Privacy Policy
Version dated: 2 February 2024
a2 Exports Australia Pty Limited (ABN 37 154 919 365) (‘a2EA’, ‘we’, ‘us’ and ‘our’) recognises the importance of your privacy. We abide by the Privacy Act 1988 (Cth) (the ‘Privacy Act’), including the 13 Australian Privacy Principles in the Privacy Act.
1 Updating this Privacy Policy and what to do if you don’t agree
1.1 We may update this Privacy Policy from time to time. You may obtain a copy of our current policy from the Website or by contacting us directly using our contact details in section 8.2 below.
1.2 If you do not agree to the processing of your personal information in the way this privacy policy describes, please do not provide your information when requested and stop using the Website or purchasing any product via the Website. By using the Website and purchasing any product via the Website, you are accepting our processing of your personal information as described in this privacy policy.
1.3 Any capitalised terms which are not defined in this Privacy Policy will be given the definition in the a2 Store® Terms and Conditions, accessible at https://www.a2milk.com.au/policies/terms-of-service.
2 What this Privacy Policy does apply to
This Privacy Policy sets out, specifically in relation to your use of the a2 Store® (https://www.a2store.com.au) (our ‘Website’):
(a) the way we collect, store, use, disclose and otherwise handle (together, ‘process’) your personal information (as defined under the Privacy Act);
(b) how we aim to protect the privacy of your personal information; and
(c) your rights in relation to your personal information.
3 What this Privacy Policy does not apply to
3.1 Please be aware that this Privacy Policy applies to dealings with us in respect to your use of the Website and purchases of product via the Website only. The applicable privacy policy will not apply to any other dealings with us including dealings via our other websites or in respect of our other website services.
3.2 You can find the The a2 Milk Company group’s general privacy policy which will apply here: https://thea2milkcompany.com/privacy-policy
3.3 This Privacy Policy also does not apply to any other third party website or application which you access using a link from the Website. In this case the privacy policy of the owner of the linked website (if any) will apply. We cannot and do not make any warranty or representation as to the practices of any linked websites in the handling of your personal information.
4 Information we collect
4.1 We collect your personal information such as:
(a) basic contact details, including your name, address, phone number, and email address;
(b) order information, including your billing and delivery details;
(c) account information, including the details you use for registering an account on the Website; and
(d) shopping and ordering information, including the items you view, put in your cart or add to your wish-list;
We also collect other information such as cookie data, pixel data, analytics data and other information you might provide when enquiring about, or using the Website, or through the course of other interactions you may have with a2EA or our related bodies corporate.
4.2 We may collect your personal information:
(a) when you give it to us directly;
(b) from third parties including from vendors and service providers who may collect information on our behalf, such as companies who support our Website (e.g Shopify);
(c) when you use the Website, purchase product from the Website, open or click on emails we send you, or interact with our advertisements, we or third parties we work with, may automatically collect certain information using online tracking technologies such as web beacons, software developer kits, third-party libraries, and cookies; and
(d) when you give us information when entering into our promotions or contacting us via the Website, including by Customer Careline, email or by telephone.
4.3 Any personal information we obtain about you from third parties will similarly be treated in accordance with this Privacy Policy and applicable privacy laws. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party's policies or practices.
4.4 We may process personal information you disclose via the Website. However, such information may also be read, collected and used by other users, the actions of whom we cannot control and for whom we take no responsibility.
4.5 We use cookies and pixels to monitor usage of our Website. A cookie or pixel involves a small amount of information which is transferred to the hard drive of your computer which can identify your web browser but not you. Cookies and pixels provide us with information about your computer’s IP address, the date and time of your visit, and the resources or information you have accessed. This information assists us in tailoring our services and making your visits easier, more productive and more efficient. This includes increasing the security of this service, storing technical data needed to play back media content, server identification for appropriately redirecting user requests, storing a user’s customised preferences, improving the website and user browsing experiences, and measuring user interactions through Google Analytics. We may also permit third parties and services providers to use Cookies on our Website to better tailor the services, products and advertising on our Website and other websites. In some circumstances, cookies or pixels may enable us to identify you. For specific information about the cookies and pixels that we use related to powering our Website with Shopify, see https://www.shopify.com/legal/cookies. Any personal information obtained through the use of cookies or pixels will only be processed in accordance with this Privacy Policy.
4.6 If at any time you provide another person’s personal information to us, then you must ensure that that person has read and understood this Privacy Policy and separately consents to their personal information being processed by us as described in this Privacy Policy.
5 Why we collect and how we use information
5.1 We collect your personal information where it is reasonably necessary for the purposes of carrying out our business and operations, including in order to:
(a) administer and improve the Website and improve your experience;
(b) respond to your queries;
(c) understand how you use the Website and purchase products from the Website and your preferences;
(d) verify who you are, and security and fraud prevention;
(e) provide and improve our a2TM branded products and services;
(f) undertake surveys in relation to your experience with our products and services;
(g) use the information for our internal business and marketing purposes and those of our related bodies corporate, and to protect the security and integrity of our business, comply with legal and regulatory obligations, or as otherwise permitted by law;
(h) conduct data analytics;
(i) conduct any promotions you participate in, including to provide you with discount codes;
(j) keep a record of our dealings with you;
(k) develop a data profile to enable us to:
(i) tailor our services to you; and
(ii) enhance the content of our Website,
(l) create aggregate anonymised data (which does not identify you) to provide to our related bodies corporate and potential stakeholders; and
(m) conduct direct marketing, including to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you may opt-out by contacting us via our contact details in section 8.2 or through the opt-out mechanism contained in the communication; and
(n) notify you regarding the status of your order, including abandoned cart notifications.
5.2 Our ability to provide you with products, services and information may be adversely affected if you choose not to provide us with your personal information (e.g. we may not be able to respond to your request or provide you with specific products or services).
5.3 By giving us your personal information, you consent to your personal information being processed for the purposes described in section 5.1 above.
5.4 We will process your personal information only:
(a) if you have provided consent;
(b) for the purpose for which it was collected, or purposes reasonably related to that purpose, and even then, only if you would reasonably expect us to use it for those purposes; or
(c) in law enforcement, public health or public safety circumstances, where authorised or required by law.
6 How we disclose your information
6.1 We will not disclose your personal information, except:
(a) to contractors and third-party service providers that provide financial, legal, administrative, marketing, information technology or other services in connection with the operation of our business who are obliged to hold your personal information in a manner consistent with our Privacy Policy (e.g. mailing houses); and
(b) to third parties that assist us to provide, maintain and improve the Website and relevant purchases. For example, payment processors and third party vendors who assist us to verify discount codes which may require us to verify your personal information against that third-party’s database to confirm your eligibility to use certain individual specific discount codes. If you would like to know more about how they process your personal information, please refer to their relevant privacy policies and the terms and conditions associated with the relevant discount code;
(c) business and marketing partners, including Shopify, to provide services and advertise to you. For example, we use Shopify to support personalized advertising with third-party services. Our business and marketing partners will use your information in accordance with their own privacy notices;
(d) to protect the health and safety of our customers and personnel;
(e) to protect or defend our business (including against fraud and misconduct), in law enforcement, public health or public safety circumstances, where required by law;
(f) to our related bodies corporate who will treat your personal information in accordance with the Privacy Act and their respective privacy policies or as part of a business transaction such as a merger or acquisition; or
(g) with your consent or when your consent can be reasonably inferred from the circumstances.
6.2 Some of the recipients we disclose your personal information to may be located in countries outside of Australia (i.e. including to the providers of the server and cloud infrastructure used to host the Website in Canada and / or the United States of America). Before disclosing any personal information to an overseas recipient, we take reasonable steps to ensure that the recipient complies with the Privacy Act or is bound by a substantially similar privacy scheme. However, please note we cannot guarantee that all overseas recipients will comply with Australian law.
7 Security and confidentiality
7.1 We take reasonable steps to ensure that all personal information we process is accurate, complete and up-to-date.
7.2 We take reasonable steps, including by maintaining organisational and technical measures, to protect your personal information from misuse, interference and loss and from unauthorised access, modification and disclosure.
7.3 We will destroy or de-identify your personal information in a secure manner if we no longer need it for the purposes for which it was collected, unless we are otherwise required or authorised by law to retain the information.
8 Your rights
8.1 Upon your request, we will inform you of what personal information we store about you and you may request access to or correction or erasure of that information. Please note that your requests may affect the extent to which we provide our services to you.
8.2 If you:
(a) wish to access, correct, erase or modify your personal information;
(b) consider that there may have been a breach of your privacy;
(c) would like to opt-out of receiving promotional communications from us;
(d) re unhappy with any aspect of the way we process your personal information,
please contact our Privacy Officer by email at privacy@a2milk.com, or in writing to PO Box 1564, North Sydney NSW 2059.
8.3 When contacting the Privacy Officer, you may be required to provide proof of your identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected. We may charge you a reasonable administration fee reflecting the costs to us for providing access in accordance with your request. We will endeavour to respond within 30 days of receiving your request. If we refuse to provide access to, or allow correction of your personal information, we will notify you in writing setting out a written explanation of the reasons for the refusal (unless unreasonable to do so) and inform you of the mechanism to complain about the refusal.
8.4 In the event you are dissatisfied with the outcome of your request, or if you still have any concerns about your privacy, you may contact the Office of the Australian Information Commissioner.