Privacy Policy

The Arnott’s Group Privacy Policy

This Privacy Policy explains how The Arnott’s Group uses the personal data we collect from
you when you:

  • make a consumer related enquiry or complaint (including via letters, telephone calls,
    text messages and emails to our Consumer Experience Centre);
  • enter into our competitions and promotions;
  • complete our surveys;
  • sign up to our newsletters;
  • sign up to join our online communities;
  • complete registration processes when you purchase a product;
  • transact with us; and
  • use our website.

The Arnott’s Group includes the entities listed in Section 13. A reference to “our Company”
in this Privacy Policy is a reference to each of these entities.

By providing your personal data to us, you acknowledge that we will collect, hold, store, use,
disclose and otherwise handle your personal data in accordance with this Privacy Policy.

 

1. What data do we collect?

Our Company collects the following data:

  • Personal identification and contact information, including your name, date of birth,
    gender, email address, phone number, address and other contact details.
  • Information relevant for promotions and competitions.
  • Information you may make publicly available online (including, but not limited to, on
    social media platforms).
  • Transaction details, if you make a purchase with us or choose to store details in your
    online profile.
  • Information we require to facilitate or improve our transactions and dealings with you.
  • Information that helps us to improve our products and develop new products.
  • A record of any enquiries you make.
  • If you make a consumer related enquiry or complaint to us, health and other sensitive
    personal data if needed in connection with your enquiry or complaint.
2. How do we collect your data?

You directly provide our Company with most of the data we collect. We collect data and
process data when you:

  • Contact us, including when you make a consumer related enquiry or complaint to our
    Consumer Experience Centre via our website, email or telephone, and in subsequent
    communications with the Consumer Experience Centre.
  • Enter our competitions and promotions.
  • Voluntarily complete a customer survey or provide feedback via our website, any of
    our social media pages or email.
  • Use or view our website, via your browser’s cookies.
  • Use or view our social media pages or use our apps.
  • Sign up to our branded newsletters.
  • Sign up to join our online communities.

We will always seek your consent to collect any health or other sensitive personal data about
you.
Our Company may also receive your data indirectly from the following sources:

  • Our agents and contractors in connection with any of our competitions or promotions.
  • Our customers if you contact them and we reasonably believe you have authorised
    them to refer your inquiry to us.
  • Third parties if it is not reasonable or practicable to collect the data from you.
3. How will we use your data?
Purpose Legal Basis
Confirm your identity. This is in our legitimate interest, for example, to ensure we
have confirmed the identity of the person making a request to
us. We also process this personal data where necessary for
us to comply with a legal obligation that we are subject to.
Provide products and
services to you.		 This is in our legitimate interest in order for us to provide
products and services to you. In addition, where we have a
contract with you, it may be necessary for us to process your
personal data in order for us to perform that contract with you.
Deal with your consumer
related enquiry or
complaint.		 This is in our legitimate interest in order to respond to your
enquiry or complaint.
Administer and manage
promotions and
competitions.		 This is in our legitimate interest in order to manage and
administer our promotions and competitions. In addition,
where we have a contract with you regarding the promotion or
competition, it may be necessary for us to process your
personal data in order for us to perform that contract with you.
Conduct marketing
activities as described in
Section 7.		 We process your personal data in order to send you marketing
materials. Where required under applicable data protection
laws, this will be on the basis of your consent.
Obtain your feedback on
our products and
services and conduct
consumer research.		 This is in our legitimate interests in order to conduct research
and obtain feedback to improve our products and services.
Conduct a business or
professional relationship
we have with you.		 This is in our legitimate interests in order to manage and
conduct our relationships with third parties in a business or
professional capacity.
Personalise and
enhance your online
experience.		 This is in our legitimate interests in order to improve our
website and online experience for our customers and visitors.

 

Sometimes we extract information from our collected records to produce aggregated data.
This aggregated data does not identify individuals. We use the aggregated data for research
and product development and may share the data with third parties in connection with those
purposes.

You are not required to provide any personal data to us. If you do not, or you inform us that
you do not want us to use your personal data to contact you, we may not be able to deal with
you effectively for the above or other purposes.

4. How will we disclose your data?

Our Company may disclose your data in the following ways:

  • If you consent, our Company will share your data with our partner companies so that
    they may offer you their products and services.
  • We may provide your data to third parties that we engage to perform functions on our
    behalf, such as processing credit card information, mailing information or prizes, data
    analysis, research, and advertising.
  • In certain circumstances, we may disclose your personal data where required or
    authorised to do so by law, including in emergency situations, for health and safety
    reasons, and to assist law enforcement agencies.
  • If you purchase a product, we may send your data to, and also use the resulting
    information from, credit reference agencies to prevent fraudulent purchases.
5. How do we store your data?

Our Company uses various systems and services to safeguard the personal data we store,
as part of our business systems and processes.

Our Company securely stores your data both at an onsite secure server and offsite using
trusted third party storage providers. Our staff are required to sign in and use multi-factor
password when accessing our secure systems. We provide training for relevant staff to
ensure that they are aware of our privacy commitments and our obligations in relation to the
collection, use and disclosure of personal data.

Our Company will keep your personal data for as long as it is required for the purposes for
which it was collected, or longer if required by applicable laws. Once your personal data is
no longer required, we will de-identify or delete your data in our systems, or ensure we are
no longer able to access and use it.

6. Cross border transfer of personal data

Our Company’s systems and services may involve other entities within The Arnott’s Group
and third party service providers located outside the country in which our Company is
located.

Your personal data may be held and processed outside the country in which our Company is
located by other entities within The Arnott’s Group and our service providers. The Arnott’s
Group entities and our service providers are based in various countries, including Australia,
New Zealand, Japan, Hong Kong, Malaysia, Indonesia, Singapore, Taiwan, India, the United
Kingdom and United States.

When we transfer personal data to others or outside the country in which our Company is
located, we will comply with applicable privacy and data protection laws and will take steps
to ensure it is treated in the same way that we would treat it. If you are located in the
European Union (“EU”), European Economic Area (“EEA”) or the United Kingdom (“UK”),
your personal data may be transferred outside of the jurisdiction in which you are located.
We may transfer your personal data to jurisdictions that are deemed as adequate for the
purposes of EU/EEA and UK data protection laws and, where that is not the case, we will
ensure appropriate safeguards are in place under EU/EEA and UK data protection laws,
such as standard contractual clauses. For more information or to obtain a copy of the
standard contractual clauses that we use, please contact us using details in Section 11.

7. Marketing

Our Company would like to send you information about our products and services that we
think you might like. This may include updates on special offers, events and rewards, and
other communications through our newsletters, online communities and/or loyalty clubs.

We will only do so if you have consented to receive marketing from us. If you have
consented to receive marketing from us, you may always opt out at a later date. If we send
a marketing offer directly to you, we will provide a way for you to opt out of future marketing
offers.

You have the right at any time to stop our Company from contacting you for marketing
purposes or giving your data to other members of The Arnott’s Group.

If you no longer wish to be contacted for marketing purposes, please contact us using the
details in Section 11. You can also follow the instructions to unsubscribe or opt out that we
include in every electronic marketing communication.

8. What are your data protection rights?

Our Company would like to make sure you are fully aware of all of your data protection
rights. Every user is entitled to the following rights under this Privacy Policy (which may
exceed your rights under applicable law):

  • Access – You can ask us to confirm whether we hold personal data about you. You
    have the right to request our Company for copies of your personal data. We will
    handle and respond to your request in accordance with applicable privacy laws,
    including if we are unable to provide you with the access you request. We do not
    impose any charge for a request for access, but where permitted under applicable
    data protection laws, we may charge you a reasonable fee for our costs associated
    with retrieval and providing you with access.
  • Rectification – You have the right to request that our Company correct any
    information you believe is inaccurate. You also have the right to request our
    Company to complete information you believe is incomplete. You should contact us if
    you believe that any of the personal data we hold about you is inaccurate, out-ofdate, incomplete, irrelevant or misleading, and provide us with a statement of the
    correction that you seek.
  • Erasure – You have the right to request that our Company erase your personal data,
    under certain conditions.
  • Restrict processing – You have the right to request that our Company restrict the
    processing of your personal data, under certain conditions.
  • Object to processing – You have the right to object to our Company’s processing of
    your personal data, under certain conditions. For example, you have the right to
    object to our processing of your personal data on the basis of our legitimate interests,
    under certain conditions. You also have the right to object to our processing of your
    personal data for direct marketing purposes as set out in Section 7 above.
  • Data portability – You have the right to request that our Company transfer the data
    that we have collected to another organisation, or directly to you, under certain
    conditions.
  • Withdrawal of consent – – If we process your personal data on the basis of your
    consent, you have the right to withdraw your consent at any time.

If you make a request, we will use reasonable endeavours to respond to you within a month,
and we will inform you if we will need longer to respond to you. If you would like to exercise
any of these rights, please contact us using the details in Section 11.

9. Cookies

Our Company uses cookies which are a small piece of information or file that is placed on
your computer or device by websites or apps to collect standard Internet log information and
visitor behaviour information for record-keeping purposes and to enhance functionality on
the website or app.
For more information regarding our use of cookies, please see our Cookies Policy.

10. Privacy policies of other websites

Our Company websites contains links to other websites. Our Privacy Policy applies only to
our websites, so if you click on a link to another website, you should read their Privacy
Policy.

11. How to contact us

If you have any questions about this Privacy Policy, the personal data we hold about you, or
you would like to exercise one of your data protection rights, please do not hesitate to
contact us using the details below:

Email us at: [email protected]
Call us:

  • Australia: 1800 24 24 92 or 1800 66 33 66
  • New Zealand: 0800 88 19 66
  • Hong Kong: +852 2811 3806
  • Indonesia: 0 800 1 80 8000
  • Japan: 0120 801639
  • Malaysia: +60 3 7787 6288
  • Singapore: +65 6273 0889

Or write to us at:
Attention: Privacy Officer
24 George Street, North Strathfield NSW 2137, Australia

12. How to contact the appropriate authority

You can also contact us to report any misuse of your personal data or if you wish to make a
complaint about how we use your personal data (including in relation to any breach of
applicable privacy and data protection laws). We aim to deal with any complaints under this
Privacy Policy promptly.

We will inform you of any applicable dispute resolution avenues that you may pursue if you
are not satisfied with our response. Should you wish to report a complaint or if you feel that
our Company has not addressed your concern in a satisfactory manner, you have the right
to contact the relevant authority in your country. These include:

Australia:
Office of the Australian Information
Commissioner
Website: https://www.oaic.gov.au/
Phone: 1300 363 992
Email: [email protected]		 Hong Kong:
Office of the Privacy Commissioner for
Personal Data
Website: https://www.pcpd.org.hk/
Phone: 2827 2827
Email: [email protected]
Japan:
Personal Information Protection Commission,
Japan
Website: https://www.ppc.go.jp/en/
Phone: 03 6457 9680		 Malaysia:
Personal Data Protection Department
Phone: 03 8911 5000
Email: [email protected]
New Zealand:
New Zealand Office of the Privacy
Commissioner
Website: https://privacy.org.nz/
Phone: 0800 803 909
Email: [email protected]		 United Kingdom:
Information Commissioner’s Office
Website: https://ico.org.uk/
Phone: 0303 123 1113
Address: Wycliffe House, Water Lane,
Wilmslow, Cheshire, SK9 5AF
EU:
If you are located in the EU, you may contact the data protection
authority in your jurisdiction.
A list of contact details for EU data protection authorities is available at
https://edpb.europa.eu/about-edpb/about-edpb/members_en
13. The Arnott’s Group entities

The Arnott’s Group includes the following entities. If you are located in one of the
jurisdictions below, the entity/entities listed are the data controller in respect of your personal
data unless otherwise indicated:

Australia:
• Arnott’s Biscuits Ltd (ABN 44 008 435 729)
• Campbell Australasia Pty Ltd (ABN 28 004
456 937)
• Good Food Partners Pty Ltd (ABN 38 104
048 400)		 Hong Kong:
• Campbell Foods HK Ltd
Indonesia:
• PT Arnott’s Indonesia		 Japan:
• Campbell Japan Inc
Malaysia:
• Campbell Cheong Chan (Malaysia) Sdn Bhd
• Campbell Soup Southeast Asia Sdn Bhd		 New Zealand:
• Arnott’s New Zealand Ltd
• 180 Degrees Ltd
United Kingdom:
• Campbell Foods UK Ltd (data controller:
Arnott’s Biscuits Ltd (ABN 44 008 435 729)
(Australian company))

All entities in The Arnott’s Group can be contacted using the details in Section 11.

14. Changes to our Privacy Policy

Our Company keeps this Privacy Policy under regular review and places any updates on this
website. If we have your email address, we will notify you via email of any significant
changes to this Privacy Policy.

This Privacy Policy was last updated in June 2022.