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“Personal Information” means any information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained from the information or opinion. Your name, address, date of birth, gender, home address, email address, telephone number and employment details are examples of Personal Information. Personal Information may also include information we may collect about your individual preferences. We do not collect Sensitive Personal Information (subject to the sections below titled “Employment Applications”).
Collection Of Personal Information By Gradi Group
We will only collect Personal Information from you that we reasonably require for one or more of our business functions or activities, and will do so in accordance with the Australian Privacy Principles.
The kinds of Personal Information we may collect from you will depend on what type of interaction you have with us. However, it may include, among other things:
• Personal Information you provide us when you participate in a promotion, competition, promotional activity, survey, market research or customer behavioural activity, subscribe to our mailing list or interact or follow our social media pages including Facebook, and Instagram. This information may include, for example, your name, postal address, email address, telephone number, date of birth, age and occupation;
• Personal Information you provide us via our stores or head office or when you place an order in store, by telephone or via our website. This information may include, for example, your name, postal address, email address, telephone number, date of birth, age, menu preferences and previous order information, IP address and credit card details;
• If you are applying for a position with Gradi Group, we will collect information as outlined in the section below titled “Employment Applications”;
• As you navigate through our website and access our mobile applications, certain information can be passively collected (i.e. gathered without you actively providing the information) using various technologies such as cookies, internet tags or web beacons, and navigational data collection (log files, server logs and clickstream data). For example, we may collect information about matters including but not limited to the date, time and duration of visits and which pages of our website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a website or mobile application is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing our website or mobile application; and
• We may combine your anonymous or personal visitor session information or other information collected through tracking technologies with other Personal Information collected from you from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a website or mobile application via links in an email we have sent and/or by accessing a website or mobile application where you have identified yourself, you consent to the collection of such information where it is Personal Information.
In some circumstances, we may collect Personal Information from third parties such as credit reporting agencies or marketing agencies. Where we do, we will ensure that we act in accordance with relevant Australian laws.
With the exception of when you apply for a position with Gradi Group, we will not collect Sensitive Personal Information about you unless you have consented to such collection or the collection is required by law.
Generally, the type of Personal Information we collect about applicants is the information included in your application for employment, for example, your name, postal address, telephone number, email address, education details, employment history and other information relating to your work experience.
In considering your application, we may also obtain Personal Information about you from third parties, for example, from your previous employers or nominated referees. Subject to your consent, we may also collect Sensitive Personal Information about you such as information about your health (including any disability) or any criminal record you may have.
We collect Personal Information for any one or more of the following purposes:
• assessing you for a position with us;
• assessing whether you are suitable to progress to each stage of the recruitment process for a vacant position; and
• storing your information for future employment opportunities.
If you do not provide us with the information we request, we will be unable to do one or more of the above.
We may disclose your information to:
• referees or previous employers;
• recruitment agencies or agencies or contractors acting on our behalf;
• our related entities;
• law enforcement agencies to verify whether you have a criminal record; or
• educational organisations to the extent necessary to verify your qualifications.
If we engage third party contractors to perform services for us which involves handling Personal Information, we will take reasonable steps to prevent the contractor from using the Personal Information except for the purpose for which it was supplied.
How We Store Your Personal Information
Where we store your Personal Information depends on what interaction you have had with us. However, some areas may include:
• Databases for processing customer enquiries or feedback; or
• Email or SMS databases for marketing communications.
We take reasonable steps to protect your Personal Information from loss and unauthorised access. Unfortunately, no data transmission over the Internet is guaranteed to be completely secure. Accordingly, although we strive to protect such information, we do not warrant the security of any information you transmit to us or from our online services and you use these services at your own risk.
If a substantial data breach has or may have occurred (for example, your Personal Information was shared with unauthorised persons) we will notify you as soon as is practicable and the Office of the Australian Information Commissioner about that actual or possible breach.
We only keep your Personal Information for as long as it is required for the purpose for which it was collected or as otherwise required by law. We will take appropriate measures to destroy or permanently de-identity your Personal Information if we no longer need to retain it. These measures may vary depending on the type of information concerned, the way it was collected and how it was stored.
How Your Personal Information Will Be Used
We collect your Personal Information so that we can use it for our functions and activities and provide products and services to you, which include, among other things:
• processing orders you place with us in our stores or via our electronic or mobile ordering system, providing you with email or SMS confirmation of your orders, providing you with our products and processing refunds where applicable;
• administering and responding to your enquiry or feedback about our products;
• conducting, and allowing you to participate in, a promotion, competition, promotional activity, survey or market research;
• promoting and marketing current and future products and services to you, informing you of upcoming events and special promotions and offers and analysing our products and services so as to improve and develop new products and services;
• assisting you with remembering and re-ordering from our menu in future;
• facilitating our internal business operations, including fulfilment of any legal and regulatory requirements;
• improving the operation or navigation of our websites;
• processing and considering your employment application and conducting reference checks (refer to Employment Application section above)
We may also use your Personal Information for other purposes not listed above which will be made clear to you at the time we collect your Personal Information, or for such purposes as may be required or permitted by law.
If Gradi Group uses or discloses your Personal Information for the purposes of direct marketing, you may request not to receive direct marketing communications from us or our related entities. We will stop sending direct marketing communications to you within a reasonable period after your request is made (usually within 5 business days from receiving your request).
Disclosure Of Personal Information To Third Parties
We may disclose Personal Information we collect from you:
• to our related entities, suppliers, consultants, contractors or agents for the purposes set out in the section above or for other purposes directly related to the purpose for which the Personal Information is collected;
• to relevant federal, state and territory authorities for the purpose of investigating a food safety or health issue;
• where the law requires or authorises us to do so (whether in Australia or overseas);
• to others that you have been informed of at the time any Personal Information is collected from you; and
• with your consent (express or implied) to others.
Access To Personal Information And Correction
We aim to ensure that any information we obtain from you is accurate. You can request access to your Personal Information or advise us of any required correction and information which you believe to be inaccurate by forwarding a request to firstname.lastname@example.org.
Furthermore, you can request that your Personal Information/data is deleted from our systems by emailing email@example.com.
The exceptions under the Australian Privacy Principles which affect your right to access your Personal Information we hold about you include the following:
• access would pose a serious threat to the life or health of any individual;
• access would have an unreasonable impact on the privacy of others;
• a frivolous or vexatious request;
• the information relates to a commercially sensitive decision making process;
• access would be unlawful or denying access is required or authorised by law;
• access would prejudice enforcement activities relating to criminal activities and other breaches of law, public revenue, a security function, or negotiations with the individual; and
• legal dispute resolution proceedings.
To ensure the integrity and security of your Personal Information, Gradi Group will only disclose such Personal Information if our internal procedures are satisfied. To make a request to access Personal Information we hold about you, please contact us in writing. We will require you to verify your identity and to specify what information you require. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.
Although we are committed to ensuring that at all times there is strict adherence to the Australian Privacy Principles, in the event that you are dissatisfied in any way with the collection, use, storage and/or disclosure of your Personal Information or believe that there has been a breach of the Australian Privacy Principles, we invite you to contact us as soon as possible. We have appointed an internal Privacy Complaints Manager (who is also our Privacy Officer) to whom your complaint or any queries may be directed by e-mail at INSERT EMAIL HERE
All complaints are to be made in writing to Gradi Group and Gradi Group is then allowed a reasonable time (within 30 days) to respond to complaints. We may ask you to participate in a dispute resolution scheme (such as mediation) in order to resolve your complaint.
If you are not satisfied with the manner in which we deal with your complaint, you may refer it to the Office of the Australian Information Commissioner (“OAIC“).
You can contact OAIC by:
• visiting www.oaic.gov.au;
• forwarding an email to firstname.lastname@example.org;
• telephoning 1300 363 992; or
• writing to OAIC at GPO Box 5218, Sydney NSW 2001