of the Personal Information transferred is dealt with in accordance with this policy and the safeguards under Australian Privacy Laws.

 

5. Transfer of Data to Third Parties

Bubs will not sell your Personal Information to any third party for any purpose. Selected third parties may be used to provide Bubs with support services in connection with our business operations, for example database IT support or media relations.  Such third parties may, from time to time, have access to your Personal Information to enable them to provide those services to Bubs.

All companies providing such support services are required by Bubs to process the Personal Information disclosed to them only for the purposes expressly authorised by Bubs. Further, third parties are required by Bubs to meet our standards of data protection and comply with the safeguards under Australian Privacy Laws.

 

 6. Data Security

Bubs has put in place safeguards to protect the Personal Information we hold from misuse, loss and unauthorised access, modification or disclosure. Bubs generally holds the Personal Information you provide to us in an electronic form on computer servers, which are password protected for limited access and are located in controlled facilities. However Bubs may also hold Personal Information in physical form, such as in paper hard copies. While Bubs cannot guarantee against any loss, misuse or alteration to data, we take reasonable steps to prevent such occurrences. 

Access to the Personal Information is restricted to those employees who need to use the data, who have been trained to handle such data properly and observe strict standards of confidentiality. Bubs destroys or permanently de-identifies Personal Information that we no longer need, where permitted.

 

7. Access, Correction and Complaints

You have the right, in most cases, to access Personal Information at any time. Bubs takes reasonable steps to ensure that any information we hold about you is up-to-date, accurate and complete. If you wish to access or correct Personal Information we hold, or you have any questions about this Policy or concerns/complaints about privacy, please contact us at the address set out in clause 3, or call our Privacy Officer on +61 2 9905 0050, setting out a full description of the matter that you would like to raise.

We will respond to your complaint within a reasonable period, usually within 30 days.

 

 8. Cookies

Cookies are small files sent to your computer as you surf the web. They store useful information about how you interact with the websites you visit. Cookies do not collect any information stored on your computer or device or in your files. Cookies do not contain any information that would directly identify you as a person. Cookies show your computer and device only as randomly assigned numbers and letters (e.g., cookie ID ABC12345) and never as, for example, Sarah Smith.

We use cookies for a number of reasons, such as:

• to serve you with relevant advertising
• to learn more about the way you interact with Bubs content
• help us improve your experience when visiting our website
• to remember your preferences, such as a language or a region, so there is no need for you to customise the website on each visit
• to identify errors and resolve them
• to analyse how well our websites are performing

These are the types of cookies we use:

• session cookies. Webpages have no memory. Session cookies remember you (using a randomly generated ID like: ABC12345) as you move from page to page so that you don’t get asked to provide the same information you’ve already given on the site. For example, session cookies are extremely helpful when shopping online—without them the items you place in your shopping cart would disappear by the time you reach the checkout. These cookies are deleted as soon as you leave our site or close your browser.
• persistent cookies. Persistent cookies allow sites to remember what you prefer when you come back again. For example, if you choose to read the site in French on your first visit, the next time you come back the site will appear automatically in French. Not having to select a language preference every time makes it more convenient, more efficient, and user-friendly for you.
• advertising cookies. These cookies can be used to learn about what interests you generally might have, based, for example, on the websites you visit and the products you buy. This can also help us infer things about you such your age, marital status, and how many kids you may have. That data allows us to send you ads for products and services that better fit the things you like or need. It also allows us to limit the number of times you see the same advertisement.
• analytics cookies. These cookies tell us how our websites are working. In many cases, we use Google analytics cookies to monitor the performance of our sites. Our ability to use and share information collected by Google Analytics about your visits to our sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

How you can control cookies: You can set your browser to refuse all cookies or to indicate when a cookie is being sent to your computer. However, this may prevent our sites or services from working properly. You can also set your browser to delete cookies every time you finish browsing.

 

 9. Updating our Privacy Policy

Bubs may review or revise this Privacy Policy and the way we handle Personal Information from time to time. Such changes will be consistent with Privacy Laws. You may request a copy of our Privacy Policy at any time.