At Best Friends Group, we value the trust our customers place in us when they provide us with their personal information.
Please be assured that we take the protection and security of that information very seriously.
Best Friends Group is bound by the Australian Privacy Act 1988 (Cth) and we will only collect and handle personal information in accordance with that Act and this Policy.
‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether recorded in a material form or not – i.e. information which identifies you as an individual or from which you can reasonably be identified.
Where we can, we will allow you to deal with us anonymously or by using a pseudonym. However, in some circumstances, this may not allow us to provide you with a service (such as delivery). If you ask about this, we will inform you if it is possible for an interaction to occur on an anonymous basis and, where it is, it will be optional for you to provide your personal information to us.
Whilst you may opt to not to provide us with your personal information, you should be aware that without this personal information, we may not be able to provide you with some of the services and/or products you are seeking.
Best Friends Group only collects the personal information that we need for one or more of our functions or activities.
For example, we may collect different types of personal information from customers who visit our stores, puppy schools, grooming salons or become members of the Best Friends VIP Club.
The types of personal information Best Friends Group may collect includes, but is not limited to:
- date of birth;
- marital status and family/spouse/partner details;
- residential address;
- email address;
- contact telephone numbers;
- identification details (e.g. student, pensioner card);
- testimonials or opinions;
- photos or video recordings of you taken instore;
- financial information, such as credit card details;
- records of your written or verbal contact with us, including voice recordings of telephone conversations you have had with us;
- your animal’s health information, conditions or veterinary treatment details;
- CV details and work experience if you have applied for an employment position;
- details about your activities, including but not limited to sporting and other lifestyle interests;
- information related to use of our online services such as device identifiers (IP address), location data, dates, times, file metadata, referring website, data entered and user activity (such as links clicked).
We will not collect sensitive information about you without your express consent. Sensitive information includes health information and information about a person’s race, ethnic origin, political opinions, membership of trade associations, religious or philosophical beliefs, sexual preferences or criminal history.
Best Friends Group will only collect personal information about you by lawful and fair means, and not in an unreasonably intrusive manner.
We only collect personal information for purposes that are directly related to our business activities, and only when it is necessary for or directly related to such purposes. We often collect personal information from customers, suppliers, veterinary professionals, employees, contractors, visitors to our website, through apps, through social media and by using digital services or other collection methods.
Best Friends may also collect personal information about you from other companies within the Best Friends Group.
It is our usual practice to collect personal information about you (and possibly about your family) directly from you (or from your authorised representative e.g. your guardian). This is done when we make a record of the personal information that is provided to us when you (or your representatives):
- visit one of our websites;
- call our customer care team;
- fill out a hard copy or digital form;
- give information to our in-store service staff;
- order or purchase goods or services;
- if you are a client of one of our veterinary surgeries;
- provide a testimonial or survey response about our products or services;
- communicate about us or our brands on social media;
- provide personal information if you post a blog or other feedback on any of our websites;
- apply for membership to our loyalty programs to or sign on for any service that we provide;
- ask us to make a credit application to a credit provider (e.g. Vetpay) on your behalf;
- post a review or comment on one of our websites or social media pages;
- post a rating or review or other user generated content on one of our websites or apps;
- enter one of our competitions (or competitions run by our partners or associates);
- provide services to us;
- click on one of our advertisements or offers (by using technology such as ‘cookies’);
- interact with us in relation to employment services, human resource management, and other corporate service functions;
- communicate with us (including e-mail and telephone) for security, dispute resolution and training purposes and when we operate video and audio surveillance devices in our premises;
- make a complaint or legal/ liability claims against us; and/or
- contact us by telephone, mail, email, online or by any digital form or social media.
Most of the personal information that we hold about you will be from your direct dealings with us,
but we may also collect your personal information from a third party, anyone authorised to act on your behalf, or via social media. We will only do this if we have been advised that you have consented to the collection of your personal information, or if you would reasonably expect us to collect your personal information in that way.
We may collect personal information from our business or related entities and affiliates which have collected your information. We may also collect information about you by accessing data from other sources and then analysing that data with the information that we already hold about you in order to learn more about your preferences and interests.
If you use Google or Facebook to log into one of our websites, this allows the website to make a request for data about you. If you if you choose to log in with your social account, your data will be shared between those social networks and Best Friends. You should therefore stay updated on your social networks' privacy policies, and only use the social log-in for sites you feel comfortable sharing data with.
If we receive information about you from a third party, and it is not information we need in respect of our business activities, we will destroy or de-identify that information (provided it is lawful to do so).
Please note that our websites are not directed to individuals under the age of sixteen (16). We ask that you do not provide personal information, post comments or submissions of anyone under that age with the express consent of the individual’s parent or guardian.
We may use your personal information for a number of purposes, including (including but not limited to):
- To identify you and any records relating to your pet or animal;
- To provide you with the products and services you have requested;
- Manage your requests for products and services including delivery, processing payments, providing refunds, discounts and incentives;
- To develop and improve the products and services we offer;
- To maintain and improve customer services and seek your feedback, including conducting product and market research and analysis;
- To improve our operational processes, enhance your customer experience and to monitor and review our compliance with relevant regulations and codes of conduct in our dealings with you;
- To provide you with general healthcare information about your pet or animal;
- To contact you in the event of an emergency (for example, if your pet or animal is sick or hospitalised);
- To send you reminders concerning the health care of your animal;
- To market the products and services of Best Friends Group and the Best Friends Group, and to enable companies in the Best Friends Group to market directly to you;
- To facilitate appropriate communication between you and Pet Health Insurance organisations or our preferred credit suppliers;
- To comply with any legal obligations or governance requirements;
- To facilitate your interaction with us on our website;
- To consider any application for employment made by you;
- To meet our legal obligations and to notify you of matters that we are required to do so by law (such as product recalls);
- To interact with Regulators or other Government agencies;
- To manage and resolve any legal or commercial complaints and issues;
- To investigate fraud and to carry out loss prevention activities;
- As part of buying or selling our businesses; and/or
- To carry out internal functions including training.
De-identified personal information may also be used to allow corporate reporting within our business and with our affiliates.
In the course of conducting our business and providing our products and services to you, we may disclose your personal information.
We only disclose personal information for the purposes for which it was given to us, or for purposes which are directly related to one of our functions or activities. We do not give it to anyone else unless one of the following applies:
- you have consented to the disclosure;
- it is otherwise required or authorised by law.
If we engage third party agents or contractors, we will take all reasonable steps to ensure that they do not breach privacy requirements in relation to the information, before we share your personal information with them.
We may disclose your personal information to:
- our employees, agents or contractors as required;
- our business affiliates or related entities, including the Best Friends Group;
- any overseas affiliates (such as insurers or superannuation administrators) and other organisations engaged to assist Best Friends in human resource administration or to provide employee benefits;
- professional advisers (such as lawyers, accountants, auditors) to the extent that is reasonably required;
- advertising, marketing and promotional agencies that we engage;
- payment systems operators and financial institutions;
- debt collectors;
- third party service providers that provide us with communication (e-mail) or data storage services;
- technology services including application, development and technical support, processing, storing, hosting and data analysis;
- administrative services, including mailing services, printing, archival and contact management services;
- third party agents or contractors with whom we contract in the ordinary course of business;
- organisations authorised by Best Friends Group to conduct promotional, research or marketing activities;
- upon lawful request from law enforcement agencies or government authorities; and/or
- any persons acting on your behalf including those persons nominated by you, executors, trustees and legal representatives.
In some circumstances, Best Friends Group may disclose your personal information to overseas recipients.
If this occurs, we take steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach the relevant privacy laws in relation to that information.
Our service providers are mainly located in Australia, however from time to time we may need to engage a service provider in another country. We may also be required to report to regulatory authorities, within or outside of Australia, as required by law.
Your personal information may be stored in a secure and/or encrypted form overseas (e.g. in data storage and cloud computing facilities operated by us or by third parties on Best Friends’ behalf).
We use IT and data service providers to send your personal information overseas for the purposes of data storage and hosted management systems. As a result, your personal information may be transferred to, and stored at, a destination outside Australia. By providing us with your personal information, you are agreeing to the disclosure of your personal information to third parties operating outside of Australia. Best Friends Group will take all reasonable steps to ensure that any personal information we disclose overseas is handled in accordance with the law.
Sometimes we make the business decision to use third party platforms and services to process sales, provide web support, send marketing messages, deliver products or otherwise provide data storage and processing services. These services are hosted and managed by organisations other than ourselves, and some of these services are hosted overseas. These services may also involve geographic locations which change from time to time which include data protection and processing efficiency. Where these services are used by us, it may not be practicable for us to notify you of which country your personal information may be located in. Our Vet currently uses an Amazon webserver (which is a transborder data system) to operate and its maintain data.
We are committed to compliance with all laws and requirements relating to the use of your personal information for direct marketing.
When you provide your personal details, you may consent to us using your personal information for direct marketing purposes (for an indefinite period). From time to time, we may contact you with information about products and services offered by us and our related entities and our business partners or affiliates, which we think may be of interest to you. When we contact you it may be by mail, telephone, email, SMS or via social media. These communications may relate to products and services that we and our affiliates provide, and other products that may be of interest to you.
Best Friends Group will also deliver advertising for products and services to you, that we think you may need or want. Where we use your personal information to send you marketing and promotional information by post, email or telephone, we will provide you with an opportunity to opt-out of receiving such information. By electing not to opt-out, we will assume we have your implied consent to receive similar information and communications in the future. We will always ensure that our opt-out and unsubscribe notices are clear, prominently displayed and easy to take up.
If you do not wish to be contacted by Best Friends, please contact Privacy Officer at firstname.lastname@example.org or send a letter to the Privacy Officer, Best Friends Group, Unit 1, 2-6 Sloane Street Maribyrnong VIC 3032.
Best Friends Group may provide you with information and services through a range of digital and online services including websites (e.g. http://www. https://www.bestfriendspets.com.au/), apps, email, online advertisements, and social media profiles. This may be done by us and our related entities to provide you with a consistent experience, personalised to your use of each of those services and to deliver targeted advertising.
Our marketing system may record of information in relation to your interactions with our online services. This can include information about software versions used, device identifiers (like IP address), location data (where available and not disabled by you), dates, times, file metadata, referring website, data entered, and your activity such as the links you have clicked.
The services Best Friends Group may use from time to time include those offered by Google (including Google Display Network and DoubleClick), Yahoo, Adobe (including Campaign Manager and Analytics), and Microsoft. You can find out more information about these services in the privacy policies for those services, including information on how to opt-out of certain things (e.g. Google Analytics Advertising Features which uses age, gender, and interests categories to target our ads to you on the Google Display Network).
You can use Ads Settings on your browser to manage the Google ads that you see and to opt out of Ads Personalisation. Please note that you may need to opt-out separately from each service.
Best Friends Group may also partner with advertising companies to serve you ads based on your web browsing activity, purchases and/or interests. Some techniques for delivering content based on your interests are referred to as online behavioural advertising. Based on your on- and offline purchase history, your behaviour on our websites (visited pages, links clicked) and interaction with chatbot(s), we will set-up and maintain your personal digital marketing profile to make sure that we only show you advertisements that will most likely suit your personal taste.
Depending on your settings, we may show you personalised ads based on your interests. You can control what information we use to show you ads by visiting your ‘ad settings’ on your browser. You can request us to remove your digital marketing profile by sending us an e- mail to email@example.com.
Best Friends Group engages in social listening – which means we monitor our social media channels for any customer feedback or direct mentions of our brands. We do this by looking out for specific keywords or topics.
If you actively communicate about us or our brands on social media, we collect a copy of your communication. For example, if you use #bestfriendspets in relation to one of our items we will retain a copy of the tweet and may use it for our brands awareness. In order to enable us to do so, we may contract third parties for the provisioning of social listening services. Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Also, if you disclose any personal data relating to other people to us or to our service providers in connection, you represent that you have the authority to do so and to permit us to use the personal information in accordance with this privacy notice. If you choose to connect your social media account to your Best Friends Group (or related brand) account (where such feature is available), you will share certain personal data from your social media account with us, for example, your name, email address, photo, list of social media contacts, and any other information that may be or you make accessible to us when you connect your social media account to your Best Friends Group (or related brand) account. We will engage in these activities to manage our contractual relationship with you, with your consent or where we have a legitimate interest.
Cookies are pieces of information that a website transfers to your computer for record-keeping purposes.
Cookies help provide additional functionality to the web site or to help us analyse site usage more accurately. We use information collected from cookies to better understand, customise and improve user experience with our websites, services and offerings, as well as to manage our advertising. For instance, our server may set a cookie that keeps you from having to enter a password more than once during a visit to one of our sites. Also, we may use web analytics services that leverage cookies to help us to understand how visitors engage with and navigate our site (e.g. how and when pages in a site are visited and by how many visitors).
We are also able to offer our visitors a more customised, relevant experience on our sites using cookies by delivering content and functionality based on your preferences and interests. If you have provided us with personal information (e.g. through a registration or a request for certain materials), we may associate this personal information with information gathered through cookies. This allows us to offer increased personalisation and functionality.
In all cases in which cookies are used, the cookie will not collect personal information except with your explicit permission. Your web browser can be set to allow you to control whether you will accept cookies, reject cookies or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognise you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting cookies.
We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers. We have a number of security controls in place and we take all reasonable steps to ensure that your personal information is stored securely and is protected from misuse and loss and from unauthorised access, modification or disclosure.
Our computer systems may be operated by us or by our service providers. In all cases, we have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, the personal information that we handle. Examples of these measures include:
- control of access to personal information through access and identity management systems (such as passwords); and
- Best Friends Group staff are bound by and trained on internal information security policies and are required to keep personal information secure at all times.
Best Friends Group will retain the personal information that we collect about you for the period that you actively interact with us. If you are no longer considered to be actively interacting with us if, for a consecutive period of two (2) years, you have not purchased an item from us or have not visited one of our website(s). After this two (2) year period we will only retain specific personal data that needs to be retained:
- in light of the purpose(s) for which it was obtained;
- if we are required to do so by law; or
- if this is necessary to protect our rights or legal position.
The personal information that we use to send you direct marketing communications will be retained and used by us until you opt-out from receiving those communications from us.
If we no longer require your personal information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or de-identify your personal information.
It is possible, moving forward, that there could be a change in our business ownership or structure (including but not limited to a merger, acquisition or sale of a portion of all or some of our assets, (including our customer databases)), or we may undertake a corporate reorganisation or other action or transfer between Best Friends Group or related entities.
In the event that this should happen, you should be aware, that when you provide your personal information (by any means, whether verbal, written or electronic) or through your use of the Best Friends Group or Best Friends Group websites at any time, you are consenting to the transfer of your personal information to a potential or actual new owner or successor entity so that services can be continued to be provided to you.
Best Friends Group will not use Government Identifiers, such as Medicare numbers, or a driver's licence number as its own identifier of individuals.
You can request access to the personal information we hold about you at any time, and we will
provide you with that information unless we are prevented by law from giving it to you. If we are unable to give you access to the information you have requested, we will give you reasons for this decision when we respond to your request.
You will not be charged for accessing your information, although we might have to charge the reasonable cost of processing your request, including photocopying, administration and postage. We will advise you of any fee payable before we process your request. If there are any circumstances that may restrict your access to this information then reasons for denying such access will be explained in accordance with our obligations.
If you believe that your personal information is not accurate, complete or up to date, please contact please write to:
- Mail: Unit 1, 2-6 Sloane Street Maribyrnong VIC 3032.
- Email: firstname.lastname@example.org or if you query relates to information held by Our Vet, please email: email@example.com.
- have queries, concerns or complaints about the manner in which your personal information has been collected or handled by Best Friends Group; or
- would like to request access to or correction of the personal information we hold about you;
Please write to:
- Mail: Unit 1, 2-6 Sloane Street Maribyrnong VIC 3032.
- Email: firstname.lastname@example.org or if you query relates to information held by Our Vet, please email: email@example.com.
We will aim to deal with your complaints in a prompt and responsive manner.
We may ask you to put your request or complaint in writing, and to provide further details about it. Our Privacy Officer will investigate the matter and attempt to resolve it in a timely way.
If you consider your privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, you can contact the Office of the Australian Information Commissioner on 1300 363 992 or visit their website at www.oaic.gov.au.