Privacy Policy

1. Asahi Holdings (Australia) Pty Ltd (ABN 48 135 315 767) and its subsidiaries (‘Asahi, ‘we’, ‘us’ and ‘our’) form one of the leading beverage company groups in Australia and New Zealand. We are committed to protecting your privacy and the confidentiality of the personal information that we collect from you in the course of running our business.
2. When you interact with us, our website or our services, we may collect, use and share information, including your personal information. Personal information is defined in the Privacy Act 1988 (Cth) and the Privacy Act 2020 (NZ) (‘Privacy Acts’). It includes information that could identify you, for example- your name, personal details or information about your use of our websites and apps.
3. Personal information is defined in the Privacy Act 1988 (Cth) and the Privacy Act 2020 (NZ) (‘Privacy Acts’). It includes information that could identify you, for example- your name, personal details or information about your use of our websites and apps.
4. This privacy policy covers all of our products and services and applies to all people who deal with us. This includes commercial customers (who we sell our products to), individual consumers of our products, individuals who participate in a game, promotion, survey or other feature conducted or operated by us, and individuals that use our websites. This also includes our suppliers and entities that enter into sponsorship or other agreements with us.
5. This policy sets out:
   1. how we handle personal information that we collect about you,
   2. the main reasons we may collect your personal information,
   3. the ways we protect your privacy and how you can access your personal information, and
   4. how we comply with our key obligations under the Australian Privacy Principles and the New Zealand Information Privacy Principles.
6. We may change this policy to reflect changes in our products and services or changes in laws. We will display a notice on our website explaining the changes we have made.
7. This policy is part of our Terms of Use. You can read our Terms of Use at https://asahi.com.au/terms-of-use.
8. In addition to this policy, when collecting personal information from Australian individuals we may also issue ‘collection notices’. Collection notices provide individuals with further information on how we intend to collect, use, disclose and retain personal information they provide.
9. Protecting children's privacy is important to us. We operate our websites and market our products and services in compliance with all applicable Australian and/or New Zealand laws. Our websites, applications and promotions are not targeted at individuals 18 years of age or younger and we do not intentionally collect or store information about any person younger than 18. All visitors to our alcohol branded websites must confirm they are at least 18 before they will be granted access.

2.1. What information do we collect?

1. We collect a range of personal information to carry out our functions and activities. We have used examples in this section to describe the information we collect and the reason we collect it, but these examples do not include all personal information that we collect.

Commercial customers: We may collect the following types of information when dealing with you as a representative of a commercial customer:

• Personal and contact details (including email address and phone number)
• Financial information (such as credit card or bank account numbers)
• Information about how you use our products and services
• Your interactions with us, including cookies
• Any visual recordings we make, such as CCTV recordings when you're at an Asahi site, or recording training or meetings that occur online

Consumers: We may collect the following types of personal information when you use our products or services, including interacting with our website, apps and social media:

• Personal and contact details (including email address, address and phone number)
• Your interactions with our websites, apps and social media profiles (this may include your social media handles, IP address, location data from your device and cookies)
• personal information provided in connection with the game, promotion, survey or other feature you are participating in

Job applicants: We may collect the following types of personal information when you apply for a job with us:

• Personal and contact details (including email address, address and phone number)
• Your employment history
• Your tax file number, if you are appointed to a job with us

1. In Australia, personal information can also be ‘sensitive information’. This includes information or an opinion about an individual’s racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, trade union membership or associations, sexual orientation or practices, criminal record, health or genetic information, some aspects of biometric information. Sensitive information has a higher level of privacy protection than other personal information.
2. We will get your consent to collect sensitive information unless we are required by law to collect it without obtaining your consent.
3. We may use CCTV at our premises that capture images of people and activity or other surveillance devices of a similar nature to help ensure workplace health and safety as well as the security of our staff, visitors and property. Footage that sufficiently identifies individuals is considered personal information and is subject to the Privacy Acts. Any footage that we collect will be used solely for these purposes or as required by applicable law. We will keep this information secure and it will be destroyed or de-identified in no more than 365 days unless we are legally required to retain it for longer.

2.2. Our use of cookies

1. We collect data about your website usage through the use of cookies and other technologies. Cookies are information that the site sends to your browser, which are stored as small files on your hard drive. The use of cookies allows the site to record what specific pages you have visited. Websites can provide services and tailored information by using cookies together with the information provided by you.
2. We may use cookies:
   1. to enhance your experience on our websites,
   2. to customise our websites, products and services to you,
   3. to help us manage advertising and displays ads likely to be of interest to you, and
   4. to statistically analyse, compile and publish information. No personal information will be included in the end result of this process.
3. You can adjust your browser settings to block the use of cookies or to warn that a cookie has been accepted. Most of the services provided on our websites can be accessed even if the browser blocks cookies. There may be some services that only offer limited access, or no access, if cookies are disabled.
4. We use also use cookies developed by our third party service providers for a number of purposes.
5. Our apps and websites may also include links to third-party apps and websites. We take reasonable care when we select the websites that we link to but we aren’t responsible for the content, accuracy or privacy practices of those websites.

2.3. When we collect personal information from third parties

1. Most of the personal information that we collect is provided by you directly when you engage with us or when we request it from you. Sometimes we also collect personal information from third parties, such as information from our related companies, credit reporting agencies, marketing and PR agencies or your representatives. We may also collect personal information by other means such as through our websites, social media sites or other publicly available sources of information.
2. Sometimes we may also ask you to give us personal information about other people, such as your authorised representative. If you provide us with this personal information, we rely on you to tell those people that you are giving their personal information to us and to provide them with a copy of this policy.

2.4. What happens if you don’t want to provide your personal information?

1. You can choose not to provide us with your personal information. However, if you don’t we may not be able to provide you with our products and services.
2. You also have the option of dealing with us anonymously or with a pseudonym. However, this is usually only possible if you have general enquiries.

We use your personal information when you interact with us, including when you buy our products or services (as a commercial customer or as a consumer). We will also use your personal information to operate our business and to develop new products and services. When you interact with us, we may use your personal information to:

• verify your identify
• facilitate your registration as a website user
• enable you to participate in promotions and other activities
• provide you with products or services that you have requested (for instance, orders made through Asahi Drinks Cart in Australia or Drinks Trolley in New Zealand), and to provide you with any other benefits you may subsequently be entitled to in relation to these products and services
• identify how our products and services are being used, and develop and improve products and services
• provide you with news and information in relation to Asahi Beverages and our products and services
• tell you about other products or services that may be of interest to you
• promote and market to you products, services and special offers made available by us or our related companies, licensees and suppliers, or deliver marketing to you about products and services we think might be relevant to you
• maintain and develop our business systems and infrastructure, including testing and upgrading these systems
• assess your suitability for a job where you have applied for a role, and notify you about similar roles in the future
• comply with our legal obligations, including for the purpose of considering any concerns or complaints you raise with us, or in connection with legal proceedings or rights
• provide or facilitate related purposes to those set out above, where you would reasonably expect us to use or disclose information for that purpose

In addition, for commercial customers, we may use your personal information to:

• provide our products and services
• manage our business and keeping records
• manage and administer a product or service, including for ancillary activities such as charging, billing and collecting debts
• offer you the right products or services and we may ask for your view on how our products and services can be improved
• conduct checks for creditworthiness or fraud

As part of operating our business we may share your personal information with:

1. our related companies, which may involve your personal information being disclosed overseas (including but not limited to Japan)
2. our professional advisers (such as lawyers and accountants) and service providers (such as marketing and PR agencies)
3. our service providers and contractors (such as outsourcing contractors, marketing, telemarketing, market researchers, website usage analysts) but only to the extent it is necessary to the services they provide to us
4. credit providers and credit related service providers
5. third party service providers that manage some of our business functions, and
6. government and regulatory authorities and other organisations, or as otherwise required by or authorised under the Privacy Acts.
7. Some of the personal information that we collect may be transferred to, stored or processed by our third party service providers located outside Australia and New Zealand. This includes:
8. Third party service providers that help us perform business functions in the Philippines and other locations.
9. Systems and IT providers that may store personal information offshore, including but not limited to the UK and the Netherlands.
10. When we engage external service providers, we take steps to ensure that those external service providers comply with the Australian Privacy Principles and Information Privacy Principles (under the respective Privacy Acts) when they handle personal information about you and that they are authorised only to use personal information that we provide to them for the limited purposes specified in our agreement with them. Where we engage external information technology service providers, we ensure that wherever possible, our data is stored within Australia and New Zealand.
11. We have taken reasonable steps to ensure that your personal information will only be used or disclosed by those providers in a way that is consistent with Australian Privacy Principles and New Zealand Information Privacy Principles privacy laws. By providing your information to us, you agree to disclosure to our overseas service providers in accordance with this policy and you acknowledge that your personal information may not receive the same protections that it would have in Australia or New Zealand.

1. We take reasonable steps to ensure the security of your personal information and have put in place reasonable security measures to prevent loss, misuse, or unauthorised access and alterations to personal information under our control. We require employees and service providers to maintain the confidentiality of any personal information we hold.
2. Unfortunately, we cannot and do not guarantee that unauthorised access to your personal information will not occur. It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.
3. If we no longer require your personal information, we will take reasonable steps to destroy or alter that information so that it no longer identifies you. Any data destroyed is disposed of in an appropriate manner that protects the privacy of your information.
4. As part of our hiring process, job candidate personal information will be stored for a period of time after we receive your application, so we may notify you about similar future roles. We can de-identify or destroy personal information provided in connection with our hiring process, on request. If you are hired for a position at Asahi, we will retain the information provided during the application and recruitment process as part of your employee record.

1. Under the Privacy Acts, you have the right to access and correct your personal information.
2. We take reasonable steps to ensure the personal information we hold, having regard to the purpose for which it is held, is accurate, complete, relevant, up to date and not misleading.
3. We may deliver direct marketing to you about our products and services, or other products and services we think might be relevant to you. You can opt out of the direct marketing communications we send you (including by email) by following the unsubscribe instructions in marketing email, or by emailing us at: consumerrelations@asahi.com.au.
4. If you want to access the personal information that we hold about you, please send us a request in writing to the Asahi Privacy Officer at: consumerrelations@asahi.com.au. We don’t usually charge a fee but if we do need to, we will let you know before we proceed. We also need to confirm your identity before we can correct your information.
5. If you ask us for access to your credit information, we won’t charge a fee unless you have already made a request in the previous 12 months. If you have made a request in the previous 12 months, we may request a reasonable charge for providing access.
6. We rely on the accuracy of personal information as provided to us both directly (from you) and indirectly. If you think that the personal information we hold about you is inaccurate, or out-of-date, or if you have other queries about accessing and correcting your personal information, please contact us.

7.1. Credit reporting

1. We may provide credit to individuals in connection with our products and services (for example, we may provide commercial credit to individuals, and conduct associated credit checks). This means that we may collect credit related information and credit eligibility information about you (referred to in this policy as ‘Credit Information’). This section of the policy sets out how we manage your Credit Information.

7.2. What Credit Information do we collect?

1. If you apply for credit or already have credit with us, we may collect the following types of Credit Information about you:
   1. identification information,
   2. basic information about your credit account and your credit history (including any missed or late repayments that you have made),
   3. details of any credit provided to you by other credit providers or details about information request we make about you to other credit reporting bodies,
   4. any credit rating or credit assessment score that we have derived or that is provided to us by a credit reporting body, and
   5. details of any credit-related court proceedings or insolvency applications that relate to you.

7.3. How do we collect Credit Information?

1. Please see paragraph 2 of this policy ‘How we collect personal information’.
2. In addition to the information listed at paragraph 2, we obtain Credit Information from credit reporting bodies.

7.4. How do we use Credit Information?

1. We may use your Credit Information in the following ways:
   1. processing credit-related applications and managing credit that we provide,
   2. determining a credit assessment score for you to help us decide whether or not to provide credit to you,
   3. collecting payments that are owed to us in respect of any credit that we have previously provided to you,
   4. assessing your suitability as guarantor or communicating with a third party who acts as your guarantor,
   5. participating in the credit reporting system and providing information to other credit reporting bodies,
   6. dealing with complaints or regulatory matters relating to credit or credit reporting,
   7. as required or authorised by another law, and
   8. where you otherwise expressly consent to the use of disclosure.
2. New Zealand only: In order to achieve some of these purposes set out in paragraph 7.2, we may disclose information to credit reporting agencies, which both collect and supply such information to us (at any time there is an amount outstanding). Where applicable information is shared with these credit reporting agencies, they are obliged to observe the confidential nature of such information and are prohibited from using any or all of this information other than for the purpose for which it was provided. Such credit reporting agencies are also required to comply with the Credit Reporting Privacy Code. If you ask us to, we will take reasonable steps to request correction of your personal information with a credit reporting agency.
3. In some cases, the people to whom we may disclose your Credit Information may be based outside of Australia or New Zealand – see paragraph 4 (‘How we share personal information’) for more information.

7.5 Access and correction to Credit Information

1. Please refer to paragraph 6 of this policy – ‘How you can access and correct your personal information’.

1. If you want to make a complaint about how we handle your personal information or your Credit Information, please contact the Asahi Privacy Officer via consumerrelations@asahi.com.au. We will deal with all requests for access to personal information or complaints as quickly as possible and will endeavour to get back to you within a reasonable time frame.
2. If you have not received a response in less than 30 days or are not satisfied with our response to your complaint, you may lodge a complaint as follows:
   1. in Australia with the Office of the Australian Information Commissioner (“OAIC”) via their website at http://www.oaic.gov.au/; or
   2. in New Zealand with the Office of the Privacy Commissioner via its website at http://www.privacy.org.nz/.