Introduction

Advanced Fresh Concepts Pty Ltd ABN 35 605 455 936 trading as Sushi Izu

(

AFC

our

) recognises the importance of protecting the privacy and the

rights of individuals in relation to their personal information in the course of

running our business. This document is our privacy policy and it tells you how we

collect and manage your personal information.

We respect your rights to privacy under the Privacy Act 1988 (Cth) (

Privacy Act

)

and we comply with all of the Privacy Act’s requirements

in respect of the

collection, management and disclosure of your personal information.

This Privacy Policy (other than section 15) explains how we manage personal

information about individuals other than employees. Section 15 explains the

position of employees.

What is personal information?

When used in this privacy policy, the term “personal information” has the

meaning given to it in the Privacy Act. In general terms, it means information or

an opinion about an identified individual or an individual who is reasonably

identifiable, whether true or not.

What types of personal information do we collect and hold?

The types of personal information we collect about you depends on the

circumstances in which the information is collected. Without limitation, we may

collect the following types of personal information about you:

• your name and contact details (such as address, email address, telephone,

mobile and facsimile numbers);

• payment details such as your debit or credit card details and billing

information;

• if you have visited, posted on or interacted with our website located at:

www.sushiizu.com.au (

Website

) or our social media pages (including

Facebook, Instagram), the information that you have shared with us on

those platforms (such as your social media account name, your email

address and any photographs that you shared);

• if you download and access our mobile application (

App

), we record your

device details, operating system and geographical location of your device

(where you have provided us with permission), and details of your activities

via the App;

• if you are a customer and have participated in any promotional activities

that we or our franchisees may run from time to time (including our Loyalty

Program), information that you submit to us as part of the promotional

activities;

• if you are a customer and have lodged a complaint or claim against us or

one of our franchisees or contractors, any personal information (including

date of birth and health information) that you may have submitted as part

of the complaint or claim;

• if you are an employee or contractor, your resume, qualifications, birth date,

current and former employment details, bank details and health information

relating to your employment or engagement with us;

• if you are prospective franchisee or a franchisee, information that you

provide to us as part of the application process or during your time as a

franchisee (such as the details of your background and experience, your

previous employment, your financial information and your credit

information);

• if you are a franchisee, information about your franchise with us; and

• any additional personal information relating to you that you provide to us

directly through our Website, or through our representatives or otherwise.

We may also collect some information that is not personal information because it

does not identify you or anyone else. For example, we may collect aggregated

information about how users use our Website or App.

How do we collect your personal information?

We collect and hold your personal information in a fair and lawful manner.

Where it is reasonably practicable to do so, we will collect your personal directly

from you. When collecting personal information from you, we may collect it in

the following ways:

• when you make an inquiry or order in relation to our goods or services;

• via our App;

• if you are a prospective franchisee or a franchisee, when you submit your

franchise application to us, throughout the application process, and also

through your franchise relationship with us;

• if you are an employee or contractor or a job applicant, when you submit

your application to us, or through your relationship with us;

• when you submit any complaint or claim against us or one of our

franchisees;

• when you participate in our promotional activities and Loyalty Program

(including online promotional activities conducted on our Website, App or

social media pages);

• when you access and upload content or interact in an identifiable manner

with our Website, App and our social media pages (including by posting any

messages or photographs, or “liking” us); or

• during conversations and correspondence (whether in writing or

electronically) between you and our representatives.

Sometimes we may collect your personal information from third parties where it

is unreasonable or impractical for us to collect it from you directly, including the

following:

• your referees, if you are a prospective franchisee, a franchisee or job

applicant;

• AFC franchisees, contractors and insurers, if you have submitted any

complaint or claim against us or a franchisee;

• where you download and use the App, from the providers of the Apple App or Google

Play stores and from AFC franchisees that you pick up products from after

ordering products via the App; and

• more generally, from law enforcement agencies and other government

entities.

We only collect sensitive information about you with your consent, or otherwise in

accordance with the Privacy Act. "Sensitive information" has the meaning set out in the

Privacy Act, and includes certain specific types of personal information such as health

information, and information about a person's racial or ethnic origin, sexual orientation or

practices, criminal record, religious beliefs or affiliations, political opinions, membership of a

political, professional or trade association, and biometric and genetic information.

The main types of sensitive information we may collect include:

• details of injuries (ie. health information) that may occur on our premises or

arising through the use of our goods or services; and

• details of disabilities or allergies (i.e. health information) so we can

accommodate any special requirements.

If you do provide sensitive information to us for any reason (for example, if you provide us

with information about a disability or allergy you have), you consent to us collecting that

information and to us using and disclosing that information for the purpose for which you

disclosed it to us and as permitted by the Privacy Act and other relevant laws.

In addition to the types of personal information identified above, we may collect personal

information as otherwise permitted or required by law.

What happens if we can’t collect your personal information?

If you do not provide us with the personal information described above, some or

all of the following may happen:

• we may not be able to consider your application to become a franchisee;

• we may not be able to continue our relationship with you under the

franchise agreement;

• you may not be able to participate in our loyalty program and promotional

activities;

• we may not be able to provide you with our goods and services, such as

processing your orders and arranging collection of those orders through our

App;

• we may not be able to process, manage and/or investigate a complaint or

claim made by you against us or our franchisee or contractor; or

• we may be unable to tailor the content of our Website or App to your

preferences and your experience of our Website or App may not be as

enjoyable or useful.

For what purposes do we collect, hold, use and disclose your

personal information?

We collect personal information about you so that we can perform our business

activities and functions and to provide best possible quality of customer service.

We may use or disclose your personal information:

• for the purposes for which we collected it (and related purposes which

would be reasonably expected by you);

• for other purposes to which you have consented; and

• as otherwise authorised or required by law.

Some of the specific purposes for which we collect, hold, use and disclose your

personal information include the following:

• if you are a prospective franchisee or job applicant, to consider your

application and to manage the application process;

• if you are a franchisee, employee or contractor of us, to manage and

maintain our relationship with you;

• if you are a customer or potential customer, to provide you with our goods

and services and to conduct promotional and marketing activities (such as

managing our loyalty program);

• if you have interacted with our Website or social media pages, to respond to

your posts and comments and to conduct promotional, marketing and

advertising activities;

• if you download and use the App, so that we can provide and allow you to

access and have the benefit of the App and its functionality;

• to conduct business processing functions including providing personal

information to our related bodies corporate, contractors, service providers

or other third parties;

• for the administrative, marketing (including direct marketing), planning,

product or service development, quality control and research purposes of us

and our franchisees;

• to update our records and keep your contact details up to date;

• if you have submitted a complaint or claim against us or one of our

franchisees, to process, investigate, manage and respond to the complaint

or claim, to inform and liaise with our insurer;

• to comply with any law, rule, regulation, lawful and binding determination,

decision or direction of a regulator, or in co-operation with any

governmental authority; and

• to contact you regarding the above, including via electronic messaging such as SMS

and email, by mail, by phone or in any other lawful manner.

Your personal information will not be shared, sold, rented or disclosed other than

as described in this privacy policy.

Our online and social media presence

Our privacy policy also applies to our Website , App and our social media pages.

Website logs

We or our hosting service provider may log IP addresses (that is, the electronic

addresses of computers connected to the internet) date and time of your visit to

the site or App, pages you accessed, type of browser you are using and referring

site to administer our Website and gather broad demographic information.

Security

As our Website and App is linked to the internet, and the internet is inherently

insecure, we cannot provide any assurance regarding the security of

transmission of information you communicate to us online. We also cannot

guarantee that the information you supply will not be intercepted while being

transmitted over the internet. Accordingly, any personal information or other

information which you transmit to us online is transmitted at your own risk.

Links

Our Website or App may contain links to other websites operated by third

parties. We make no representations or warranties in relation to the privacy

practices of any third party website and we are not responsible for the privacy

policies or the content of any third party website. Third party websites are

responsible for informing you about their own privacy practices.

Social media platforms

We do not operate, host or control any social media platforms on which we may

have a presence. We therefore make no representations or warranties in relation

to the privacy practices of the social media platform operators, and we are not

responsible for how the social media platform operators may collect, use, store

or host your personal information. You should inform yourself about their

privacy practices.

Who do we disclose your information to?

We may disclose your personal information to:

• our employees, related bodies corporate, franchisees, suppliers, contractors

or service providers for the purposes of operation of our Website, App or

our business, fulfilling requests by you, and to otherwise provide services to

you including, without limitation, web hosting providers, IT systems

administrators, mailing houses, couriers, payment processors, data entry

service providers, electronic network administrators, debt collectors, and

professional advisors such as accountants, solicitors, business advisors and

consultants;

• our insurers for claims management purposes;

• suppliers and other third parties with whom we have commercial

relationships, for business, marketing, and related purposes; and

• any organisation for any authorised purpose with your express consent.

We may combine or share any information that we collect from you with

information collected by any of our related bodies corporate.

We may also disclose your personal information in accordance with any consent

you give or where disclosure is authorised, compelled or permitted by law.

Direct marketing materials

If you are a customer, we may send you direct marketing communications and

information about our products that we consider may be of interest to you.

These communications may be sent in various forms, including mail, SMS, fax

and email and if applicable, social media platforms, in accordance with

applicable marketing laws, such as the Spam Act 2003 (Cth).

If you indicate a preference for a method of communication, we will endeavour

to use that method whenever practical to do so. In addition, at any time you may

opt-out of receiving marketing communications from us by contacting us (see

the details below) or by using opt-out facilities provided in the marketing

communications and we will then ensure that your name is removed from our

mailing list.

Do we disclose your personal information to anyone outside

Australia?

We may disclose personal information to our related bodies corporate and third

party suppliers and service providers located overseas for some of the purposes

listed above.

We take reasonable steps to ensure that the overseas recipients of your personal

information do not breach the privacy obligations relating to your personal

information.

We may disclose your personal information to entities located outside of

Australia, including our related bodies corporate, located in the United States.

Security and data quality

We take reasonable steps to ensure your personal information is protected from

misuse and loss and from unauthorised access, modification or disclosure.

We may hold your information in either electronic or hard copy form. Personal

information is destroyed or de-identified when no longer needed or when we are

no longer required by law to retain it (whichever is the later).

How can you access and correct your personal information?

You may request access to any personal information we hold about you and/or to

make corrections to that information at any time by contacting us (see the contact

details in section 14 below).

Where we hold information that you are entitled to access, we will try to provide

you with suitable means of accessing it (for example, by mailing or emailing it to

you). We may charge you a reasonable fee to cover our administrative and

other reasonable costs in providing the information to you. We will not charge

for simply making the request and will not charge for making any corrections to

your personal information. As part of this request, we may need to verify your

identity.

There may be instances where we cannot grant you access to the personal

information we hold. For example, we may need to refuse access if granting

access would interfere with the privacy of others or if it would result in a breach

of confidentiality. If that happens, we will give you written reasons for any

refusal.

If you believe that personal information we hold about you is incorrect,

incomplete or inaccurate, then you may request us to amend it. We will consider

if the information requires amendment. If we do not agree that there are

grounds for amendment, then we will provide written notice to you stating our

reasons for refusing your correction request.

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us using the

contact information in section 14 below and provide details of the incident in

writing so that we can investigate it. We will treat your complaint confidentially,

investigate your complaint and respond to your complaint within a reasonable

time (and in any event within the time required by the Privacy Act, if applicable).

After we have completed our enquiries, we will contact you, usually in writing, to

advise the outcome and invite a response to our conclusions about the

complaint. If we receive a response from you, we will assess it and advise if we

have changed our view.

If you are dissatisfied with the handling of your complaint, you may contact the

Office of the Australian Information Commissioner:

Office of the Australian Information Commissioner

GPO Box 5218, Sydney NSW 2001

Telephone: 1300 363 992

Email: enquiries@oaic.gov.au

Contacting us

The contact details for our Privacy Officer are as follows:

Post: Privacy Officer

Unit 12, 512 Gardeners Road

Mascot NSW 2020

Tel: (02) 9667 5800

Email: privacy@afcsushi.com.au

Employees

We collect information in relation to employees as part of their application and

during the course of their employment, either from them or in some cases from

third parties such as recruitment agencies. Such information may include

contact details, qualifications, resume, current and former employment details,

pay rate and salary, bank details, feedback from supervisors, training records and

logs of your usage of our equipment (e.g. phones, computers and vehicles).

Under the Privacy Act, personal information about a current or former employee

may be held, used or disclosed in any way that is directly connected to the

employment relationship. We handle employee information in accordance with

legal requirements and our applicable policies in force from time to time.

Changes to our privacy policy

We may change this privacy policy from time to time. Any updated versions of

this privacy policy will be posted on our Website and will be effective from the

date of posting.

Where applicable privacy laws provide for exceptions or exemptions, we may

rely on those exceptions or exemptions in our information handling practices.

This privacy policy was last updated on 21 January 2021.

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