Privacy Policy

1.0 Purpose

Oji Fibre Solutions (including Oji Fibre Solutions (NZ) Limited, Oji Fibre Solutions (AUS) Pty Limited and Oji Foodservice Packaging Solutions (AUS) Pty Limited) (Oji) is committed to protecting your privacy and Personal Information when you deal with us and ensuring that it collects, stores and deals with your Personal Information appropriately and lawfully, including in accordance with the relevant privacy legislation.

The Privacy Act 1988 (Cth) (as amended) ('Australian Privacy Act') applies to the collection of personal information by Oji's Australian entities The New Zealand Privacy Act 1993 (as amended) ('New Zealand Privacy Act') applies to the collection of personal information by Ojis New Zealand entities.

2.0 Coverage

This policy applies to all Personal Information collected by Oji in relation to its customers, suppliers and other third parties ('external parties' or 'you'). In this policy, we outline:

what types of Personal Information we collect and hold;
the purposes for which we collect, hold, use and disclose Personal Information;
how we collect Personal Information;
how you may access your Personal Information that we hold and seek any correction to that information;
how you are entitled to complain about a breach of this policy or any relevant law;
how we disclose Personal Information; and
if we are likely to disclose Personal Information to overseas recipients and if so, to which countries.

3.0 Personal Information

Personal Information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable, or as defined in the relevant Privacy Act ('Personal Information').

3.1 Types of Personal Information we collect and hold

The types of Personal Information we may collect from our external parties and hold include (without limitation):

Name, address and contact details;
Date of birth;
Drivers Licence details;
Financial details including annual earnings, bank account details and trade reference details;
Details of the products and service provided; and
Credit history information.

3.2 Purpose of Collecting, Holding or Using Personal Information

Oji collects, holds, discloses and uses your Personal Information:

to provide you with products and services;
to administer our relationship with you including responding to queries;
for internal administrative purposes, such as but not limited to procedural assessment, risk management, staff training, accounting, billing, product and service reviews;
to determine the provision of credit in accordance with the terms of our Application For Commercial Credit;
to assess or exchange information relating to your creditworthiness, credit history or credit capacity in accordance with the terms of our Application For Commercial Credit;
to assist in the collection of overdue payments;
to comply with legislative requirements such as under the Personal Property and Securities Act 2009 (Cth);
to monitor activity on our websites;
to identify and inform you about other products or services that may be of interest to you; and
to provide you with information about products, services and offerings that may be of interest to you.

Section 3.5 of this policy sets out the other parties to which we may disclose personal information.

By submitting your Personal Information to Oji, you consent to us using your Personal Information in the above ways.

3.3 Collection of Personal Information

Oji collects Personal Information directly from an individual unless it is unreasonable or impracticable to do so (in accordance with the relevant Privacy Act). Oji may also collect such information from other sources, including:

Other related entities to Oji;
Credit providers and credit reporting bodies; and
Publicly available sources of information.

3.4 Access to and Correction of Personal Information

In most cases, you can gain access to Personal Information about you held by Oji. The Australian Privacy Principles under the Australian Privacy Act and the New Zealand Privacy Act set out some circumstances in which we are not required to provide you with such access. For example, we are not required to give access where we reasonably believe that giving access to the Personal Information would pose a serious threat to the life, health or safety of any individual or the public.

To make a request to access your Personal Information held by Oji, contact the Privacy Officer in any of the ways set out in section 8.0 of this policy. Oji may charge a fee (which will not be excessive) to cover the cost of retrieving and copying requested information.

Oji takes reasonable steps to ensure that the Personal Information we collect, use or disclose is accurate, complete and up to date, relevant, and not misleading. If your Personal Information is incorrect or changes, please contact the Privacy Officer in any of the ways set out in section 8.0 of this policy so that Oji can update your Personal Information.

3.5 Use and Disclosure

Oji understands the importance of keeping Personal Information private, and will only disclose such information to others in limited circumstances. Other parties to which Oji may disclose Personal Information include:

credit providers and credit reporting bodies in accordance with the terms of our Application For Commercial Credit;
Ojis professional advisers;
government and regulatory authorities; and
our related entities

in connection with (or for reasons directly related to) any of the purposes set out at section 3.4 of this policy.

Oji also discloses Personal Information to contractors (such as IT service providers) who provide services to us or who manage services provided to an individual on Ojis behalf. Personal Information is only disclosed to contractors to the extent necessary to enable them to provide these services.

In Australia, Ojis Australian entities may also be permitted or obligated to disclose Personal Information to other third parties where:

Oji reasonably believes that the disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety and it is unreasonable or impracticable to obtain your consent to the disclosure;
there is reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to Ojis functions or activities has been, is being or may be engaged in, and Oji reasonably believes that the disclosure is necessary for us to take appropriate action in relation to this matter;
Oji is required or authorised to do so by law;
Oji is required to do so by an enforcement body; or
as otherwise permitted by the Australian Privacy Act.

In New Zealand, Ojis New Zealand entities may also be required to disclose Personal Information to other third parties where Oji reasonably believes that disclosure is necessary:

to prevent or lessen a serious and imminent threat to public health or safety, or the life or health of the individual concerned or another individual
to avoid prejudice to the maintenance of the law by any public sector agency;
for the purposes of law enforcement;
for the protection of the public revenue;
for the conduct of proceedings before any court or tribunal (being proceedings that have been commenced or are reasonably in contemplation); or
as otherwise permitted by the New Zealand Privacy Act.

3.6 Disclosure to overseas recipients

Oji is unlikely to disclose your Personal Information to overseas recipients except to our related companies in Australia, New Zealand, or Japan. Oji will not disclose your Personal Information outside of the country the information was collected from (except to our Australian, New Zealand or Japanese related companies) unless we first obtain your consent.

3.7 Retention and destruction of Personal Information

Oji maintains procedures and standards and takes reasonable steps to prevent unauthorised access to, use, modification, or disclosure of, Personal Information. Oji takes reasonable steps to protect an individual's information from misuse, interference or loss including the use of firewalls, anti-virus software and on-going internal monitoring. Once an individual's information is no longer needed by Oji, reasonable steps are taken to destroy or de-identify it (except where archiving is required for the purposes for which the information was collected).

4.0 Sensitive Information

Some information is classed as Sensitive Information. This includes information or an opinion about a person's racial or ethnic origin, political opinions, philosophical or religious beliefs or affiliations, membership of a political, trade or professional association or trade union, sexual preferences or practices, criminal record, health or genetic information, biometric information that is used for the purpose of biometric verification or identification, or biometric templates.

Oji will only collect, hold or disclose Sensitive Information if:

the individual has consented; or
the collection is required or authorised by or under law (including the relevant Privacy Act) or a court/tribunal order.

5.0 Complaints

If you have a complaint in relation to the collection and handling of your Personal Information, please contact Oji Privacy Officer via any method set out in section 8.0 of this policy. All complaints will be dealt confidentially and investigated internally In Australia, a response will be provided within 30 days unless otherwise specified (in accordance with the Australian Privacy Act).

6.0 Updates to this Policy

This policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The latest version of this policy will be the version posted to our website. We reserve the right to amend this policy from time to time.

7.0 Credit Reporting Policy

Our Commercial Credit Reporting Policy sets out the details on how we manage your credit information and credit reporting information and can be viewed on here.

8.0 Contact Us

If you have any queries about this Policy, or wish to request access to (or correction of) your personal information, please contact Oji's Privacy Officer at:

Private Bag 92004
Victoria Street West
Auckland 1142
Ph: +64 (9) 633 0600
Fax: +64 (9) 633 0601
Email: [email protected]