XPO Brands Privacy Policy

Last updated: February 2021

In the course of carrying out our activities, including providing our platforms and services, XPO Brands Pty Ltd (ABN 17 162 579 893), and our subsidiaries and related bodies corporate (together,we, us or our), will collect, store, use and disclose personal information.  We are committed to the protection of your personal information and to compliance with Australian privacy law.

Personal information

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

Types of personal information we collect and hold

We collect and hold personal information about individuals for the provision of our services (including our websites, vending machines, mobile applications and other online platforms and services) and purposes connected to those services.

Consistent with the provision of our services, the types of personal information we may collect and hold includes the following.

  • Identity and contact details – including individuals’ full name, address, date of birth, telephone number, email address and other identifying and contact information.
  • Video images and metadata – audio-visual and visual images, including of individuals using our vending machine platforms, as well as other related metadata (such as time and location of the vending machine platforms used by an individual).
  • Payment details – if individuals purchase goods and/or services from us, payment card details (please note payment transactions are encrypted by the acquiring bank so we will not retain any payment card details).
  • Profile data – profile information, photos or avatars, usernames, passwords, preference data, and related information.
  • Other information – text of written and oral communications gathered in the course of our interaction with you, including where you use voice activated technologies connected to our platforms, comment within our platforms and/or otherwise interact on live-chat, social media and emails, including feedback and online reviews and other information from your interactions with us online, including cookie information, IP address, URL’s, search histories and other associated information.

How we collect and hold personal information

We may collect personal information directly from you in the course of providing our services, from our website, vending machines mobile applications and other online platforms, and/or directly from you, including using cookies (data files placed on your device or computer) and also when you interact with our platforms using third party technologies, including using voice activated assistants (such as Google Assistant, Alexa and/or other similar platforms).

Personal information is held securely, is subject to various security protections and is held only for as long as the information remains relevant to the purpose for which it was collected.

Purposes for which we hold, use and disclose personal information

We will not use or disclose personal information for any secondary purpose, unless that secondary purpose is related to the primary purpose for which we have collected that information, and you would reasonably expect the disclosure in the circumstances, or unless you consent to that use or disclosure.

If your personal information is not collected by us, we may not be able to provide our platforms and services to you (for example, we will not be able to send you samples without an address). 

The purposes for which we collect, hold, use and disclose information may include:

  • conducting our business, which includes providing our services, or the services of a third party, to you, such as sending you samples you have requested via our platforms;
    • (where you have consented, if such consent is required by law) to:
      • communicate information about our products and services or third party products or services that may be of interest to you (including brands participating in our services); and
      • provide you with information or advertising relating to our products or services (including serving and targeting advertisements) or marketing communications we believe may be of interest to you;
    • to improve and optimise our services and platforms;
    • for our internal administrative, research, planning, marketing and product development purposes; and
    • to comply with legal obligations.

We may also disclose personal information to our parent companies and other affiliates and related bodies corporate, as well as to logistics partners for delivery and freight purposes, as well as third party brands, clients and technology and marketing partners, including but not limited to brands participating in our services, Amazon, Facebook and Google (including Google Assistant, Google Analytics) and other technology and marketing service providers for their use for the same purposes.  

The disclosure set out above includes disclosure of your personal information to third party brands when you request a sample from such a brand.  Such brand’s use of your personal information, including contacting them with any queries you have about the personal information they hold and how they are using it, will be governed by their privacy policy. It is your sole responsibility to review such privacy policies.

Overseas disclosure

We may, in the course of providing products and services, disclose personal information to overseas entities including by utilising overseas data servers to process information. Those overseas entities are likely to be located in the following territories: the European Economic Area (EEA) and the USA.

Changes to this Privacy Policy

We will review and update this Privacy Policy from time to time as needed without notice. Therefore, you should review the terms of this policy periodically to make sure that you are aware of how we collect, hold, store and use personal information.

Retention, access and correction

We will only retain records of your personal information to the extent they are still necessary for the purposes for which such personal information was collected.

We will take all reasonable steps to ensure any personal data we collect, use or disclose is up to date and accurate.  If you believe personal information that we hold about you is not up to date or accurate, you may ask us to correct it.

You may ask us to provide you with details of the personal information we hold about you, and copies of that information.  We will respond to your request and attempt to provide you with the data within 30 days of receipt of your request.

If we provide you with copies of the information you have requested, we may charge you a reasonable fee to cover the administrative costs of providing you with that information.

Please direct all request for access and correction to info@xpobrands.com.au  

Complaints

If you consider a breach of the Privacy Act 1988(Cth) has occurred, you may direct your query to our Privacy Officer using the details set out below and we will attempt to resolve your complaint. 

If you do not consider our response satisfactory, you may contact the Australian Privacy Commissioner at its website www.oaic.giv.au or by telephone on 1300 363 992.

Contacting us

If you have any questions about this Privacy Policy and would like further information, please contact us at info@xpobrands.com.au