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Privacy Policy

In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means Rhubarb Group Pty Ltd (ABN 58 653 651 855) and our related bodies corporate. We are committed to respecting your privacy. Our Privacy Policy sets out how we collect, use, store and disclose your personal information. By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.

We may change our Privacy Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Privacy Policy. Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name, age, gender, postcode and contact details. It may also include financial information, including your credit card information.

What personal information do we collect?

Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

The types of Personal Information that we may collect from you and how we use it will depend on the products, services and facilities you use, how you use them and upon your status as an Independent distributor or Client.

If you do not provide this information we may not be able to process your application for registration, or provide you with any product or services offered in connection with our business, or otherwise effectively conduct our relationship with you.

The types of personal information we may collect about you include:

  • your name;
  • images of you and/or copy of drivers license;
  • copy of another form of identification documentation such as passport and/or proof of address such as a utility bill
  • your contact details, including email address, mailing address, street address and/or telephone number;
  • your marital status;
  • your age and/or date of birth;
  • your credit card and/or bank account details;
  • your demographic information, such as postcode;
  • your preferences and/or opinions;
  • information you provide to us through customer surveys;
  • details of products and services we have provided to you and/or that you have enquired about, and our response to you;
  • your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
  • information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
  • additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information;
  • your occupation and employment details including employment status and any previous work experience;
  • information from or in connection with your resume or job application if you apply for a position with us; and
  • any other personal information requested by us and/or provided by you or a third party.

We collect and record personal information about individuals such as:

  • our clients and independent distributors, potential clients and independent distributors, and their representatives;
  • our suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders;
  • contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to us;
  • our employees past and present, including applicants; and
  • any other person who comes into contact with us.

We may collect these types of personal information directly from you or from third parties, and other sources such as:

  • our independent distributors, when you as a client give them personal information which they provide to us;
  • your nominated representatives (eg spouse, power of attorney, brokers and other professional advisors);
  • publicly available sources of information; and
  • our related entities, companies and businesses.

 

Why do we collect, use and disclose personal information?

We may collect, hold, use and disclose your personal information for the following purposes:

We may collect your personal information in the course of providing you with goods or services, or:

  • when you use or buy our products or services;
  • when you provide us, or you offer or apply to supply us, with goods or services;
  • when you provide information to us in any way (including by completing a form, disclosing information over the phone or via email, or providing us a business card);
  • when you request information about us, our products or services;
  • when you provide feedback to us;
  • when you visit or fill in a form on our Site;
  • when you visit premises from which we operate;
  • when you (or your employer) provide that information to us in the course of conducting or administering our relationship with you, or when you are carrying out activities in connection with our business operations;
  • when you submit a job application with us;
  • when you otherwise contact us by telephone, fax, email, social media, post or in person; or
  • where we are otherwise required or authorised by law to do so.

We may collect, hold, use and disclose personal information for the following purposes:

  • to process applications and orders;
  • to deliver ordered products;
  • calculate and process payments;
  • to confirm identification;
  • dealing with requests, enquiries, complaints and other customer care related activities;
  • to contact and communicate with you;
  • to enable you to access and use our Site, associated applications and associated social media platforms;
  • for internal record keeping and administrative purposes;
  • for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
  • to run competitions and/or offer additional benefits to you;
  • to comply with our statutory and legal obligations and resolve any disputes that we may have;
  • to promote and market our products and services to you;
  • to provide you with information that we believe may be of interest to you or that you may be interested in receiving, including advertising material, regarding us, our clients, and our business partners;
  • to provide for the safety and security of workers and onsite visitors;
  • to help us manage our business operations;
  • for business support purposes including maintenance, backup and audit;
  • to process any job application submitted by you; or
  • to respond to any queries or complaints you may have.

Where we engage with you multiple times over a short period in relation to the same matter, we may not provide you with a separate notice about privacy each time we engage with you.

If we do not collect your personal information, or if you provide us with inaccurate or incomplete information, we may not be able to provide you with the product or service, or fulfil the other purposes for which we collect personal information.

We reserve the right to at all times monitor, review, retain and/or disclose any information as necessary to satisfy any applicable law, but we have no obligation to monitor the use of our Site or to retain the content of any user session.

We may otherwise collect, use or disclose your personal information where the collection, use or disclosure is in accordance with this Privacy Policy or any agreement you enter into with us, or as required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth).

Do we use your personal information for direct marketing?

We and/or our carefully selected business partners may send you direct marketing communications and information about our services and products. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this privacy policy to:

  • third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
  • professional service providers and advisors who perform functions on our behalf, such as lawyers;
  • our employees, contractors and/or related entities;
  • our existing or potential agents or business partners;
  • sponsors or promoters of any competition we run;
  • courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
  • third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia;
  • third parties to collect and process data, such as Google Analytics or other relevant businesses. This may include parties that store data outside of Australia as contemplated by this Privacy Policy.

We may also disclose your personal information to our Site host or software application providers in certain limited circumstances, for example when our Site experiences a technical problem or to ensure that it operates in an effective and secure manner.

Disclosure of personal information outside Australia

Some of your personal information may be disclosed, transferred, stored, processed or used overseas by us, or by third party service providers. This may happen if:

  • our offices or related entities are overseas;
  • we outsource certain activities overseas;
  • transactions, information, services or products have an overseas connection; or
  • our computer systems including IT servers are located overseas.

You consent to the collection, use, storage, and processing of your personal information outside of Australia as set out in this Privacy Policy.

In particular, your personal information may be disclosed to third parties in Japan (where our parent company is located), other countries in which we have branches or offices (see https://enagic-australia.com/our-branches for details of our office locations around the world), the USA, and such other countries in which those parties or their, or our, computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy. In these circumstances, you consent to the collection, use, storage and processing of your personal information in those countries, without us being responsible under the Privacy Act 1988 (Cth) for such use (or for any breach). Where such parties are located overseas, you may have rights to enforce such parties’ compliance with applicable data protection laws, but you might not have recourse against those parties under the Australian Privacy Act in relation to how those parties treat your personal information.

Using our website and cookies

We may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer. 

We may also use ‘cookies’ or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy. 

Security

We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we [insert measures taken]. However, we cannot guarantee the security of your personal information. 

Links

Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites.

Accessing or correcting your personal information

You can access the personal information we hold about you by contacting us here. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.

Making a complaint

If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us here. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take. 

Any passing on of personal data for legal purposes will only be done in compliance with laws of the country you reside in.

Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us here.

Effective: Saturday 1 July, 2023