Privacy notice

Introduction

Hop Nhat International Joint Stock Company (abbreviated as HNC) and its related bodies corporate (collectively, “HNC”, “we”, “our” or “us”) are committed to the protection of the privacy and rights of individuals about their personal information. This Privacy Policy describes how we collect, hold, use, and disclose personal information about individuals.

HNC may update this Privacy Policy from time to time. The most current version will be posted on the Metcash websites and will be effective from the date of posting. A copy of this Privacy Policy is also available by contacting our Privacy Officer by email or at the address detailed below under the heading “Contact Us”.

Where we refer to the “Privacy Act” in this Policy we mean, if you are located in Australia, the Privacy Act 1988 (Cth), and if you are located in New Zealand, the Privacy Act 1993 (NZ).

In some circumstances, alternative specific privacy policies or notices may apply to you in addition to or instead of this one.

If you are a HNC employee, this Privacy Policy does not apply to you. Please instead refer to HNC’s Employee Privacy Policy.

What personal information do we collect and hold?

The types of personal information we collect and hold will vary depending on your dealings with us and the circumstances in which we collect and hold your information. For example, we may collect and hold different types of personal information about customers, suppliers, contractors, advisers, retailers, and job applicants.

The types of personal information, current and historical, which we collect and hold include:

name;
contact details (e.g. address(es), email address(es), telephone number(s));
name of any organization you are employed by or associated with;
position, title, profession or occupation;
identification details (e.g. date of birth, gender, and government identifiers like ABN, driver's license number, and passport number)
financial details, including bank and credit card details;
details of transactions, communications, and activity relating to our products, services, benefits, and business;
preferences, interests, and opinions relevant to our business and operations;
membership numbers or other personal identifiers related to your access to or use of our services;
health and medical information (e.g. injury details if there is an incident at one of our stores or sites, vaccination information where required or for safety purposes, medical records relevant to staff absences or suitability for roles);
other personal information you provide to us.

We may also collect the following types of current and historical information in the context of work and recruitment arrangements (e.g. about contractors, suppliers, retailers, and job applicants):

work history and other work-related details;
details of your assets and credit history;
payroll information (e.g. salary, benefits, leave, tax file number (TFN), superannuation details);
background checks including criminal background and financial information;
citizenship, visa, and work eligibility information;
CVs, references, application forms, details of education, job history and experience (both within Metcash and with previous employers), areas of expertise, qualifications, contracts of engagement and offer letters;
trade union / professional association membership;
emergency contact details;
information for identifying and managing conflicts of interest and financial and personal interests (including those of family members); and
your date of birth and driver’s license number where required (for example, to comply with age restrictions, or to verify your identity such as through “Know Your Customer” (KYC) and other due diligence checks under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act) when you apply for credit terms/financial accommodation with us).

From time to time, you may provide to us, and we may collect from you, the personal information of a third party. Where you provide the personal information of third parties, please ensure that those persons are aware of, and understand, this Privacy Policy.

How do we collect your personal information?

HNC collects personal information in a range of ways, often directly from you, but sometimes in other ways. The ways we collect personal information include:

through your access to and use of our websites, or when you email us;
through the use of digital technologies as described further below;
during conversations with you in person (such as in-store or via telephone);
through security cameras at our premises;
when you apply for credit terms/financial accommodation with us or complete an application, expression of interest form, purchase order, agreement, or similar or related paperwork;
through your participation in our procurement processes;
when you apply for a job with us;
when you enter into a competition or promotion run or supported by HNC;
when you register to use one of our marketing or promotional programs, platforms, or portals;
when you subscribe to receive communications from us;
when you complete one of our surveys;
from business partners we collaborate with to conduct marketing and promotional activities (including suppliers and retailers, and their service providers);
in connection with pre-employment screening checks (e.g. criminal record checks, bankruptcy checks, and medical records and health information that may be collected from a medical practitioner as part of a pre-employment medical examination);
from third parties that assist us with identity verification KYC checks, and other due diligence checks under the AML/CTF Act (e.g. when you apply for credit terms/financial accommodation with us), including credit reporting agencies, AML/CTF service providers, law enforcement agencies and government entities;
from related companies and HNC group companies;
from your representatives (including legal representatives);
from other third parties such as those described under “Who do we disclose your personal information to?”;
from publicly available information and databases;
by creating new information through analysis, interpretation, combination, and review of existing information;
otherwise in the course of us providing you with a requested product, service, or benefit; and
when you have other dealings with us.

Why do we collect, hold, use, and disclose your personal information?

General

HNC collects, holds, uses, and discloses personal information for a variety of different purposes relating to our functions and activities, which include:

to establish and maintain our relationship with you, and provide you with information to enable you to remain in contact with HNC;
to assess and process an application you may make to us;
to provide the products or services you have requested from us, and keep a record of them, and process any payments you make to us;
to ensure that you can provide products or services to us in the course of any engagement that we may have with you;
to administer our promotions and competitions;
to provide credit to you, or pay you for products or services you provide to us;
to provide you with access to protected areas of our websites;
to respond to your inquiries;
to process and respond to your complaints;
to perform our internal and external administrative functions, including maintaining and updating our records;
to notify you of, and register you for, our events and promotions;
to conduct surveys;
to assess the performance of our websites and to improve the operation of the websites, and for other data analytics purposes;
to assist us in making our services and products more valuable or useful to you;
to conduct due diligence, identity verification, and KYC checks;
to evaluate, enter into, implement, and otherwise facilitate corporate transactions such as mergers and acquisitions involving us;
to recruit, train, manage, and work with our workforce including staff, retailers, and suppliers;
to enable us to perform any duties we owe to you;
to otherwise enable us to perform our business activities and functions;
any other purposes described to you at or around the time of collection of the information;
purposes to which you have provided your consent;
to protect the safety and security of our customers, workers, sites, systems and assets;
to protect and enforce our legal rights and obtain professional advice;
to comply with industry standards and our policies;
to investigate, review, mitigate risks associated with, and inform you of, a data or other security breach involving your personal information; and
as required or authorized by law, or a court or tribunal order. For example, we are required or authorized by law to collect personal information under certain laws including the Income Tax Assessment Acts and other tax laws; Corporations Act; Privacy Act; Occupational Health and Safety Acts; Public Health Acts; Workers Compensation Acts; liquor, liquor control and liquor licensing acts; tobacco and smoking acts; surveillance devices act and similar laws.

Direct marketing

Where we have your consent or are otherwise permitted by law to do so, HNC may also use and disclose your personal information to send direct marketing to you from:

Hop Nhat International Joint Stock Company and its related bodies corporate; and
third parties who provide services to us.

The direct marketing may relate to:

our products and services;
the products and services of other parties;
promotions run by us or other parties; or
other new developments we believe may be of interest to you.

You may opt out of receiving this direct marketing from HNC or third parties through the unsubscribe function that will be made available to you with each direct marketing communication.

If personal information is not provided

You do not generally have to provide us with any personal information however, if you do not do so, this may limit the assistance we can provide you. For example, we may not be able to complete a transaction you have entered into, finalize payment for a product or service you have ordered or supplied, consider or process an application you have made, provide a product, service, or benefit that you have requested, ensure that you can provide us with products or undertake services that we have requested of you, grant credit terms, accept or validate your entry in a promotion or contact you in connection with the promotion, tailor, optimize or enhance your use or experience of our websites, respond to your queries or complaints or otherwise handle your inquiries or process your job application.

Who do we disclose your personal information to?

HNC may disclose your personal information to various third parties including:

our personnel;
related companies and HNC group companies;
manufacturers and suppliers;
couriers and delivery contractors;
customers and suppliers, for example, in connection with complaints or queries, or to the extent this is required (whether by the customer, the supplier, HNC, or by law, including public health orders) for you to perform your role (such as attending a customer or supplier site);
marketing consultants and promotions companies (some of whom are engaged for directly marketing products, services, and promotions to you);
our professional advisers such as accountants, solicitors, business advisers, and consultants;
government bodies and regulatory authorities;
credit reporting agencies or bodies by our Credit Reporting Data Management Policy;
companies that we plan to merge with or be acquired by or who may invest in us;
payment processors, debt collectors, web hosting providers, IT service providers, and other third-party service providers that are used by Metcash to verify or store collected information;
in the context of work and recruitment arrangements (e.g. about contractors, suppliers, retailers, and job applicants): referees, educational and training institutions, and background check services.

How do we store and protect your personal information?

HNC stores personal information in a combination of computer storage facilities, paper-based files, and other records, both at our premises and with the assistance of service providers.

In so doing, we have taken reasonable steps to protect your personal information from misuse, interference, loss, and unauthorized access, modification, or disclosure.

When we no longer need your personal information, we take reasonable steps to destroy or permanently de-identify the information.

How you can access and correct your personal information

HNC will take reasonable steps to make sure that the personal information we collect, use, or disclose is accurate, complete, and up-to-date. If your personal details change, such as your address or phone number, please contact our Privacy Officer by email (at cs@igafigtreedrive.com) or at the address detailed below.

At your request, HNC will provide you with a copy of, or correct, any personal information that we hold about you unless an exception under the Privacy Act applies. We may charge reasonable fees for retrieving this information, in which case we will let you know about the fee and get your agreement to that fee before providing the information.

Digital Technologies

We and third parties may use digital technologies such as cookies, location services, web server logs, and web beacons in connection with HNC’s websites and other online services. Some of these technologies may operate without collecting or using any personal information. Please note this Privacy Policy applies to our collection, use, disclosure, and storage of personal information only.

The HNC websites use cookies to track user traffic patterns and to serve you better when you revisit a website. A cookie is a small data file that a website may write to your hard drive when you visit it. A cookie file can contain information, such as a Session ID which the website uses to track the pages you have visited. Other technologies we use include web beacons. We allow cookies and other digital technologies to be used:

so that your preferences for a particular site can be stored;
to improve your browsing experience; and
to help tailor advertising and promotions to you.

Information is also generated whenever a page is accessed on an HNC website that records information such as the time, date, and specific page. We collect such information for statistical and maintenance purposes that enable us to continually evaluate our website’s performance.

In some cases, we and third parties may use cookies and other technologies in connection with HNC websites and digital marketing initiatives, for example, online behavioural advertising, surveys website analytics, and email campaign tracking. The third-party technologies we may use from time to time include, but are not limited to Google Analytics, Google AdSense, Google Tag Manager, and Meta tracking. You can find more details about these technologies, the data they collect, and how you can opt out of certain conduct in the privacy policies and other consumer-facing documentation for those technologies (e.g. via Google’s Ads Preferences Manager). You may need to opt out separately from each technology.

How to contact us or make a complaint

If you have any questions about this Privacy Policy, if you wish to update information we hold about you, or if you wish to make a complaint about our collection, use, or disclosure of your personal information under this Privacy Policy, please contact:

Hotline: +61 2 9763 7001
E-mail: cs@igafigtreedrive.com (please only use this email address for complaints related to our Privacy Policy or practices)

We will promptly acknowledge and investigate any complaint about the way we manage personal information.

For any complaints related to our businesses that do not relate to this Privacy Policy.

HNC will take reasonable steps to remedy any issues resulting from our failure to comply with our privacy obligations.