The Hardie Grant Group and its related entities are bound by the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). We understand the importance of, and are committed to, protecting your personal information (that is, information or an opinion about you, whether true or not, which identifies you or from which your identity is reasonably identifiable). This Privacy Policy explains how we collect, manage and disclose your personal information, including our obligations and your rights in respect of our dealings with your personal information.
Please take a moment to read our Privacy Policy as it describes what happens to your personal information that is collected when you interact with us or use our websites (Websites).
1. Who we are
In this Privacy Policy, 'we', 'us' and 'our' refer to the Hardie Grant Group, which includes:
(a) Hardie Grant Pty Ltd (ABN 92 079 618 394);
(b) Hardie Grant Media Pty Ltd (ABN 17 080 486 755), which includes Heads & Tales Content Agency, Sherpa and tide.pr;
(c) HGX Pty Ltd (ABN 15 612 186 946), which includes Halliday Wine Companion and Handsel;
(d) Hardie Grant Publishing Pty Ltd (ABN 15 080 486 746), which includes Bright Light Books and Ultimo Press;
(e) Reload Media Pty Ltd (ABN 86 121 216 608); and
(f) their related entities.
2. How we collect your personal information
We will collect and hold your personal information in a fair and lawful manner, and not in an intrusive way. Where it is reasonably practical to do so, we will collect your personal information directly from you. We may collect the personal information you directly give us through some of the following means:
(a) when you make a purchase from us;
(b) when you subscribe to receive information from us;
(c) when you make an inquiry or place an order in relation to goods or services through our Websites;
(d) when you register as a user of our Websites;
(e) in administering and performing any contracts with service providers;
(f) when you contact us via telephone or email;
(g) from correspondence (whether in writing or electronically);
(h) through any mobile applications provided by our organisation;
(i) while conducting customer satisfaction and market research surveys;
(j) when administering any of our services;
(k) if you apply for employment or any other engagement with us; and
(l) as otherwise required to manage our businesses that you interact with.
However, in certain cases we may collect personal information from publicly available sources and third parties, such as suppliers, recruitment agencies, contractors, your employers, our clients and business partners.
If we collect personal information about you from a third party we will, where appropriate, request that the third party inform you that we are holding such information, how we will use and disclose it, and that you may contact us to gain access to and correct and update the information as set out in this Privacy Policy.
3. Types of personal information we collect
The type of personal information we may collect can include (but is not limited to), your name, your region or postal address, age, email address, phone numbers, book preferences, together with information about the products or services we have provided you, billing information and, if applicable, employment information.
If you enter into contracts with us, request or receive goods or services from us or have any other commercial dealings with us, we may also collect your signature, date of birth, billing information (including credit card and/or bank account details), and in the case of a supplier or contractor, your company name, ABN and GST status. If you are a director of an organisation that is our customer and have agreed to act as guarantor, we may collect information about your assets and your other liabilities, to assess the credit risk position of that organisation.
In some cases, you may provide sensitive information (for example, information about a health condition, injury or disability you have). Sensitive information is a sub-category of personal information that includes information about an individual's health, racial or ethnic origin, sexual orientation or practices, criminal record, religious beliefs or affiliations, political opinions, membership of a political, professional or trade association, and biometric and genetic information. We only collect sensitive information about you with your consent or otherwise in accordance with the Privacy Act. If you do provide sensitive information to us, 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.
Where you do not wish to provide us with your personal information, we may not be able to provide you with requested goods or services.
4. Our purposes for handling your personal information
As a general rule, we only process personal information for purposes that would be considered relevant and reasonable in the circumstances. The purposes for which we use and disclose your personal information will depend on the circumstances in which we collect it. Whenever practical we endeavour 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.
We commonly collect, hold, use and disclose personal information:
(a) to offer and provide you with our goods and services;
(b) to manage and administer those goods and services, including account keeping procedures;
(c) to communicate with you, including (but not limited to), emailing you tax invoices, dispatch and tracking information, returns and exchange authorisations;
(d) to facilitate your participation in competitions, promotions or offers;
(e) to verify your identity;
(f) to display information about you, such as your name and profile photo (if you have uploaded one), alongside any reviews or other posts you submit on our Websites;
(g) to contact you (directly or through our service providers and marketing research agencies) to obtain your feedback and to find out your level of satisfaction with our goods and services;
(h) to operate, monitor, develop and improve our Websites, applications and our goods and services;
(i) to optimise and customise the user experience (including content and advertising) for users of the Websites, mobile applications and services;
(j) to comply with our legal and regulatory obligations;
(k) for any other purpose (or related purpose) for which we collected it or to which you have consented; and
(l) as otherwise required to manage our business or comply with law.
We will not use or disclose your personal information for any other purpose unless you have consented to that use or disclosure. You will be deemed to have consented to any such purposes we indicate when collecting your information (such as in a notice on a form) unless you tell us otherwise.
Our companies maintain separate records and do not ordinarily share personal information with our other companies unless necessary to perform their business functions.
We may disclose personal information to third parties such as our suppliers, organisations that provide us with technical and support services, or our professional advisors, where permitted by the Privacy Act. In the unlikely event that any of our companies (or their assets) may be acquired or considered for acquisition by a third party, we may disclose personal information that company holds to the third party and its advisors. If we disclose personal information to a third party, we generally require that the third party protect your personal information to the same extent that we do.
If you post information to certain public parts of our Websites or to our social media pages, you acknowledge that such information may be available to be viewed by the public. You should use discretion in deciding what information you upload to such sites.
5. Protection of personal information
We may hold personal information as secure physical records, electronically on our intranet system, in cloud storage, and in some cases, records on third-party servers, which may be located overseas.
We maintain a range of physical, procedural and technical security measures for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information.
We further protect personal information by restricting access to personal information to only those who need access to the personal information to do their job. Physical, electronic and managerial procedures have been employed to safeguard the security and integrity of your personal information.
If you become aware of any suspected breach of security, please contact our Privacy Officer immediately on the contact details set out in section 14 below.
6. Direct marketing
Like most businesses, marketing is important to our continued success. We believe we have a unique range of products and services that we provide to customers at a high standard. We therefore like to stay in touch with customers and let them know about new opportunities. We may provide you with information about new products, services and promotions either from us, or from third parties which may be of interest to you, where you have asked us to (or have otherwise consented to us doing) or it is otherwise permitted by law.
We may disclose personal information to service providers such as Customer.io, Hubspot, MailChimp and Salesforce to manage and send marketing communications on our behalf.
You may opt out at any time if you no longer wish to receive commercial messages from us. You can make this request by following the unsubscribe process in our communications or by contacting our Privacy Officer.
7. Email analytics
Like many organisations, we use e-mail analytics to track and measure the success of our e-mail newsletters, fundraising e-mails and other e-mail campaigns.
We use various technologies (such as tracking pixels) to collect information such as: which of our emails you have opened, which links you have clicked, which email client you are using, whether you opened our email on a computer or mobile device, and the geolocation of your IP address. We use this data to analyse and improve the performance of our e-mail campaigns.
8. Internet Advertising
We may also use your information with online targeted advertising services that help our ads to reach you (and other people who may be interested in our products and services) on websites, apps and social media platforms across the Internet. These online targeted advertising services are operated by third party vendors. The advertising service providers that we currently use include Google (GoogleAds and YouTube), LinkedIn, Meta (Facebook and Instagram), Pinterest, X (formerly Twitter) and TikTok.
Some of these services work by using non-identifying data about your behaviour and demographics that has been collected through cookies and other tracking technologies (such as pixels and device identifiers) when you use the Internet, including when you move between different websites and apps and use different devices. For example, third-party vendors, such as Google, may use cookies and/or device identifiers to serve ads based on your past visits to our Websites. Your browser or device may provide you with the option to disable or opt-out of some of these cookies and other tracking technologies (such as device identifiers).
Other services require us to use limited amounts of your personal information. For example, we may include your information in a customer list that we provide to selected online advertising service providers (such as Google, Facebook, Instagram and LinkedIn) so that we can conduct audience-based advertising. This allows us to show our ads to you (if you also use those platforms) and to other users of those platforms who share similar characteristics with you. The customer list is usually hashed (to improve security and confidentiality) before it is processed by the service provider to target and serve our ads.
Our online advertising service providers also help us by measuring the effectiveness of our ad campaigns and providing us with analytics data that we use to inform and optimise our ad campaigns. The analytics data we receive is generally aggregated and non-identifying.
When we use any advertising service that requires us to use or disclose your personal information, we will only do so if we are permitted to do so by applicable privacy laws. You can notify us at any time if you would like us to stop using your personal information for these targeted advertising purposes by contacting our Privacy Officer as set out in section 14 below.
You can also:
(a) opt-out of certain online targeted advertising networks directly by visiting:
· the Digital Advertising Alliance’s opt-out portal (http://optout.aboutads.info/); and
· the Network Advertising Initiative’s opt-out page (https://thenai.org/opt-out/);
(b) use Facebook’s settings you to manage the types of advertising you are shown (https://accountscenter.facebook.com/ad_preferences/);
(c) use Google’s settings to manage your ad preferences and opt-out of Google’s use of cookies and device identifiers (http://www.google.com/settings/ads);
(d) use LinkedIn's settings to manage your ad preferences and control data collected about you (https://www.linkedin.com/mypreferences/d/categories/ads);
(e) use Instagram's settings to manage your ad preferences (https://help.instagram.com/2885653514995517/?helpref=uf_share).
9. Our Websites
A cookie is a small text file that our Websites may place on your computer. Usually, cookies are used as a means for our Websites to remember your preferences. As such, cookies are designed to improve your experience. In some circumstances, cookies may collect and store personal information about you. We will take all reasonable steps to protect your personal information. We may also use cookies for targeted online advertising. Most browsers are pre-set to accept cookies; however, you can adjust your browser to disable cookies or warn you when they are being used. Note that if you disable your cookies it may impact on your website experience.
We use Google Analytics to gather statistics on the usage of our Websites. Google may aggregate data they collect from their various services including Google Analytics, Google Maps, Google Translate and YouTube. More details are available on the Google Analytics website (https://support.google.com/analytics/answer/6004245).
Our Websites may contain links to other websites operated by third parties. We make no representations or warranties in relation to privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third-party website. We recommend that you refer to the privacy policies of the sites you visit.
10. Social Media
We use social media platforms such as Facebook, Instagram, LinkedIn, Pinterest, Threads, TikTok, X (formerly Twitter) and YouTube to communicate with the public about our services and businesses. We may collect the personal information that you choose to share with us through these platforms, including photos, videos and comments and posts.
These social media platforms have their own privacy policies, and may handle your personal information for their own purposes. You can access the privacy policies for these social media platforms on their websites.
If you choose to use these social media platforms to communicate with us, please be mindful that certain pages within these platforms may be publicly available. We encourage you to use the privacy settings available on each platform.
11. Employees
We collect personal information in relation to employees and prospective employees as part of their job application and during the course of their employment, either from the employee directly or, in some cases, from third parties such as recruitment agencies, referees, government bodies (e.g. police checks, if required) and academic and professional bodies (e.g. to validate details and currency of qualifications).
The information we collect may include contact details, qualifications, resume, current and former employment details, pay rate and salary, bank details, feedback from supervisors, training records, and logs of the employee’s usage of our equipment (e.g. phones, computers and vehicles).
We may also collect details of disabilities, allergies and health issues that may impact the employee’s role, or which arise while on our premises or in the performance of the employee’s duties, so we can accommodate and otherwise assist the employee with any related requirements and manage any incidents.
Under the Privacy Act, personal information about a current or former employee may be held, used or disclosed in any way that is directly connected to the employment relationship. We handle employee information in accordance with legal requirements and our applicable policies in force from time to time.
12. Accessing and correcting your personal information
You may contact our Privacy Officer to request access to the personal information that we hold about you and/or to request corrections to that information, at any time. You generally have the right to access your personal information, subject to some limitations contained in the Privacy Act.
The APPs set out some circumstances in which we are not required to provide you with such access. On the rare occasions when we refuse access, we will notify you in writing, stating our reasons for refusing access. We may seek to recover from you reasonable costs incurred for providing you with access to any of the personal information we hold about you.
We are not obliged to correct any personal information if we do not agree that it requires correction and may refuse to do so. If we refuse a correction request, we will notify you in writing, stating our reasons for refusing.
We will respond to all requests for access to or correction of personal information within a reasonable time.
13. Overseas transfers of personal information
From time to time we may engage overseas business partners and service providers, such as cloud-based storage solutions, email newsletter distributors, statistical analysts, etc. This may involve disclosing your personal information to those overseas entities in order to do business effectively. Because these entities may change from time to time and may have offices and services in many different places around the world, it is not practicable to list the countries where they are located in this Privacy Policy.
By providing your personal information to us, you consent to us disclosing your personal information to overseas recipients for purposes necessary or useful in the course of operating our business, and agree that APP 8.1 will not apply to such disclosures. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able seek redress under, the Privacy Act.
If you do not want us to disclose your information to overseas recipients, please let us know.
14. Resolving personal information concerns
If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your personal information, including if you believe we have breached the APPs, please contact our Privacy Officer:
Privacy Officer
Hardie Grant Group
Building 1, 658 Church Street
Richmond VIC 3121
Telephone: + 61 3 8520 6444
Email: [email protected]
Please provide as much detail as possible about your request or concern to assist our Privacy Officer in responding appropriately. We take all complaints seriously and will respond within a reasonable period (and within any applicable timeframes imposed by law).
If you are dissatisfied with the handling of a privacy-related complaint, you may contact the Office of the Australian Information Commissioner:
Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
Email: [email protected]
15. Removal of personal information
We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.
You may request the deletion of your personal information from our records at any time. These requests can be directed to our Privacy Officer as set out above. If we agree, your personal information will be removed from all our platforms. We may need to verify your identity before we can process your request.
We may not be able to honour a deletion request if we need to retain records containing personal information to comply with recordkeeping obligations or for other legitimate business purposes (such as quality assurance).
16. Changes
We reserve the right to change the terms of this Privacy Policy from time to time, without notice to you. An up-to-date copy of our Privacy Policy is available on our Websites.
The last update to this document was 9 May 2024.
