Zarraffa’s Privacy Policy
1.Introduction
This Policy sets out how Zarraffa’s Coffee collects, handles and uses information about you. We reserve the right to update this Policy at any time without notice.
2. Purpose
The purpose of this Policy is to set out:
(a) the types of information that Zarraffa’s Coffee may collect;
(b) how that information will be collected, used, handled, stored and disclosed (including international disclosures);
(c) the reasons for which Zarraffa’s Coffee collects, holds, uses and/or discloses the personal information;
(d) how you can access your personal information and request for that information to be corrected; and
(e) how you can make a complain.
3. Application
This policy applies to information that Zarraffa’s Coffee may collect about you.
This policy does not apply to information that may be collected by a third party or how that third party may use, handle, store or disclose your information.
4. Definitions
Area Developers means a developer of ZAD Pty Ltd.
Franchisees means a franchisee of Zarraffa’s Franchising Pty Ltd.
Organisation means a natural person, a body corporate, a partnership, any other unincorporated association, or a trust, that is not a small business operator, a registered political party, an agency, a State, Territory or national authority or a prescribed instrumentality of a State, Territory or Nation.
Personal Information means information or an opinion about an identified natural person, or a natural person who is reasonably identifiable.
Privacy Officer means the Privacy Officer of Zarraffa’s Coffee, as pointed from time to time or a position of a similar nature.
Zarraffa’s Coffee, we and us means Zarraffa’s Coffee Group Pty Ltd and its ‘related bodies corporate’ (as that term is defined and used in the Corporations Act 2001 (Cth)), including but not limited to Zarraffa’s Franchising Pty Ltd, Zarraffa’s Management Pty Ltd and Zarraffa’s Roastery Pty Ltd
5. Legislative Framework
In Australia – Privacy Act 1988 (Cth) which includes the Australian Privacy Principles set out therein
In New Zealand – Privacy Act 1993 (NZ)
In the United States of America – Privacy Act of 1974, 5 U.S.C, § 552a; California Business and Professions Code sections 22575-2257
as substituted, amended, replaced or varied from time to time.
6. Policy
6.1 How, what and why we collect your information
Zarraffa’s Coffee collects information about you (including, but not limited to, that information set out in the table below) that:
(a) you give us directly (for example information we receive from you directly when you create an account, join our loyalty programs, enter competitions, register or subscribe for our electronic newsletter, apply to become associated with us (including by seeking employment with us) or when you communicate with us by email or through social media);
(b) we receive from other sources (for example information we receive from our Franchisees, Area Developers, business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers, search information providers); and
(c) we collect about you and your device (for example technical information, including the IP address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, type of device. This includes when you use mobile applications (if any) developed by Zarraffa’s Coffee or logon to wireless facilitates provided in a Zarraffa’s Coffee store).
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What information do we collect? |
Why we might collect this information |
| Your full name, sex, date of birth, age, residential address, postal address, email address, telephone number, facsimile number and proof of identity information. |
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| Information or opinions about your racial or ethnic origin, political opinions, or memberships, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation, or criminal record. |
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| Information, communication or opinions about any of our products, services, transactions, payment history and business activities. |
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| Video footage and audio surveillance. |
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| Identifiers (such as tax file number and business number), citizenship and residency details, details regarding and information provided by your referees, details regarding and information provided by your guarantor(s) and business partner(s), financials/credit/criminal history checks, results of any pre-employment or profile tests, employment history, education history, identity documents, health information and next of kin details. |
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| Information that may be collected by us or on our behalf via third parties including the date and time of your visit to our website, IP address, documents and pages you access, type of browser and setting, operating system, address of a recurring site you are about to visit; information you submit regarding payment particulars, device identifier, pages visited, language selections, cookies, tracking pixels, geographic area and location. |
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| Other information. |
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In some situations you will have the option to deal with Zarraffa’s Coffee anonymously or through a pseudonym, however, where you are requesting products or services from us, it may become impracticable to provide those products or services to you without verifying your identity. Where you fail to provide us information or where the information provided is incomplete and/or inaccurate, or you choose not to provide us with the information that we have requested, it may affect our ability to provide you with our products and services.
In the event that we receive identifiable information from a third party, we will take reasonable steps to ensure that you have given express or implied consent to the collection of that information. If it is determined that we are unable to have possession of the information under a relevant law, we will destroy the information or ensure that the information is de-identified.
6.2 Do Not Track settings
For some (but not all) services operated by Zarraffa’s Coffee, the Do Not Track browser setting is accepted (which can be adjusted in your browser). Because a uniform technological standard has not yet been developed for Do Not Track, Zarraffa’s Coffee does not currently respond to all Do Not Track signals. Zarraffa’s Coffee continues to review new technologies and may adopt a standard once one is created.
6.3 Storing your information
Zarraffa’s Coffee is a growing and mobile business. In order to offer a consistent service to you we may store and manage data electronically or in paper form. Where data is stored electronically, it is done so by a third party cloud service provider that may store your information or a backup of your information in Australia, New Zealand, the United States of America, Germany, Ireland, Luxembourg, Singapore or such other locations that the third party cloud service provider determines from time to time. The data that we collect from you may be transferred to, and stored to these servers or processed by Organisations operating in other countries, who work for or are otherwise engaged by Zarraffa’s Coffee or for one of our suppliers.
We will take all steps reasonably necessary to ensure that your information is secured from misuse, interference, loss, unauthorised access, unauthorised modification or unauthorised disclosure. Any information will be handled in accordance with this Policy and applicable privacy laws. Despite using all steps reasonably necessary, the transmission of information through the internet is not completely secure.
When Zarraffa’s Coffee collects your Personal Information, Zarraffa’s Coffee will provide notification of the collection to you.
Submission of any information to Zarraffa’s Coffee is an acknowledgement that you agree to such use, storage and disclosure and the risk (if any) associated thereto.
6.4 Disclosing your information
Zarraffa’s Coffee may share your information with:
(a) any of its ‘associates’ (as that term is defined in section 50AAA of the Corporations Act 2001 (Cth));
(b) third parties including our Franchisees, Area Developers, business partners, suppliers and subcontractors;
(c) any prospective buyer of any part of the Zarraffa’s Coffee business or asset; or
(d) where we are required to disclose your information in order to comply with any legal obligation, or in order to enforce any agreements; or to protect the rights, property, or safety of Zarraffa’s Coffee and its customers, or others. This includes, where relevant, exchanging information with Organisations for the purposes of fraud protection and credit risk reduction.
6.5 Accessing and correcting your information
(a) You may request access to Personal Information that we hold about you at any time by contacting our Privacy Officer using the details set out in this Policy. We will respond to any such request for access to Personal Information within a reasonable time frame and we will provide you access to the Personal Information that we hold pertaining to you, unless we are authorised or otherwise permitted by law not to do so. If we refuse your request to give access, then we will give you a written notice setting out:
(i) our reasons for refusal;
(ii) the manner available to you to make a complain about our decision; and
(iii) any other information required by law.
(b) We may charge you a reasonable fee for processing your request to access your Personal Information and should we decline you access to your Personal Information, a written explanation will be provided setting out the legal reasoning for doing so.
(c) If upon receiving your Personal Information, or at any other time, you believe the Personal Information that we hold about you is incorrect, out of date, incomplete, irrelevant or misleading, please notify our Privacy Officer using the details set out in this Policy.
(d) If we decline to correct your Personal Information as requested by you, a reason for refusal will be provided except to the extent that it is unreasonable to do so. In the event that we decline the request to correct Personal Information, you may request to associate a statement with your Personal Information.
6.6 Complaints
Should you believe that we have not fulfilled our obligations under any relevant law or have not complied with the terms of this Policy, or would like to appeal a decision made by us in relation to your Personal Information, you can make a complaint in writing to our Privacy Officer using the contact details set out in this Policy.
We will respond to you within a reasonable period of time (or where a period is specified by any law, that period) to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
In Australia if after getting our response you are still not satisfied that your complaint has been resolved or adequately dealt with, you may direct your complaint to the Australian Information Commissioner (AIC). The contact details of the AIC are listed on their website: oaic.gov.au
In New Zealand if after getting our response you are still not satisfied that your complaint has been resolved or adequately dealt with, you may direct your complaint to the Office of the Privacy Commissioner, New Zealand (OPC). The contact details of the NZPC are listed on their website: www.privacy.org.nz
In the United States of America if after getting our response you are still not satisfied that your complaint has been resolved or adequately dealt with, you may direct your complaint to the Federal Trade Commission (FTC). The contact details of the FTC are listed on their website: ftc.gov
6.7 Zarraffa’s Coffee stores and regions privacy policies
Some stores and regions of Zarraffa’s Coffee are operated by independent third parties. If you are concerned that there may have been a breach of this Policy by an independent third party related with Zarraffa’s Coffee, please contact the relevant entity or store directly. Alternatively, you may contact the Privacy Officer at the details set out in this Policy.
6.8 Contact us
If you have any comments, concerns or questions regarding this Policy or Personal Information that Zarraffa’s Coffee holds about you, please contact our Privacy Officer by email to privacy@zarraffas.com or by post at:
Privacy Officer
Zarraffa’s Coffee Legal Department
PO Box 2089
BEENLEIGH QLD 4207, Australia