1. Introduction
We care about your privacy and have put measures in place to protect the information you have entrusted to us.
This Policy sets out.

(a) the types of information that First Things First Coffee may collect;
(b) how that information will be collected, used, handled, stored and disclosed (including internationally);
(c) the reasons for which First Things First Coffee collects, holds, uses and/or discloses the Personal Information;

(d)how you can access your Personal Information and request for that information to be corrected; and

(e)how you can make a complaint. 

We reserve the right to update this Policy from time to time. Although we will not provide notice of the changes, you can view the latest version of this Policy on our website. It is your responsibility, and we encourage you, to check the website from time to time in order to determine whether there have been any changes.​

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2. Application

(a)    This Policy applies to information that First Things First Coffee collects (or may collect) about you.
(b)    This Policy does not apply to information that may be collected by a third party or how that third party may use, handle, store or disclose your information (including where links to third party websites are provided). First Things First Coffee does not have any control over the privacy practices of any third party, other than Zarraffa’s Coffee. Any information you provide via the platforms of third parties (including via social media platforms) will be managed by the terms and condition of that platform provider. 
(c)    This Policy does not cover any information collected by a Franchisee. 
(d)    We are subject to the Australian Privacy Principles (APPs).
 

3. Policy

3.1  How, what and why we collect your information

First Things First Coffee collects information about you (including, but not limited to, information set out in the table below):

(a)              (direct interactions)  For example information we receive from you directly when you create an account, join our loyalty program(s), download or use our mobile application, enter competitions or promotions, register or subscribe to our electronic newsletter, apply to become associated with us (including by seeking employment with us), submit an online form on our website, make enquiries or discuss opportunities of franchise or becoming a contractor or supplier, follow our social media accounts or when you communicate with us by email or through social media;

(b)              (interactions you have with other sources)  For example information we receive from our Franchisees, business partners, sub-contractors in technical and delivery services, advertising networks, analytics providers or search information providers; and

(c)              (automated technologies or interactions)  For example technical information, including the IP address used to connect your computer to the internet when you visit our website, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, type of device. This includes when you use mobile applications (if any) developed by First Things First Coffee or logon to wireless facilities provided in a First Things First Coffee store. We may use the following technologies to collect technical and third-party data:

(i)               social media features and widgets (for example the “like” and “share” buttons), where such features may collect information such as the page you are visiting. If you are logged into your account with the third-party company, then the third-party may be able to link information about your visit to and use of our website or mobile application to your social media account with them;

(ii)              “Cookies”, being data files that are placed on your device or computer and often include an anonymous unique identifier;

(iii)             "Log files” track actions occurring on our website and mobile application and collect data including your IP address, browser type, internet service provider, referring/exit pages, and date/time stamps; and

(iv)             “Web beacons”, “tags”, and “pixels”, being electronic files used to record information about how you browse our website or mobile application.

(d)             (you give us directly as a result of being employed by us)  For example:

(i)               medical records and/or information pertaining to existing medical conditions we are required to hold in case of an emergency to assist you; or

(ii)              and results of any tests we are required to undertake.

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​3.2 Employee records

First Things First Coffee’s handling of employee records in relation to current and former employment relationships is exempt from the Australian Privacy Principles where those records are related to either a current or former employment relationship between First Things First Coffee and the individual an employee record held by First Things First Coffee relating to the individual

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3.3 Sensitive Information

We will not request any sensitive information (‘Sensitive Information’) from you, as defined under section 6(1) of the Privacy Act 1988 (Cth), unless:

(a)              you are adequately informed before giving consent;

(b)              you give consent voluntarily;

(c)              the consent is current and specific;

(d)              you have the capacity to understand and communicate their consent; or

(e)              as required or authorised by or under an Australian Law or a court/tribunal order.

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3.4 How do we use your personal information 

Generally, the information (including Personal Information) we collect can be used for any of the following purposes (“Primary Purpose”):

(a)              to perform a contract with you and provide you with our products and/or services;

(b)              professional or employment related purposes;

(c)              to communicate with you;

(d)              to manage our relationship with you;

(e)              to provide you with support, including technical support;

(f)               where we have legitimate interests to process the personal data and they are not overridden by your rights;

(g)              provide marketing to you;

(h)              to protect you;

(i)               to provide technical support to you;

(j)               in accordance with a legal obligation;

(k)              for analytical and reporting purposes; or

(l)               where we have your consent.

We will not share your Sensitive Information unless required by law or in an emergency situation.

We have expanded on these points below.

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​What information do we collect?
Your full name, gender, date of birth, age, residential address, postal address, email address, telephone number, mobile number, facsimile number, proof of identity information, tax file number, country of residence, CV, resume or application, professional advisors and/or date and time of visit to particular First Things First Coffee retail outlet or office location.

Why we might collect this information:

• to identify you and conduct appropriate identity checks;

• to review or otherwise consider your application, including completing the process to become a franchisee;

• to create an account with us;

• to allow you to become part of our loyalty program(s);

• to send you updates about your account;

• to communicate about and provide you with our products and services;

• to send you relevant news, promotion and marketing materials (including notifying you of the outcome of a competition);

• to respond to your requests, questions, comments and/or complaints;

• to register for conferences and special events;

• to facilitate your completion of surveys;

• to provide you with an opportunity to provide  feedback or share your experience;

• to comply with any legislative or regulatory contact tracing requirements;

• to review or otherwise consider your application, including your application for employment or to become a franchisee;

• for analytical purposes; or

• any other reason allowed at law
   

​What information do we collect?

Sensitive Information, such as information or opinions about your racial or ethnic origin, political opinions, or memberships, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation, and/or criminal record and medical history.

Why we might collect this information:

·      to assist you in a medical emergency;

·      to create a safe workplace for you and for others in accordance with our obligations under the Work Health and Safety Act 2011 (Qld);

·      any other reason required by law;

·      to the extent that we consider it is reasonably necessary to provide our products and services to you or to improve the products, services and business activities that we undertake;

·      when you complete surveys or provide us with feedback; 

·      to review or otherwise consider your application, including your application to become a franchisee;  

·      to comply with our legislative or regulatory reporting obligations, including to complete workplace gender and equality reporting; 

·      for analytical purposes; or

any other reason allowed at law.

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​What information do we collect?

​Information, communication or opinions about any of our products, services, transactions, payment history and business activities.

Why we might collect this information:

·      to improve the products, services and business activities that we undertake; 

·      to send you relevant news, promotion, informative materials and marketing materials; 

·      to keep you informed of our products, services, events or promotion; 

·      for analytical purposes; or 

any other reason allowed at law.

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​What information do we collect?

​Payment account information. However, the entirety of the details may be held by payment gateway providers.​

Why we might collect this information:

·      process a transaction;

·      to create an account with us;

·      to become part of our loyalty program(s);

·      to provide you with products, services and undertake business activities; or

any other reason allowed at law.

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​What information do we collect?

Video footage and audio surveillance.

Why we might collect this information:

·         for the safety and security of First Things First Coffee and its stores, staff, customers and suppliers;

·         for internal training and quality purposes; 

·         to ensure effective delivery of products and services;

·         to resolve disputes or problems; or

any other reason allowed at law.

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​What information do we collect?

Photos and any printed material posted on social media.

Why we might collect this information:

·         to communicate about and provide you with our current and future products and services;

·         to send you relevant news, promotion and marketing materials (including notifying you of the outcome of a competition);

·         to allow you to participate in competitions or promotions; 

·         for promotional activities; or 

any other reason allowed at law.

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​What information do we collect?

Identifiers (such as tax file number, business number, driver’s licence, passport), citizenship and residency details, details regarding and information provided by your referees, details regarding your Organisation, details regarding and information provided by your guarantor(s) and business partner(s), marital status, family and dependent status, details of proceedings or legal actions, financials/credit/criminal history checks, results of any pre-employment or profile tests, employment history, education history, identity documents, health information and next of kin details. Information around sales, profit and loss and other financial data.

Why we might collect this information:

·       to identify you;

·       to identify your referees and guarantor(s);

·       to conduct identity and criminal checks;

·       to conduct credit checks;

·       to assess your suitability for employment;

·       to assess your suitability for a relationship with us as a franchisee, supplier or other form of business partner;

·       to act as your agent;

·       to process your application;

·       to register for conferences and special events; 

·       to monitor performance (including performance of our Franchisees); 

·       for all things of or incidental to carrying out the role of a franchisor or a supplier to the Franchisees; or 

any other reason allowed at law.

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What information do we collect?

Information that may be collected by us or on our behalf via third parties including the date and time of your visit to our website, IP address, documents and pages you access, type of browser and setting, operating system, address of a recurring site you are about to visit; information you submit regarding payment particulars, device identifier, pages visited, language selections, cookies, tracking pixels, geographic area and location.

Why we might collect this information:

·       to provide you with local information and alerts about our products and services;

·       to improve our website and services;

·       to comply with local legal restrictions;

·       to gather anonymous statistics;

·       for analytical purposes;

·       to ensure proper function of the website and online software; or

any other reason allowed at law.

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What information do we collect?

Other information.

Why we might collect this information:

·       to provide you with products, services and undertake business activities;

·       as described to you at the point of collection; or

any other reason allowed at law.

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In some situations, you will have the option to deal with First Things First Coffee anonymously or through a pseudonym, however, where you are requesting products or services from us, it may become impractical to provide those products or services to you without verifying your identity. Where you fail to provide us information or where the information provided is incomplete and/or inaccurate, or you choose not to provide us with the information that we have requested, it may affect our ability to provide you with our products and services.

In the event that we receive identifiable information from a third party, we will take reasonable steps to ensure that you have given express or implied consent to the collection of that information. If it is determined that we are unable to have possession of the information under a relevant law, we will destroy the information or ensure that the information is de-identified.

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3.5 Tax File Number

We will handle your tax file number in accordance with Privacy (Tax File Number) Rule 2015 (Cth).

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3.6 Do Not Track settings

For some (but not all) services operated by First Things First Coffee, the “Do Not Track” browser or mobile application setting is accepted (which can be adjusted in your browser). First Things First Coffee does not currently respond to all “Do Not Track” signals. First Things First Coffee continues to review new technologies and may adopt applicable standard on such matters.

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3.7 Disclosure of Personal Information

(a)              Primary Purpose

We will collect and use the Personal Information for the Primary Purpose(s) as provided in this Policy.

As well as the abovementioned purpose, the primary purpose includes facilitating our internal business processes, communicating with customers, prospective customers and other external parties, providing ongoing marketing information about our products and services, complying with our legal obligations and dealing with enquiries and complaints.

(b)              Secondary Purpose

In certain circumstances, the law may permit or require us to use or disclose Personal Information for other purposes, for instance where a client would reasonably expect us to and the purpose is related to the purpose of collection.

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3.8 Disclosing your information

We may share your information with:

(a)              any of our ‘associates’ (as that term is defined in section 50AAA of the Corporations Act 2001 (Cth));

(b)              third parties including:

(c)              franchisees;

(d)              regulators, including Commonwealth and State Governments;

(e)              superannuation fund administrators;

(f)               business partners, agents, suppliers and subcontractors;

(g)              payment providers;

(h)              software providers;

(i)               any other entities disclosed in this policy,

(j)               any prospective buyer of any part of our business or assets; or

(k)              where we are required to disclose your information in order to comply with any legal obligation, or in order to enforce any agreements; or to protect the rights, property, or safety of us and our customers, or others. This includes, where relevant, exchanging information with organisations for the purposes of fraud protection and credit risk reduction.

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3.9 Storing your information

First Things First Coffee and Zarraffa’s Coffee is a growing and mobile business. In order to offer a consistent service to you we may store and manage data electronically or in paper form. Where data is stored electronically, it is done so by a third party cloud service provider that may store your information or a backup of your information in a jurisdiction other than Australia. Your Personal Information may reside on a servers outside of Australia and as determined by those third party providers from time to time. At Effective Date, we understand our third party service provider servers are in the in Australia, New Zealand, the United States of America, Germany, Ireland, Luxembourg, Singapore or such other locations that the third party cloud service provider determines from time to time. The data that we collect from you may be transferred to, and stored to these servers or processed by Organisations operating in other countries, who work for or are otherwise engaged by First Things First Coffee or for one of our suppliers.

We will take all steps reasonably necessary to ensure that your information is secured from misuse, interference, loss, unauthorised access, unauthorised modification or unauthorised disclosure. Any information will be handled in accordance with this Policy and applicable privacy laws. Despite using all steps reasonably necessary, the transmission of information through the internet is not completely secure.

When First Things First Coffee collects your Personal Information, First Things First Coffee will provide notification of the collection to you.

We will take all steps reasonably necessary to ensure that your Personal Information is handled in accordance with the APPs and this policy. Despite our endeavours, the transmission of information through the internet is not completely secure.

Submission of any information to First Things First Coffee is an acknowledgement that you agree to such use, storage and disclosure and the risk (if any) associated thereto.

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3.10 Disclosing your information

First Things First Coffee may share your information with:

(a)              any of its ‘associates’ (as that term is defined in section 50AAA of the Corporations Act 2001 (Cth));

(b)              third parties including our Franchisees, business partners, suppliers and subcontractors. This includes sharing the information with suppliers of IT based solutions and data hosting providers;

(c)              financial institutions such as banks, when processing financial transactions, any prospective buyer of any part of the First Things First Coffee or Zarraffa’s Coffee business or asset and to their legal and accounting advisors or representatives; 

(d)              with third parties to help us use your Personal Information and provide our services, and/or employ you. Specifically, we share your Personal Information with the following service providers:

(e)              We use the following bookkeeping and accounting services to provide the Services;

(f)               We may use Google Analytics to help us understand how our customers use the website;

(g)              We may also use Facebook Pixel as an analytics tool to help us understand how our customers use the website and to determine how effective our advertisements on Facebook and Instagram are;

(h)              general public in instances of announcing the winner of a competition, including via website or social media account;

(i)               with third parties:

(i)               when you have expressly approved the disclosure; or

(ii)              where your consent to disclosure can be reasonably inferred in the circumstances; and/or

(j)               any other party where we are required to disclose your information in order to comply with any legal obligation, in order to enforce any agreements or to protect the rights, property, or safety of First Things First Coffee or Zarraffa’s Coffee and its customers, or others. This includes, where relevant, exchanging information with Organisations for the purposes of fraud protection and credit risk reduction.

(k)              We will not share your Sensitive Information unless required by law or in an emergency situation.

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3.11 Accessing and correcting your information

(a)              You may request access to Personal Information that we hold about you at any time by contacting our Privacy Officer using the details set out in this Policy. We will respond to any such request for access to Personal Information within a reasonable timeframe and we will provide you access to the Personal Information that we hold about you, unless we are authorised or otherwise permitted by law not to do so. If we refuse your request to give access, then we will give you our comments in writing, outlining:

(i)               our reasons for refusal;

(ii)              the manner available to you to make a complaint about our decision; and

(iii)             any other information required by law.

(b)              We may charge you a reasonable fee for processing your request to access your Personal Information.

(c)              If upon receiving your Personal Information, or at any other time, you believe the Personal Information that we hold about you is incorrect, out of date, incomplete, irrelevant or misleading, please notify our Privacy Officer using the details set out in this Policy.

(d)              If we decline to correct your Personal Information as requested by you, a reason for refusal will be provided except to the extent that it is unreasonable to do so. In the event that we decline the request to correct Personal Information, you may request to associate a statement with your Personal Information.

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3.12 Complaints

Should you believe that we have not fulfilled our obligations under any relevant privacy law or have not complied with the terms of this Policy or would like to appeal a decision made by us in relation to your Personal Information, you can make a complaint in writing to our Privacy Officer using the contact details set out in this Policy.

We will respond to you within a reasonable period of time (or where a period is specified by any law, that period) to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.

If after getting our response you are still not satisfied that your complaint has been resolved or adequately dealt with, you may direct your complaint to the Office of the Australian Information Commissioner (). The contact details of the OAIC are listed on their website: www.oaic.gov.au

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3.13 First Things First Coffee stores

It is noted that the coffee shops branded First Things First Coffee are operated by ZC NDS Pty Ltd ACN 623 767 528 which is a subsidiary of Zarraffa’s Coffee Group Pty Ltd ACN 608 519 375.

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3.14 Contact us

If you have any comments, concerns or questions regarding this Policy or Personal Information that First Things First Coffee holds about you, please contact our Privacy Officer by email to privacy@zarraffas.com or by post at:

Privacy Officer
Zarraffa’s Coffee Legal Department
PO Box 2089
BEENLEIGH QLD  4207, Australia

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4 Definitions

In this Policy, unless contrary to or inconsistent with the context:

(a)              Franchisee means a franchisee of Zarraffa’s Franchising Pty Ltd ACN 093 874 250 authorised to operate a First Things First Coffee or Zarraffa’s Coffee retail outlet from time to time.

(b)              Organisation means a natural person, a body corporate, a partnership, any other unincorporated association, or a trust, that is not a small business operator, a registered political party, an agency, a State, Territory or national authority or a prescribed instrumentality of a State, Territory or Nation.

(c)              Personal Information means information or an opinion about an identified natural person or a natural person who is reasonably identifiable, whether the information or opinion is:

(i)               true or not; and

(ii)              recorded in a material form or not,

but excludes Employee Records.

(d)              Privacy Officer means the Privacy Officer of First Things First Coffee, as appointed from time to time or a position of a similar nature.

(e)              You includes any of the following:

(i)               any individual visiting the First Things First Coffee website;

(ii)              Franchisees or prospective franchisees;

(iii)             Organisation;

(iv)             customers of First Things First Coffee;

(v)              customers of Franchisees;

(vi)             suppliers or contractors (whether current, previous or prospective) of First Things First Coffee or Zarraffa’s Coffee. This includes the employees of such suppliers and contractors; or

(vii)            employees of First Things First Coffee or Zarraffa’s Coffee.

(f)               First Things First Coffee, we and us means Zarraffa’s Coffee Group Pty Ltd ACN 608 519 375 and/or any of its “subsidiaries”, as the context requires. The term “subsidiaries” has the same meaning as in the Corporations Act 2001 (Cth)).