1 Our commitment
Foodco Group Pty Ltd 007 145 057, its Related Bodies Corporate (including Muffin Break Pty Ltd, ACN 007 192 529, Jamaica Blue Pty Ltd, ACN 059 236 387, and Foodco New Zealand Ltd, CN 583535 (“we”, “our” and “us”) recognise that your privacy is very important to you.
We are committed to protecting the privacy of your Personal Information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (“Privacy Act”).
‘Personal Information’ has the meaning set out in the Privacy Act. Essentially, Personal Information is information or an opinion about an individual who is reasonably identifiable (including names, addresses, birth dates, or email addresses). We do not collect Sensitive Personal Information (including any information about your race, ethnic origin, political affiliation, religion or health).
‘Related Body Corporate’ has the same meaning as ‘Related Body Corporate’ under Section 50 of the Australian Corporations Act.
3 What types of Personal Information do we collect?
The types of Personal Information we collect from you depends on the circumstances in which the information is collected.
For example, we may collect:
- contact details (including your name, address, email address or phone number), your date of birth or age, as well as information about your interests;
- preferences and purchase history relating to our product & promotional activity;
- demographic information and service related information which you provide to us when you respond to customer surveys;
- Information about the computers, phones, or other devices that you may use to connect to our products;
- Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals; and
- Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.
- Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers.
4 How do we collect your Personal Information
We may collect Personal Information from you in a number of ways. The most common ways we collect your Personal Information are:
- directly from you when you provide it to us or our agents or contractors (for example when you enter a competition, participate in a promotional activity or complete a survey or customer comment card);
- when you participate in any loyalty scheme which is made available to our customers (including any loyalty scheme which is designed to run on a mobile device, and is made available to customers by means of a mobile application);
- via our website or when you deal with us online (including through our social media pages);
- from publicly available sources;
- from our Related Bodies Corporate;
- from third parties (for example, from referees if you apply for a position as an employee or contractor with us); and
- via devices that you may use to connect to our products.
If we are able to collect your information in a de-identified manner or anonymously for a particular purpose we will do so.
5 Why we collect and how we use Personal Information
The purposes for which we use and disclose your Personal Information will depend on the circumstances we collect it. Whenever practical, we endeavour to inform you why we are collecting your Personal Information, how we intend to use that information, and to whom we intend to disclose it at the time we collect your Personal Information.
We may use or disclose your Personal Information:
- for the purposes for which we collected it (and related purposes which would be reasonably expected by you);
- for other purposes to which you have consented; and
- as otherwise permitted or required by law.
In general we collect, use and disclose your Personal Information so that we can do business together and for purposes connected with our business operations.
Some specific purposes for which we commonly collect, use and disclose Personal Information are:
- to conduct transactions with you;
- to respond to you if you have requested information (including via our websites or via an email or other correspondence you send to us);
- for market research purposes to help us improve products and services;
- to assess your application as a potential franchisee of our Related Body Corporates or potential employee (as applicable);
- to administer surveys, competitions or other promotional activities or events conducted, sponsored or managed by us or our business partners;
- to provide you with direct marketing materials if you are a customer who is a member of our loyalty scheme or a person who has entered into a competition;
- to administer the participation of any customer who is a member of our loyalty scheme or who has entered into a competition;
- to provide you with goods or services through one of our franchises;
- to address any issues or complaints that we or you have regarding our relationship; and
- to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.
6 Direct marketing
Direct marketing involves communicating directly with you for the purpose of promoting our services or the goods or services of our Related Bodies Corporate. We may also communicate with you for the purpose of providing you with special offers. Direct marketing may be delivered by a range of methods including mail, telephone, email, SMS, social media, online advertising and through app notifications.
We may use and disclose your Personal Information for the purpose of direct marketing to you where:
- you have consented to us doing so; or
- it is otherwise permitted by law.
7 What happens if you don’t provide Personal Information?
Generally, you have no obligation to provide to us any Personal Information requested by us. However, if you choose to withhold requested Personal Information, we may not be able to do provide you with the services requested or allow you to participate in the activities that depend on the collection of that information.
8 Sharing your Personal Information with third parties
We never sell, rent or trade your Personal Information.
This may include disclosing your Personal Information to the following types of third parties (depending on the purposes for which we have collected your Personal Information):
- our Related Bodies Corporate;
- our contractors and other third parties that provide goods and services to us including:
- website and data hosting providers;
- companies that evaluate service quality and customer satisfaction;
- analytics, marketing and profiling service providers; and
- direct mailing service providers;
- payment system operators;
- Related Bodies Corporate franchisees that need the information to provide you with a product or service which you would reasonably expect to receive from them;
- our accountants, insurers, lawyers, auditors and other professional advisors and agents;
- if you are an individual contractor to us or a prospective employee, to HR related service providers (e.g. for outsourced payroll processing, background checks);
- any third parties to whom you have directed or permitted us to disclose your Personal Information (e.g. referees);
- if we or any of our Related Bodies Corporate or their assets may be acquired or considered for acquisition by a third party, that third party and its advisors; and
- otherwise as permitted or required by law.
9 Does your Personal Information leave Australia?
We may disclose Personal Information outside of Australia to our Related Bodies Corporate, service providers and other third parties including those located in New Zealand and the United Kingdom.
Except in some cases where we may rely on an exception under the Privacy Act, we will take reasonable steps to ensure that such overseas recipients do not breach the Australian Privacy Principles.
10 Security of your Personal Information
We may store Personal Information on computer databases and/or in hard copy. We may also engage third party service providers to assist in storing and processing certain types of Personal Information for us. Some of these service providers may be located outside of Australia, or use facilities located outside of Australia to provide us with services.
We destroy or permanently de-identify Personal Information if it is no longer needed for the purposes for which it may be used or disclosed by us unless it is otherwise required by law to be retained.
We are committed to keeping your Personal Information secure and will use all reasonable precautions to protect it from loss, misuse or unauthorised access or alteration. However, except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
Please notify us immediately if you become aware of any breach of security.
11 Accuracy of the Personal Information we hold
We take reasonable steps to maintain the accuracy your Personal Information.
12 Access & Corrections
Upon receipt of your request, we will reply, using the same method in which you contacted us or as you otherwise specify, usually within five (5) business days or as soon as we reasonably can in the circumstances. We may require that the person requesting access provide suitable identification and where permitted by law we may charge a fee for granting access to your Personal Information.
13 Links, cookies and use of our websites and applications
When you click on links on our website, they may direct you away from our site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
14 Questions suggestions or complaints
You can obtain information on privacy issues in Australia by visiting the web site of the Office of the Australian Information Commissioner at www.oaic.gov.au or by telephoning 1300 363 992.
15 Our Contact Address
Foodco Group Pty Ltd at Building Building 208-1M, The Entertainment Quarter 122 Lang Road, Moore Park, NSW 2021 or email: firstname.lastname@example.org.
Version date: 9 November 2017