Version date: March 2014
1.1 Here at Carlton & United Breweries we are committed to protecting your privacy and the confidentiality of the personal information that we collect in the course of running our business.
1.2 This policy explains how Carlton & United Breweries and its related companies (CUB, we, us and our) collects, uses and discloses personal information. Among other things, it describes:
- what information we collect and why we collect it;
- how we use the information that we collect (including who we may disclose it to); and
- how you may contact us if you have any questions about the information that we hold.
1.3 This policy applies to all individuals, except CUB employees, who deal with CUB. This includes consumers of CUB products, individuals who participate in promotional activities conducted by CUB, suppliers to CUB and users of CUB websites and mobile applications.
Carlton & United Breweries means CUB Pty Ltd (ABN 76 004 056 106) of 77 Southbank Boulevard, Southbank, Victoria, 3006.
Personal information means information about an individual whose identity is apparent or can reasonably be identified (for example, a person’s name, address, phone number or date of birth).
Privacy Act means the Privacy Act 1988 (Cth).
Sensitive information includes information about race, religious beliefs, sexual orientation, health information, membership of trade unions or political associations, criminal records or philosophical beliefs.
3 What types of personal information does CUB collect?
3.1 We collect information to provide better products and services to all of our consumers and customers. The types of information we collect depends largely on the circumstances in which the information is collected, some key examples of which are set out below.
- CUB may collect contact details including your name, address, email address, phone numbers and your date of birth / age. We may also collect answers you provide to questions we ask and other information in relation to your dealings with CUB (such as your personal interests and preferences). If you purchase products or services from us, we may also collect certain details to process the transaction.
- When you use our websites, we may collect website usage information such as the IP address you are using, the name of your Internet service provider, your browser version, the web site that referred you to us and the next website you go to, the pages you request, the date and time of those requests and the country you are in. Similarly, when you use our mobile applications, we may collect information such as your device ID, your location and details of how you used the mobile application.
- If you apply for employment with CUB, in addition to the information referred to above, we may also collect information for the purpose of considering your application including your qualifications and resume as well as reference information from your nominated referees.
- If you are an individual contractor to CUB, in addition to the information referred to above, we may also collect information relevant to your engagement with CUB including qualifications, resume, reference information from your nominated referees, bank details, feedback from supervisors and training records.
3.2 CUB does not generally require you to disclose any sensitive information to us. If you do provide sensitive information to us for any reason, you consent to us collecting that information and to us using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.
3.3 In addition to the types of personal information identified above, CUB may collect personal information as otherwise permitted or required by law.
4 How do we collect your personal information?
4.1 CUB collects personal information in a number of ways. The most common ways we collect your personal information are:
- directly from you when you provide it to us or our agents or contractors;
- via our websites or when you deal with us online (including through our social media pages and our mobile applications);
- when you enter a competition or promotion or use one of our mobile applications;
- if you are an individual contractor to CUB, from your employer or recruitment agency; and
- from third parties (for example, from referees if you apply for a position as an employee or contractor with us).
5 For what purposes do we collect, use and disclose your personal information?
5.1 Broadly speaking, we use the personal information we collect to provide and improve our products and services. Some examples of how we use your personal information includes:
- to provide or promote our products and services to you;
- to inform you about upcoming events, special promotions or offers which CUB believes may be of interest to you;
- to facilitate your entry and participation in a competition or promotion, or to enable you to use our mobile applications;
- to contact you to obtain your feedback, to find out your level of satisfaction with our products and services and for other market research activities; and
- to consider you for a job at CUB (whether as an employee or contractor) or other relationships with us.
5.2 CUB will take reasonable steps to inform you why we are collecting your personal information, how we intend to use that information and to whom we intend to disclose it at the time we collect your personal information.
5.3 In addition to the purposes listed above, CUB may use your personal information for other purposes which will be made clear to you at the time CUB collects that information, or for other purposes permitted by law.
5.4 Where CUB uses your personal information to promote or market products or services directly to you (including by way of email, telephone, SMS, MMS and mobile push notifications) we will provide you with an opportunity to unsubscribe from any future direct marketing correspondence. You can also contact us directly on the details below if you wish to unsubscribe from our direct marketing.
6 What happens if you don’t provide personal information?
6.1 Generally, you have no obligation to provide any personal information requested by us. However, if you choose not to provide certain personal information we may not be able to provide you with the products and services that you require.
7 To whom do we disclose personal information?
7.1 We may disclose your personal information to third parties in connection with the purposes described above. We may also disclose your personal information where we are required or authorised to do so by law.
7.2 This may include disclosing your personal information to the following types of third parties:
- our related companies;
- our contractors and other third parties that provide goods and services to us (including marketing and promotions agencies, website and data hosting providers, and HR-related service providers);
- companies that may use your personal information in order to tailor electronic advertising to you (e.g. on a webpage) in relation to our products and services;
- our accountants, insurers, lawyers, auditors and other professional advisers; and
- if you are an individual contractor to CUB, to your employer or agency.
7.3 We take reasonable steps to ensure that these third parties are bound by confidentiality and privacy obligations in relation to the protection of your personal information. Importantly, CUB will never sell your personal information to a third party.
7.4 If you post information to public parts of our websites or social media pages (including through our mobile applications), you acknowledge that such information (including your personal information) may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.
8 Does personal information leave Australia?
8.1 Some of the third parties to whom we disclose personal information may be located outside Australia. Where this is the case, we take reasonable steps to ensure that your personal information will not be held, used or disclosed by such third party in a way that is inconsistent with the principles contained in the Privacy Act.
8.2 These overseas third parties (which are often related companies of CUB) typically provide data-storage related services, and are located in countries such as the United States of America, the United Kingdom, India and Germany.
9 How do we protect personal information?
9.1 CUB takes reasonable steps to ensure that the personal information we collect from you is held securely and protected from misuse and unauthorised access or disclosure.
9.2 Unfortunately, we cannot and do not guarantee that unauthorised access to your personal information will not occur. Accordingly, where consistent with applicable legislation, any personal information you provide to CUB will be at your own risk (even if we are negligent). If you do become aware of a breach of security in relation to your personal information, please contact us.
10 Links, cookies and use of CUB websites and applications
10.2 CUB uses “cookies” and similar technology on its websites and in other technology applications. The use of such technologies is an industry standard, and helps us monitor the effectiveness of our advertising and how visitors use our websites/applications. We use such technologies to generate statistics, measure your activity, improve the usefulness of our communications and to enhance the “user” experience.
10.4 Each time you access one of our websites, we may deliver certain customised information, including ads and marketing campaigns, to you based on the data stored in your cookie. Third party vendors may show our ads and marketing campaigns on sites on the Internet and serve these ads and marketing campaigns based on a user’s prior visits to our website and other Internet activity. CUB may also use analytics data supplied by third party vendors to inform and optimise our ad and marketing campaigns.
11 How can you access and correct personal information we hold about you?
11.1 You have a right to access your personal information that we hold, subject to some exceptions allowed by law. If you would like to access that personal information, please contact us. We may require that the person requesting access provide suitable identification and, in certain circumstances, we may charge a fee for searching for and providing access to your personal information.
11.2 We try to maintain your personal information as accurately as reasonably possible. We rely on the accuracy of personal information as provided to us both directly (from you) and indirectly. We encourage you to contact us if the personal information we hold about you is incorrect or to notify us of a change in your personal information.
12 Queries, comments and complaints about our handling of personal information
12.2 When contacting us please provide as much detail as possible in relation to your question, comment or complaint. CUB will take any privacy complaint seriously and we will endeavor to respond to you within 30 days. If you are not satisfied with the outcome, you may wish to contact the Office of the Australian Information Commissioner (click here for information).
13 How can you contact us?
13.1 If you have any questions in relation to privacy or the steps that CUB has taken to protect your personal information or privacy, please contact us on 1800 007 282 between 9am and 5pm (Eastern Standard Time), Monday to Friday.
13.2 Alternatively, you can contact us at firstname.lastname@example.org or by writing to us at:
Carlton & United Breweries
77 Southbank Boulevard
Southbank Victoria 3006