1. INTRODUCTION
In this privacy policy “we”, “us”, “SO”, and “our” means Soul Origin, its associates, related entities and subsidiaries including Catering by Soul Origin and SO espresso. Please read this Privacy Policy carefully as it describes how we collect, use and handle your Personal Information.
Soul Origin recognizes the importance of your privacy and your right to control your Personal Information and is committed to complying with applicable privacy laws. We will only request Personal Information that is reasonably necessary for us to perform our functions and activities as a QSR business.

2. WHAT TYPES OF PERSONAL INFORMATION MAY WE COLLECT?
The types of Personal Information Soul Origin may collect depends on the purposes for which such information is collected but may include (without limitation):

a) your name, gender, date of birth, occupation, residential address, email address, telephone number and other contact details;
b) loyalty program, subscriptions and attendance frequency at Soul Origin stores; and
c) purchasing preferences and financial data which we may collect when you buy products, utilise order ahead functionality through our app, join our loyalty program, and/or as part of competitions and promotions.
d) Financial information, police background checks, personal references and other required information as set out in clauses titled “Franchise Applications” and “Employment Applications” below.

Soul Origin will generally not collect Sensitive Information from you. The exception to this is when you apply for a position, or to become a franchisee, in which case refer to the sections below titled “Employment Applications” and “Franchise Applications”. We will not use Sensitive Personal Information for marketing purposes.
In addition to Personal Information, we use cookies, web beacons and other technologies on our network to collect information about your usage (for instance, third party websites you visit to better understand your preferences and what types of products and services you may be interested in).

3. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?
Where it is reasonable and practicable to do so, Soul Origin will collect Personal Information directly from you (without limitation):

a) When you participate in a promotion, competition, promotional activity, survey, market research or customer behavioural activity;
b) When you subscribe to our mailing list or interact or follow our social media pages including Facebook, Twitter, LinkedIn and Instagram;
c) When you download or use the Soul Origin App;
d) When you sign up to the Soul Origin Loyalty program;
e) When you provide us with Personal Information via our stores or head office or when you place an order in store, by telephone or via our mobile or electronic catering or order ahead ordering system;
f) If you use social media, any information that you allow the social media site to share with us;
g) If you contact our Support Centre we may record calls in and out of our Support Centre and so we will collect any Personal Information you provide during the call;
h) If you are applying for a position with Soul Origin, we will collect information as outlined in the section below titled “Employment Applications”.
i) If you are applying to become a Soul Origin franchisee, we will collect information as outlined in the section below titled “Franchise Applications”;
j) 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. 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;
k) We may collect transaction details related to your use of our services, including your order details, date and time the service was provided, amount charged, and payment method;
l) We may also collect Personal Information through cookies and other identification technologies, please refer to “Cookies and Web Beacons” section below; and
m) We collect information about how you interact with our services. This includes information such as access dates and times, app features or pages viewed, app crashes and other system activity.

Soul Origin may collect Personal Information from you, including but not limited to:

a) If you use the Soul Origin app and have location services enabled, your most recent location each time you open the app will be cached. Previous locations are trashed, but each app open is stored.
b) Depending on the Soul Origin services that you use, and your app settings or device permissions, we may collect your precise or approximate location information as determined through data such as GPS, IP address and WiFi.
c) If you use our ‘store locator’ feature, you can agree to share your location so that you can easily find the nearest store. If you use the store locator feature on our website(s) the data is cached (temporarily stored) and then trashed.
d) We may use CCTV in or around Soul Origin businesses to investigate any type of incident and protect our personnel. We will restrict access to any footage.
e) Soul Origin may combine the information collected from these sources with other information in its possession.
f) 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.

4. WHY DO WE COLLECT, USE, HOLD AND DISCLOSE YOUR PERSONAL INFORMATION?
Soul Origin collects, uses, discloses or holds Personal Information that is reasonably necessary for Soul Origin to perform one or more functions or activities as a business including (without limitation):

a) direct marketing, sales and promotion of Soul Origin products (for instance, providing you information about upcoming offers and deals);
b) to enable us to provide you with benefits of our loyalty program
c) direct marketing, sales and promotion of Soul Origin Franchising
d) to assess your eligibility and suitability to purchase and operate a Soul Origin franchise
We use, disclose or hold your Personal Information for the primary purpose for which it was collected, or as otherwise required in accordance with applicable privacy laws (for instance, we may be required to disclose your Personal Information to a law enforcement agency).

5. WHO DO WE DISCLOSE YOUR PERSONAL INFORMATION TO?
Soul Origin may provide your Personal Information to third parties as part of our functions and activities including (without limitation):

a) Delivery, courier and postal organisations: we may disclose your Personal Information to delivery, courier and postal organizations in order to deliver products you order;
b) Law enforcement and emergency services agencies: we may disclose your Personal Information where required or authorised to do so by law, including in emergency situations and to assist law enforcement agencies with active investigations. We will always ensure that those to whom we disclose your Personal Information have the legal right to receive it; and
c) Soul Origin may engage email marketing providers, market research companies, promotions management and other data analytics companies to perform direct marketing on our behalf. You will always have the right to opt out of receiving promotional materials from Soul Origin.

6. DISCLOSURE OF PERSONAL INFORMATION TO OVERSEAS RECIPIENTS
Soul Origin has stores around Australia. Our network comprises of a number of stores, trained staff, trusted third party service providers and company officers. Given the size of our operation, we are sometimes required to provide your information to other related companies. This means that sometimes your information is transferred to a country that is not your country of residence or the country where you initially provided the information to us.
Our privacy practice may vary among our countries of operation. All appropriate steps will be taken by us to ensure that your information is collected, stored and used in accordance with the legal requirements of the relevant country and through our privacy policy.

7. HOW IS YOUR PERSONAL INFORMATION SECURED?
We understand you have entrusted us with the protection of your Personal Information. As such, we take reasonable steps, to protect your Personal Information from misuse, loss, unauthorised access, modification or disclosure. This includes engaging reputable third party service providers and ensuring that we engage (where possible and practical to do so) in best practice security systems and procedures.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. We limit access to Personal Information about you to employees and/or contractors who we believe reasonably need to come into contact with Personal Information to provide products or services to you or in order to do their jobs.
The security of your personal information is important to us.

8. WEBSITE VISIT INFORMATION
Visiting our website requires the collection of general and personal information. The collection of such information may be executed by our third party contractors which collect information regarding your visit to website and includes the pages you accessed, the information downloaded, the date and time of your visit and your server address. Such information is collected for statistical purposes and assists us in keeping up the quality of our website and its convenience for our users.

Keep in mind that any personal information, or comment that you voluntarily disclose on the Website, for example on comment pages, or on the blog forums, become publicly available. Your account name is displayed to other Users when you send and/or post messages through the Website. Please note that any comment or other content you post or send to the Website becomes published content and is not considered personally identifiable information subject to this Privacy Policy.

9. COOKIES AND WEB BEACONS
A cookie is a computer file containing certain information about your use of our website sent by your computer to us with each request. Cookies used by us and/or associated third parties may identify individual users.

As you navigate through our websites or smart device applications, certain information can be passively collected (by us or our vendors) using various technologies such as cookies, internet tags or web beacons, and navigational data collection (log files, server logs and clickstream data). Using “cookies” enables us to collect data regarding your personal preferences, including what products you have ordered, at what times and in what amounts, the pages you have visited in what order and so forth. This enables us to recognise you as a specific customer and to help us and our third-party service providers present targeted and customised advertising to you. For example, we can keep track of the products you like such that if you consent, we can send you information about new products and promotions that you might be interested in.

It is important to note that our cookies do not hack into your computer so as to seek and retain other personal information stored on your computer nor do they contain any viruses.

If you do not wish to receive cookies, you can change your browser settings such that your device does not accept cookies. However, please note that certain areas of the Soul Origin website or Soul Origin app may only be accessed in conjunction with cookies.

10. GOOGLE ANALYTICS
We use Google Analytics to understand how our websites are used and identify how we can make the websites more effective. For information on how Google Analytics collects and processes data please see the site “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners.

11. THIRD-PARTY LINKS
The websites 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. We do not control, endorse or make representations about these third-party sites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy notice of every website you visit. If you choose to give Personal Information to unrelated third parties it will not be covered by this Privacy Policy.

12. EMPLOYMENT APPLICATIONS
We collect Personal Information when you interact with us with regards to employment.

Examples of when we collect Personal Information includes when you apply for a position with us, complete an employment form for us, contact our Support Centre in respect to an employment opportunity, visit our website, social media channels or mobile applications.

In considering your application, we may also obtain Personal Information about you from third parties. For example, from your previous employers, recruitment agencies, nominated referees, government agencies and regulatory authorities. Subject to your consent, we may also collect Sensitive Personal Information about you such as information about your health (including any disability), any criminal record, if it is relevant to the role that you are applying for, and whether you identify as Aboriginal or Torres Strait Islander.
We collect Personal Information for a variety of purposes, including but not limited to any one or more of the following purposes: verifying your identity, communicating with you, assessing you for a position with us or one of our related entities 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.

We will hold your Personal Information for future job opportunities with us unless you tell us not to.

13. FRANCHISE APPLICATIONS
We collect Personal Information about franchise applicants. This may include Personal information about residency status, employment history, financial capacity (including bank account information) and other information relating to your qualifications and experience.

Examples of when we collect Personal Information includes when you apply to be a franchisee with us, complete a form for us (Soul Origin Franchise Enquiry Form), contact our Support Centre, visit our website, social media channels or mobile applications or otherwise provide Personal Information to us.

We may combine and compare Personal Information that we hold about you with other information collected from, or held by, others.

In considering your application, we may also obtain Personal Information about you from third parties, for example, from your previous employers, business contacts or nominated referees.

Subject to your consent, we may also collect Sensitive Personal Information about you such as information about any criminal record you may have or your membership of any professional or trade association.

We collect Personal Information for any one or more of the following purposes:

a) assessing your application to become a Soul Origin franchisee;
b) assessing whether you are suitable to progress to each stage of the Soul Origin franchise recruitment process; and/or storing your information for future Soul Origin franchise 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.

14. FRANCHISEES
A number of Soul Origin businesses are owned and operated by franchisees. Soul Origin’s franchisees are required to follow this privacy policy. If you are concerned that there may have been a breach of this privacy policy by a franchisee, please contact the relevant franchisee entity or Soul Origin directly.

This privacy policy does not apply to our franchisee’s conduct on websites or mobile apps they operate.

15. 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, feedback or for general data processing or databases for email or SMS marketing communications.

16. VENDORS
Soul Origin does not rent or trade Personal Information with third parties. We may however, share your Personal Information with vendors who provide services to us, such as fulfilling orders (e.g. UberEats), carrying out research (data processing), banking institutions, managing promotions, personalising customer experiences and other information technology services. We do not allow these vendors to use this information or to share it for any purpose other than to provide services on our behalf.

17. CHILDREN’S PRIVACY NOTICE
Our policy is not to collect Personal Information from any person under 13-years-old unless collection is for a specific activity and that person’s parent or guardian has provided us with written consent to collect their Personal Information for that specific activity.

Whilst some of our Soul Origin products (e.g. Crushers) are targeted towards children, we do not intend for our online services to be used by anyone under the age of 16. If you are a child under the age of 16, PLEASE DO NOT provide any Personal Information to us. If you are a parent or guardian and believe we may have collected information about your child, please contact us.

18. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
You can access or correct your Personal Information through:

a) your Soul Origin loyalty profile; or
b) contacting our Privacy Officer at the ‘Inquiries Procedure’ set out below.

Please ensure that any written request for access or correction addressed to our Privacy Officer provides adequate detail that identifies what Personal Information you want access to or corrected. Where your request will incur costs, we may charge you a fee to cover those costs (for instance, reasonable staff costs in searching for, locating and retrieving the requested Personal Information). We will inform you of any such charges prior to your request being actioned.

In certain circumstances, we may refuse to provide you access to your Personal Information. Where we refuse you access, we will provide you with a written explanation as to the reasons for the rejection (for instance, we may refuse to disclose Personal Information to you where such access would have an unreasonable impact on the privacy of other individuals).

19. BDC FRANCHISE RECRUITMENT PARTNERS
Soul Origin may use the services of BDC Franchise Recruitment Partners in the process of recruiting, screening, and selecting Franchisees on its behalf.

Your data will only be shared with BDC Franchise Recruitment Partners to allow us to deliver the services agreed to between Soul Origin and you.

For more insight, you may access and review the BDC Franchise Recruitment Partners Privacy Policy here.

20. CHOICE/OPT-OUT
We will provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purpose, at the time of asking for this information.

If you no longer wish to receive our newsletter and promotional offers, you may “opt-out” of receiving them by following the instructions included in each newsletter or communication, or by contacting us.

21. INQUIRIES PROCEDURE
All complaints and inquiries concerning your Personal Information, including in respect of alleged breaches of this Privacy Policy or the Privacy Act, should be directed to the Soul Origin Privacy Officer:

The Soul Origin Privacy Offer
Soul Origin
PO Box 998, Marrickville NSW 1475
Email: info@sohq.com.au

22. PRIVACY POLICY UPDATES
This Privacy Policy was last updated in November 2020. We may update this Privacy Policy from time to time. We will post the updated version of the Privacy Policy on our website but may not personally notify you. Please check periodically to see if our Privacy Policy has been updated. Capitalised terms in this Collection Statement have the meaning given to such terms in the Soul Origin Privacy Policy or the Privacy Act.

Effective Date: This Privacy Policy was last modified in November 2020.