Privacy Policy | Best Friends Pets

1. OUR PRIVACY COMMITMENT

We are committed to protecting the privacy of your personal information.

If you decide to share your personal information with us, we want to gain and keep your trust. We will do this by handling your personal information in a transparent and accountable way, and by ensuring that it is held securely.

We will always collect, store, use and disclose personal information in accordance with all applicable privacy laws, including the Privacy Act 1988 (AU) in relation to our activities in Australia and Privacy Act 2020 (NZ) in relation to our activities in New Zealand. When used in this privacy policy, the term ‘personal information’ has the meaning given to it in those Acts (as applicable with respect to the relevant country that applies). In general terms, it is any information that can be used to personally to identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

This Privacy Policy applies to PETstock Pty Ltd ACN 098 394 588 and all Petspiration Group businesses, related brands, entities and digital services (Petspiration Group, we, us or our). Please note that this privacy policy applies to any personal information or data gathered through the use of any websites or mobile applications that we own and control and that link to this policy.

Important Note: If you choose to provide your personal information or data to us, you are accepting the terms of this privacy policy and consenting to the handling of your personal information, including the collection, use and disclosure of that information as set out in this policy by us. You should familiarise yourself with our privacy policy before deciding whether you would like to share your information with us.

2. WHAT PERSONAL INFORMATION MIGHT WE COLLECT ABOUT YOU?

We collect personal information that we need for one or more of our business functions or activities. We will collect personal information about you by lawful and fair means, and will not do so in an unreasonably intrusive manner.

We have provided details below on the information that we collect in a number of ways, including:
information that you provide directly to us;
other information that we collect about you;
information we collect using third-party automation;
collection of cookies;
collection of personal information via interest-based advertising; and
information we collect via our websites.

You can read more about the types of personal information we may collect and the ways that we may do this in the sections below.

a. Information that you provide to us

In order to handle your purchases, provide customer service, improve our products, provide in-person experiences or events and send you information about our products, trends and promotions, we may ask you to provide us with your:

name;
mailing/shipping address;
billing address;
e-mail address;
date of birth, age or age range;
gender;
clothing and accessory size/fit information;
purchase/return/exchange information;
contact telephone numbers;
product reviews;
account or loyalty username/password;
payment information (credit/debit card);
social media names or other details;
identification details (e.g. licence number, student, pensioner card);
testimonials or opinions;
photo (possibly including recordings of you on video and audio surveillance devices in our premises);
financial/ purchase information (such as credit card details);
information required for a credit assessment;
records of written or verbal contact with us, including voice recordings of telephone conversations you have had with us;
pet’s name and details; and
preferred activities, including but not limited to lifestyle and other interests.

We may also collect some personal information from our vendors and suppliers when we conduct and manage our business, with or if we need to undertake a credit assessment. In NZ, the Privacy legislation covers the personal information of employees and job applicants, and so we may also collect your personal information if we make you an offer for employment purposes or to undertake employment, human resource and payroll related functions in NZ.

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 you have asked for (such as delivery). If you ask us about this option, we will inform you if it is possible for an interaction to occur on an anonymous basis. 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.

If you provide us with information about any third-party, you must obtain that third-party's permission to give us the information and inform them that you have given the information to us. If you provide your personal information to a third-party via a link from any of our websites or apps, you should be aware that the information you provide may be collected and managed by those third-parties, which may not be related to us. You should familiarise yourself with their privacy policy before deciding whether you want to provide them with your personal information.

Whilst links to third party websites may be provided on our various websites, we are not responsible for the content or practices of third-party websites. These links are provided for your convenience and are not endorsed by us. No links may be made to our websites without our prior written consent.

b. Other information we collect about you

We may collect information about you or your activities from our related brands, entities, business partners, affiliates and digital services, such as web hosting providers, analytics companies, social media platforms, data companies, and advertising services. This could include information such as:

demographic information;
shopping preferences; and/or
information about your pets and other interests.

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 also collect personal information from our businesses or related brands, entities, business partners, affiliates and digital services that have collected your information, or by accessing data from other sources. We may then analyse that data and match it with the information that we already hold about you, in order to learn more about your preferences and interests. If we receive your personal information from a third-party, and it is not information we need for the purposes of our business activities, we will destroy or de-identify that information (provided it is lawful to do so).

You may be offered the option to join one of our loyalty programs. If you choose to do this, we will collect personal information including your profile information, purchase history and the contents of any online wish list. In our store, we may collect your company name, personal name, address and other relevant personal details if this is needed to comply by local fiscal and legal requirements such as to provide a tax receipt.

When you make a purchase via one of our online stores or a mobile app we will collect information such as your name, shipping and billing address and contact details such as telephone and email address, ordered and returned products, delivery information and invoice information. We also collect data on your usage vouchers and/or gift cards.

If you interact with any of our chatbots (automated messengers) we will record what you respond to these chatbots, how you interact with them and we will store data related to the device that you use. Depending on the platform for the chatbot and your permissions, the data we collect may include your IP address, social media handle, time zone, country and GPS location. The platform that provides the chatbot may also collect some of this data. For example, if the chatbot is provided on Facebook, this platform will collect your user data as well.

c. Third party automated information collection
When you visit any of our websites or applications or access our in-store Wi-Fi, we may automatically collect your:

device ID;
device type;
browser types and version;
geo-location and in-store location;
IP address;
your network activities when using our Wi-Fi; and/ or
how you use our site (search terms, page views, referring sites, content views).

d.Collection of Cookies

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).

There are four main types of cookies that we use:

site functionality cookies – these allow you to navigate the site and use our features, such as ‘Add to Cart’;
site analytics cookies – these cookies allow us to measure and analyse how our customers use the site, to improve both its functionality and customer shopping experience;
customer preference cookies – when you're browsing or shopping on our website(s), these cookies will remember your preferences (like your language or location), so we can make your shopping experience as seamless as possible, and more personal to you; and
targeting or advertising cookies – these are used to deliver ads relevant to you. They also limit the number of times that you see an ad and help us measure the effectiveness of our marketing campaigns.

Our use of cookies means we are able to offer our visitors a more customised, relevant experience on our sites by delivering content and functionality based on your preferences and interests.

We, and any third-parties we engage (including our service providers), may collect data using cookies and other device identifying technologies. We use cookies and tracking technologies to collect your IP address, device ID information, ISP provider, browser type, the pages and content you view on our website (s), the search terms you enter on our website, and the actions you take on our website.

In some cases, the third parties we work with may use cookies and other technologies (such as those described in this policy) to support our digital marketing initiatives. Analytics collects any demographic and interest information available in a cookie. These technologies may be used in connection with activities like surveys, online behavioural advertising, website analytics, and email campaign management. The ‘Help’ section of your browser may tell you how to prevent your browser from accepting cookies.

If you have provided us with personal information (for example, if you join one of our loyalty programs or order a product), 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 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.

e. Collection of information via Interest Based Advertising

We may use third-party advertising companies to display ads that are tailored to you based on how you browse and shop online. This is a practice commonly referred to as ‘interest-based’ or ‘behavioural’ advertising.

We allow these third parties to collect certain information when you visit our websites or use our applications, including non-personally identifiable information (browser type, subject of advertisements clicks on, session IDs) and personal data (such as static IP address). The information that we obtain about you from social media platforms depends on your account and privacy settings within the platforms and the platforms privacy policies. For example, 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.

The services that we may use from time to time include those offered by Facebook (Custom Audience), 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 (for example, Google Analytics Advertising Features which uses age, gender, and interests categories to target our ads to you on the Google Display Network).

If you use a third-party authentication service or social account (for example, Google or Facebook) to log into one of our websites, this allows our website to make a request for data about you. If you if you choose to log in with an authentication service or social account, your data will be shared between those social networks and us. 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.

We may also engage 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 #PetspirationGroup or #Petstock in relation to one of the items we sell, we may retain a copy of the tweet or other communication and may use it for our brands awareness. In order to enable us to do this, 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 information relating to us, other people or to our service providers, you represent that you have the authority to do so and also permit us to use the personal information in accordance with this privacy policy.

If you choose to connect your social media account to a member account or loyalty program with us (where such a feature is made 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 a member account or loyalty program with us. We will engage in these activities to manage our contractual relationship with you, with your consent or where we have a legitimate interest. If you have the option to logon to your account through Facebook, Google, Instagram or other social media accounts, we collect profile information from your social media account including your name and email address. Please note that when accessing your account through a social media platform, the social media provider will be notified of your access to the account. Please refer to the privacy notice of the respective social media provider(s) for more information on how your personal information is stored.

f. Website Usage
Please note that our websites are not directed to individuals under the age of sixteen (16). We ask that you do not provide your personal information to us if you are under that age. We also ask that you do not share the personal information of anyone else under that age with us, unless this is required by us and you are their parent or guardian, or have the express consent of their parent or guardian to do this.

Your personal information and other data is stored on our secure servers in Australia, New Zealand, United States of America, Singapore. These servers are only accessed by our authorised staff or authorised suppliers.
However, the Internet is not in itself a secure environment and we cannot give an absolute assurance that your personal information will be secure at all times. Transmission of personal information over the Internet is at your own risk and you should only enter, or instruct the entering of, personal information within a secure environment.
If we assess that there is a risk of ‘serious harm’ to you or a related individual, we will advise you at the first reasonable opportunity upon discovering or being advised of a security breach where your personal information is lost, stolen, accessed, used, disclosed, copied, modified or disposed of by any unauthorised persons or in any unauthorised manner (as required by law).
It is your responsibility to keep your login details, password and security questions in respect of our business with you safe and secure. You should notify us as soon as possible if you become aware of any unauthorised use of your login details, password or security questions, and immediately change that security information promptly.
To ensure you are accessing a secure server, check for the unbroken key or closed lock symbol located generally either at the bottom left or top right of your browser window. If it appears, then SSL is active. You can double check this by looking at the URL as well. If SSL is active, then the first characters of that line will read ‘https’ rather than just ‘http’. It is important for you to protect against unauthorised access to your password and to your computer. Ensure you logout when you have finished visiting our websites especially if you accessed them from a shared computer.

g. Collection of information via our app/s
If you choose to download, install and use one of our apps (e.g. the Petspiration app available on the Apple Store or on Google Play), these apps will collect personal information about you which will be linked to your Petspiration identity or profile. The information that is collected may include the user's name, email address, telephone number, physical address, IP addresses, log data, information about user purchases, user content, identifiers, financial information, search history and usage data. Some of the personal information that you share via the app may be collected by third-parties, which include Google Analytics, Firebase and Apple App Analytics. You should carefully read the privacy links in the apps, which include information about the types of data that may be collected by Petspiration and also by our third party partners during normal app usage. But you should also bear in mind, that the data collected from you may not all be listed in these links or sections, and may also vary from what is displayed. For example, the information or data we collect about you may depend on the features of the app that you use. If you post a review of one of our apps, and this includes your name or any other personal information, this will also be collected and may be published. If you wish to revoke your consent to Petspiration collecting your data via one of our apps, please contact e-mail our Customer Experience Manager at customerservice@petspiration.group.

3. HOW YOUR PERSONAL INFORMATION IS HANDLED BY US

We may use your personal information for a number of purposes, including but not limited to:

to identify you and any records relating to you;
to provide you with the products and services you have requested;
to 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 send you reminders;
to manage your gift card balance;
to market our products and services and any related companies and affiliates;
maintain and improve customer services, including conducting product and market research and analysis;
to collect information from your computer through the use of cookies;
to enable us to undertake a credit assessment (if you have applied for credit or otherwise authorised this);
to facilitate services and appropriate communication between you and our preferred financial services and credit suppliers Afterpay, Openpay, PayPal, Zip, Certegy T/A Humm, Visa, mastercard, amex, Apple Pay, Google Pay, PayPal, Pay in 4, Payment Express, Braintree and Stripe;
to comply with any legal obligations or governance requirements;
to facilitate your interactions with us on our website or mobile apps;
to consider making an offer for employment purposes;
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 carry out internal functions such as training;
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; and/ or
as part of buying or selling our business.

Use of your information for Direct Marketing
When you provide your personal details to us, you 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 brands, entities, business partners, affiliates and digital services, 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 offered by us and any of our related brands, entities, business partners, affiliates and digital services, and other products that may be of interest to you.

De-identified personal information may also be used to allow corporate reporting within our business and with our related our related brands, entities, business partners, affiliates and digital services.

We will not use Australian Government Identifiers, such as Medicare numbers, or a driver’s licence number as its own identifier of individuals. In New Zealand, unique identifiers such as driver’s licence numbers, passport numbers, or IRD numbers will only be used when this is necessary. We will take reasonable steps to protect unique identifiers from misuse.

Where we use or disclose your personal information for the purpose of direct marketing, we will:

allow you to request not to receive direct marketing communications (also known as ‘opting-out’); and
comply with your request to ‘opt-out’ of receiving further communications within a reasonable timeframe.

If you do not wish to be contacted by us, please click the unsubscribe link at the bottom of any email we send you or e-mail our Customer Experience Manager at customerservice@petspiration.group.

Using your information for Interest Based Advertising and Social Media Targeting

Social media and other IT platforms offer us the possibility to connect with you via those platforms and to share content from our website and other advertising with you. We may therefore use the personal Information that we obtain from you to maintain your personal advertising profile.

We are only allowed to use personal information or data from customers for social media targeting if they have given us their consent to market to them. If you have given us your consent to use your personal information for marketing, we may use your personal information to create a customer list that we can use to advertise to you, or create a lookalike audience to find new people who share similar behaviours and interests as you.

For example, to make a ‘Custom Audience’ for our use on Facebook, we would upload information about you which would include an ‘identifier’ (such as email, phone number, address) to Facebook via a CSV or TXT file. Facebook would then create a Custom Audience or lookalike audience for us to use for marketing purposes. When we upload the customer list to Facebook (that may include your personal information) for the matching process, the information is ‘hashed’ and will be unidentifiable at an individual level. Hashing is a type of cryptographic security method that turns your identifiers into randomised code.

If you do not want your information to be used by us for the purposes of interest based advertising or social media targeting, please e-mail our Customer Experience Manager at customerservice@petspiration.group.

How your personal information is disclosed or shared by us

In the course of conducting our business and providing our products and services to you, we may disclose or share 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;
you would reasonably expect, or have been told (for example, by means of this privacy policy), that your information will be disclosed to us, our related brands, entities, business partners, affiliates or digital services; or
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 we share with them, 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;
professional advisers (such as lawyers, accountants, auditors) to the extent that is reasonably required;
advertising, marketing, social media and promotional agencies that we engage;
payment systems operators and financial institutions including but not limited to Afterpay, Openpay, PayPal, Zip, Certegy T/A Humm, Visa, Mastercard, Amex, Apple Pay, Google Pay, PayPal, Pay in 4, Payment Express, Braintree and Stripe;
online review platforms including YotPo Google reviews & Trust Pilot;
debt collectors (where legally allowed);
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 us to conduct promotional, research or marketing activities;
where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities;
when we believe in good faith that the law requires disclosure;
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 all circumstances where your personal information is disclosed, we will take reasonable steps to ensure that those third parties undertake to protect your privacy (for example, putting in place a data sharing agreement where this is reasonable and practicable).

Disclosure to overseas recipients

Your personal information may be disclosed to our related companies and affiliates in Australia and in other overseas countries. If we do this, we will take reasonable steps to ensure that the overseas recipient does not breach the relevant privacy laws in relation to that information.

Sometimes we use third-party platforms and services to process sales, provide web support, send marketing messages, deliver products or otherwise deliver information.

Our service providers are mainly located in Australia, New Zealand, United States of America, Singapore. However, from time to time we may need to engage service providers in other countries. 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 which country your personal information may be located in. We may also be required to report to regulatory authorities, within or outside of Australia or New Zealand.

Your personal information may also 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 our behalf). By providing us with your personal information, you are agreeing to the disclosure of your personal information to third parties operating outside of Australia or New Zealand. We will take all reasonable steps to ensure that any personal information we disclose overseas is handled in accordance with the law.

Business transfer clause

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 the personal information we handle between our related brands, entities, business partners, affiliates and digital services.

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 our websites at any time, you are consenting to the future 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. It is possible that our member information, including your personal information, may be transferred to the new business entity as one of our assets. In such an event, we will update this policy to reflect any change in ownership or control of your personal information.

By agreeing to the terms of this privacy policy, you acknowledge that such transfer of your personal information may occur in the future, and that any new owner or successor entity can continue to handle your personal information as set forth in this privacy policy.

4. WHAT CHOICES CAN YOU MAKE ABOUT YOUR PERSONAL INFORMATION?

Unsubscribe/Opt-Out

You can unsubscribe from general marketing or promotions via the ‘unsubscribe’ or ‘opt out’ button below each email, or by requesting us to do so by sending a message to our Customer Experience Manager at customerservice@petspiration.group. A request to opt-out may take three to five business days to take effect. If you are a member of any of our loyalty clubs or membership programs, you may still receive communications related to your account, loyalty points or special officers (such as birthday discounts). Also, an opt-out request will also not stop transactional emails related to your purchases.

If you no longer wish to receive the text messages that you had consented to previously, you can text “STOP” after receiving a message.

If you would like to cancel your membership of any of our loyalty clubs or membership programs and stop receiving communications related to your account please e-mail our Customer Experience Manager at customerservice@petspiration.group.

Access or correction of your personal information

You can request access to, or correction of, the personal information we hold about you at any time please e-mail our Customer Experience Manager at customerservice@petspriation.group.

We will provide you with the information you have requested 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, or make the correction you require, 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 if required. We will advise you of any fee payable before we process your request.
If you believe that your personal information is not accurate, complete or up to date or you wish to request that we delete (or refrain from processing) any of your personal information that we handle, please e-mail our Customer Experience Manager at customerservice@petspiration.group.
.

Sale of personal information

We do not share your personal information directly with third-parties for their own marketing purposes in exchange for monetary consideration. However, as mentioned in this policy, we do engage in Interest-Based Advertising, where we allow third parties to place cookies, pixels, and trackers on our site to provide you with personalized ads. The ‘Help’ section of your browser may tell you how to prevent your browser from accepting cookies.

If you want to opt out of such advertising please advise e-mail our Customer Experience Manager at customerservice@petspiration.group.

5. HOW WE PROTECT YOUR PERSONAL INFORMATION

We hold personal information, at our premises in Australia 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 or 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
our personnel are bound by and trained on internal information security policies and are required to keep personal information secure at all times.

We have measures in place to protect your personal information including credit card information. Your credit card details are not held or processed on our website or systems and all transactions are processed through a secure payment service provider.

We use 3D Secure which is provided by Shopify Payments or Cardinal to process local and international transactions. All transactions are processed using encrypted methods. Your credit card details are not held by us and cannot be accessed by any of our staff members. However, they may be held by our secure payment service provider.

Data Retention Policy

We will only keep your personal information for as long as we require it for the purposes of operating our business. However, we may also be required to keep some of your personal information for specified periods of time, for example under certain laws relating to companies, money laundering and financial reporting legislation.

6. PRIVACY OFFICER CONTACT

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.

If you have any queries, concerns or complaints about the manner in which your personal information has been collected or handled by us or would like to request access to or correction of the personal information we hold about you please contact e-mail our Customer Experience Manager at customerservice@petspiration.group.

This privacy policy is effective from November 2021. From time to time, our privacy policies and procedures will be reviewed and, if appropriate, updated. If any changes are made to this policy, these will be posted on our website. We are constantly developing and enhancing our use of online technologies and make reasonable efforts to ensure that we keep this Policy and related documents up to date in this regard. Please check back on a regular basis to ensure you are familiar with our current practices.

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.

You should know, that in this Privacy policy – when we refer to ‘Best Friends Group’, ‘we’, ‘our’, and ‘us’ we are referring to Best Friends Holdings Pty Ltd (ABN: 54 159 280 412), Best Friends Retail Pty Ltd (ABN: 79 159 053 399), Best Friends Support Services Pty Ltd (ABN: 93 159 054 645), Best Friends OPCO Pty Ltd (Trading at My Pet Warehouse) (ABN: 80 629 424 406), Pet Imports Pty Ltd (ABN: 50 155 418 367), Pet Wise Investments Pty Ltd (ABN: 48 166 845 423), Our Vet Pty Ltd (ABN 66 126 436 628), Our Vet Tweed Heads Pty Ltd (ABN: 47 153 249 168) and each of their related bodies corporate. Any personal information that you provide via our websites or directly to us, is collected and managed by Best Friends Group.

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.

This Privacy Policy has been designed to help you understand what information we collect, why we collect it, and how you can contact us to update and access your personal information. When you provide your personal information (by any means, whether verbal, written or electronic) or through your use of the Best Friends Group website, you are agreeing to the terms of this Privacy Policy and also providing us with consent for the collection, handling, use, disclosure and storage of that personal information. There may also be additional privacy notices and terms that are relevant to you depending on the nature of your dealings with us (e.g. if we share customer personal information with you as a third-party service provider).

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.

If you have any questions regarding the Best Friends Group Privacy Policy, please contact our Privacy Officer at customerservice@bestfriendspets.com.au or send a letter to the Privacy Officer, Best Friends Group, Unit 1, 2-6 Sloane Street Maribyrnong VIC 3032. If you would like us to send you a copy of this Privacy Policy, please contact us and we will do so. If you query relates to information handling by Our Vet, please email: drnick@ourvet.net.au.

What kind of personal information does Best Friends Group collect and hold?

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:

name;
date of birth;
gender;
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).

The nature and amount of information collected will depend on the purpose for which it is being collected. If you provide your personal information to a third party via a link from a Best Friends Group website (e.g. you enter a competition or register for another type of promotion run by one of our partners), that information is collected and managed by those third parties. You should familiarise yourself with their privacy policy prior to deciding whether you wish to provide them with your information.

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.

How and why does Best Friends Group collect and hold your personal information?

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.

Where possible and practicable we will only collect personal information directly from you. If you provide us with information about any third party, you must obtain that person’s permission to give us the information and inform them that you have given the information to us. We rely on you to inform those individuals that you are providing their personal information to us and to advise them about this Privacy Policy.

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.

How does Best Friends Group use your personal information?

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 collect information from your computer through the use of cookies;
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 what circumstances will Best Friends Group disclose your personal information?

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;
you would reasonably expect, or have been told (for example, by means of this Privacy Policy), that your information will be passes on to those individuals, entities, affiliates bodies or agencies; and/or
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.

Who may we disclose your personal information to?

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 all circumstances where your personal information is disclosed, we will take all steps reasonable to ensure that those third parties undertake to protect your privacy. Except as set out in this Privacy Policy, your personal information will not be passed to third parties without your consent.

Does Best Friends Group disclose your personal information to overseas recipients?

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.

Direct marketing

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 customerservice@bestfriendspets.com.au or send a letter to the Privacy Officer, Best Friends Group, Unit 1, 2-6 Sloane Street Maribyrnong VIC 3032.

Personalised and targeted digital advertising

Best Friends Group may provide you with information and services through a range of digital and online services including websites (e.g. 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.

To be able to show you targeted advertisements, we can also match your data profile with customers that have a similar profile. Best Friends Group may use the information we collect from you to customise our offers and services for you, including providing recommendations, personalised content, and customised search results. We only use your data for targeted advertising if you have given your consent for the placement of cookies of and the collection of personal data via the cookie. Our use of cookies, pixels and other digital tools with similar functionality, is described in more detail in our ‘Collection of Cookies’ section (included in this Policy).

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 customerservice@bestfriendspets.com.au.

Social listening

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.

Collection of Cookies

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, and third parties, including our service providers, collect data collected using cookies and other device identifying technologies. We use Cookies and Tracking Technologies to collect your IP address, device ID information, ISP provider, browser type, the pages and content you view on our website (s), the search terms you enter on our website, and the actions you take on our website.

In some cases, the third parties we work with may use cookies and other technologies (such as those described in this Policy) to support Best Friend’s digital marketing initiatives. Analytics collects any demographic and interest information available in a cookie. These technologies may be used in connection with activities like surveys, online behavioural advertising, website analytics, and email campaign management.

Information Security

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.

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.

Our websites are professionally hosted and operate in a secure environment. You should however be aware that there is always an inherent risk in transmitting your personal information via the Internet. Our website may contain links or references to websites to which this Privacy Policy may not apply. We are not responsible for the privacy policies and practices of third-party websites.

How long will we retain your personal information?

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.

Business transfer clause

By agreeing to the terms of this Privacy Policy, you acknowledge that such transfer of your personal information may occur in the future, and that any new owner or successor entity can continue to handle your personal information as set forth in this Privacy Policy.

Use of Government Identifiers

Best Friends Group will not use Government Identifiers, such as Medicare numbers, or a driver's licence number as its own identifier of individuals.

How you can access or correct your personal information

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: customerservice@bestfriendspets.com.au or if you query relates to information held by Our Vet, please email: drnick@ourvet.net.au.

How you can notify us of a privacy concern or contact our Privacy Officer?

If you:

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: customerservice@bestfriendspets.com.au or if you query relates to information held by Our Vet, please email: drnick@ourvet.net.au.

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.

This privacy policy is effective from April 2020. From time to time, our privacy policies and procedures will be reviewed and, if appropriate, updated. If any changes are made to this policy, these will be posted on our website. We are constantly developing and enhancing our use of online technologies and make reasonable efforts to ensure that we keep this Policy and related documents up to date in this regard. Please check back on a regular basis to ensure you are familiar with our current practices.

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1. OUR PRIVACY COMMITMENT

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