This Privacy Policy applies to United Franchise Group Pty Ltd ACN 128 152 385 and the following related entities:
- SIGN*A*RAMA INC. ABN 96 080 258 215
- EMBROIDME.COM, INC. ABN 14 107 509 508; and
- GRAZE CRAZE FRANCHISING PTY LTD ABN 87 660 594 927 (collectively referred to as “we”, “us” or “our”, as applicable).
In this Privacy Policy, reference to personal information and sensitive information have the same meanings as defined in the Privacy Act 1988 (Cth) (“the Privacy Act”). If the definition of the words is modified by the Privacy Act, the reference to the words will have the updated meaning from the Privacy Act.
The aim of this Privacy Policy is to clearly set out how we manage the use and disclosure of any information related to you as a customer, potential customer or customer’s representative. Information held or collected about our current or former employees are not covered by this Privacy Policy.
2. Our Privacy Principles
We are committed to protecting your privacy by upholding and adhering to the Australian Privacy Principles (“APPs”) as contained in Privacy Act. We have adopted rigorous internal policies and procedures to ensure that personal or sensitive information we collect, store, use and disclose is dealt with in accordance with the APPs.
3. If you are a customer, interacting with or browsing on our website
We will only collect personal information if it is necessary for one of our business functions or activities, we will ensure all collection is lawful and fair.
3.1. Information we collect
Personal information may be collected by us when you:
(a) when we are contacted about our products or services, in person or over the telephone or internet or otherwise submit an enquiry with us;
(b) when we are provided such information by third parties engaged by us legally collect data on our behalf;
(c) when you subscribe to receive our alerts or emails
(d) when you interact with our websites at www.signarama.com.au, www.signaramafranchise.com.au, www.fullypromoted.com.au, www.fullypromotedfranchise.com.au, www.grazecraze.com.au, www.grazecrazefranchise.com.au or social media; and
(e) when you register an account on our website.
The information we may collect includes your:
(f) Name;
(g) Date of birth;
(h) Address;
(i) Phone number;
(j) Email address;
(k) Behavioral information discernable from the links you click; and
(l) Any other information you share with us.
3.2. How we use it
We will generally use your personal information for the primary purpose it was collected, or for any secondary purpose related to the purposes. Some of these uses include but are not limited to:
(a) provide or offer you products, services or other benefits whether provided by us or by our third-party partners;
(b) to inform you or others of our marketing initiatives, or marketing initiatives relating to products or services that are provided by our third-party partners;
(c) to identify you and protect your customer account from unauthorized access;
(d) to derive or aggregate anonymous information from which individuals cannot be identified for marketing or other business requirements;
(e) any internal administrative, analytical or tracking requirements associated with marketing or any other business function
(f) where disclosure is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim;
(g) purposes which you would reasonably expect us to use the information;
(h) develop and implement initiatives to improve our products, services, business or customer experiences;
(i) any other purpose you have consented to; and
(j) any use which is required or authorized by law.
Any additional purpose for which the information is collected (not included in this policy) will be identified when we collect the personal information, or as soon as practicable afterwards.
3.3. Who we share it with
We will not disclose your personal information without your prior consent, where that consent is required by law however you specifically authorize us to use and disclose your personal information in the following ways for the following purposes:
(a) between our various related entities including between different franchisees pursuant to any franchise agreement or franchise operations manual between us as franchisor and them as franchisee.
(b) to various third-party service providers who may from time to time manage our databases;
(c) where such disclosure is permitted, required or authorized by law; and
(d) to suppliers and other third parties with whom we have engaged for business, marketing and other related purposes.
4. If you are applying to own a franchise
4.1. Information we collect
If you are applying for a franchise, in addition to all the information we may need to collect as set out in this Privacy Policy, we may also need to collect the following:
(a) Details regarding your occupation;
(b) Details regarding your level of formal education and business experience;
(c) Proof of earnings and expenses;
(d) Financial information relating to either you or your related body corporates (this may include credit card details, profit loss statements, balance sheets);
(e) Information related to your financial position including details regarding your assets (including those where your interest is set out as the legal beneficial owner); and
(f) Any other information we determine reasonably necessary for us to ascertain your suitability to operate one of our franchises.
If you are already a franchisee under our one of our franchise networks, pursuant to any relevant franchise agreement, we may collect information regarding your clients, suppliers, employees and franchised business including information. This information may be obtained by us either directly or from third parties such as your lending institutions, financiers, suppliers, creditors, clients and employees or other government departments or authorities.
4.2. How we use it
In addition to all the functions set out in this Privacy Policy, if you are applying for a franchise, we may use your personal information to:
(a) conduct credit checks or to verify any other information you have provided us;
(b) verifying any information required under any franchise agreement;
(c) to conduct checks for compliance with any relevant law; and
(d) all other things of or incidental to carrying out our role as franchisor.
4.3. Who we share it with
In addition to all the potential disclosure as set out in this Privacy Policy, if you are applying for a franchise, we may share your information with:
(a) Third party credit reporting agencies; and
(b) Our lawyers, accountants and other professional advisors engaged by us to help assisting in reviewing or processing your application.
5. If you are applying to join our team
5.1. Information we collect
Information held or collected about our current or former employees are not covered by this Privacy Policy. However, if you are applying to join our team, we might collect personal information about you to assist with our review of your application. For more information regarding how we treat information relating to our current or former employees, please contact the Privacy Officer (details found below).
5.2. How we use it
Your personal information may be used for the following:
(a) Reviewing your application for the position you are applying for, or any other positions that may suit your experience.
(b) Responding to you about your application or any future application you may make to work with us.
(c) Contacting your referees to discuss your application.
6. Personal information collected from a third party
We may collect personal information about others from you or about you from others (e.g. when you obtain a quote for your employer or enquire about our services on behalf of someone else via our “Refer a Friend” or “Refer a Client” functions). In such circumstances, we rely on you to obtain that person’s consent to the use and disclosure of their personal information.
If we have collected your personal information from a third party, we will at the time, or as soon as practicably, notify you of the following:
(a) who that personal information is being collected from;
(b) what personal information we collected and for what purpose it was collected;
(c) which related entities the personal information may be shared with including whether that personal information may be shared overseas;
(d) where the person information was required under Australian law or a court / tribunal order, the name of the Australian law and details of the order; and
(e) a link to this Privacy Policy.
7. Collecting sensitive information
In certain circumstances we may need to collect sensitive information about you. Unless permitted by law, we will seek your consent before collecting your sensitive information and inform you of the primary purpose of the collection at that time. Your sensitive information will always be used for the primary purpose it was collected (as informed to you by us at the time of collection) and will not be used or disclosed for a secondary purpose unless you have consented to such use or disclosure and such purpose is directly related to the primary purpose.
8. Cookie Tools
To improve the user experience on our website, and to develop our online services, we may collect aggregated information by using cookies. Cookies are unique identification numbers like tags that are placed on the browser of our website users.
We may use analytic cookies to track use of our website, and to compile statistics on your visits to our website or on your online interactions in an aggregated form and log anonymous information to provide personalized features. Some of the information obtained from our cookies include your:
(a) IP address;
(b) Browser and device characteristics;
(c) Operating system;
(d) Language preferences;
(e) Your actions on our sites, such which content you click and how long you spend on each of our pages.
The cookies do not in themselves identify users personally, but are linked back to a database record about them. While we may be able to identify you from the combination of information collected by our cookies, however, once we are no longer using this data (or as the law requires) we will de-identify the data so that you cannot be personally identified from the information we obtained using cookies or through the combination of that information.
Some of the information we can obtain from cookies include:
(f) Which of our webpages you visit the most;
(g) How you generally use our websites;
(h) Counting our audience size and countries which access our websites the most; and
(i) Understanding how effective our advertising and marketing is.
If you chose not to have your browser accept cookies from our site, you will still able to view the text on our webpages however the page may not function as intended. To disable cookies you must do so from your device or desktop.
9. Marketing Communications
As part of our marketing activities, we may send direct marketing communications to you about our services and products and other material we consider you may be interested in. We will do this for both prospective customer and franchisees.
You may at any time opt out from receiving direct marketing communications by either using the unsubscribe function available on each piece of marketing material or you may opt out by emailing our Privacy Officer set out below.
Please note that if you chose to opt out from one of our brands, you will not be automatically unsubscribed from our other brands, if you wish to opt out entirely you will need to let us know.
10. Updating your information
We ask that you tell us of any changes to the personal information we hold about you. You may notify our Privacy Officer (whose contact details appear at the end of this policy) at any time to request that your personal information is amended or updated at no cost. We will then take reasonable steps to correct the information in the manner requested. If we consider that the personal information we retain does not require amendment, upon inform you of our reasons we may refuse to update our information. In such circumstances, we will include a statement of your request on our files.
11. Security
The protection of personal information is a priority for us and to ensure your personal information is protected, we are committed to maintaining:
- Safeguards to protect personal information against unauthorised use, disclosure, access, interference, modification, destruction and accidental loss.
- All personal information we hold is dealt with in accordance with the APPs;
- Industry standards for the security and protection of information and ensuring personal information is stored securely and access is restricted to authorised personnel only. Our computer systems require access passwords and these are kept secure by our personnel; and
- Internal policies on management of personal information and staff training to ensure compliance with these policies. All our staff are required to read this policy and understand their responsibilities regarding personal information.
Notwithstanding our best efforts we cannot guarantee the safety of information transmitted to us via the internet. Other than liability that cannot be legally excluded, we are not liable in any way in relation to any breach of security relating to any unintended loss, disclosure or misuse of personal information during internet transmission.
12. Storage and Destruction of Records
The personal or sensitive information we collect is generally recorded in hard copy files designated for the primary purpose for which the personal or sensitive information was collected and/or updated on our computer database.
We will destroy or de-identify any personal or sensitive information that we hold which is no longer needed for any purpose permitted by the APPs unless we are required by law to retain such personal information.
13. Access to personal information
We will generally allow an individual access to any personal information that we hold about them on request – subject to any restrictions on access. We will try to give the individual concerned access in a form and manner that suits their needs. To request such access please contact our Privacy Officer. Contact details for our Privacy Officer appear at the end of this policy.
Although we do not charge for requesting access, we may charge are a reasonable fee for providing access to the requested personal information. We will inform you at the time of your request whether a fee is applicable.
14. Restrictions on access
Where permitted by the APPs, we may restrict access to certain personal information we hold. In such circumstances, we may give you an explanation for the decision, rather than direct access to the information.
Some instances where it may not be appropriate to provide you with access to the personal information we hold, include where:
- Giving access would reveal evaluative information generated by us in connection with a commercially sensitive decision-making process;
- Providing access would pose a serious and imminent threat to the life or health of any individual;
- Providing access would have an unreasonable impact upon the privacy of others;
- The request for access is frivolous or vexatious; or
- The information relates to an anticipated or existing legal dispute and disclosure would compromise our position or the position of others.
15. Transferring information overseas
From time to time, we may transfer your personal information to entities overseas. In such circumstances we will always take reasonable steps to ensure that the overseas
recipient handles the information in a way that is consistent with the APPs. These entities may include [insert relevant entities e.g. parent company, IT providers, account processers]
16. Changes to our policy
We may update or change this policy. When we do so, we will publish the current policy on our website. Please check our website to review this policy regularly.
17. Complaint resolution
We are committed to constantly improving our procedures so that personal information is treated appropriately. If you feel that we have failed to deal with your personal information in accordance with the APPs or this Privacy Policy, please contact our Privacy Officer (set out below) to raise your complaint. If this process does not result in an outcome that is satisfactory to you, you may contact the Office of the Australian Information Commissioner’s Office (“OAIC”). We will work together with the Information Commissioner’s Office to resolve the issues between us. Further information about privacy and your rights, including how to lodge an enquiry or complaint can be obtained at the OAIC’s website at www.oaic.gov.au.
18. Contact us
If you wish to access any personal information that we hold about you, or have a query about this policy, please contact our Privacy Officer:
Privacy Officer
United Franchise Group
Office B, Level 1
396 Lane Cove Road
Macquarie Park NSW 2113 Australia
P: +61 2 8878 0400
F: +61 2 9807 2033
www.unitedfranchisegroup.com