We generally collect your Personal Information where you provide it to us willingly and with your full consent, unless it is unreasonable or impracticable to do so. We only collect Personal Information where it is reasonably necessary for one or more of our functions or activities, for example to improve delivery of our services, tell you about our great offers or developments, invite you to participate in our promotions and competitions, or to investigate your complaints and grievances. When collecting your personal information, we will do so only by lawful and fair means.

Generally, we collect your Personal Information in the following situations:

WHERE YOU VOLUNTARILY PROVIDE INFORMATION TO US
For example when you:

• contact our Consumer Services Team;
• participate in our promotions, prize draws or competitions;
• subscribe to publications or communications from us; or
• register to become a member of one of our clubs.

The information we collect from you may include, but is not limited to your name, address and email address. Our communications always include information on how to opt out from receiving further information or services from us. Entry into promotions, prize draws and competitions is entirely voluntary and you are under no obligation to enter. Should you choose to enter, we recommend that you read and print out the terms and conditions of the promotion, prize draw or competition in question, as these may include additional information about how we may use your data in relation to that particular prize draw or competition.
If you wish to communicate with us anonymously or by using a pseudonym, you may do so. However, it may be impracticable in some circumstances, for example, if you wish to participate in a promotion.

WHERE WE COLLECT INFORMATION FROM YOUR DEVICE WHEN YOU VISIT OUR WEBSITE

When you visit our website or download information from it, our Internet Service Provider makes a record of your visit and records the following information:

• your internet address;
• domain names, if applicable; and
• the date and time of your visit to the website.

We use this data to analyse trends and statistics. This web site also uses Cookies and Google Analytics service.

COOKIES
“Cookies” are a standard mechanism for storing small pieces of data on a web client (i.e. the web browser on your computer). Any web server (including this one) may:

• store one or more cookies in your browser; or
• request your browser to transmit the data to the web server.

This web site may store cookies on your web client in order to better serve you upon your subsequent visits to this web site.

By using cookies, web sites can track information about visitors’ usage of the site and provide customised content. Note that some browsers can be configured to allow cookies to be accessed by servers other than the originating server.

Please note that most web browsers can also be configured to notify the user when a cookie is received, allowing you to either accept or reject it. For further information about working with cookies, visit your browser manufacturer’s website or read the Wikipedia entry (http://en.wikipedia.org/wiki/HTTP_cookie).

GOOGLE ANALYTICS
Google Analytics is a web analytics service provided by a third party company (“Google”). Google Analytics installs cookies to analyze how the website is being used. Google Analytics uses cookies to define user sessions, as well as to provide a number of key features in the Google Analytics reports. Google Analytics sets or updates cookies only to collect data required for the reports. Additionally, Google Analytics uses only first-party cookies. This means that all cookies set by Google Analytics for your domain send data only to the servers for your domain. This effectively makes Google Analytics cookies the personal property of your website domain, and the data cannot be altered or retrieved by any service on another domain.

The information generated by those cookies about your use our websites and your current IP address will be transmitted by your browser to Google and will be stored by Google on servers in the United States of America and other countries. Google will use this information on our behalf for the purpose of evaluating your use of this website, compiling reports on website activity and providing other services relating to website activity and internet usage for us. The IP address collected through Google Analytics will not be associated with any other data held by Google. You may choose to disable or block the Google cookies by selecting the appropriate settings on your browser. You may download and install the Google Analytics Opt-out Browser Add-on available on the Google website.

All the information we collect from your device is anonymous and cannot be collated to identify you personally. Most internet browsers are set up to accept cookies. If you do not wish to receive cookies, you may be able to change the settings of your browser allowing you to either accept or reject them.

We collect minimal amounts of sensitive information. We generally only collect sensitive information (for example, information regarding your health) which is provided to us by you (or is provided to us with your consent) and which is reasonably necessary to fulfil our obligations pursuant to the mandatory reporting provisions of the Australian Consumer Law.

As much as possible, we will collect your Personal Information directly from you, unless it is unreasonable or impracticable to do so.

In some instances, we may collect your Personal Information from a third party. We will do so only in the following circumstances:

• If you have consented for us to collect your information from a third party; or
• Where such collection is authorised or required under Australian law; or
• Where it is unreasonable or impracticable to collect your Personal Information directly from you.

If we collect your Personal Information from a third party, then as soon as is practicable, we will take such steps as are reasonable in the circumstances in order to notify you of such matters that we are obliged to make you aware of, pursuant to the Privacy Act 1988 (Cth). For example:

• your identity and contact details;
• the fact that we collect or have collected the information and the circumstances and the purpose of that collection;
• information about how you may access your Personal Information that is held by us and how you may seek correction of this information;
• information about how you may complain about a breach of the Australia Privacy Principles by us and how we will deal with your complaint.

We collect, use and disclose your Personal Information for a range of purposes. These purposes depend largely upon your relationship with us. At the time of collection or if this is not practicable, as soon as is practicable after we collect your Personal Information, we will notify you of the purpose for which we have collected it (“Primary Purpose”).

We will generally use your Personal Information for the Primary Purpose and will not use or disclose this information for another purpose (“Secondary Purpose”), unless such disclosure is permitted by the Privacy Act 1988 (Cth).

Generally speaking, we use or disclose Personal Information for purposes such as:

• to notify customers of products and services that may assist you, including any special offers available;
• to deal with any inquiries by customers;
• to fulfil our mandatory statutory obligations; or
• to improve the quality and level of services offered by us.

We may, where necessary for business, contract out various services associated with our functions and activities. This may involve the disclosure of your Personal Information (subject to this Privacy Policy and the provisions of the Privacy Act 1988 (Cth)) to other persons and organisations that we engage on our behalf or to other companies within our group of companies. Please be assured that all service providers and subcontractors that act on our behalf are contractually obligated to comply with the Privacy Act 1988 (Cth) and to ensure that your Personal Information is handled in a manner consistent with our obligations under this Privacy Policy.

The types of persons and organisations to which we may disclose your Personal Information include the following:

• organisations with whom we have arrangements or agreements for the purpose of promoting our products or services and any agents used by us in administering such arrangements or agreements;
• our agents, contractors and external advisers who carry out our functions and activities or who assist us to carry out our functions and activities from time to time; and
• other parties to whom we are authorised or required by law to disclose information.

We do not generally receive any Personal Information without requesting it.
If we do receive your Personal Information without requesting it (unsolicited), we will treat such information in exactly the same way as if we had asked for it, that is, in accordance with this Privacy Policy and the Privacy Act 1988 (Cth).

If within a reasonable time, we determine that the unsolicited Personal Information received by us is not reasonably necessary for one or more of our functions or activities or where it is it collected by unlawful and unfair means or without your consent, we will destroy or de-identify your Personal Information as soon as is practicable, but only if it is lawful and reasonable to do so and if the information is not contained in a Commonwealth record.

We take reasonable steps to protect your Personal Information from misuse, interference and loss and from unauthorised access, modification or disclosure. We do this by means of various physical and electronic security measures, including restricting physical access to our offices and implementing a number of technological and security policies and procedures.

If we no longer require your Personal Information for the purpose for which this information was collected, we will take all steps reasonable in the circumstances to destroy the information (unless we are required to retain this information pursuant to an Australian law) or ensure that the information is de-identified.

We may use servers in the USA or New Zealand to route through and store your Personal Information. No overseas recipients have access to your information. A number of policies and procedures are in place to ensure the safety and secure storage of your Personal Information handled and stored by us.

We only use or disclose your Personal Information for direct marketing purposes (that is, to communicate with you directly to promote our goods and services) when we have your permission to do so, or where you have a reasonable expectation that your Personal Information will be used for this purpose and where you have not opted out from us contacting you.

In cases where you would not expect us to use your Personal Information for direct marketing purposes or the information has been collected by us from a third party, we will use or disclose your information for direct marketing purposes with your consent (or without your consent if it is impracticable for us to obtain your consent) and within each communication provide you with a simple and obvious means by which you may easily opt out from receiving further communications from us.

If you receive marketing offers from us and do not wish to receive them any longer, please call our Consumer Services Team on FREECALL: 1800 037 058.

You may request details of the Personal Information we hold about you by writing to us or contacting us by telephone. We will respond to your request within a reasonable period of time and give you access to the information in the manner requested by you if it is reasonable and practicable to do so.

In general, we will allow you access to the Personal Information we hold about you, unless a specific exception applies, and will take such steps as are reasonable to provide you with the information in the form you require.

If we deny you access to any Personal Information following an access request or provide you with access not in the manner requested by you, we will give you a written notice that will set out the reasons for the denial and the mechanisms available to you to complain about our refusal.

We will not charge any fee for the provision of this information, except when we are required to spend an unreasonable amount of time or effort to provide you with the information. If there is a charge, it will not be excessive and will not apply to the making of the request.

We will take all reasonable steps to ensure that your Personal Information that is in our possession is accurate, up-to-date and complete. If you are aware that any of your Personal Information is inaccurate, incomplete or out of date, please inform us on FREECALL: 1800 037 058 so that we can update our records.

If you make a request to correct your Personal Information we will respond to your request within a reasonable period of time. We will not charge you any fee for making the request or for correcting your Personal Information.

If you have a complaint about the way we collect, store or handle your Personal Information please call our Consumer Services Team on FREECALL: 1800 037 058.

Within a reasonable period of time after the complaint has been made, we will follow up and investigate the complaint with a view to resolving it with you directly.

We will provide you with a written note with the results of our investigation and the mechanisms available to you to complain if you are not satisfied with our investigation or proposed resolution.

You can also contact The Office of the Australian Information Commissioner (OAIC) (http://www.oaic.gov.au) if you believe that your privacy has been interfered with or if you are not satisfied with the results of our investigation.

Our Privacy Policy is reviewed on a regular basis. We may change our policies and update the Privacy Policy from time to time. We may send you updates to our Privacy Policy using methods we choose from time to time, and the most up-to-date copy will be published on our website.

In this Privacy Policy:

• “Us” means H.J. Heinz Company Australia Limited and includes any of its directors, employees, associated entities and affiliates. “Our” and “we” have the corresponding meanings.
• “Personal Information” means any information from which your identity is apparent or can be reasonably ascertained.

If you have any concerns or enquiries about how we deal with your Personal Information, you should contact us:

Privacy Officer
Consumer Services Team
H.J. Heinz Company Australia Limited
Level 9, 2 Southbank Boulevard
Southbank VIC 3006
FREECALL: 1800 037 058