1. Royalgem Group’s commitment to privacy
          The Royalgem Group is committed to managing personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws (see below for further information about the Royalgem Group). We understand the importance of being open and transparent with you in the way in which we collect, hold, store, use and share your personal information. We take protecting your privacy very seriously. We strongly encourage you read this document, so that you understand and are comfortable with how we handle your personal information. If you have any questions about this document, or about Royalgem Group’s handling of your personal information, please contact us using the relevant contact details set out in section 17.
  2. About Royalgem Group
           The Royalgem Group is an integrated pet care business in Australia and New Zealand, and our purpose is to make the world a happier place through the love of pets. In summary, the Royalgem Group consists of the following brands and services:   Brands and/or Services Services • Royalgem
    • City Farmers
          Retail and related services
    Our retail businesses hold a range of third party and private label products including food in dry, wet, fresh and frozen categories, flea, tick and worm products, pet bedding, pet housing, pet toys, aquarium fish and grooming products as well as provide pet services such as grooming, training and washing services. • PetWise
    • Leaps & Bounds
    • Barkers Best
    • Providore
    • ProBalance
    • active BLEND
          Private label brands
    We create a range of private label pet food and other products. • Royalgem Vets
    • Animal Emergency Centre
    • Veterinary Referral Hospital
    • Animal Referral Hospital
    • Vepalabs
    • Petrest
    • Pets Eternal
    • Animates – Vetcare
          Veterinary and related services
    We operate general practice veterinary clinics and specialist and emergency centres across our veterinary network and also provide pathology and cremation services. • Healthy Pets Plus (membership program)
    • Friends for Life Program (loyalty program)
          Membership program
    We have a paid membership program (Healthy Pets Plus) which is a preventative healthcare program designed to keep your pet healthier and happier for longer. Loyalty program
    We have a free loyalty program (Friends for Life Program), which individuals can join to receive special promotions and offers in relation to our products and services which may be offered across the Royalgem Group.  
  3. When does this privacy policy apply?
           This Privacy Policy applies to all Australian Royalgem Group websites, subsidiaries, affiliates and businesses, unless that website subsidiary, affiliate or business has adopted a separate privacy policy.
  4. About this privacy policy
           This document sets out our policies for managing your personal information and is referred to as our Privacy Policy. In this Privacy Policy, “we”, “us” and “our” refers to the Royalgem Group and “you” and “your” refers to any individual about whom we collect personal information. This Privacy Policy sets out how we collect, store, process, use and disclose personal information (including personal information we collect, and personal information submitted to us, whether offline or online). For example, this can include:
    • information we may collect when a customer creates an account with or becomes a client of one brands or services;
    • information we may collect when individuals join the Healthy Pets Plus membership program or Friends for Life loyalty program and other membership and loyalty programs we may make available; and
    • information we may collect when you interact with us .
    Other terms and conditions may apply to you such as:
    • the privacy terms and conditions contained in our Royalgem Group Terms and Conditions (as applicable to you); and
    • the collection notices and privacy statements which may be provided to you at the time your personal information is collected.
  5. What is personal information?
           “Personal information” is defined in the Privacy Act, and means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
    • whether the information or opinion is true or not; and
    • whether the information or opinion is recorded in a material form or not.
    In this Privacy Policy, whenever we use the term “personal information”, we are referring to this legal definition. Personal information does not include:
    • aggregated or de-identified data; or
    • information about your pet (such as your pet’s name and medical history).
  6. What information do we collect about you and how do we collect this information?
           Normally we collect your personal information from you directly, however on occasion, we may also collect personal information about you from other people and organisations. In summary, we may collect your personal information when you:
    • create an account with us (for example, when you create a Royalgem account or become a Royalgem client);
    • join the Healthy Pets Plus membership program or Friends for Life loyalty program (or other membership or loyalty programs we may make available to you);
    • make a purchase or complete purchase orders for our products or services (via phone, in person or electronically);
    • communicate with us during competitions, special events and promotions;
    • interact with us in person (such as when you visit one of our stores or clinics), via phone or online (including through our website or our social media channels), such as when you contact us to make an enquiry or give us feedback; or
    • apply for a position with us (including for work experience).
    We may also:
    • receive personal information from another member of the Royalgem Group; and
    • collect personal information from third parties (such as through acquisition of third party mailing lists and from organisations with whom we have an affiliation), to improve the personalisation of our offerings for you, and from our partners (such as Uber).
    Summary of personal information we collect and how we collect this information Type of personal information What this includes How do we collect this information? Personal information and contact details This may include your:
    • full name;
    • date of birth;
    • address;
    • email address;
    • phone number;
    • loyalty membership ID with us (as appropriate);
    • photo; and/or
    • signature.
    This may also include contact details for your emergency contact. We may collect this information:
    • directly from you during conversations with our staff members (in person, via phone or online);
    • when you create an account with us, in person or online (for example,
    • when you join the Healthy Pets Plus membership program or Friends for Life loyalty program (in person or online) or other membership or loyalty programs we may offer from time-to-time;
    • when you communicate with us during competitions, special events and promotions;
    • when you make purchases or complete purchase orders for our products or services (by phone, in person or electronically);
    • if our security or staff members are investigating whether you may have breached any store or clinic rules, if you witness an incident, or if you get injured;
    • when you contact us via our online chat functionality, or via our social media channels;
    • if you apply for a position at Royalgem Group;
    • from our partners (for example, when you use our delivery service);
    • when you otherwise interact with us on a commercial basis.
    Pet ownership and insurance information This may include information:
    • about your pet ownership; and
    • about any pet insurance you have (including details of your policy).
    This may be collected when you join the Healthy Pets Plus membership program or the Friends for Life loyalty program (in person or online) or when we provide veterinary services to your pet or animal. Information about your purchases and use of Friends for Life loyalty program benefits This includes information about:
    • purchases you have made which count towards your Friends for Life loyalty program account, such as what, how and when you make purchases (including the price of those purchases); and
    • use of any Friends for Life loyalty program benefits (such as using a voucher towards any of your purchases).
    We may collect this information when you are logged into / agree to use your Friends for Life loyalty program account and you make a purchase of or complete purchase orders for our products or services (in person and online). If you do not want us to collect this information (i.e. you do not want your purchases to be attached to your Friends for Life loyalty program account), you can always:
    • in store: not provide your account information when making purchases; and
    • online: checkout as a guest.
    Workplace information This may include:
    • information relating to your work history;
    • information about your education and qualifications;
    • your working eligibility rights;
    • your suitability for the role you are applying for; and
    • details about your referees.
    We may collect this information if you apply for a position at Royalgem Group (including if you are applying for work experience with us). Information collected during our interactions This includes details of your interactions with us, for example information you provide us when you make an enquiry or complaint. We may collect this information:
    • when you visit one of our premises;
    • when you call us or we call you;
    • when you use our online services (such as our websites or our social media channels);
    • when you make an enquiry, provide feedback, or make a complaint (via phone, email or in person); and
    • in your responses to customer satisfaction, service development, quality control, research surveys and similar activities.
    Online and digital services information (including behavioural information) We may collect information from you electronically, which includes information such as your IP address, and details about your device. Please see
    section


    12
    for further information on the digital information we collect. We may collect this information when you use our online services Please see
    section


    12
    for further information on the digital information we collect. Call recording information This may include the voice recording, time, date, number and name of individuals on the call. We may collect this information in circumstances where we monitor and record our call with you, when we call you, or you call us. We will let you know if we are going to record call information. Camera surveillance information We may collect camera surveillance information which includes photographs or video recordings of you. We may collect this information in circumstances where we use camera surveillance (e.g. CCTV) at our premises for the safety of our staff and customers, such as where you attend in person at our clinics and stores. Information required to be collected by law We may collect information as required by law (such as under State and Territory veterinary surgeons legislation). We may collect this as required. Publicly available online information We may collect information that is publicly available online, such as on online forums, websites, and social media channels (for example, information that relates to a complaint). We may collect this directly from the publicly available source (e.g. on the online forum, website, or social media channel). In some cases you may provide us with personal information which relates to another person (for example, an emergency contact, a job referee, or a joint pet owner). If you do so, you agree that you have received permission from these individuals for us to collect, use, and share, their personal information in accordance with this Privacy Policy. You should also let them know about our Privacy Policy (including the information in this Privacy Policy). 
  7. Can you deal with us without providing me your name?
           Most of the time, you will have the option of not providing your name, or using a fake name, when you deal with us (where it is lawful and practicable). This includes for example, when you make a general enquiry, or when you purchase products from our retail stores. In some circumstances however, we may need your real name as it may not be practicable for us to deal with you anonymously or pseudonymously on an ongoing basis. For example, this includes when providing treatment to your pet or animal, or when adding points to your Friends for Life loyalty program account. This means that if we do not collect your personal information, we may not be able to provide you with the products and/or services you have asked for.
  8. Why do we collect, store and use your personal information?
           We collect personal information that is necessary to provide you with our products and services, and to carry out our business. We may use your personal information for purposes which are incidental to the sale and promotion of our goods and services, or for other purposes which are within your reasonable expectation or permitted by law. The purpose for which we usually collect, store, and use your personal information depends on how you interact with us (for example, whether you are part of our Friends for Life loyalty program), but may include the following purposes: Purpose Explanation To provide you with our products or services when you are a customer or client We may collect, store and use your personal information to:
    • provide you with our products or services you have purchased online, in store or at one of our clinics (including to provide a delivery service, if appropriate);
    • provide safe and effective veterinary care to your pet or animal;
    • administer, manage and communicate with you about existing products or services we are providing to you (including about upcoming appointments and to answer any questions you may have / provide veterinary advice);
    • manage our relationship with you, including to remind you when any services are due;
    • improve our products and services, and your experience with us; and/or
    • personalise your shopping experience with us by communicating with you about, displaying and promoting our products and services (including to let you know about other products and services you may be interested in based on information you have provided us with).
    To administer and manage the Healthy Pets Plus membership program and Friends for Life loyalty program We may collect, store and use your personal information to:
    • manage fees in relation to your Healthy Pets Plus membership;
    • provide you with special offers and promotions (including your loyalty or member benefits, such as price discounts and vouchers);
    • provide you with the benefits of the Healthy Pets Plus membership program or Friends for Life loyalty program;
    • communicate with you about our Friends for Life loyalty program and promote our products and services (including to let you know about other products and services or promotions you may be interested in); and
    • gather information about your purchases, including for data analytics activities (see ‘To conduct data analytics activities’ below in this table for further information); and
    • improve the Healthy Pets Plus membership program and Friends for Life loyalty program.
    To manage your working relationship with us (including when you are a contractor) We may collect, store and use your personal information to assess your suitability for a position with us, and, if you successfully join us, to manage our working relationship with us. We may collect, store and use your personal information for administration and management purposes (such as if you are a veterinary surgeon or contractor). To do business with you We may collect, store and use your personal information about you if you interact with us on a commercial basis (such as if you are a service provider, contractor or supplier to us), or you otherwise interact with us on a commercial basis. To manage and improve our operations and business We may collect, store and use your personal information to:
    • manage fees and administer billing (including administration of pet insurance and other third-party payment arrangements) and debt recovery;
    • manage, monitor, plan and evaluate our products and services;
    • conduct safety and quality assurance and improvement activities, including quality control of our products, services and communications with you;
    • train staff (including sales and retail staff, as well as veterinary care workers);
    • test and maintain information technology systems;
    • investigate any incidents that may occur (both in relation to cyber security, as well as any health and safety incidents that occur at our premises);
    • handle and respond to any complaints made; and/or
    • assist with product and service development, to test the effectiveness and customer satisfaction of our products and services, improve the way we provide products and services to you, and for other quality assurance and compliance purposes.
    To create identified or aggregate data for data analytics activities We may collect, store and use your personal information to create  identified or aggregate data sets (which is no longer personal information). We do this by deidentifying or aggregating your information such as combining your information with information we have about our other customers, for example purchasing information, and with data we obtain from other sources. We use this  identified or aggregate data to assist with our business decisions, such as to:
    • help us in understanding trends in customer behaviour (such as the success of our products and services, and our different marketing campaigns (such as promotions));
    • create look-a-like audiences for the purposes of providing targeted advertising to other customers;
    • improve the products and services we offer; and
    • develop new products and services that better meet our customers’ preferences and behaviours.
    To assist with any business, share sale or corporate restructure We may collect, store and use your personal information for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale.
  9. Who do we share your personal information to and why?
           We may share your information with third parties:
    • for the reasons for which we collect, store and use that information (see above in section 8);
    • for other purposes explained at the time we collect your personal information; or
    • where we are otherwise allowed or required to do so under law.
    Some of the third parties we may share your information with include the following: Recipient Explanation Other members of the Royalgem Group We may share your personal information across the Royalgem Group, between members of the group (as appropriate). For example:
    • when you are part of the Friends for Life Program, we may share your personal information and information about your purchases with other members of the Royalgem Group, to better understand consumer behaviour in relation to the products and services we offer;
    • we may share your personal information to another Royalgem Group member where that member provides backend IT support and other corporate services to the Royalgem Group;
    • where it is necessary, for example you have entered into a promotion or competition operated by one Royalgem Group member, however, another Royalgem Group member is responsible for delivering all or some of the prize; and
    • for direct marketing purposes, for example we
    may share your personal information with another member of the Royalgem Group so that the other member of the Royalgem Group can serve targeted advertising which may be of interest to you. Our partners, suppliers and other entities we do business with We may share your personal information with our partners and other entities we do business with to assist in providing our products and services. The kinds of third parties to whom we may disclose personal information to include delivery services providers, manufacturers, suppliers and distributors. Our service providers and advisors We may share your personal information with a variety of our service providers to assist us with providing, promoting, and managing our products and services. These may include our:
    • IT service providers and third party storage providers;
    • marketing and communications agencies;
    • data analysis organisations; and
    • professional advisors and consultants (such as legal, insurance and financial advisors).
    Corporate restructure We may share your personal information with third parties, whether affiliated or unaffiliated, for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale. In this context, your personal information may be transferred to another entity (or if such a sale, transfer, acquisition or corporate restructure is being contemplated by us). Government and law enforcement agencies We may share your personal information with regulatory bodies, government agencies and law enforcement bodies to comply with our legislative or regulatory obligations (such as to assist with police investigations).
  10. Do we share your personal information overseas?
           We generally collect your personal information in Australia. However, it is likely that we will share your personal information with overseas recipients located in the United States of America, and New Zealand. These recipients include our service providers who may handle, process or store your personal information on our behalf. For example, we may share your personal information with service providers who assist us with storing our data on secure data storage servers, or with improving our products and services (by analysing sales information and trends, and conducting customer satisfaction enquiries). We only ever share your personal information outside of Australia where we are permitted to do so under the Privacy Act. Generally this means we will take reasonable steps to ensure your personal information is treated securely and in accordance with applicable privacy laws. There are other circumstances where we may disclose your personal information to an overseas recipient. For example, where you have provided your consent or we are otherwise permitted to do so under other relevant laws.
  11. Do we use or share your personal information for direct marketing?
           When you provide your personal information to a Royalgem Group member, we may use that personal information to send you direct marketing communications to keep you informed about products and services offered by the Royalgem Group and carefully selected partners which we think might be of interest to you based on your interactions with us. For example, when you create an account with us (including with Royalgem or with Royalgem Vets), or join the Healthy Pets Plus membership program or Friends for Life loyalty program, we may send you direct marketing communications and information about our products and services (including those provided by other members of the Royalgem Group) that we consider may be of interest to you, or as otherwise allowed under applicable privacy laws. We may communicate with you (and send these electronic messages and tailored advertising) through various channels, such as via regular mail, email, SMS, telephone, push notifications or social media (including through targeted advertisements on certain websites and social media channels). We will only send these communications in accordance with applicable privacy and marketing laws (such as the Privacy Act (including Australian Privacy Principle 7) and the Spam Act 2003 (Cth)), and only where you have not opted out from receiving such communications from the relevant Royalgem Group brand or service. If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so. How can you opt out? You are always in control of the direct marketing communications which you receive and can opt-out at any time. Generally you can opt-out by following the relevant opt-out or unsubscribe instructions in the relevant communication (such as email or SMS message). You can also contact us using the detail set out in section 17 to tell us you would like to stop receiving direct marketing communications from us. For cookies which use your personal information for direct marketing (such as targeted advertising) you can only opt-out by adjusting your device setting and online privacy settings (for advertising on certain websites and social media channels). For more information about cookies, including how to opt-out of targeted advertising, see our Cookies Policy. Important points regarding opting out Importantly:
    • if you are a customer of multiple Royalgem Group members (for example you have an account with Royalgem, and are also separately a client of Royalgem vets), even if you opt out from receiving direct marketing communications from Royalgem, this will not mean you are opted out from receiving direct marketing communications from Royalgem vets (for example); and
    • regardless of whether you opt out from receiving any or all direct marketing communications, we will still communicate with you if we are required by law to provide you with information, or in relation to the services or products we are providing you with (for example, in relation to delivery information for products, sending you an invoice in relation to a transaction or providing you with any vouchers you have earnt through the Friends for Life loyalty program).
  12. How do we interact with you via the internet?
           Third party links and sites When you use our websites or receive communications from us, links to websites which belong to other third parties may be included (and are provided for your convenience). You should make your own enquiries as to the privacy policies of these parties. We are not responsible for information on, or the privacy practices of, any third party websites. In addition, when you make online payments using our websites, we do not collect your credit card or banking details. This is because online payments are handled by third parties. Website use and cookies You may visit our websites without identifying yourself. If you identify yourself (for example, by creating an online account or making an enquiry), any personal information you provide to us will be managed in accordance with this Privacy Policy. Our websites also use cookies (and we share personal information we collect between members of the Royalgem Group). A ‘cookie’ is a small file stored on your computer’s browser, which assists in managing customised settings of the website and delivering content. We collect certain information such as your device type, browser type, “click-through” information, IP address, pages you have accessed on our websites and on third-party websites. Depending on the circumstances, this may or may not be personal information. At a high level, cookies can be used for a variety of reasons, such as to personalise your browsing experience (for example, by remembering your preferences and recognising you as a repeat visitor to our websites), and to track statistics about the usage of our website. This allows us to better understand our users and improve the layout and functionality of our websites. If you do not wish to receive any cookies (other than those that are strictly necessary) you can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our websites. Please see our separate Cookies Policy for further information about what cookies we use and information we collect online and through digital services.
  13. How do we store and protect your personal information?
          We are committed to protecting your personal information, and ensuring that we securely store any personal information we collect (and in accordance with applicable privacy laws). We may hold your personal information in hard copy (paper) or electronic form. We take all reasonable steps to ensure that any personal information we collect, use or disclose is accurate, complete, up-to-date and stored in a secure environment protected from misuse, interference and loss, and from unauthorised access, modification or disclosure. Security and storage of personal information Form Explanation Paper-based files We store personal information in paper-based files in secure storage (generally at our head office, or at the relevant store or clinic). Personal information may be collected in paper-based documents and converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We maintain physical security measures to ensure that personal information in paper-based files is protected, such as physical locks and security systems at our premises. Electronic records We store electronic records in secure databases, using trusted third party storage providers based in Australia, United States of America, Germany, Singapore and New Zealand. We also maintain physical security measures in relation to storage of our electronic records (such as through locks and security systems at our electronic data stores). Using technical methods, we also maintain computer and network security. For example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems. Our websites (including for making payments) Our websites use encryption or other technologies to ensure that your personal information is securely transmitted via the internet (including to protect any payments you make).
      We encourage you to exercise care when sending your personal information via the internet (for example, when communicating with us online, we ask that you do not include your full account or card details). How long do we keep your personal information? We will only keep your personal information we store for as long as is necessary for the purposes set out in this Privacy Policy or as required to comply with any applicable legal obligations. When we no longer require your personal information (and in accordance with any applicable laws), we will take steps to delete, destroy or de-identify that information.
  14. How can you access or seek correction of your personal information?
          You are entitled to request access to any of your personal information that we have. To make such a request, please contact us using the relevant contact details set out below in section 17. We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you and informing us of any change in your personal details (for example, if your email address changes or if you move and change address). If you consider any personal information we have about you is inaccurate, out-of-date, incomplete, irrelevant or misleading, you are also entitled to request correction of the information (again, please contact us). After receiving a request from you, we will take reasonable steps to correct your information. We may decline your request to access or correct your information in certain circumstances in accordance with the applicable privacy laws. If we do refuse your request, we will provide you with a reason for our decision. In addition, in the case we refuse your request for correction, we will include a statement about your request with the personal information we store.
  15. How can you make a complaint about the handling of your personal information?
          If you have any questions or concerns about this Privacy Policy or how we have handled your personal information, you may contact us at any time using the relevant contact details set out below in section 17. Please also contact us if you have a complaint about privacy. If you make a complaint about privacy, the following will occur: No. Step 1 We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally acknowledge your complaint within a week. 2 If your complaint requires more detailed consideration or investigation:
    • we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly; and
    • we may ask you to provide further information about your complaint and the outcome you are seeking.
    3 We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved. 4 In most cases, we will respond to your complaint within 30 business days from when we receive your complaint. If the matter is more complex or our investigation may take longer, we will let you know. If you are not satisfied with our response to a complaint, or you consider that we may have breached the Privacy Act (including the Australian Privacy Principles), you are entitled to make a complaint to the Office of the Australian Information Commissioner (the Australian privacy regulator).  
  16. How are changes made to this privacy policy?
           We may make changes to this Privacy Policy, with or without notice to you. However, where we make a material change to the Privacy Policy, we will provide notice to you (including by updating our websites, and, where appropriate, notifying you directly). We recommend you visit this Privacy Policy regularly to keep you up to date with any changes we make.