We respect the privacy of all people we deal with and are committed to building trust by handling and safeguarding your personal information in accordance with our obligations under the Privacy Act 1988 (Cth) (Privacy Act) (including the Australian Privacy Principles (APPs)).
TYPES OF PERSONAL INFORMATION WE COLLECT
The Privacy Act defines “personal information” as information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or individual who is reasonably identifiable.
The kinds of personal information we may collect, hold and use about you include:
- date of birth;
- contact details (including phone number, address and e-mail address);
- image and persons movements upon entering our venue as captured by on-premise CCTV;
- where we are required to scan your ID at particular venues such as the Argyle – personal information appearing on your ID;
- personal information (including your social media user details, feedback, comments, and photos) you post on your social media channels that references us; and
any other personal information provided to us when you make an inquiry, request information, correspond with us or lodge a complaint.
HOW WE COLLECT PERSONAL INFORMATION
If it is reasonable and practical to do so, we collect your personal information directly from you, including when you:
- make a reservation or dine at one of our venues;
- request services from us;
- join one of our mailing lists;
- register for promotions, respond to surveys or provide feedback to us;
- sign up to or participate in our loyalty program; and
- otherwise interact with us (including post information or photos on social media channels that references us).
We may have photographers present at our venues during weekends or large events, who may take photos and share them on our social media pages for marketing purposes. We will only do this to the extent that is reasonably necessary for our functions and activities. If a photo captures sensitive information about you, we will ask for your consent before taking them.
We may also collect your personal information from someone other than you, for example from:
- entities that are our related bodies corporate (including Hunter St Hospitality brands);
- third parties who make bookings or enquiries on your behalf;
- our service providers or contractor in order to provide our services, including online booking system providers and in-venue digital ordering providers;
- publicly maintained records or other publicly available sources of information including social media.
PURPOSES FOR WHICH PERSONAL INFORMATION IS USED
Generally speaking, we collect and use personal information so that we can provide our hospitality services, interact with you in relation to our services and venues and administer and manage our business and our venues.
We may collect, hold, use and disclose your personal information for the purposes set out below:
- create and respond to booking requests;
- provide dining and other hospitality experiences at our venues;
- manage and administer the provision of our services and our relationship with you;
- verify your identity;
- maintain venue, patron and employee safety;
- supply you with information you request from us;
- conduct promotions, competitions, giveaways and events;
- contact you to obtain your feedback regarding our products or services or to conduct other market research;
- provide you with marketing information regarding us and our venues (as further detailed below);
- analyse information we collect so that we can administer, support, and improve and develop our business and the products and services we offer, including by undertaking data analytics and related activities using your personal information; and
- comply with our obligations under any applicable laws.
We may also use or disclose your personal information for another purpose related to the primary purposes set out above.
You are under no obligation to provide your personal information to us. However, without certain information from you, we may not be able to provide services or information to you or may be limited in how we can interact with you.
DISCLOSURE OF YOUR PERSONAL INFORMATION
We may disclose your personal information to any of our employees, officers and agents to enable them to provide services to us and our customers. We may also disclose your personal information to certain third parties insofar as reasonably necessary for the purposes set out in this Policy, including:
- related bodies corporate (incl Hunter St Hospitality venues);
- suppliers or subcontractors to whom we outsource certain functions, for example, IT support, advertising; and
- insurers and professional advisers.
We may also from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
Where we disclose your personal information to third parties, we will request that the third parties follow this Policy regarding handling your personal information.
TRANSFER OF PERSONAL INFORMATION OUTSIDE OF AUSTRALIA
There may be instances where we will need to disclose your personal information to recipients that are located outside of Australia.
Any overseas disclosures will only be made once we have taken all reasonable steps to ensure any personal information will be treated at least in accordance with the Privacy Act and other applicable privacy laws.
This may include (but not limited to) taking steps to ensure that contractual arrangements with overseas recipients include obligations on those recipients to:
- handle any personal information they receive in accordance with the Privacy Act; and
- maintain administrative, technical, and physical safeguards to help protect the security, confidentiality, and integrity of personal data consistent with applicable requirements of the Australian privacy laws.
DATA RETENTION AND DISPOSAL
Except as otherwise permitted or required by applicable law or regulatory requirements (in particular, data retention periods), we will take reasonable steps to retain your personal information only for as long as it is necessary to fulfil the purposes for which the personal information was collected.
We will also retain and use your personal information for as long as necessary to resolve disputes and/or enforce our rights and agreements.
Outside of reasonable retention and other legal requirements, we will take reasonable steps to destroy or de-identify personal information where it is no longer necessary to be retained.
Non-personally identifiable and aggregated information may be stored indefinitely.
SECURITY OF YOUR PERSONAL INFORMATION
We are committed to ensuring that the information you provide to us 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 information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
ACCESS AND CORRECT YOUR PERSONAL INFORMATION
You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act. If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at firstname.lastname@example.org. We will respond to a request for access or correction within a reasonable period after the request is made, either by giving you access to the personal information requested, or by notifying you of our refusal to give access. We may request to verify your identity before responding to any request. If we decide not to provide you with access to or make a correction to your personal information, we will give you reasons for our decision.
We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act.
COMPLAINTS ABOUT PRIVACY
If you have any complaints about our privacy practises, please contact us using the contact details below. Please note that we may ask you to lodge your complaint in writing. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
If the complaint is not resolved to your satisfaction, you can refer it to the Office of the Australian Information Commissioner. Such complaints generally are resolved through conciliation.
If you wish to contact us regarding our handling your personal information or any of the matters covered in this policy, please contact the Reservations Manager by email at email@example.com, or by post to Level 2, Cleland Bond Building, 33 Playfair St, The Rocks NSW 2000.