SOULFRESH GLOBAL PTY LIMITED ACN 631 326 595 Unit 4, 28-50 Cyanamid Street, Laverton North, Victoria 3026 (‘Soulfresh’, ‘we’, ‘us’ and ‘our’) understands the importance of protecting the privacy of an individual’s personal information. This policy sets out how Soulfresh aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Soulfresh and the way Soulfresh collects, holds, uses, discloses and handles your personal information.
For the purposes of this policy, when we say ‘you’ or ‘our’ we mean any individuals about whom we process personal information from time to time including our customers, any persons creating an account on our platforms, users of our website, and all other persons who may provide personal information to us from time to time.
In handling your personal information, Soulfresh will comply with the Privacy Act 1988 (Cth) (Privacy Act) and with the 13 Australian Privacy Principles in the Privacy Act. This policy may be updated from time to time. You may obtain a copy of our current policy from our website or by contacting us at the details at section 10 ‘How to contact us’.
You are under no obligation to provide your personal information to Soulfresh. However, without certain information from you, Soulfresh may not be able to provide its services to you. You consent to Soulfresh collecting, holding, using, disclosing and otherwise handling your personal information in accordance with this policy.
2 What kinds of personal information does Soulfresh collect?
Personal information is information or an opinion about an identified, or reasonably identifiable, individual. Information or an opinion may be personal information regardless of whether it is true. During the provision of our services and products, Soulfresh may collect your personal information.
Generally, the kinds of personal information Soulfresh collects are your name, address, telephone number and email address. In some circumstances Soulfresh may also hold other personal information provided by you. This may include device information, location information, log on information (whether you access our website, any of our social media platforms or other online forums or links) and other similar information using our application data caches, cookies (as noted below) and/or other browser web storage devices.
If at any time you provide the personal information of another person to us, then you must ensure that that person has read and understood this policy and separately consents to that personal information being collected, held, used, disclosed and otherwise handled by us as described in this policy.
3 How does Soulfresh collect personal information?
3.1 Interactions with you
Generally, Soulfresh collects your personal information directly from you, through completion of a form, telephone enquiries or online applications and communications.
There may be other occasions when Soulfresh collects your personal information from other sources such as from an information services provider or a publicly maintained record.
Generally, Soulfresh will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect the personal information from you.
Soulfresh uses data collection devices such as ‘cookies’ to monitor usage of its online resources. Cookies are small files placed on your computer’s hard drive when you access Soulfresh’s online resources. Cookies provide Soulfresh with information about your computer’s IP address, the date and time of your visit, and the resources or information you have accessed. This information assists Soulfresh in monitoring and improving how its online resources are being used. In particular, Soulfresh can use information obtained through cookies to tailor information to you and make your visits easier, more productive and more efficient.
3.3 Social Media
Soulfresh often uses social media platforms and other interactive online forums through which to communicate and provide its services. Information you disclose to Soulfresh through such forums may be read, collected and used by Soulfresh. However, it may also be read, collected and used by other users, the actions of whom Soulfresh cannot control and for whom Soulfresh takes no responsibility. You may also access third party websites, forums or links through our website or online resources, which will be subject to their own privacy policies and usage terms. Please refer to the privacy policies and usage terms of any third party websites or entities for information on their privacy standards and procedures. We are not responsible for the privacy practices or the content of other websites to which any of our online platforms or forums may link or which link to our online platforms or forums.
4 Why does Soulfresh need your personal information?
Soulfresh collects, holds, uses, discloses and handles your personal information where it is reasonably necessary for the purposes of carrying out its business and operations This includes:
- undertaking surveys in relation to the food and beverage industry, your experience with Soulfresh and/or products, services and issues related to the food and beverage industry;
- providing educational and awareness information about our food and beverage categories ;
- distributing, or facilitating the distribution of, industry-relevant publications;
- accounting, credit control, billing and other internal administrative purposes;
- browser and other online information in order to optimise your use of our online platforms or forums and to maintain a record of your activity on our online platforms or forums (including as permitted under paragraph 3.2 (Cookies) above);
- identifying and informing you of resources (including health resources), products, services and/or issues that may be of interest or relevance to you;
- improving promotional and online services; and
- any other legal requirements.
Where personal information is used and disclosed, Soulfresh first takes steps reasonable in the circumstances to ensure the personal information is relevant to the purposes for which it is to be used or disclosed.
5 Who does Soulfresh disclose your personal information to?
Soulfresh discloses your personal information for the purpose for which it is collected.
That is, generally, Soulfresh will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to third parties engaged to perform administrative, promotional, research, information technology or other services. We may also disclose your personal information to affiliated entities for the purposes set out in this policy.
This disclosure is always on a confidential basis and subject to agreements prohibiting misuse of the personal information in line with the protections set out in this policy.
Soulfresh may also disclose your personal information with your consent, or when your consent may reasonably be inferred from the circumstances, or if disclosure is required or authorised by law.
6 Overseas disclosure
Soulfresh may disclose personal information to overseas recipients for administrative or other business management purposes.
Before disclosing any personal information to an overseas recipient, Soulfresh takes steps reasonable in the circumstances to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme unless you consent to the overseas disclosure or it is otherwise required or permitted by law.
7 Direct marketing
Soulfresh may use and disclose your personal information in order to inform you of products and services that may be of interest to you. This may include providing you with information related to the food and beverage industry or other industries. In the event you do not wish to receive such communications, you can opt-out by contacting Soulfresh via the contact details set out in paragraph 10 or through any opt-out mechanism contained in a communication.
8 Security of your personal information
Soulfresh takes all steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. Soulfresh holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.
However, as the transmission of information across the internet is not completely secure we cannot guarantee the security of your personal information transmitted to our website, through social media interactions or other online forums. Any such transmission is at your own risk.
Soulfresh will destroy or de-identify personal information in circumstances where it is no longer required for the purposes for which it was collected or for any secondary purpose permitted under the Australian Privacy Principles and the Privacy Act, unless Soulfresh is otherwise required or authorised by law to retain the information.
9 Can you access and correct the personal information that Soulfresh holds about you?
Soulfresh takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and/or seek correction of your personal information that is collected and held by Soulfresh.
If at any time you would like to access or correct the personal information that Soulfresh holds about you, or you would like more information on Soulfresh’s approach to privacy, please contact Soulfresh via the contact details set out in paragraph 10 below. Soulfresh will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
- you will have to provide proof of identity. This is necessary to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
- Soulfresh requests that you be reasonably specific about the information you require; and
- Soulfresh may charge you a reasonable administration fee, which reflects the cost to Soulfresh, for providing access in accordance with your request.
If Soulfresh refuses your request to access or correct your personal information, Soulfresh will provide you with written reasons for the refusal and details of complaint mechanisms. Soulfresh will also take steps reasonable in the circumstance to endeavour to provide you with access in a manner that meets your needs and the needs of Soulfresh.
Soulfresh will endeavour to respond to your request to access or correct your personal information within 30 days from your request.
10 How to contact us
For further information or enquiries regarding your personal information held by Soulfresh, or if you would like to opt-out of receiving from Soulfresh any promotional communications, please contact Soulfresh’s Privacy Compliance Officer at firstname.lastname@example.org or calling +61 3 9416 7165.
11 Privacy complaints
Please direct all privacy complaints to Soulfresh’s Privacy Compliance Officer. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and Soulfresh.
Soulfresh’s Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation.
In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner.