3.1. Fonterra will process your personal data based on:
- The performance of a contract you have with us, or to enter into a contract and to act on your requests. For example, when you order a product, provide us with contact details for a contract, or when we are fulfilling our delivery and payment obligations.
- Fonterra’s legitimate business interests, for example, fraud prevention, maintaining the security of our data and systems, marketing, and the improvement of our services. Whenever we rely on this lawful basis to process your data, we assess our business interests to make sure they do not override your rights. Additionally, in some cases you have the right to object to this processing. For more information, visit the ‘How can you exercise your privacy rights?’ section of this policy.
- Compliance with mandatory legal obligations, including for example accounting and tax requirements, which are subject to strict Fonterra Group Policies and Group Standards (such as retention periods).
- Consent you provide where Fonterra does not rely on another legal basis. Consent may be withdrawn at any time. When you give your consent, you will be given details on how to change your mind. For more information, visit the ‘How can you exercise your privacy rights?’ section of this policy.
3.2. We collect your personal data, for example:
3.2.1. When you do business with us:
(a) For the assessment and acceptance of a customer, supplier or business partner;
When you get in contact with us, either via our website, telephone, offline or otherwise, we may process your personal data for assessment and acceptance purposes, for example to confirm and verify your identity. We may further process your personal data for other administrative purposes such as due diligence and screening against publicly available government and/or law enforcement agency sanctions lists.
(b) For the conclusion, execution and performance of agreements:
When you have purchased a product or service from us as a customer or consumer, either online through an online shop, via telephone or offline, or when you work together with us as a vendor, supplier or business partner, we may process your personal data for administrative purposes such as sending invoices and making payments. We also use your personal data to deliver or receive and administer our or your products or services. We process your personal data to further execute our agreement, including for the delivery of customer services.
(c) For relationship management and marketing
We may use the information stored in our customer database to send you suitable offers and newsletters, to invite you to take part in competitions, as well as to provide customer services, perform account management and communicate recalls. We may also use your personal data for the development, execution and analysis of market surveys and marketing strategies.
(d) For business process execution and internal management
We process your personal data in the performance and organisation of our business. This includes general management, order management and management of our assets. We have central processing facilities which conduct audits and investigations, implement business controls, and manage and use consumer, customer, vendor and business partner directories. Also, we process your personal data for finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution.
(e) For organisational analysis and development, management reporting and acquisition and divestitures
At Fonterra, we process your personal data in the preparation and performance of management reporting and analysis. We use aggregated and anonymised personal data to create management reports and to analyse our business and report on certain metrics, either to comply with reporting regulations or to improve our processes and services. We may conduct customer, supplier and business partner surveys to learn more about your views and opinions in preparation of our management reporting. We may process your personal data for management reporting purposes in the context of mergers, acquisitions and divestitures and to manage such transactions.
(f) To monitor and investigate compliance and fraud within Fonterra
We monitor our IT systems to check for compliance with regulations and laws, fraud, and compliance with Fonterra policies. During compliance and monitoring activities, personal data we hold about you may be accessed and viewed for this purpose. The personal data that are accessed and viewed for this purpose will not be stored following such checking unless we need them to further investigate potential non-compliant behaviour.
3.2.2. When you use our Websites or Apps:
(g) To deliver you our websites’ or apps' functionalities and for their technical and functional management
If you open a user account with us, to administer the account and to ensure confidentiality and security of your transactions
(h) When you choose to register with one of Fonterra’s websites, apps or online portals, you need to provide personal data so that we can create a personal account for you. Upon creating your account, we will send you your personal login information. These personal data enable us to administer your account and enable us to ensure confidentiality and to maintain the security of your transactions or use of the account. We are, for instance, able to change your password for you. We are, however, not able to view your password.
(i) To allow you to connect with us (e.g. via social media)
We are active on social media platforms like Facebook, Twitter, and Instagram. When you contact us via social media, we process your personal data to answer your questions, to respond to your messages, and to provide customer services support.
In addition, when you visit a 'Connect with us' screen on one of our websites or apps, you can contact us through a variety of communication channels. We provide you with our email address, for you to send us your feedback and suggested improvements, as well as our website, Twitter, Facebook, Instagram details. When you click one of the corresponding icons we will refer you to the website or app of the applicable external party, whether this is your email provider or a social media platform.
3.2.3. When you interact with Fonterra (online or offline):
If you get in touch with us via our customer services centres, corporate email addresses, phone numbers, physical address or via a contact form on a Fonterra website, we will use your personal data to reply to and answer your question or to provide other customer services or commercial support. For this purpose, we process your name, contact details, your correspondence with us your question and all other personal data which are necessary to respond to your communication.
(j) For the development and improvement of products and/or services
We process your personal data to assess, analyse and improve our products and services for our customers and consumers. We use aggregated personal data to analyse consumer and customer behaviour and to adjust our products and services accordingly. When you use a website, app, or online portal, enter or search data through this website or app, we also process your personal data to compile analytics reports. We use aggregated personal data to analyse customer behaviour and to adjust our products and services accordingly, to ensure that it is relevant to our customers. This means that we may analyse how often you read our newsletters, how often you visit our website, apps or portals, which pages you click on and what transactions you make. We may purchase supplementary data from public sources to complement our database for the above purposes.
(k) To protect health, safety, security and to ensure integrity
At Fonterra, we value your health, safety, security and integrity highly. We process your personal data to safeguard our employees, customers, suppliers and business partners. As such, we authenticate your access rights to our premises. We also process your personal data to protect Fonterra and employee and customer assets.
(l) To comply with the law
In some cases, we process your personal data to comply with laws and regulations. This could, for example, be the case where tax or business conduct related obligations apply. To comply with relevant laws and regulations, we may need to disclose your personal data to government institutions or supervisory authorities.
3.3. The types of information we may collect and process are, where applicable:
- Your contact details such as your address, phone number and email address, and contact preferences, personal details such as your title, name, and date of birth, payment and credit information, tax and GST or VAT details.
- Your correspondence with us, such as a note or recording of a call you make to a customer service centre, or with any of our employees, a live chat log, an email or letter sent, or other records of any contact or correspondence with us.
- Where you have a personal account with us, your account information such as order history, payment history, account numbers, login data, correspondence with us, account management information or other information that you have added to your account.
- Credential information – we’ll collect passwords, hints and similar security information used for authentication and access to any accounts and services.
- Your preferences for particular products, services and activities when you tell us what they are (for example by completing a survey), or we assume what they are, based on how you use any of our products and services.
- Data generated during the performance of the agreement(s) between you and Fonterra, and other data stored in our customer, supplier and business partner databases.
- We process the personal data you have entered into our websites, apps or online portals or that is generated by the functionalities you have used in these forums and the technical data from your device such as its IP address, the internet browser you use, the pages you have visited on our websites, portals or apps, your click and surf behaviour and the length of your session. We process the communication channel you may have chosen to use to connect with us (such as Facebook or Twitter) and the personal data you supply to us.
- See the 'Cookies' section for details on what we collect using cookies and visit www.fonterra.com/cookiesstatement for our full Cookies Statement.
- Your location data. This may be precise such as where you enable location-based services or features on our websites, apps or online portals, or less precise where, for example, a location is derived from your IP address or data such as an address.
- If you physically visit our premises, we may also collect information about you on CCTV as part of our security and crime prevention measures, we may also collect your name and contact details for security and health and safety purposes, and your visiting history to our premises, and to provide to facilities such as wifi.
- Information we obtain from other sources, such as credit agencies, fraud-prevention agencies, and from other data providers that may relate to your interactions with us.