Tropico Privacy Policy

Tropico Fruits Pty Ltd – Version (1) – 29.5.14 1
1. Background
The privacy of your personal information is important to TROPICO FRUITS PTY LTD ABN 75 114 759 778, its
assignees, licensees, successors in title, parents, subsidiaries and affiliates (“us”, “we”, “our”).
We are an Australian company, with operations based in Australia. Being an Australian company, we act in
accordance with the Australian Privacy Act 1988 (Cth), as amended or superseded from time to time, and all
relevant privacy legislation protecting the rights of individuals in Australia (Privacy Laws).
If we receive personal information from outside Australia, we endeavour to act in accordance with global best
practice but at all times we will comply with the Australian Privacy Laws.
This document sets out the way in which we will use, manage and protect your personal information in
accordance with the Privacy Laws.
We will strictly comply with all Privacy Laws, and, in the event of inconsistency, the legislative requirements under
the Privacy Laws will override the provisions in this document.
We reserve the right to amend our Privacy Policy at any time without notice to you, and such amendments will
take effect from the date of issue on our website. Please check back regularly for updates.
2. What is Personal Information?
Personal information is information we hold about you from which your identity is apparent or can be reasonably
determined. This can include your name, address, date of birth, phone number, email address, credit card number
or drivers licence.
Special provisions apply to the collection of personal information which is sensitive information. Sensitive
information is information about your racial or ethnic origin; political opinions; membership of any political
association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade
association; membership of a trade union; sexual preferences or practices; or criminal record. It also includes
health and genetic information.
3. Collection of Information
We will only collect personal information where it is reasonably necessary to do so for the conduct of our
business. Any collection of personal information by us will be fair and lawful and will not be intrusive. In general,
we will collect personal information directly from you, and only to the extent necessary to provide a product or
service to you.
We may collect personal information from you when:
  1) you participate in our websites by:
       i) subscribing to the e-newsletter;
       ii) contributing, by way of comments, feedback and testimonials;
      iii) contact us through the website or ask us to contact you after visiting our website;
  2) you participate on our social media pages;
  3) you fill in an application form or entry form for one of our competitions either online or at shopping
centres, consumer shows or otherwise in person;
  4) you complete a credit application form for business customers; or
  5) you contact us by dealing with us over the phone, by email or have contact with us in person.
For example, when you enter a competition, we collect personal information from you such as your name, email
address, mailing address and/or telephone number. When you make purchases on our websites, we will collect
your order information including your credit card details and delivery address in order to arrange payment and
If you choose not to provide certain personal information (e.g. your date of birth), we may not be able to provide
you with the services you require, or the level of service on which we pride ourselves.
If you wish to participate in the online community, but do not wish to give us your name, you can use a
pseudonym. But you will still need to give us your email address if you wish to receive a response or if you have
subscribed to one of our e-newsletters and wish to be kept informed by us.
Occasionally, you may need to provide personal information about other individuals to us (e.g. about your
authorised representatives). If so, we rely on you to inform those individuals that you are providing their personal
information to us and to advise them that we can be contacted for further information.
4. Sensitive Information
We will not collect, use or disclose sensitive information except with your specific consent or in the circumstances
permitted in the Privacy Laws.
5. Clickstream Data
In general, when you visit our websites you do not have to tell us who you are, or reveal any personally
identifiable information to us. Unless you specifically agree to tell us, we will never know who you are, and you are
able to interact with our websites in a relatively anonymous way.
When you visit our websites our servers automatically record basic information about your usage, such as the
type of internet browser and operating system you are using, the date, time and duration of your visit and the
pages you viewed. This information is anonymous and does not identify you as an individual, nor will we combine
it with information that does identify you as an individual. This information is collected and analysed to provide us
with a greater understanding of how visitors use our website.
6. Cookies
At times we may use a feature of your browser (called a "cookie") to automatically assign you a unique user ID or
a session ID. A cookie, by itself, cannot be used to find out your identity, it merely identifies your computer to our
servers when you visit our websites. We will not combine your user ID or session ID with information that does
identify you as an individual. You may, at anytime, set your browser to allow, notify you or refuse altogether the
use of cookies. However, without cookies certain personalised services cannot be provided to users of our
website which means you may not be able to enjoy the full benefits of our website.
7. Use and Disclosure Information
We use personal information you provide only for purposes consistent with the reason you provided it, or for a
directly related purpose. If you give us your personal information, it will be clear what it will be used for.
In addition, we may also use the personal information you give us for the following purposes:
  1) to assist us in understanding the demographic of our website users and to help us improve our products
and services (this may include personal information such as age and sex); and
  2) to customise our advertising and the content on our website in order to improve the marketing and
promotion of our products and services.
You will always be able to "unsubscribe" to any of our mailings at any time. In any direct marketing that you
would reasonably expect to receive from us, you always have an opportunity to ‘opt-out’ of receiving future
communications of that nature.
We will not sell, trade or rent personal information to third parties such as advertisers or telemarketers.
We will not share your personal information with other organisations unless:
  1) you give us your express or implied consent;
  2) sharing is otherwise required or permitted by law;
  3) we reasonably believe there is a serious threat to life, health or safety of any individual, or to public
health or safety;
  4) we reasonably suspect unlawful activity or serious misconduct; or
  5) where this is necessary on a temporary basis to enable our contractors to perform specific functions.
We may share personal information with our affiliates, retailers or other business partners to support your
customer relationship with us. We may release your address information to the delivery service to deliver
products that you ordered; and provide order information to third parties that help us provide customer service
(for example, for third party redemption services).
If we temporarily provide personal information to companies who perform services for us, such as specialist
information technology companies, or other contractors we require those companies to protect your personal
8. Quality and Security of Information
To the extent required by the Privacy Laws, we will take reasonable steps to:
  1) make sure that the personal information that we collect, use and disclose is accurate, complete and up to
  2) protect the personal information that we hold from misuse and loss and from unauthorised access,
modification or disclosure; and
  3) destroy or permanently de-identify personal information that is no longer needed for any purpose that is
permitted by the Privacy Laws.
Any personal information you provide to us is stored and held under industry best-practice standards of
technology and operational security. We employ appropriate technical, administrative and physical procedures to
protect your personal information from unauthorised disclosure, loss, misuse, alteration, or destruction. We limit
access to personal information to authorised individuals with a business need consistent with the reason the
information was collected. Authorised individuals are required to treat your personal information as confidential.
9. Access
You may request access to your personal information at any time by sending a written request to our Privacy
Contact (see contact details below). You do not need to provide a reason for your request. We may charge a small
fee for providing access if it requires a significant amount of time to locate your information or to collect or
present it in an appropriate form.
In rare circumstances, and only where it is permitted under the Privacy Laws, we may not be able to provide you
with access to your personal information. For example, where the requested access will have an unreasonable
impact upon the privacy of others or where we are required by law to withhold the information, we may refuse
access. If we are unable to provide you with access, we will provide you with reasons for our refusal.
10. Corrections
We will take reasonable steps to ensure that the personal information that we hold is up to date, accurate and
We undertake regular reviews of our records. As part of our review process, we may ask you to confirm that your
personal information is accurate. If your information changes at any time, let us know so that we can update our
records as soon as practicable.
If you wish to modify or de-activate any information you have submitted, please contact our Privacy Contact. We
will modify or de-activate any information that could be used to identify you as soon as practicable after your
request, unless we are required or authorised by law not to do so. Once de-activated your data will not be
accessible. However, due to system backups to various types of data storage media, your data may in some
circumstances remain on these types of data storage media.
11. Unsolicited information
If we receive unsolicited personal information from you, we will determine whether or not we could have lawfully
collected that information or if it is information we would ordinarily collect from you for the purposes of our
business. If not, we will destroy or de-identify that information unless it is contained in a Commonwealth record
and it is lawful to do so.
12. Transfer of Personal Information Overseas
If we transfer your personal information outside Australia, we will comply with requirements of the Privacy Laws
that relate to trans-border data flows. This means that we will take reasonable steps to protect personal
information and ensure that the overseas recipient does not breach any Privacy Laws in relation to the
information no matter what country it is stored in or transferred to.
13. Third Party Services
Our websites may provide links to other third party websites. We are ultimately not responsible for the privacy
practices or the content of such web sites. We encourage you to read and understand the privacy policies and
terms and conditions of using their websites before providing any information to them.
Some of the content appearing on our website may be supplied by third parties. In such cases we will ensure that
our contractual arrangements with these third parties protect your personal information in compliance with the
Privacy Laws.
We also use third party platforms, including social media. Some of these platforms are not operated or controlled
by us and in that case our ability to protect your personal information is limited.
We encourage you to be careful about the protection of your own personal information when using third party
digital services such as social media platforms. As far as reasonably practicable, and as required by the Privacy
Laws, we will ensure that third party digital services include appropriate protection of your privacy.
14. Contact
Please contact us if you have any queries about the personal information that we hold about you or the way we
handle that personal information. Our contact details for privacy queries are set out below:
To: Tropico Fruits Pty Ltd
Attention: The Privacy Contact
Address: c/O: ICM Australia Pty Ltd
Level 2, 1 Collins Street
Melbourne, Victoria, 3000 Australia
Phone: +61 3 9661 8999
Fax: +61 3 9654 4041
15. Complaints
Please contact our Privacy Contact using the above details if you have any concerns or complaints about the
manner in which your personal information has been collected or handled by us.
You can also contact the Office of the Australian Information Commissioner (OAIC) for more information or to
make a complaint about the handling of your personal information (