Where we refer to the ‘Privacy Act’ in this Policy we mean the Privacy Act 1988 (Cth).
2. Updates to this policy
3. What personal information do we collect and hold in connection with the Program?
The types of personal information we collect and hold about Program members may include:
- contact details (e.g. address(es), email address(es), telephone number(s));
- other identification information (e.g. date of birth, membership numbers or other personal identifiers related to your participation in the Program);
- details of your registered “primary store”;
- household / demographic information;
- transaction information / history (including details of the products you purchase, and the value of your purchases);
- details and history of preferences, interests and behaviour relating to transactions, products and interaction with our digital services and platforms;
- reward details (including details of reward redemptions);
- records of your automatic competition entries;
- your browsing history and cookie preferences;
- records of your communications and interactions with us and in connection with the Program;
- information regarding your participation in third party loyalty programs associated with the Program; and
other personal information you provide to us or to IGA Retailers.
The kind of information we may collect regarding other participants in the Program (such as IGA Retailers and rewards providers) includes:
- contact details (e.g. address(es), email address(es), telephone number(s));
- other identification information (e.g. date of birth);
- relevant employment details (e.g. role title); and
- any other personal information those participants provide to us.
4. How do we collect your personal information in connection with the Program?
We may collect your personal information from your interactions and transactions with us, IGA Retailers and their service providers or existing loyalty program operators, and other Program participants (such as rewards providers).
This includes when you:
- use or access the Program website or Program-related digital services;
- email or contact us, or we otherwise have conversations with you (such as in-store or over the telephone); or
- have other dealings with us, or otherwise in the course of us providing you with a requested product, service or benefit.
For SUPA CLUB program members, we may also collect your information when you:
- register to participate in the Program directly with us (e.g. via our website or any Program app we provide);
- use the loyalty card which has been linked to your Program account, including when you make a purchase instore or online;
- participate in a promotion, competition or survey in connection with the Program; and/or
- redeem a reward or access an offer provided in connection with the Program.
We may also collect personal information from third parties including:
- IGA Retailers and their service providers (such as point of sale vendors) or existing loyalty program operators;
- other Program participants (such as rewards providers) and their service providers;
- other Metcash group companies; and
- your representatives (including legal representatives).
5. How do we hold and protect your personal information?
We hold personal information in a combination of computer storage facilities, paper-based files and other records, both at our own premises and with the assistance of service providers.
In so doing, we take reasonable steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification or disclosure.
When we no longer need your personal information, we take reasonable steps to destroy or permanently de-identify the information.
6. Consequences if you do not provide personal information
If you do not provide your personal information, we may not be able to provide you with products, services or benefits in connection with the Program. For example, if you have not provided your email address, we will not be able to issue personalised email communications or grant you automatic competition entries.
7. Why do we collect, hold, use and disclose your personal information?
We handle your personal information for the purposes of providing, administering, improving and personalising the Program, our products and services, and the products and services of IGA Retailers and other Program participants. This can include registering you to participate in the Program; enabling you to access Program portals; providing Program benefits; managing Program promotions and competitions; enabling automatic entry in Program-related and Retailer-related promotions for Program members; offering and facilitating the offer of other Program benefits; offering and facilitating the offer of other products or services that may be of interest to you; verifying your identity, communicating with you (including through direct marketing, where we are permitted to do so); understanding your interests and preferences to help us tailor our communications and offers and to improve our offerings and the offerings of IGA Retailers; handling your queries and complaints; assessing the performance of Program websites, apps and digital platforms and improving their operation; for other data analytics purposes, including to provide participating IGA Retailers with information about the purchasing trends of members who have registered that IGA Retailer as their “primary store” and to provide aggregated, anonymous information about Program activity, shopper trends and campaign/promotional performance, and other Program insights, to IGA Retailers and other Program participants; conducting surveys, and market and product research; otherwise providing goods, services and benefits you have requested or are eligible to receive in connection with the Program; working with our service providers; and any other purposes which we have notified to you at the time of collection of the information, or to which you have provided your consent.
We may also handle your personal information:
- to enforce our legal rights and obtain professional advice;
- to comply with industry standards and our policies;
- for other activities that you may reasonably expect us to use the information for;
- as required or authorised by law or a court or tribunal order; and
- to facilitate purchases or potential purchases of, or investments in, our business or a group company.
Where we have your consent or are otherwise permitted by law to do so, we may also use and disclose your personal information to provide you with marketing communications and targeted advertising on an ongoing basis by electronic messages (such as SMS or email), through our digital services and by other means. These communications may be sent by third parties on our behalf.
These communications may relate to the products and services we, other Program participants (such as our Retailers or rewards providers) and other group companies provide, promotions run by us or for which there is automatic entry for Program members, and other products or developments which may be of interest to you.
You may opt-out of receiving future electronic and telephone direct marketing communications through the unsubscribe function that will be made available to you with each direct marketing communication although this may limit your ability to receive the benefits of the Program. Please see the Member Terms and Conditions supaclub.com.au/terms to understand the consequences of unsubscribing from email communications.
8. Who do we disclose your personal information to?
We may disclose your personal information to:
- various third party service providers we or our group companies engage in connection with the Program, including service providers who assist with the development, administration, marketing or improvement of the Program, or with Program-related data processing/analysis;
- the IGA Retailer you have registered as your “primary store”, from time to time for the purposes of that Retailer’s participation in the Program and also when that Retailer ceases participating in the Program;
- the third party operator of an existing loyalty program run on behalf of the IGA Retailer you have registered as your “primary store”, to enable you to also be registered in that program, and to obtain the benefits of membership of that program. Please see the “Third Party Programs” section of the Member Terms and Conditions (at supaclub.com.au/terms) for more information;
- other Program participants, including rewards providers, as is reasonable or necessary for the operation of the Program. In this regard, we do not share identifiable member data with IGA Retailers, except with a member’s registered “primary store”. However, we may use and analyse member personal information to create aggregated, anonymous data which we report to other participating IGA Retailers and other Program participants, to enable them to gain insights into general shopper trends and campaign and store performance;
- our professional advisers such as accountants, solicitors, business advisers and consultants;
- government bodies and regulatory authorities, including if required or authorised by law;
- companies that we plan to merge with or be acquired by or who may invest in us or our group companies; and
- our related group companies, for their internal purposes only.
We disclose personal information, for some of the purposes described above, to organisations located in Australia and in other countries, including the United Kingdom and the United States of America. We or our service providers may also make personal information held in Australia or the other countries listed above remotely available for processing by service provider personnel located in other countries, such as China and Thailand.
We take reasonable steps to ensure that overseas recipients of your personal information do not breach the privacy obligations relating to your personal information and only use it for the purpose for which it was disclosed.
9. Digital Technologies
- so that your preferences for a particular site can be stored;
- to improve your browsing experience; and
- to help tailor advertising and promotions to you.
Information is also generated whenever a page is accessed on the SUPA CLUB Program website that records information such as the time, date and specific page accessed. We collect such information for statistical and maintenance purposes and in order to enable us to continually evaluate our website’s performance.
10. How you can access and correct your personal information
We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up to date. If your personal details change, such as your address or phone number, please update your account profile via the Program website or contact our Privacy Officer by email or at the address provided in section 11 below.
At your request, we will provide you with a copy of any personal information which we hold about you, unless an exception under the Privacy Act applies. We may charge reasonable fees for retrieving this information, in which case we will inform you of the fee and obtain your agreement to that fee before providing the information.
11. How to contact us or make a complaint
The Privacy Officer – SUPA CLUB Program
Metcash Trading Limited
1 Thomas Holt Drive
Macquarie Park NSW 2113
Fax: (02) 9741 3027
E-mail: [email protected]
We will promptly acknowledge and investigate any complaint about the way we manage personal information.
We will take reasonable steps to remedy any issues resulting from our failure to comply with our privacy obligations. If our response to your complaint does not address your concerns to your satisfaction, you may have the right to make a complaint to the Office of the Australian Information Commissioner, whose website is located at: oaic.gov.au