Protecting your privacy and personal information is important to CRM (“us”).
CRM has developed privacy practices, procedures and systems for the management of Personal Information in accordance with the Privacy Act 1988 (Cth) (the Act).
WHAT IS PERSONAL INFORMATION?
“Personal Information” is information (in recorded form or otherwise) about an identified, or reasonably identifiable individual (“you”). This may include name, date of birth, gender, email, telephone number, previous order information, IP address, credit card details, preferences, tastes, and purchasing behaviour.
“Sensitive Personal Information” is a sub-set of Personal Information and includes information or opinions about racial or ethnic origin, political opinions, memberships, religious beliefs, sexual orientation, health or criminal record. CRM does not collect this!
COOKIES AND WEB BEACONS
As you navigate through CRM’s website, app, social media platforms, certain information may be passively collected by CRM or its representatives using various media technologies such as cookies, tags or beacons. These are pieces of information that a website transfers to a computer’s hard disk for record keeping purposes. The use of these enables CRM to collect data regarding personal preferences and enables CRM to recognise specific preferences so as to target customised individual marketing. Most web browsers are set to accept these tracking technologies. Settings can be changed in the web browser, but some functions may only be accessed in conjunction with open settings.
CRM’s website, apps and social media platforms may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. CRM does not control, endorse, or make representations about these third-party sites and are not responsible for their privacy policies.
CRM does not collect or store Personal Information of applications for employment. All applications for employment at a specific Cold Rock store is sent directly to that store and CRM does not collect or store that information.
CRM does collect Personal Information from franchise applications. This may include information about residency status, employment history, financial capacity, qualifications, experience and other matters.
CRM may disclose your information to referees, previous employers, recruitment agencies, or others acting on CRM’s behalf.
COLLECTION AND STORAGE OF PERSONAL INFORMATION
Where possible, CRM collects Personal Information directly from you. Where it is not practicable or reasonable to collect information directly from you, we may collect it from other sources.
From time to time, photos may be taken and used for marketing and promotional purposes which may include images of franchised businesses, franchisees, employees or employees of franchisees, and/or customers; and from these images individuals may be able to be identified.
HOW DOES CRM USE PERSONAL INFORMATION?
CRM uses Personal Information for purposes that relate to the operation of the Cold Rock system and the provision of services, which may include:
- supplying CRM’s products and services to customers;
- providing quality assurance for CRM’s products and services;
- responding to enquiries and feedback regarding the business, the products and services of CRM and its franchisees;
- communicating with entrants of competitions;
- monitoring the performance of the Cold Rock franchise business and its franchisees;
- marketing, including email marketing, promotional and educative activities, the regular updates of products, services, events, and promotions which CRM thinks would be of particular interest to customers;
- planning, product development, and/or research purposes;
- enforcing the terms and conditions of CRM’s engagement with users of its products and services;
- the management of the various CRM databases;
- ensuring compliance with statutory obligations; and where applicable to:
- ensure compliance with the franchise agreement;
- provide franchisee support;
- comply with disclosure requirements under the Franchising Code of Conduct; and
- all other things of or incidental to carrying out CRM’s role as a franchisor.
HOW WOULD PERSONAL INFORMATION BE DISCLOSED BY CRM?
Personal Information may be disclosed to:
- any CRM related body corporate;
- third party consultants who may, from time to time, manage some or all or part of CRM’s databases, computer systems or internet sites;
- third party service providers where CRM outsources any of functions, including but not limited to development, production, and/or printing of advertising and marketing material and campaigns, including where such material contains photos or video of individuals;
- parties who undertake mystery shopping and customer satisfaction surveys on behalf of CRM;
- to prospective purchasers and their legal, accounting and business representatives where that information relates to a particular sale of all or part of CRM;
- the general public when notifying of competitions and results
- media outlets when photographs or video are used in advertising material or campaigns;
- where there has been express consent to the disclosure or the consent may be reasonably required; and
- as required or authorised to do so by law.
CRM does not and will not rent, sell or otherwise disclose Personal Information to any other persons.
DISCLOSURE OF PERSONAL INFORMATION VIA SOCIAL MEDIA SITES
By engaging in social media activity on any CRM social media platform, the user agrees to and are subject to CRM’s terms and conditions and the privacy policies of such social media platforms. CRM is not responsible for the terms and conditions or privacy practices of any social media platforms.
Photographs and other materials posted to social media platforms will be able to be viewed by the general public and as, such may be shared infinitely. While material initially shared on a social media platform may be able to be removed, all material that has been further shared may not be able to be removed. CRM is not responsible for any material that has been shared.
CRM reserves its rights to remove any photograph, comment/s or other material that it deems inappropriate or offensive from all CRM social media platforms.
CRM may hold Personal Information in electronic format or in hardcopy. While CRM is committed to ensure the security of Personal Information and will take all reasonable steps to protect this information from misuse, interference, loss, unauthorised access, modification or disclosure, the transmission of Personal Information across the internet is not completely secure. As such CRM cannot guarantee the security of Personal Information transmitted to its website, via email, through social media interactions or any other online forums. All transmission is at a user’s own risk and CRM is specifically not liable for any breach of security or unintended loss or disclosure of information due to the website being linked to the internet.
You may request access to the Personal Information CRM holds about you at any time. To access this, send a request to the Privacy Officer at email@example.com. A reasonable fee may be charged for such access.
Where CRM believes that the information held is inaccurate, out-of-date, incomplete, irrelevant or misleading, it will take reasonable steps to correct that information.
If you believe that the information CRM holds about you should be corrected, you may request an amendment or deletion to the Privacy Officer at firstname.lastname@example.org.
There may be some circumstances in which CRM is not required to give access to Personal Information, and if this is the case, CRM will to the extent it is able to inform you of the reasons.
ENQUIRIES AND COMPLAINTS
CRM usually responds in writing within 30 days, unless further information is needed to respond to the enquiry, concern or complaint.
All concerns will be investigated and if applicable action taken.
If CRM’s response is unsatisfactory to you, you may make an inquiry or complaint to the Office of the Australian Information Commissioner on 1300 363 992 or via email at email@example.com.