1. Greencross Group’s commitment to privacy
The Greencross Group is committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws (see below for further information about the Greencross Group).
We understand the importance of being open and transparent with you in the way in which we collect, hold, store, use and share your personal information. We take protecting your privacy very seriously.
We strongly encourage you read this document, so that you understand and are comfortable with how we handle your personal information. If you have any questions about this document, or about Greencross Group’s handling of your personal information, please contact us using the relevant contact details set out in section 17.
2. About Greencross Group
The Greencross Group is an integrated pet care business in Australia and New Zealand, and our purpose is to make the world a happier place through the love of pets.
The Greencross Group includes Greencross Pty Limited (ACN 119 778 862), Greencross Operations Pty Ltd (ACN 130 686 743), Petbarn Pty Limited (ACN 001 802 759), City Farmers Retail Pty Ltd (ACN 083 012 211) and their Australian subsidiaries and affiliates, including businesses that provide retail and veterinary (and related) services (Greencross Group).
In summary, the Greencross Group consists of the following brands and services:
- information we may collect when a customer creates an account with or becomes a client of one brands or services;
- information we may collect when individuals join the Healthy Pets Plus membership program or Friends for Life loyalty program and other membership and loyalty programs we may make available; and
- information we may collect when you interact with us (including when you visit one of our premises in person, when you visit our websites (such as petbarn.com.au, greencrossvets.com.au, www.greencrossvets.com.au/healthy-pets-plus/ and www.friends-for-life.com.au), or contact and communicate with us via our social media channels (such as via Facebook, Instagram, TikTok, Pinterest or LinkedIn), phone or online).
Other terms and conditions may apply to you such as:
- the privacy terms and conditions contained in our Greencross Group Terms and Conditions (as applicable to you); and(as applicable to you); and
- the collection notices and privacy statements which may be provided to you at the time your personal information is collected.
5. What is personal information?
“Personal information” is defined in the Privacy Act, and means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
Personal information does not include:
- aggregated or de-identified data; or
- information about your pet (such as your pet’s name and medical history).
6. What information do we collect about you and how do we collect this information?
Normally we collect your personal information from you directly, however on occasion, we may also collect personal information about you from other people and organisations.
In summary, we may collect your personal information when you:
- create an account with us (for example, when you create a Petbarn account or become a Greencross client);
- join the Healthy Pets Plus membership program or Friends for Life loyalty program (or other membership or loyalty programs we may make available to you);
- make a purchase or complete purchase orders for our products or services (via phone, in person or electronically);
- communicate with us during competitions, special events and promotions;
- interact with us in person (such as when you visit one of our stores or clinics), via phone or online (including through our website or our social media channels), such as when you contact us to make an enquiry or give us feedback; or
- apply for a position with us (including for work experience).
We may also:
- receive personal information from another member of the Greencross Group; and
- collect personal information from third parties (such as through acquisition of third party mailing lists and from organisations with whom we have an affiliation), to improve the personalisation of our offerings for you, and from our partners (such as Uber).
Summary of personal information we collect and how we collect this information
|Type of personal information||What this includes||How do we collect this information?|
|Personal information and contact details||This may include your:
This may also include contact details for your emergency contact.
|We may collect this information:
|Pet ownership and insurance information||This may include information:
||This may be collected when you join the Healthy Pets Plus membership program or when we provide veterinary services to your pet or animal.|
|Information about your purchases and use of Friends for Life loyalty program benefits||This includes information about:
||We may collect this information when you are logged into / agree to use your Friends for Life loyalty program account and you make a purchase of or complete purchase orders for our products or services (in person and online).
If you do not want us to collect this information (i.e. you do not want your purchases to be attached to your Friends for Life loyalty program account), you can always:
|Workplace information||This may include:
||We may collect this information if you apply for a position at Greencross Group (including if you are applying for work experience with us).|
|Information collected during our interactions||This includes details of your interactions with us, for example information you provide us when you make an enquiry or complaint.||We may collect this information:
|Online and digital services information (including behavioural information)||We may collect information from you electronically, which includes information such as your IP address, and details about your device.
Please see section 12 for further information on the digital information we collect.
|We may collect this information when you use our online services (such as petbarn.com.au, greencrossvets.com.au, or our social media channels), via use of online behavioural technologies, such as cookies.
Please see section 12 for further information on the digital information we collect.
|Call recording information||This may include the voice recording, time, date, number and name of individuals on the call.||We may collect this information in circumstances where we monitor and record our call with you, when we call you, or you call us. We will let you know if we are going to record call information.|
|Camera surveillance information||We may collect camera surveillance information which includes photographs or video recordings of you.||We may collect this information in circumstances where we use camera surveillance (e.g. CCTV) at our premises for the safety of our staff and customers, such as where you attend in person at our clinics and stores.|
|Information required to be collected by law||We may collect information as required by law (such as under State and Territory veterinary surgeons legislation).||We may collect this as required.|
|Publicly available online information||We may collect information that is publicly available online, such as on online forums, websites, and social media channels (for example, information that relates to a complaint).||We may collect this directly from the publicly available source (e.g. on the online forum, website, or social media channel).|
7. Can you deal with us without providing me your name?
Most of the time, you will have the option of not providing your name, or using a fake name, when you deal with us (where it is lawful and practicable). This includes for example, when you make a general enquiry, or when you purchase products from our retail stores.
In some circumstances however, we may need your real name as it may not be practicable for us to deal with you anonymously or pseudonymously on an ongoing basis. For example, this includes when providing treatment to your pet or animal, or when adding points to your Friends for Life loyalty program account. This means that if we do not collect your personal information, we may not be able to provide you with the products and/or services you have asked for.
8. Why do we collect, store and use your personal details?
We collect personal information that is necessary to provide you with our products and services, and to carry out our business.
We may use your personal information for purposes which are incidental to the sale and promotion of our goods and services, or for other purposes which are within your reasonable expectation or permitted by law.
The purpose for which we usually collect, store, and use your personal information depends on how you interact with us (for example, whether you are part of our Friends for Life loyalty program), but may include the following purposes:
|To provide you with our products or services when you are a customer or client||We may collect, store and use your personal information to:
|To administer and manage the Healthy Pets Plus membership program and Friends for Life loyalty program||We may collect, store and use your personal information to:
|To manage your working relationship with us (including when you are a contractor)||We may collect, store and use your personal information to assess your suitability for a position with us, and, if you successfully join us, to manage our working relationship with us.
We may collect, store and use your personal information for administration and management purposes (such as if you are a veterinary surgeon or contractor).
|To do business with you||We may collect, store and use your personal information about you if you interact with us on a commercial basis (such as if you are a service provider, contractor or supplier to us), or you otherwise interact with us on a commercial basis.|
|To manage and improve our operations and business||We may collect, store and use your personal information to:
|To create deidentified or aggregate data for data analytics activities||We may collect, store and use your personal information to create deidentified or aggregate data sets (which is no longer personal information). We do this by deidentifying or aggregating your information such as combining your information with information we have about our other customers, for example purchasing information, and with data we obtain from other sources. We use this deidentified or aggregate data to assist with our business decisions, such as to:
|To assist with any business, share sale or corporate restructure||We may collect, store and use your personal information 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.|
9. Who do we share your personal information to and why?
We may share your information with third parties:
- for the reasons for which we collect, store and use that information (see above in section 8);
- for other purposes explained at the time we collect your personal information; or
- where we are otherwise allowed or required to do so under law.
Some of the third parties we may share your information with include the following:
|Other members of the Greencross Group||We may share your personal information across the Greencross Group, between members of the group (as appropriate).
may share your personal information with another member of the Greencross Group so that the other member of the Greencross Group can serve targeted advertising which may be of interest to you.
|Our partners, suppliers and other entities we do business with||We may share your personal information with our partners and other entities we do business with to assist in providing our products and services.
The kinds of third parties to whom we may disclose personal information to include delivery services providers, manufacturers, suppliers and distributors.
For example, we have partnered with Portier Pacific Pty Ltd (ACN 622 362 459) (Uber), and will share your personal information with Uber to facilitate the delivery service (including to keep you updated about the status of your product order and delivery).
|Our service providers and advisors||We may share your personal information with a variety of our service providers to assist us with providing, promoting, and managing our products and services. These may include our:
|Corporate restructure||We may share your personal information with third parties, whether affiliated or unaffiliated, 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).|
|Government and law enforcement agencies||We may share your personal information with regulatory bodies, government agencies and law enforcement bodies to comply with our legislative or regulatory obligations (such as to assist with police investigations).|
10. Do we share your personal information overseas?
We generally collect your personal information in Australia. However, it is likely that we will share your personal information with overseas recipients located in the United States of America, Germany, Singapore and New Zealand. These recipients include our service providers who may handle, process or store your personal information on our behalf.
For example, we may share your personal information with service providers who assist us with storing our data on secure data storage servers, or with improving our products and services (by analysing sales information and trends, and conducting customer satisfaction enquiries).
We only ever share your personal information outside of Australia where we are permitted to do so under the Privacy Act. Generally this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with applicable privacy laws.
There are other circumstances where we may disclose your personal information to an overseas recipient. For example, where you have provided your consent or we are otherwise permitted to do so under other relevant laws.
11. Do we use or share your personal information for direct marketing?
When you provide your personal information to a Greencross Group member, we may use that personal information to send you direct marketing communications to keep you informed about products and services offered by the Greencross Group and carefully selected partners which we think might be of interest to you based on your interactions with us.
For example, when you create an account with us (including with Petbarn or with Greencross Vets), or join the Healthy Pets Plus membership program or Friends for Life loyalty program, we may send you direct marketing communications and information about our products and services (including those provided by other members of the Greencross Group) that we consider may be of interest to you, or as otherwise allowed under applicable privacy laws.
We may communicate with you (and send these electronic messages and tailored advertising) through various channels, such as via regular mail, email, SMS, telephone, push notifications or social media (including through targeted advertisements on certain websites and social media channels).
We will only send these communications in accordance with applicable privacy and marketing laws (such as the Privacy Act (including Australian Privacy Principle 7) and the Spam Act 2003 (Cth)), and only where you have not opted out from receiving such communications from the relevant Greencross Group brand or service.
If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so.
How can you opt out?
You are always in control of the direct marketing communications which you receive and can opt-out at any time. Generally you can opt-out by following the relevant opt-out or unsubscribe instructions in the relevant communication (such as email or SMS message).
You can also contact us using the detail set out in section 17 to tell us you would like to stop receiving direct marketing communications from us.
For cookies which use your personal information for direct marketing (such as targeted advertising) you can only opt-out by adjusting your device setting and online privacy settings (for advertising on certain websites and social media channels).
Important points regarding opting out
- if you are a customer of multiple Greencross Group members (for example you have an account with Petbarn, and are also separately a client of Greencross vets), even if you opt out from receiving direct marketing communications from Petbarn, this will not mean you are opted out from receiving direct marketing communications from Greencross vets (for example); and
- regardless of whether you opt out from receiving any or all direct marketing communications, we will still communicate with you if we are required by law to provide you with information, or in relation to the services or products we are providing you with (for example, in relation to delivery information for products, sending you an invoice in relation to a transaction or providing you with any vouchers you have earnt through the Friends for Life loyalty program).
12. How do we interact with you via the internet?
Third party links and sites
When you use our websites or receive communications from us, links to websites which belong to other third parties may be included (and are provided for your convenience). You should make your own enquiries as to the privacy policies of these parties. We are not responsible for information on, or the privacy practices of, any third party websites.
In addition, when you make online payments using our websites, we do not collect your credit card or banking details. This is because online payments are handled by third parties (Braintree, Zippay, Afterpay, NAB and Paypal) – please use these links to see details of their privacy and security policies before making online payments.
Website use and cookies
At a high level, cookies can be used for a variety of reasons, such as to personalise your browsing experience (for example, by remembering your preferences and recognising you as a repeat visitor to our websites), and to track statistics about the usage of our website. This allows us to better understand our users and improve the layout and functionality of our websites.
If you do not wish to receive any cookies (other than those that are strictly necessary) you can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our websites.
Please see our separate Cookies Policy for further information about what cookies we use and information we collect online and through digital services.
13. How do we store and protect your personal information?
We are committed to protecting your personal information, and ensuring that we securely store any personal information we collect (and in accordance with applicable privacy laws). We may hold your personal information in hard copy (paper) or electronic form.
We take all reasonable steps to ensure that any personal information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment protected from misuse, interference and loss, and from unauthorised access, modification or disclosure.
Security and storage of personal information
|Paper-based files||We store personal information in paper-based files in secure storage (generally at our head office, or at the relevant store or clinic). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed).
We maintain physical security measures to ensure that personal information in paper-based files is protected, such as physical locks and security systems at our premises.
|Electronic records||We store electronic records in secure databases, using trusted third party storage providers based in Australia, United States of America, Germany, Singapore and New Zealand. We also maintain physical security measures in relation to storage of our electronic records (such as through locks and security systems at our electronic data stores).
Using technical methods, we also maintain computer and network security. For example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
|Our websites (including for making payments)||Our websites use encryption or other technologies to ensure that your personal information is securely transmitted via the internet (including to protect any payments you make).
We encourage you to exercise care when sending your personal information via the internet (for example, when communicating with us online, we ask that you do not include your full account or card details).
How long do we keep your personal information?
When we no longer require your personal information (and in accordance with any applicable laws), we will take steps to delete, destroy or de-identify that information.
14. How can you access or seek correction of your personal information?
You are entitled to request access to any of your personal information that we have. To make such a request, please contact us using the relevant contact details set out below in section 17.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and informing us of any change in your personal details (for example, if your email address changes or if you move and change address).
If you consider any personal information we have about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you are also entitled to request correction of the information (again, please contact us). After receiving a request from you, we will take reasonable steps to correct your information.
We may decline your request to access or correct your information in certain circumstances in accordance with the applicable privacy laws. If we do refuse your request, we will provide you with a reason for our decision. In addition, in the case we refuse your request for correction, we will include a statement about your request with the personal information we store.
15. How can you make a complaint about the handling of your personal information?
Please also contact us if you have a complaint about privacy. If you make a complaint about privacy, the following will occur:
|1||We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally respond to your complaint within a week.|
|2||If your complaint requires more detailed consideration or investigation:
|3||We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved.|
|4||In most cases, we will respond to your complaint within 30 business days from when we receive your complaint. If the matter is more complex or our investigation may take longer, we will let you know.|
If you are not satisfied with our response to a complaint, or you consider that we may have breached the Privacy Act (including the Australian Privacy Principles), you are entitled to make a complaint to the Office of the Australian Information Commissioner (the Australian privacy regulator).
The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992, or you can fill out this form to make a complaint about our handling of your personal information. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.
17. Contact us
You can contact us using the details below:
|Contact Greencross Group|
You can contact us 9am to 5pm, Monday to Friday AEST
|Postal Address||Quarter One, Level 2, 1 Epping Road, North Ryde, NSW 2113|