Privacy Policy

Date of last revision: 25 June 2021

ABOUT THIS PRIVACY POLICY
Greencross Operations Pty Ltd ACN 130 686 743 (Greencross, we, us, our) operate the website, thenoshproject.com.au (Site). The Site is designed to provide recipes for meals that you can prepare for your pet and personalised recommendations on products for your pet (Services) and let you know about our latest products, including ‘The Nosh Project’ range, Petwise product range and any products made available by us from time to time (Products).

The term ‘you’ refers to the person accessing or using the Site or our Services or otherwise providing personal information to us. This Privacy Policy applies to all personal information collected by us, or submitted to us, through or in connection with the Site.

We are committed to handling personal information in accordance with applicable privacy laws, including the Australian Privacy Principles set out in Privacy Act 1988 (Cth) (Privacy Act).

This policy explains how we collect your personal information, what we do with it, and how it is protected and is referred to as our Privacy Policy.

OTHER TERMS MAY APPLY
Other terms may also apply to you and the personal information we hold about you. For example, sometimes we may also provide a privacy collection statement at the time we collect personal information from you. This privacy collection statement may include additional terms.

We are part of the Greencross group, which includes Petbarn Pty Ltd (Petbarn) and City Farmers Retail Pty Ltd (City Farmers) which operate retail stores under the Petbarn and City Farmers brands. Greencross also operates the Friends for Life Loyalty Program. Greencross Pty Limited operates the Greencross Vets aspect of the Greencross group’s business. This Privacy Policy explains how we may disclose your personal information to companies in the Greencross corporate group, including Petbarn, City Farmers and Greencross Pty Limited or in relation to the Friends for Life Loyalty Program which have their own separate privacy policies which explain how we collect, use, disclose and handle your personal information in relation to those different brands and businesses within the Greencross group. You can find these privacy policies here:

• https://www.petbarn.com.au/privacy-policy
• https://www.cityfarmers.com.au/
• https://friends-for-life.com.au/
• https://www.greencrossvets.com.au/privacy/

1.KINDS OF PERSONAL INFORMATION COLLECTED AND HELD

Typically when you use this Site or our Services, the kinds of personal information we collect about you includes but is not limited to:
1.1.1          your first name and last name;
1.1.2          your age;
1.1.3          your date of birth;
1.1.4          your contact details (such as your email address, phone number and residential address);
1.1.5          pet ownership details;
1.1.6          shopping habits and preferences;
1.1.7          marketing preferences, including the type of marketing materials you wish to receive and the method of delivery (email, SMS, direct mail, or other);
1.1.8          whether you have purchased our Products.
1.1.9          whether you have used the Services;
1.1.10        your opinion of the Products or Services as expressed by the customer reviews you submit; and
1.1.11        device identification information (see the section 7 ‘Online and Digital Services’ below for further information).

2.HOW PERSONAL INFORMATION IS COLLECTED AND HELD

2.1 How we collect your personal information
Normally we collect personal information from you directly, when you access or interact with the Site. When you visit our Site, we collect your personal information directly from you when you:

• complete a ‘contact us’ form;
• submit a customer review;
• use the live chat function;
• download a recipe; and
• participate in a ‘personalisation journey’ on the Site so that we can suggest a Product for your pet.

We generally collect personal information from you directly when you sign up to:

• our mailing list to receive communications about the Products or Services;
• our mailing list to receive communications about other products or services provided by us; or
• our related bodies corporate’s mailing lists to receive communications about their products or services.

We may also collect and update your personal information over the phone, by email, over the internet or social media, or in person.

We may also collect personal information from third parties including through the acquisition of third party mailing lists and from organisations with whom we have an affiliation.

We may collect personal information from the Greencross group of companies (comprising Greencross Pty Limited and its subsidiaries and affiliates, from time to time).

2.2 How we hold your personal information
We may hold your personal information in hard copy (paper) or electronic form.

If you provide information to us electronically, we retain this information in our computer systems and databases. Information held in electronic form is generally held on servers controlled by us and on servers controlled by third parties under contractual arrangement with us. We use physical security, password protection and other measures to ensure that personal information stored in electronic form is protected from misuse, interference and loss and from unauthorised access, modification and disclosure.

Personal information collected in hard copy (paper) form may be converted to electronic form. Where this occurs, generally the hard copy is securely destroyed at the end of this process. Information held in paper-based form is generally securely stored at our head office or at our retail locations. We use physical security and other measures to ensure that personal information in hard copy form is protected from misuse, interference and loss and from unauthorised access, modification and disclosure.

3. ANONYMITY AND PSEUDONYMITY

You may choose to not provide us with certain types of personal information, but if you do so we may not be able to provide you with the products and services you have asked us to provide or it may affect your ability to use the Site or receive some Services.

4. PURPOSES FOR COLLECTING, HOLDING, USING AND DISCLOSING PERSONAL INFORMATION

The main purposes for which we collect, hold and use your personal information are:

• to provide you with the Services that you have requested from us e.g. providing you with the recipe requested;
• to respond to a query you have submitted using the ‘contact us’ form or live chat function on the Site;
• where you have signed up to our mailing list to receive communications about the Products or Services, to send you communications about the Products and/or Services;
• where you have signed up to our mailing list to receive communications about other products or services provided by us, to send you communications about other products or services provided by us or special offers, which might interest you;
• where you have signed up to our related bodies corporate’s mailing lists to receive communications about their products or services, for the relevant related body corporate to send you communications about their products or services; and
• to edit, delete, link to other material, use or publish any information, content and materials (such as customer reviews of Products or Services) which you have submitted to the Site and/or us for publication on the Site (User Generated Content). For example, if you submit a customer review of the Products or Services, we may choose to display personal information (such as your first name and age and breed of your pet) on the Site or on The Nosh Project advertising materials.

Where you have signed up to one of our related bodies corporate’s mailing lists to receive communications about their products or services, we will disclose your personal information to the relevant related body corporate so that the relevant related body corporate can send you communications about their products or services.

We may also disclose your personal information which we collect from using cookies on the Site (see section 7 for more details) to our related bodies corporate.

We may disclose your personal information which we collect when you submit User Generated Content to our related bodies corporate.

We may collect, hold, use and disclose your personal information for other purposes explained at the time of collection (such as in a specific privacy collection statement or notice) or otherwise as set out in this Privacy Policy. This includes disclosing your personal information to our related bodies corporate for purposes explained in a specific privacy collection statement or notice.

We will also use and disclose personal information for a range of administrative, management and operational purposes. For example, we also use and disclose your personal information:

• to carry out administration, marketing, planning, risk management, fraud and loss prevention activities;
• for product and service development, quality control and research to improve the way we and our service providers provide products and services to us and you;
• for training staff, contractors and other workers;
• to seek your feedback in relation to customer satisfaction and our relationship with you and perform research and statistical analysis using such feedback; and
• for obtaining advice from consultants and other professional advisers;
• to comply with laws or regulations or to comply with any directions given by regulators or authorities.

The kinds of third parties to whom we may disclose personal information to include delivery services providers, manufacturers, suppliers, distributors, marketing and communications agencies, data analysts, IT service providers and our advisors including our professional advisors (including legal and financial advisors). We also disclose your personal information to other entities in our corporate group who provide back-end or other services to us.

We may share your personal information with third parties, which may be our related bodies corporate or completely unrelated parties, for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale. In this context, your personal information may be transferred to another entity (or if such a sale, transfer, acquisition or corporate restructure is being contemplated by us).

5. DIRECT MARKETING

We may send you direct marketing communications to keep you informed about products and services we provide and other products and services that may be of interest to you (including products and services offered by the Greencross group of companies) via email, SMS, social media, or regular mail.

Where you have signed up to our mailing list to receive communications about our Products or Services, we may send you direct marketing communications to keep you informed about the Products and/or Services.

Where you have signed up to our mailing list to receive communications about other products or services provided by us, we may send you direct marketing communications to keep you informed about other products or services provided by us or special offers, which might interest you.

Where you have signed up to our related bodies corporate’s mailing lists to receive communications about their products or services (such as Petbarn, City Farmers or in relation to the Friends For Life Loyalty Program), we will disclose your personal information to the relevant related body corporate to enable that relevant related body corporate to send you communications about their products or services

If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so.

We acknowledge and respect our customers’ choice to “opt-out” of direct marketing communication activities from us. You may opt out of direct marketing communications at any time by  emailing contact@thenoshproject.com.au or by otherwise using the unsubscribe or opt-out method used in the marketing message we have sent to you.

6. OVERSEAS DISCLOSURE OF PERSONAL INFORMATION

Your personal information will also be disclosed to overseas recipients (including services providers who provide back-end IT services to us, assist us to improve our products and services by analysing sales information and trends and conducting customer satisfaction enquiries). Those overseas recipients are likely to be located in the USA and New Zealand.

Unless we have your consent, or an exception under the Australian Privacy Principles applies, we will only disclose your personal information to overseas recipients where we have taken reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to your personal information.

7. ONLINE AND DIGITAL SERVICES

7.1 Customised experience
There are technologies that help us deliver customised visitor experiences. When you visit the Site, Greencross may make a record of your visit and log the following information for statistical or advertising purposes:

• your server address;
• your top level domain name (for example .com, .gov, .au, .uk etc);
• the date, duration and time of your visit to the site;
• the pages you accessed and documents downloaded;
• how you navigate through the Site and interact with pages;
• your device IMEI number;
• your IP address or MAC address;
• your location information;
• the previous site you have visited;
• whether you followed a link sent to you by email; and
• the type of browser you are using.

If you do not want us to collect this information, please do not access our Site.

7.2 Third party sites
The Site, our communications or our related bodies corporate’s communications to you, may also contain links to websites which are owned or operated by third parties. Those websites may be subject to their own terms and conditions of use and privacy policies. You should review and comply with those terms and conditions and we are not responsible for information on, or the privacy practices of, any third party websites.

7.3 Related bodies corporate’s websites
The Site, our communications or our related bodies corporate’s communications to you, may also contain links to websites of our related bodies corporate, such as Petbarn. Those websites are subject to the terms and conditions of use and privacy policies of the relevant related body corporate. You should review and comply with those terms and conditions if accessing those websites.

7.4 Cookies
Our Site uses cookies or similar tracking technologies that help us track your usage of the Site and remember your preferences. A cookie is a small element of data that the Site may send to your computer. A cookie is typically stored on your computer’s hard drive and permits the Site to recognise you when you return. Our use of cookies helps us to provide you with a better experience during your use of our Site by allowing us to understand what areas of the Site are of interest to you. You may configure your web browser to not accept cookies, although you may experience a loss of functionality as a result.

We use and third-party vendors use first-party cookies and third-party cookies together to inform, optimise, and serve ads based on an individual’s past visits to the Site and third party websites.

7.5 Third Parties and Interest-based Advertising
Greencross does not sell personal information to third parties. Greencross does permit third parties to collect personal information through our Site for the purpose of providing advertising on the Site and elsewhere based on users’ online activities over time and across different sites, services, and devices (so-called “interest-based advertising”). The information practices of these third parties are not covered by this Privacy Policy.

8. ACCESSING AND SEEKING CORRECTION TO PERSONAL INFORMATION

8.1 Accessing Personal Information
You are entitled to access your personal information we hold about you on request. To request access to your personal information, please contact The Privacy Officer using the contact details set out below under ‘Contacting Us’. In limited circumstances, access to your personal information may be declined in accordance with the Australian Privacy Principles. We may charge a reasonable fee for providing access to your personal information.

8.2 Updating personal Information
We will endeavour to keep your personal information accurate, up-to-date and complete. You can assist us with this by letting us know if you notice errors or discrepancies in information we hold about you and letting us know if your details change.

If you consider any personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or misleading you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

9. DESTRUCTION OF PERSONAL INFORMATION

We take reasonable steps to delete or securely destroy or permanently de-identify your personal information where it is no longer required and to protect your personal information from unauthorised access, disclosure, loss, misuse and alteration.

If you wish to have your personal information removed from our records, you may request that your personal information be deleted or securely destroyed. It will not always be possible to comply with your request to delete or destroy your personal information.

10. COMPLAINTS ABOUT HANDLING OF PERSONAL INFORMATION

If you have any questions or concerns about this privacy policy or how we have handled your personal information, you may contact us at any time. The contact details for the Privacy Officer are set out below under ‘Contacting Us’.

If you have a complaint about privacy, please contact the Privacy Officer. The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. If your complaint requires more detailed consideration or investigation, we may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved. We will respond to your complaint as soon as reasonably practicable and, in any case, within 30 days.

If you are not satisfied with our response to a complaint, or you consider that we may have breached the Australian Privacy Principles or the Privacy Act, you are entitled to make a complaint to the Office of the Australian Information Commissioner.

The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.

11. CHANGES TO THIS POLICY

We reserve the right to make changes to this privacy policy from time to time. Any changes to the privacy policy will be published on the Site. We encourage you to periodically review the Privacy Policy for the latest information on our privacy practices.

12. CONTACTING US

If you would like to contact us in relation to this privacy policy or your personal information please contact us at:

Greencross Operations Pty Ltd
Unit 6, 372 Eastern Valley Way
Chatswood  NSW  2067 Australia
Telephone: 02 8595 3333
Fax: 02 8595 3399
Email: contact@thenoshproject.com.au