“ST Group”, “We” or “Us” means ST Group Food Industries Holdings Pte Ltd and any of its subsidiaries and related parties or entities including PappaRich Australia, NeNe Chicken (Australia), HBCT (Aust), Pafu Australia, IPR (WA), IPR NZ Limited, Idarts Australia, GCHA (NZ) and GC (England) Pte Ltd. By providing your personal information to us, you consent to it being used in accordance with this statement.
1. Open and transparent management of personal information
If you believe that ST Group has breached the APPs, please contact the Privacy Officer in writing and we will respond to you within 30 days. If you are not satisfied with our response, you may address your complaint to the Office of the New Zealand Commissioner.
2. Anonymity and pseudonymity
We will not generally ask for your personal information to be used in our retail food outlets. However, if you wish to use our other services, such as any of the ST Group phone apps, take part in promotions, it will, in most
cases, be impractical for us to provide such services to you unless you disclose your personal information.
3. Collection of solicited personal information
Your ability to use our phone app and/or receive special offers from us is dependent on you providing your information to us, including:
• date of birth
• phone number
In most cases, we will collect personal information directly from you unless you consent to us collecting it otherwise or it is unreasonable or impracticable to do so.
4. Dealing with unsolicited personal information
If we receive unsolicited personal information of the type which we could or should have solicited from you, we will keep it as if we had solicited this personal information. If it is information of the type that we could not or should not have ordinarily solicited from you and this information is not contained in a government record, we will destroy or de-identify it if it is lawful and reasonable to do so.
5. Notification of the collection of personal information
Sometimes we may need to collect your personal information from a third party and when this occurs we will inform you. We will also be clear about the purpose of the collection, who we might disclose this information to, whether the personal information is required under an Australian law or a court/tribunal order and the main consequences of not collecting this information. We will also inform you if ST Group is likely to disclose the personal information to overseas recipients, including the countries in which the recipients are located. As our group businesses are spread out through Asia, our data systems are likely to be shared through the group in Asian countries including Singapore and Malaysia.
6. Use or disclosure of personal information
We will use your personal information for purposes that relate to the provision of our services to you. These generally include:
• supplying our products and services to you;
• marketing including email marketing, promotional activities and keeping you up-to-date with new products and services;
• providing quality assurance of our products and services;
• planning, product development or research purposes;
• seeking or responding to your enquiries and feedback regarding our business, our products and services;
• monitoring the performance of our business and our products and services.
We work with third parties who provide services such as data analysis, targeted advertising and reporting and may give them secure access to the personal information they need. These companies may use this information to deliver advertising and promotions that are customized or more relevant to your interests.
We may also need to disclose your personal information in the following instances:
• if reasonably necessary to assist a law enforcement agency
• if required by an external service provider for the purposes of audit, peer reviews, legal advice, consultancy, outsourced administration, issuing statements or handling mail
• if required by reporting entities for the purpose of complying with the Anti-Money Laundering and Counter-terrorism Financing legislation, or
• if considered practical and is permitted by the Privacy Act in New Zealand.
7. Direct marketing
ST Group may use or disclose the personal information we hold about you for the purpose of direct marketing, such as offers and/or promotions that may be of interest to you, if there is a reasonable expectation that your personal information will be used for this purpose and you have not opted out of receiving direct marketing communications from us, or where you have provided your consent.
We will not directly market to you using information that is considered sensitive unless you have provided
8. Cross-border disclosure of personal information
ST Group may transfer or store your personal information outside Australia as some of our businesses are based outside of Australia and as part of our standard IT practices and/or performing our services in respect of the primary purpose for which you provide your personal information to us.
If we disclose personal information to an overseas recipient without your consent, we will take reasonable steps to ensure that this recipient complies with the Privacy Act in New Zealand in relation to that information.
9. Adoption, use or disclosure of government related identifiers
ST Group will not adopt, use or disclose government agency identifiers as our primary means of identifying you.
10. Quality of personal information
We will aim to keep your personal information accurate, up to date and complete. If you believe that any personal information we hold is inaccurate, incomplete or out of date, please contact us by e-mailing email@example.com.
11. Security of personal information
ST Group maintains a high standard of integrity and security of our database which contains the personal information of our customers. We have implemented significant precautions to protect the personal information we hold from such risks as misuse, interference, loss, or from unauthorised access, modification or disclosure. If we no longer need your personal information, we will take reasonable steps to destroy or de-identify such information.
12. Access to personal information
You may at any time request access to your personal information we hold. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested or providing you with an accurate summary of the information we hold.
We may refuse to provide access to personal information in circumstances where the Privacy Act in New Zealand allows such refusal. In such instances, we will provide written notice of the reasons for refusal (unless unreasonable to do so).
All requests for access to personal information should be in writing to the Privacy Officer. We will respond to your request within no more than 30 days. We may charge a fee in respect of our costs to produce the requested information.
13. Correction of personal information
If we hold information about you which we know to be inaccurate, out of date, incomplete, irrelevant or misleading, we will take steps to correct the information. If you request us to correct the information we will take reasonable steps to do so. If a third party is relying on this information, at your request we will also notify them, unless it is impracticable or unlawful to do so.
If we refuse to make a correction, we will let you know why and the complaint mechanisms that are available to you. If we continue to use this information, you may request us to associate a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading to notify third party users of the information.
All requests for correction to personal information should be made in writing to the Privacy Officer. We will respond to your request within no later than 30 days and will not charge you for making the request for the correction of personal information.