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CREMA FRANCHISING PTY LTD – PRIVACY POLICY
Crema Franchising Pty Ltd (ACN 658 860 729) (we, us or our) understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or collected by us, when interacting with you.
The information we collect
Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.
The types of personal information we may collect about you include:
• Identity Data including first name, middle name, last name, maiden name, title, date of birth, gender, job title, photographic identification, marital status, pronouns and images of you.
• Contact Data including your telephone number, address and email.
• Financial Data including bank account and payment card details (through our third-party payment processors, e.g. Stripe, PayPal, Shopify and Afterpay, who stores such information and we do not have access to that information).
• Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.
• Technical and Usage Data when you access any of our websites or platforms, details about your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries and/or browsing behaviour, access and use of our website (including through the use of Internet cookies or analytics), communications with our website and support requests you have made.
• Profile Data including your username and password for purchases or orders you have made with us, your interests, preferences, feedback and survey responses.
• Interaction Data including information you provide to us when you participate in any interactive features, including surveys, contests, promotions, activities or events.
• Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
• Professional Data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.
How we collect personal information
We collect personal information in a variety of ways, including:
• Directly: We collect personal information which you directly provide to us, including for example through the ‘contact us’ form on our website or a third-party website, when you sign up for or activate our Crema Rewards Membership, when you complete a form, such as registering for any events or newsletters, or responding to surveys, when you apply for a job with us, or when you request our assistance via email, or over the telephone or when you join a promotion, competition or otherwise.
• Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.
• From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.
• From publicly available sources: We collect personal data from publicly available resources such as the Australian Securities and Investment Commission (ASIC) and professional networking sites such as LinkedIn.
Why we collect, hold, use and disclose personal information
We have set out below, in a table format, a description of the purposes for which we plan to collect, hold, use and disclose your personal information.
| Purpose of use / disclosure | Type of Personal Information |
| To assess whether to take you on as a new client, including to perform anti-money laundering, anti-terrorism, sanction screening, fraud and other background checks on you. |
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| To dispatch and deliver our products to you, register your attendance at our events, assess your application, manage your appointments, or provide you with Crema Membership Rewards. |
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| To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us. |
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| To contact and communicate with you about any enquiries you make with us via our website. |
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| For internal record keeping, administrative, invoicing and billing purposes. |
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| For analytics including profiling on our website, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms. |
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| For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you. |
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| To run promotions, competitions and/or offer additional benefits to you. |
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| If you have applied for employment with us; to consider your employment application. |
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| To comply with our legal obligations or if otherwise required or authorised by law. |
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Our disclosures of personal information to third parties
Personal information: We may disclose personal information to:
• our employees, contractors and/or related entities;
• IT service providers, data storage, web-hosting and server providers;
• marketing or advertising providers;
• delivery or logistics providers who deliver our goods to you;
• professional advisors, bankers, auditors, our insurers and insurance brokers;
• payment systems operators or processors;
• our existing or potential agents or business partners;
• anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
• courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
• courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
• third parties to collect and process data, such as analytics providers and cookies; and
• any other third parties as required or permitted by law, such as where we receive a subpoena.
Overseas disclosure
While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.
Your rights and controlling your personal information
Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to do business with you.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.
Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.
Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
Cookies
We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Meta, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Links to other websites
Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.
Personal information from social network accounts
If you connect your account with us to a social network account, such as Facebook or Google, we will collect your personal information from the social network. We will do this in accordance with the privacy settings you have chosen on that social network.
The personal information that we may receive includes your name, ID, user name, handle, profile picture, gender, age, language, list of friends or follows and any other personal information you choose to share.
We use the personal information we receive from the social network to create a Crema Rewards Membership profile for you on our platform.
If you agree, we may also use your personal information to give you updates on the social network which might interest you. We will not post to your social network without your permission.
Where we have accessed your personal information through your Facebook account, you have the right to request the deletion of personal information that we have been provided by Facebook. To submit a request for the deletion of personal information we acquired from Facebook, please send us an email at the address at the end of this Privacy Policy and specify in your request which personal information you would like deleted. If we deny your request for the deletion of personal information, we will explain why.
Use of location services data
We collect your precise or approximate location via our mobile application for the following purposes:
• to enable you to pick up deliveries and to deliver them to our client’s customers;
• to generate routes and improve routes via the data collected;
• to allow the warehouse to monitor the vehicle location within their account dashboard;
• to allow our client to access order location in real time;
• for security and safety;
• to prevent and detect fraud; and
• as permitted by law.
We collect this information when our mobile application is open (whether on-screen or not). If you do not want us to use your location for the purposes above, you should turn off the location services in your mobile phone settings. If you do not provide geolocation data to us, it may affect our ability to do business with you.
Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact us at:
Crema Franchising Pty Ltd (ACN 658 860 729)
Email: andrew@cafefg.com.au
Last update: 10 July 2023
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