Privacy Policy

Privacy Policy


1. Purpose:


Empire Supplies (“Empire”) recognises the importance of your privacy and is committed to the management and handling of personal information in an open and transparent way.


Empire is required to comply with the Australian (Commonwealth) Privacy Act 1988 (“The Privacy Act”) and this Policy sets out how Empire seeks to ensure that any personal information we hold about you is collected, used, stored and disclosed in accordance with the Australian Privacy Principles in the Privacy Act.


In this policy ‘personal information’ and ‘sensitive information’ have the same meaning as in the Privacy Act.


This policy does not apply to the handling of personal information about Empire employees. Employee records are exempt from the Privacy Act, but Empire has a separate employee privacy policy.


2. Scope:


This Privacy Policy documents the handling of personal information by Empire Supplies (collectively referred to as “Empire”). ‘We’, ‘our’ and ‘us’ refers to Empire.


3. What information does empire collect and hold?


Empire may hold information about individuals who may be members of the general public, our customers, our business contacts, prospective employees and others. The information Empire typically holds includes:


3.1 Customers and The General Public:

  • Your name, gender, date of birth, relevant address, telephone number(s) and email address;
  • Dealings with Empire such as purchases, product enquiries and complaints.

3.2 Other Individuals Such as General Business Contacts, Third Party Contractors and Job Applicants:

  • Your name, business address, business telephone number(s) and email address;
  • Dealings with Empire in respect of general business relationships, or work and employment references, reports and assessments. If you are seeking employment with us we may also collect information about your prior employment, education and your right to work in Australia.
  • Depending on the nature of your dealings with us, we may collect and hold other types of personal information. For example, information collected and held via our secure financial systems about the debit or credit card you might use for your purchases from us.

You generally have the option of not identifying yourself or of using a pseudonym when dealing with us. But not where this is impractical (for example when you shop online with us) or where the law or a court order provides otherwise.

You are not required to provide any personal information to us, but if you do not, we may not be able to deal with your query.


4. How will Empire Supplies collect and hold your personal information?


We will, wherever possible, collect information about you directly from you.

When we collect personal information about you, we do so by making a record of it. We do this when:

  • you register with us, for example to create an account, to become a member of one of our clubs or loyalty programs or to send you information;
  • you communicate with us online;
  • you take part in our promotions, testimonials, surveys and focus groups;
  • you deal with us in other ways involving a need for personal information to be provided such as when you make a credit purchase, contact our office or bring a claim against us.

We may also collect personal information about you by accessing data from other sources and then analysing that data together with the information we already hold about you in order to learn more about your likely preferences and interests.

On some occasions, it may be collected from other sources, such as:

  • Agents or service providers;
  • Publicly available directories and listings such as telephone directories;
  • Newspapers, magazines, professional journals and the electronic media;
  • The internet and other electronic communications such as articles and information pieces in which you feature on a website such as a health information site or a medical professional site;
  • The date, time and domain from which you access an Empire website;
  • Personal communications with Empire staff.

Empire will not collect sensitive information about you, such as information about your health, race or professional associations, without your consent.


5. Collection through Empire websites


In addition to some websites which provide for direct input of personal information, most Empire websites make use of ‘cookies’ which are small text files that are stored in the visitor's local browser cache. Using such cookies, it is possible to recognise the visitor's browser in order to optimise the website and simplify its use. Data collected via cookies will not be used to determine the personal identity of the website visitor. Most browsers are set up to accept these cookies automatically. In addition, you can deactivate the storing of cookies or adjust your browser to inform you before the cookie is stored on your computer. Some Empire websites may not offer full functionality unless you accept cookies.


Empire increasingly makes use of web analytics, including analysis by third party service providers, which may use IP addresses. While this may in some circumstances be ‘personal information’ neither Empire nor the service providers have any interest in individuals’ browser activity and will not use the information to take any action targeted to individuals.


Empire will also not collect, process or use on our websites information relating to an individual we know to be under 13 years of age, without the prior verifiable consent of his or her legal representative. Such legal representative has the right, upon request, to view the information provided by the child and/or to require that it be deleted.


6. What does empire do with your personal information?


6.1 Use

Personal information collected and held by Empire may be used for one or more of a variety of purposes depending on the circumstances. These include:

  • Normal sales and customer service functions including order processing and fulfilment, accounting, and responding to enquiries or complaints;
  • Meeting legal requirements such as notification of product withdrawals and recalls, and monitoring compliance with relevant regulations and codes of conduct;
  • Empire’s marketing and market research;
  • to promote and market directly to you products and services that we consider may be of interest to you, unless you tell us not to do so;
  • to evaluate our products and services and conduct consumer research;
  • for a business or professional relationship, we may have with you;
  • to assess any application for employment you make; and
  • to amend records to delete personal information.


6.2 Direct Marketing

You may request that we do not send you information regarding our programs, events, services or products which we think may be relevant to you (direct marketing). In such a case, we will take reasonable steps to ensure we do not send you marketing material.


6.3 Our Websites, Social Media, Apps and Advertising

Like many companies, we use technology and tools that tell us when a computer or device has visited or accessed our content.


We notify you when we might or will collect personal information such as through entering a promotion or competition.


If we use your personal information to contact you and you would prefer not, please let us know and we will do our best to respect your preference.


When we send a marketing offer directly to you, we provide a way for you to opt out.


6.4 Disclosure

Empire may disclose information about you in the course of any of the uses described above, including to related businesses and third party service providers, such as for order delivery, marketing, data processing, printing and mailing, and organizing conferences. Empire will use only reputable service providers and will ensure that contractual provisions safeguard your privacy.


We will otherwise only disclose personal information about you to a third party where required by law, including to regulatory authorities; and then only that information which is necessary.


6.5 Overseas Recipients

Empire is a business unit of the Systematrix Pty Ltd; a global organisation with offices within and outside of Australia.


Information held by Empire about you may in some circumstances be stored on Empire databases housed in overseas locations including but not limited to Switzerland, Taiwan and Denmark. All Systematrix Group of companies are committed to compliance with internal data protection policies which contain provisions substantially similar to the Australian Privacy Principles, and in many cases to similar laws in the other jurisdictions.


Empire also deals with external service providers located in countries within and outside of Australia, such as in Singapore, and in such cases, Empire takes reasonable steps, including by contract provisions, to ensure that these service providers do not breach the Australian Privacy Principles.


6.6 Security and Retention

Empire uses technical and organisational security precautions to protect your data from misuse, interference or loss and from unauthorised access, modification or disclosure. Any personal data that is provided to Empire by you through Empire systems will be encrypted in transit to prevent its possible misuse by third parties. Our security procedures are continuously revised based on new technological developments.


Empire will delete from its records personal information no longer required or if we are required to retain it (e.g. clinical trial records, or tax information), then wherever practicable it will be held in a form that does not permit your identity to become apparent.


You may notify us at any time that you do not wish us to retain your personal information, and wherever practicable and lawful we will comply with such a request.


6.7 Access

You may request access to your personal information and may seek to have it corrected if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading.


Access or correction requests should be sent to the Privacy Officer at the address below.


Your request should give as much detail as possible to help us locate information about you such as your name, contact details, any former name, and if possible the context, for example, your relationship with us. Please specify any particular information to which you are seeking access.


Empire will respond to your request within 30 days of receipt or within any further time notified to you in writing.


6.8 Complaints About a Breach

All enquiries or complaints regarding your privacy should be made in writing to:


The Privacy Officer

Office 109

585 Little Collins Street

Melbourne VIC 3000

Telephone: +61 3 9077 6597

Or email: privacy.officer@empiresupplies.com.au


Empire will ensure that your complaint is responded to within 30 days of our receipt of your correspondence. If we cannot meet this timeframe we will contact you and provide you with a reasonable estimate of the length of time we require in order to resolve your complaint or enquiry.


Empire reserves the right to make changes to this Privacy Policy from time to time, but will ensure that they are posted to our website without delay.


7. More information


More information about privacy law and privacy principles is available from the Privacy Commissioner. The Privacy Commissioner may be contacted at www.oaic.gov.au (email - enquiries@oaic.gov.au) (Australia).


7.1. Cookie Statement

7.1.1. About This Statement

This statement gives you information about our use of cookies. This is relevant to when you use your computer or mobile device to visit online content (such as websites and mobile apps) which display or promote us or our goods or services. The content may be our own, or may be the content of others in which we have an interest, such as our banner advertisements.


Cookies may be arranged (“set”) by us or by others under an arrangement with us, such as companies whose business it is to analyse information. We may also access information from cookies set by others (“3rd party cookies”).


7.1.2. Why Should You Know About Cookies?

You should know about cookies because they involve the collection of information about you (which may or may not be personal information) in a way which may not be obvious to you.


7.1.3. What Is a Cookie?

Cookies are small pieces of information captured when your device is used to access online content. Cookies are stored in your device by the person who arranges for the cookie to be set. This person may be the provider of the content being accessed. It might be a 3rd party. 3rd party cookies are used to provide information about your device's access to more than one discrete site or data set.


7.1.4. Why Do We Allow Cookies to Be Used?

We allow cookies to be used for three reasons.


First, we allow session cookies to be used when you visit our online content. This enables your device to move from page to page without having to log in repeatedly. These generally improve your browsing experience.


Secondly, we allow persistent (permanent) cookies to be used to better inform how the content your device visits may be presented to you. Persistent cookies can store your preferences for a particular site, so they will be remembered when the site is visited again.


Thirdly, we allow persistent and other kinds of permanent cookies (such as “flash” cookies) to be set and we access information from 3rd party cookies in order to assist in compiling and analysing the types of online content you visit and your interaction with that content. This assists us to assess what promotions to make to you, when and how. It also assists us to measure the effectiveness of our promotions.


7.1.5. What Are Your Choices About Cookies?

You can control the extent to which your device allows cookies to be set on it. You can do this by changing the settings on the software your device uses to access the internet (your browser software). For example, depending on which browser your device uses, you may be able to disable third party cookies.


There is a lot of information available about how cookies work and how to change your browser’s cookie preferences. This includes information at the following links: Stay smart online – all about cookies and your privacy; Your online choices and Privacy Commissioner Fact Sheet on online behavioural advertising.


Last updated: January 2017