(a) using our website (vuse.com.au);
(b) visiting our various offices throughout Australia;
(c) who contact customer service (through phone, email, SMS, website apps, contact us forms, online chat functions or any other method via our website);
(d) who respond to the emails and surveys we send, including, emails and surveys where we request participation from customers through feedback forms or surveys;
(e) who participate in our promotional activities including prize draws;
(f) who interact with us via our social media channels (where applicable), including, those who interact with our posts, and users who directly message us through our social media channels; and
(g) who interact with us at an event or function, including events or functions where we collect customer information.
(a) visit our website;
(b) visit one of our various offices;
(c) contact us by any means (including by calling our customer response centre or contacting us online);
(d) authorise us to collect your personal information in any other way, such as at promotional events;
(e) interact with our social media channels (including by interacting with our posts or directly messaging us through our social media channels); or
(f) respond to the emails and surveys we send, including, but not limited to, emails and surveys where we request participation from you.
3. How can you contact us?
Privacy Officer, BAT Australia Ltd, Locked Bag 20, Royal Exchange NSW 1225, Australia.
Telephone: 1800 044 831
4. What personal information do we collect?
4.1. We may collect any personal information that you provide to us or authorise us to collect. This may include:
(a) your name, date of birth and contact details (including address, phone number and email address);
4.2. We will usually collect your personal information directly from you unless it is not reasonable or practical to do so. We may collect personal information about you from another person if we have, or they confirm that they have, your consent.4.3. There may be times when you provide us with personal information about another person, for example, in connection with promotional events. If you do so, you confirm that:
(b) details of transactions you carry out or orders you place through our website and information that you submit online via our website;
(c) details of your visits to our website and the resources that you access (which may include, amongst other things, traffic data and communication data);
(d) details about other people that you provide to us with their consent (see section 4.3);
(e) personal information you provide to our customer service representatives;
(f) identification information including, but not limited to, driver's licence details, that you provide to us so that you can use certain services, or so that we may verify your age;
(g) information that you provide in response to the emails and surveys we send, including, but not limited to, emails and surveys where we request participation from you; or
(h) any other personal information that you authorise us to collect, for example, if you authorise us to collect your photo at a promotional event.
(a) they are over eighteen years old;
(b) you have their authorisation to:
(i) provide their personal information to us; and
4.4. We will not intentionally collect any information about anyone who is under eighteen years of age. If we become aware that anyone who is under eighteen years of age has provided us with any information, that information will immediately be deleted from our records.
4.5. When you use our website, we may also collect information about you and your use of our website using automatic data collection tools. These tools collect certain standard information about your access and computer, such as your browser type, operating system and language, access times and your Internet Protocol (IP) address. We use the information for statistical reporting and analytics and do not link it to any named individuals.
4.6. You do not have to provide us with any personal information that we request. However, if you do not do so, it may affect our ability to provide you with products or services or further information you have requested.
4.7. We use WorldPay to process payments you make using our websites. WorldPay operate a secure server to process your payment details. WorldPay encrypt your credit or debit card. Any payment transactions will be stored on WorldPay's hosting services.
4.8. This means that your credit card or debit card are never revealed to us.
4.11. Cookies enable us to provide you with a better experience by enabling our website to recognise that you have visited before and in some cases to record preferences to personalise your visit. Cookies also assist us to analyse the profile of our visitors and how you use our website.
4.12. Sometimes we partner with third parties (such as advertising and social media partners) who may place a cookie (or cause a pixel event to trigger) on your device when you visit our website to remember that you have visited our website. This means that when you later visit another website, the advertisements displayed to you may be advertisements for our website or products or about other products and services that are tailored to your apparent interests. If you click on one of our advertisements, it will redirect you back to our website. Our third-party partners may provide us with information about the total number of views, shares, and click-throughs these advertisements have received. However, other than your IP address, they will not collect or provide to us or any other third party any information that identifies you.
4.13. To delete or stop cookies being placed (or pixel events triggering) on your computer, refer to the help menu on your internet browser. In some cases, blocking cookies and pixels may reduce the functionality of our website or otherwise prevent access to them depending on your chosen browser options. For further information visit www.aboutcookies.org.
5. What do we do with your personal information?
Use of your personal information
5.1. We (and the third parties described in section 6) may use your personal information:
(a) to provide you with information, products and services that you request;
(b) to respond to your queries (including when you contact our customer care centre);
(c) to, if required, verify your age and identity (see sections 5.7 to 5.11);
(d) to facilitate our internal business operations (including for training and for developing, maintaining and testing our IT systems and infrastructure);
(e) to ensure that our website’s content is presented as effectively as possible for you;
(f) for our internal purposes, such as quality control, website performance, system administration and to evaluate the use of our website, so that we can provide you with enhanced services;
(g) to notify you about changes to our website or our services;
(h) to provide you with information about products or services that we think may interest you (see section 5.4 and 5.5);
(i) to create reports to assist with future marketing, including sharing your information with third-party agents, representatives, business partners, sub-contractors, suppliers, or other organisations to assist with marketing or responding to your requests;
(j) to carry out our obligations arising from any contracts with you, including providing you with the products you have ordered and for billing and delivery purposes;
(k) to enable you to participate in the features of our website, when you choose to do so; or
(l) for any other purpose that you authorise or that is permitted by applicable law, including the Privacy Act.
Use of statistical and aggregated information
5.2. We may monitor your use of our website and record your email address and/or IP address, operating system and browser type, for system administration and to report aggregate information. This is statistical information about our users’ browsing actions and patterns and does not identify any individual.
5.3. We may collect non-personal aggregated statistics data about visitors to our website and, if applicable, sales and traffic patterns. Just to be clear, this information does not identify users in any personal capacity and we do not use this information to build profiles on individual users; it just contains generalised information about the users of our website.
5.4. Unless you have ‘opted-in’ and indicated that you consent to us directly communicating with you, if you provide us with your contact details, we will not contact you by electronic means (including email or text message) and by telephone and post, with information about products and services that we think may be of interest to you. Please indicate with the relevant boxes when you create an account, or at any other entry point on the website when we collect your information, if you consent to receiving such direct marketing communications. With your consent, we may also pass your information to other organisations who may contact you to provide marketing information about their products and services by electronic means (including email or text message) and by telephone and post.
5.5. You may ask us at any time not to use your information for direct marketing purposes by contacting us using the details set out under the “How to contact us” heading below or by following the unsubscribe instructions contained in each electronic marketing communication you receive from us.
5.6. We may also use statistical and aggregated information, as well as Cookies, for marketing purposes. Please refer to the information above, including details on how to delete or stop cookies being placed on your computer
Verifying your age
5.7. If you use our website, you will be asked to confirm that you are 18 years or over and we may keep a record of that confirmation.
5.8. We may take additional steps to verify that you are aged 18 years or over before we supply any products to you. To enable us to do this we will require certain information about you. This information will then be passed to our identity verification service provider who will check it against public sources of information to deliver confirmation of your identity and age. To verify your identity, we may also require you to provide:
(a) demographic information (such as gender and birth date); and
(b) personally identifiable information (such as your passport number or driving licence number) which may be used by our identity verification service provider to verify your details.
This information is checked against secure independent data sources to help verify identity.
5.9. In some cases, we may need to ask for further information to verify your age. If this is necessary, we will contact you to explain why.
5.10. Failing age verification will mean you cannot complete a purchase.
6. Who do we share your information with?
6.1. We may share your personal information in the following ways:
(a) From time to time your personal information may be transferred to
(i) other BAT entities worldwide; or
(ii) third party agents, representatives, business partners, sub-contractors or suppliers, to provide us with services, such as system maintenance and support, marketing, storage services, customer response centre services and to assist us to respond to your requests (including, if required, to verify your age and identity).
(b) We may also disclose your personal information to other BAT entities worldwide for any of the purposes set out in section 5 above.
(c) We may also be required to disclose your personal information to
(i) respond to duly authorised information requests from the police and governmental authorities;
(ii) comply with any law, regulation, subpoena or court order;
(iii) help prevent fraud or to enforce or protect the rights and properties of BAT or its subsidiaries; or
(iv) protect the personal safety of BAT employees, third party agents or members of the public.
6.2. We may also disclose your personal information to enforce or apply our terms or any other agreements we have with you or to protect our rights, property or our customers. This may involve exchanging information with other companies and organisations for fraud protection and credit risk reduction.
6.3. Circumstances may arise where, whether for strategic or other business reasons, BAT decides to sell, buy, merge or otherwise reorganise businesses or our assets in some countries. Such a transaction may involve the disclosure of your personal information to prospective or actual purchasers, or the receipt of it from prospective or actual sellers. It is BAT’s practice to seek appropriate protection for personal information in these types of transactions.
6.4. We may, with your consent pass your information to other organisations who may contact you to provide marketing information about their products and services by electronic means (including email or text message) and by telephone and post (see section 5).
6.5. We may share the non-personal aggregated statistics data about visitors to our website with third parties.
6.7. Any third party, agent or representative of BAT who imports personal information in the course of providing services to BAT is required to keep that information confidential and comply with national data protection laws or, where applicable, to be bound by appropriate contractual obligations that protect your personal information, to ensure that your personal information continues to be protected by security safeguards that are comparable to the safeguards that are required under the Privacy Act.
7. How do we manage the accuracy of your personal information?
7.1. We strive to keep your personal information accurately recorded. Generally, we will rely on you to update any personal information that you have provided to us.
7.2. If you would like copies of your personal information that we hold about you, or to request correction of any factual inaccuracies in that information, please contact our Privacy Officer (see section 3).
8. How do we manage the security and storage of information we hold?
8.2. We take reasonable technical and organisational security measures to prevent loss or unauthorised access, use, alteration or disclosure of personal information you provide to us or authorise us to collect. Any third party, agent or representative of ours who requires access to your information is also required to implement reasonable technical and organisational security measures to protect your information.
8.3. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information transmitted to or from our website and any transmission is at your own risk.
Links to third-party websites
8.4. Our website may, from time to time, contain links to and from other websites. If you follow a link to any of those sites, please note that those sites ought to have their own privacy policies and that we do not accept any responsibility or liability for those sites or their privacy policies. Please check those privacy policies before you submit your information to those sites.
8.5. If you have a username, password or other login details which enable you to access certain parts of our website, you must not allow any other person to use them and must treat them as confidential. If you believe or suspect that someone else knows your login details you must contact us as soon as possible (see section 3). Please also see our Terms and Conditions of Sale.
9. Our e-commerce websites?