Our Privacy Policy and Practices

You entrust us with your personal information to connect to our natural health services and high-quality products. Your privacy is important, and we have a responsibility to protect it.

Key Messages

• You choose what personal information you provide us. To help you make informed decisions and provide consent, we will tell you why we need certain personal information and how we will use it.
• We use personal information to deliver products and services to you in the way you would expect. We also use it to help us analyse and continuously improve our operations.
• We do not sell or trade your personal information with third parties.
• We store and protect personal information using trusted partners and platforms, as appropriate to the sensitivity of the personal information.
• By continuing to use our website and/or share personal information with us, you agree to our Privacy Policy.

Privacy Policy

About this Policy

Our Privacy Policy explains how we collect, use, store, and share your personal information. We handle your personal information in compliance with the Australian Privacy Act 1988 (Cth) (“Australian Privacy Act”) and other applicable privacy laws of the countries within which we operate.

“Blackmores” or the “Blackmores Group” means Blackmores Limited (ACN 009 713 437) and each of its related entities, both current and in the future. In this Privacy Policy, “Blackmores”, “the Blackmores Group”, “Group”, “we” and “us” may be used as a reference to all companies or any one or more of the companies or entities in Blackmores Group as may be applicable in the context. Blackmores Group includes FIT-BioCeuticals and Blackmores Institute.

“Personal information” means any information or an opinion about a person who is reasonably identifiable, regardless of whether it is true. This adopts the basic definition of “personal information” in the Australian Privacy Act and is intended to include equivalent definitions of “personal data” protected under privacy laws of the countries within which we operate.

“Sensitive information” refers to a type of personal information that includes information or an opinion about a person’s racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union membership or association, sexual orientation or practices, criminal record, health or genetic information and some aspects of biometric information consistent with the basic definition in the Australian Privacy Act.

In addition to our Privacy Policy, we give you specific information about why and how we handle certain personal information before or at the time you provide it to us through collection notices. For example, a collection notice will be displayed when you are completing webforms, subscribing, or becoming a member, etc.

This Privacy Policy applies to all our operations across the globe, noting that:

• if you are outside Australia, you may have additional rights which are set out in additional information sheets of this Privacy Policy; and
• in the event of a conflict between translations of this Privacy Policy, the English version prevails to the extent of the inconsistency.

We update our Privacy Policy from time to time. You can always find the latest version here on our website.
If you have any questions about privacy, contact our Privacy Officer by email [email protected] or use the alternative contacts outlined at the end of our Privacy Policy.

Collecting your personal information

Types of information we collect

Your relationship with us determines the types of personal information we collect.
Across all our relationships, we may collect personal and contact details, socio-demographic information, lifestyle or fitness related information, health information, transaction information, payment information, feedback or complaint information, device information, and behavioural or generated information. We may also collect:

• For practitioners using our services - information relating to professional and trade associations or accreditations.
• For businesses which sell our products (retailers, pharmacies, practitioners) - credit related information.
• For individuals applying for a job with us and employees - information relating to professional and trade associations or accreditations, screening checks and unique identifiers and health information.
• For participants of research initiatives - unique identifiers and health information.

Type of Personal Information	Examples
Personal and contact information	Your name, postal address, email address, phone number and date of birth are used to provide you with products and services and to complete order transactions.
Socio-demographic information	Your age, gender, occupation, nationality and country of residence are used to assist us to provide information relevant to the country in which you reside or to personalise your experience.
Lifestyle or fitness related Information Health Information	For website users and individuals who purchase of our products: Your goals for health or fitness, lifestyle patterns, current or historic wellbeing experience, or health information is used to personalise your experience, provide you education to support your goals, and assist us to understand how we can improve our products' benefits. For example, you may complete a quiz with questions on sleeping patterns, stress levels, and/or dietary preferences to receive wellbeing suggestions. If an adverse reaction to a Blackmores product occurs and you report this, your symptoms and other relevant health information will be used to provide you with assistance and shared with third parties as required or permitted by law (e.g. notification to the regulator). This information will also be used to assess our operations including product assessment and development. For job applicants and employees Any health information you provide will be used as necessary to fulfil obligations as a prospective or current employer to provide a safe working environment, make necessary workplace adjustments or otherwise support you with improvements in your wellbeing. For participants of research initiatives: Your medical history or conditions will be used to assess your suitability to participate in the research initiative.
Unique Identifiers / Documents	In limited circumstances, such as for job applicants or participants of research, we may require government issued identifiers or documents to verify your identity.
Transaction Information	Your order history and other information associated with the use of your account including purchasing preferences, wish lists, products added to cart and browsing interactions, etc assist us to personalise your experience and to conduct analytics to improve our products and services.
Payment Information	Your credit card information is used to complete order transactions. If you choose to purchase a product from us, our third-party payment processors will collect your payment information, and it goes directly to our processor or the bank. Blackmores does not store payment information and none of our personnel will have access to your payment information.
Feedback, query or complaint information	All the details you provide to us when you enquire, provide feedback or make a complaint or request, will be used for the purpose they are provided. This information may also be used for other purposes such as analytics and continuous improvement of Blackmores operations. Information may include: voice recordings of calls where you have been provided notice and the opportunity to request the recording is disabled; and, information of another person where the individual is acting as an authorised representative.
Device Information	Information associated with the electronic device you use to access our websites including but not limited to: IP address; type of device being used (computer, phone, tablet etc); identifiers about the device and the interactions while on our website, such as items viewed, idle time, cart additions, clicks made, pages viewed, session times; and geolocation data. This information may not identify you specifically on its own but may distinguish you from other users. If you are logged in to your account, it may be combined with your personal information to improve your experience through personalisation and enable analytics and continuous improvement of Blackmores operations.
Credit Information	If you apply for or use a commercial account with us, we may require credit information as outlined in the additional information sheet. We collect credit information directly from you, your representative and from third parties, including credit reporting bodies.
Personal information for job applications	If you apply for a job, your application requires education and employment history, screening checks (such as references, nationality and residential status, eligibility to work, professional accreditations, criminal record checks) to assess employment suitability and certain voluntary information such as health or ethnicity to complete accessibility requests and provide other diversity, inclusion and equity support.

Do you have to provide your personal information?

You do not have to provide us with your personal information. However, if you do not provide us with necessary information, we may not be able to provide you with our products, services or assistance, and you may not be able to use all the features available on our website.

As we are passionate about inspiring people to take control of and invest in their wellbeing, we provide education and give you options for a personalised view of our services, e.g. quizzes, surveys and consultations. This may involve health information which is “sensitive information” under many privacy laws. This means you should not provide this information to us unless you consent to its collection and use. It also means we must undertake stringent safeguarding of such information to prevent unauthorised access, unauthorised disclosure and loss. If you provide health information for a personalised services and products, it is entirely voluntary, and your submission will be taken as consent.

How do we collect personal information?

How we collect	Examples
Directly from you when you engage with us	When you create an account on our website, subscribe for an email newsletter, participate in promotions or competitions, purchase products from our website, use the services available on our website e.g. quizzes, contact us and/or share information with us, including by telephone or in writing. You will be provided collection notices or a consent mechanism as appropriate.
Indirectly from you via cookies, ‘pixel tags’ and similar technologies on our website	When you use our website and do not adjust your settings to disable features that are not strictly necessary, personal information about you, your device, your interactions may be collected.
From third parties authorised to provide information to us	When information is provided by: individuals who are acting as your authorised representative, past employers, educational or professional institutions, or current referees, credit-reporting agencies, third party partners and service providers that assist us to provide services and products or operate our business. When information is publicly available, this may also be collected.

Using your personal information

We may use your personal information if:

• it is necessary for us to perform a contract we have with you;
• it is necessary for us to comply with applicable legal or regulatory obligations;
• we have a legitimate interest which is not overridden by specific interests, right or freedom you may have under law; or
• you have provided your consent (where necessary) for use in connection with specific purposes.

Generally, we collect and use your personal information to perform our business functions and activities, to provide our products and services, and to meet our legal obligations. We do not sell or trade personal information about you to or with third parties.

Examples of how we use your personal information includes the following purposes:

• fulfilling your orders for products;
• providing information about our products and services;
• providing other available services and assistance via our website;
• managing enquiries and complaints;
• providing information to professional practitioners about our products and services, including about how our products might be of benefit to members of the public to whom they provide advice;
• operating programs and forums in different media in which you can share information, including your personal information, with us and publicly via our website;
• providing you with marketing communications, newsletters and alerts, surveys and invitations and offers for products including new products that may be of interest to you (and if we do so, we will provide you with a way to opt out);
• to administer and manage promotions and competitions;
• to determine if you are eligible for certain products, services, programs or research initiatives;
• for a business or professional relationship, we may have with you;
• if you apply for employment with us, to consider your application;
• developing and administering learning and education materials;
• to evaluate our products and services, conduct product development activities and consumer research;
• to undertake research relating to public health;
• to investigate or respond to a data breach or a suspected data breach;
• to fulfil any personal information access requests made under applicable privacy laws;
• to comply with or respond to any requests for information such as a subpoena, undertaking, notice for discovery, governmental, regulatory and/or statutory investigation (such as a privacy commissioner and/or authority or a statutory notice to produce); and/or
• for other reasonable business functions and activities, including monitoring, analysing and improving our business.

Where required by applicable law, we will obtain your consent before using your personal information for a secondary purpose that you would not expect (having regard to the purposes of the initial collection).

Marketing and your choices to opt-out

We may send you marketing and other educative material based on our relationship with you and the consent that you have provided. You may withdraw your consent to direct marketing at any time by using the “unsubscribe” option contained in the message you are sent (e.g. email or SMS). If you have any concerns or issues, please contact our customer service team for further assistance.

How do we use automated-decision making?

Automated decision-making involves using a computer program to make a decision.

In general, we do not currently use automated-decision making in a way that will significantly impact your rights or interests. In any circumstances where we do use automated decision-making and your personal information may be involved to significantly impact your rights or interests, we will inform you of the types of your personal information used in the computer program, the kinds of decisions that may be made, and how it may affect your rights or interest.

How do we use Artificial Intelligence (AI)?

AI is the ability of a computer system to perform tasks that would normally require human intelligence, such as learning, reasoning, and making decisions. We may use AI and similar technologies to enhance our products, services and operations to improve your experience with us. Improving our operations with AI may include analysing data, automating processes, assisting with document review, analysing contracts, or providing innovative access to services.

In general, we do not use AI to process your personal information. In circumstances where we do use AI and your personal information may be involved, we will ensure that all AI applications comply with relevant laws and regulations.

Storing and holding your personal information

How do we secure and protect your personal information?

We use physical, technical and organisational measures to safeguard your personal information to protect against loss or unauthorised access, alteration, disclosure, misuse, and contamination. Business systems and processes we use to maintain the availability, integrity, confidentiality, and security of personal information includes:

• team member training and conditions of employment which require all personal information to be treated as confidential;
• governance through policies and procedures;
• premises secured with access restricted to pass card holders;
• access controls used to restrict access to a ‘need to know’ basis;
• security controls such as data encryption and password protection; and
• audits and a continuous improvement approach.

Blackmores may use commercial solutions provided by third parties and various systems and services to implement and maintain the above. Despite Blackmores best efforts, security cannot be absolutely guaranteed against all threats even though reasonable steps are taken to prevent and mitigate against such risks.

How long do we keep your personal information?

The length of time we keep your personal information will vary depending on why it was collected (i.e. the purpose of collection). In some cases, we may be legally required to retain the record for a specific minimum period.

Where the records not legally required to be held for a minimum period, we take steps to securely destroy or de-identify such personal information once it is no longer necessary for the purposes for which we collected it, any secondary purposes which you would reasonably expect or any new purposes which you provided subsequent consent.

Disclosing your personal information

Blackmores is an international business, and your personal information, including sensitive information, may be stored and/or shared with our related entities and third-party service providers in a range of locations outside of the country in which you are located.

These locations may include New Zealand, the United State of America, countries within Asia (excluding North Korea), or any other country in which we or our service providers maintain facilities.

The usual disclosures we may are:

• to our related entities, including for the purposes of different entities within the Group providing services to or supporting the functions and activities of other entities within the Group;
• to government or regulatory bodies where required by law, for example, if there is an adverse reaction to one of our products; or
• to third party service providers so that they can perform services for or on behalf of Blackmores. For example, this includes the following types of service providers:
  • other companies and individuals which we engage to provide you promotional and informational offers on our behalf, such as email marketing services (e.g. analysing customer lists, deliverability statistics, opens and clicks), marketing assistance or consulting services. These third parties may have access to information needed to perform their function but cannot use that information for any other purpose;

• advertisers, which may collect aggregated statistics from us;
• payment processors who will collect your payment information if you choose to purchase a product from us;
• credit reporting agencies and other financial institutions including our bankers and service providers;
• our professional advisers, such as our accountants, auditors and lawyers, insurers and industry groups having a legitimate reason to receive such information;
• technology service providers, such as cloud-based software-as-a-service providers;
• other persons that we need to deal with in connection with engagement of team members (such as training or medical providers, insurers, next-of-kin, referees); and
• other companies and individuals as permitted under applicable laws.

When we disclose your personal information to third parties, we take reasonable steps to ensure that those recipients deal with your personal information, including sensitive personal information, as required or authorised by applicable law.

Other examples of when we may disclose your personal information include:

• if we are required or authorised by law; or
• where you provide us with your express consent in accordance with applicable privacy laws; or

in the event of potential or actual sale, purchase, merger, reorganisation, liquidation, or dissolution or other disposal of assets or interests of all or any of Blackmores or its affiliates or business units.

Your rights relating to personal information

What are your privacy rights?

Depending on where you are located, you may have certain rights in respect of your personal information that are granted to you by law. Upon request, we will engage with you to clarify your rights and determine the best steps to address your concerns in a reasonable timeframe.

Right	Explanation of Right
Access	Right to inquire about the personal information held, or request a copy such information. For example, this would include how your personal information may have been used and disclosed in the twelve months prior to your request.
Blocking	Right to suspend, withdraw or order the blocking of your personal information.
Cessation	Right to request the discontinuing of collection or processing of your personal information.
Correction / Rectification	Right to request correction of personal information we hold about you if it is incorrect or incomplete.
Data portability	Right to have personal information arranged in a commonly readable format and transferred to another data controller.
Deletion	Right to have your personal information erased, destroyed, or anonymised.
Indemnification	Right to indemnification for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorised use of personal information.
Complaint	Right to lodge a complaint to the competent authority when you believe our processing of your personal information violates or does not comply with the relevant law.
Opt-out	Right to choose not to provide personal information.
Objection	Right to object the collection, use, or disclosure of personal information.
Restriction	Right to restrict the use of personal information.
Withdraw consent	Where you have given us your consent, the right to withdraw that consent at any time.

If you wish to exercise any of the rights granted to you by applicable privacy laws, please contact our Privacy Officer. If you withdraw your consent, we may not be able to continue to provide products or services or communicate with you. Such withdrawal will not affect any processing which took place prior to the withdrawal of consent or has been collected under another type of authority e.g. it is a legally required. Again, we note that not all the rights listed above may be available to you, depending on your location.

How can you access, update or correct your personal information?

The personal information we hold about you should be kept accurate, up-to-date and complete. We undertake reasonable steps to achieve this, and you can contact us if you wish to access, update and correct your personal information by contacting our Privacy Officer.

What happens when you contact us about your privacy rights?

We will respond to rights requests as soon as reasonably possible, noting that some may have a timeframe condition under applicable laws. We may also ask you for additional information to verify your identity or for security purposes. We do not impose any charges in connection with the exercise of these rights but, where permitted by law, we may charge you a reasonable fee for our costs associated with fulfilling the request, such as our administrative costs.

Where we are unable to grant your request (for example, if you have asked to access information that we no longer hold or if we are not required to comply with the request under applicable privacy laws), we will inform you of this outcome.

How are privacy complaints managed?

We will consult with you and establish a reasonable process, including time frames and the resolution you are seeking. You may also contact your local competent authority in your country of residence if you are unsatisfied with our handling of your complaint.

Contacting Blackmores Group about your personal information

If you have any questions, comments, concerns, or would like to exercise your rights under applicable privacy laws, please contact us using the relevant details below:

Privacy Officer Contact

All Blackmores, BioCeuticals and Blackmores Institute contacts can be made directly to our Group Privacy Officer: By Email: [email protected] By Post Privacy Officer Blackmores Group 20 Jubilee Avenue WARRIEWOOD NSW 2102 AUSTRALIA Phone: 1800 803 760 Privacy Officer Blackmores Group Level 4, 64 Kippax Street SURRY HILLS, NSW AUSTRALIA Alternatively, each of our brands have contact us pages on our websites that you can raise your privacy queries with, which will be referred to our Group Privacy Officer: Blackmores: https://www.blackmores.com.au/contact-us BioCeuticals: https://www.bioceuticals.com.au/contact-us Blackmores Institute: https://www.blackmoresinstitute.org/contact-us The Privacy Officer also fulfils the role of Data Protection Officer Additional International Contacts China PRC Representative Data Protection Officer at: Attn. PRC Data Protection Officer, 6F, Tower B, One ITC Plaza, No. 1901 Huashan Road, Xuhui District, Shanghai China, e-mail: [email protected], telephone: +86 21 6229 1788 Singapore Singapore Representative Data Protection Officer at: Email: [email protected] Telephone: 6225 3933 (Monday - Friday, 9am to 5pm)

Changes to this Privacy Policy

We may change this Policy from time to time and the most recent version will be published on our website. In cases of substantial change, impacted individuals or notification of changes may be communicated directly or prominently published. Where we are required to do so by applicable law, we will seek your consent to such changes.