POLLITO
PRIVACY POLICY
1. Introduction
1.1 Thank you for visiting www.pollito.com.au (Website). Pollito Chipotle Grill and its related bodies (collectively referred to as Pollito, we, us) are committed to protecting the privacy of personal information in accordance with privacy laws in Australia.
1.2 This Privacy Policy sets out Pollito’s approach to handling personal information, and how Pollito is expected to handle your personal information, including the collection, usage, storage and security, disclosure and provision of access to your personal information. We respect your rights to privacy under the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles (APPs) and we comply with all of the Act’s requirements with respect to the collection, usage, management, storage, disclosure and provision of access to your personal information.
1.3 The scope of this Privacy Policy covers the personal information handling practices of restaurants owned by Pollito in Australia, its website and mobile applications.
2. What is personal information?
2.1 When used in this Privacy Policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, gender, date of birth, address, telephone number, email address and profession or occupation.
2.2 If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
3. What personal information does Pollito collect and how is it collected?
3.1 We will collect your personal information in a fair and lawful manner. Where it is practical to do so, Pollito will collect your personal information directly from you, and only to the extent that we reasonably require for one or more of our business functions or activities, to provide you with a Pollito product or service.
3.2 The personal information we may collect may include, amongst other things:
a. personal information that you provide to us when you participate in a promotion, competition, promotional activity, survey, market research, SMS, MMS and other mobile services, subscribe to our mailing list, participate in our Chipotle Club loyalty programme or other loyalty program introduced from time to time, utilise the Pollito mobile application, participate in and contribute to our online forums or interact or follow our social media pages like Facebook, Twitter, LinkedIn and Instagram. This information may include, for example, your first and last names, postal and physical addresses, email address, telephone numbers, facsimile number, age, date of birth and Chipotle Club membership details;
b. personal information that you provide to us via our restaurants or when you place an order in a restaurant by telephone or via an online ordering system, when purchasing a gift card or when you logon to wi-fi provided at one of our restaurants. This information may include, for example, your first and last names, postal and physical addresses, email address, telephone numbers, age, date of birth, menu preferences, previous order information, loyalty membership details, credit card details, Internet Protocol (“IP”) address and your demographic and other data for market research, advertising and promotional purposes;
c. personal information that you provide to use via telephone, email or in person when making a request or enquiry or submitting compliments, complaints or feedback. This information may include, for example, your first and last names, postal and physical addresses, email address, telephone numbers, facsimile number, age, date of birth, loyalty membership details, previous order information and IP address;
d. information regarding your interests, preferences, purchasing behaviour and experience with our products and services, together with any additional information necessary to deliver those products and services and respond to your enquiries;
e. if you are applying for a position of employment with Pollito, we will collect information as detailed in the section below entitled “Employment Applications”;
f. any additional information relating to you that you provide to us directly through our online ordering system, any third-party online ordering system, your access and use of our Website or indirectly through use of our Websites, social media platforms, online forums, applications, wi-fi service or online presence, or through our representatives or otherwise.
3.3 Pollito may also collect some information that is not personal information because it does not identify you or anyone else. For example, the collection of anonymous answers to surveys or aggregated information about how users use our Website.
3.4 Except for when you are applying for a position of employment, Pollito will not collect sensitive information about you (which includes information about your racial or ethnic groups or political or religious beliefs) unless you have specifically consented to such collection or the collection is required by law.
3.5 Polltio will use your personal information only for the particular purpose that you provided it, or for a directly related purpose. We may otherwise use your personal information where that other use is required or permitted by law or with your express or implied consent.
4. Cookies and Web Beacons
4.1 In some cases we may also collect your personal information using cookies where our third-parties, or Pollito directly, sends "cookies" to your computer or devices, or use similar technologies, to enhance your online experience at our Website and across the Internet. "Cookies" are files that can identify you as a unique customer and store your personal preferences as product preferences to tell us which site pages you have visited and in what order. This enables us to recognise your computer and greet you each time you visit our Website. Pollito uses cookies and other technical information to personalise your visit to the Website, to analyse traffic on the Website, to track user trends, patterns and selections for authorised downloads and for technical reasons connected with your use of the Website. Cookies can either be permanent (i.e. they remain on your computer until you delete them) or temporary (i.e. they last only until you close your browser). If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. However, please note that certain areas of the Website can only be accessed in conjunction with cookies or similar devices.
4.2 Pollito may also use "web beacons" that monitor your use of our Website. Web beacons (or web bugs) are small strings of code that provide a method for delivering a graphic image on a web page for the purpose of transferring data, such as the IP address of the computer that downloaded the page on which the web beacon appears, the Uniform Resource Locator (“URL”) of the page on which the web beacons appears, the time the page containing the web beacon was viewed, the types of browser that fetched the web beacon and the identification number of any cookie on the computer previously placed by that server. When corresponding with you via HTML capable e-mail, web beacons let us know whether you received and opened our email. By setting your web browser to display HTML emails as text only, you may be able to prevent the use of some web beacons.
4.3 On their own, cookies or web beacons do not contain or reveal any personal information. However, if you choose to provide us with personal information, it can be linked to the anonymous data stored in the cookies and/or web beacons.
5. What happens if Pollito can’t collect your personal information?
5.1 You are not required to disclose your personal information to us, and where lawful you may deal with us anonymously or using a pseudonym.
5.2 However, if you remain anonymous, use a pseudonym or choose not to provide the personal information described above, some or all of the following may happen:
a. we may not be able to provide the requested services or products to you, either to the same standard or at all;
b. we may not be able to provide information about products and services that you may want, including information about special promotions;
c. we may not be able to provide you with details, information or an appropriate response to any enquiries or requests for information that you have made; or
d. we may be unable to tailor the content of our Website and other relates sites to your preferences and your experience of our Website may not be as enjoyable or useful.
6. For what purposes does Pollito collect, hold, use and disclose your personal information?
6.1 Pollito collects personal information about you to perform its business activities and functions and provide the best possible quality of customer service. The way in which Pollito will collect, use and disclose your personal information depends on the reasons for which it was collected, however this is generally for the following purposes:
a. processing meal orders that you place in our restaurants or via an online meal ordering system, providing you with Pollito’s products and services and processing meal refunds where applicable;
b. processing orders for gift cards that you place in restaurants, by telephone or via the gift card ordering system;
c. where you choose to receive mobile services and content via SMS, MMS and other mobile services, including the Pollito mobile application. This information is used to deliver such mobile services and content to you, to carry out market research, to track sales data, to inform you of upcoming events and to help plan and promote other promotional activities which may be of interest to you;
d. to respond to any questions or queries that you may have and to process, investigate and respond to any feedback, complaint or compliment made by you;
e. promoting and marketing current and future products, services, promotions, offers, games, programs and competitions to you;
f. to improve the operation or navigation of our Website and social media platforms, and inform you of changes made to the Website and/or social media platforms;
g. assisting you with remembering and re-ordering from Pollito’s menu in the future, developing an online customer profile and keeping your contact details up to date;
h. to obtain opinions or comments about products and/or services and to conduct other statistical and market research with a view to improving our services and products;
i. for the purposes of and incidental to your use of wi-fi services (if applicable);
j. processing and considering your employment application (if applicable) (see Employment Application section below);
k. facilitating internal business operations, including fulfilment of any legal, security, and regulatory requirements.
6.2 Pollito may also use your personal information for other purposes not listed above which will be made clear to you at the time we collect your personal information, for a directly related purpose, where you have consented to such use or disclosure, or for such other purposes as may be required or permitted by law.
7. To whom may we disclose your information?
7.1 For the purposes described in the section above, Pollito may disclose your personal information to, and share personal information with, the following:
a. Pollito’s subsidiaries and related bodies corporate, especially where you have placed an order online via an online ordering system, or made an enquiry or complaint relating to a restaurant;
b. Pollito’s officers, employees, contractors or agents for the purposes of operating its business or its Website, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, agencies, advertisers and business partners, payment processors, data entry service providers and professional advisors such as accountants, legal advisors, business advisors and consultants;
c. suppliers and other third parties with whom Pollito has commercial relationships for business, marketing and other related purposes;
d. third parties where the law requires or authorises to do so; and
e. any organisation for any authorised purpose with your express consent.
7.2 Pollito may combine or share any personal information that we collect from you with information collected by any of our related bodies corporate (within Australia).
8. Direct marketing materials
8.1 Pollito may send you direct marketing communications and information about its own products and services and direct marketing communications on behalf of other related companies within Pollito that we consider may be of interest to you. These communications may be sent in various forms, including by post, telephone calls, SMS, MMS, fax and email in accordance with applicable laws. By providing your personal information to us, you consent to Pollito sending you those direct marketing communications by any of those methods.
8.2 If you indicate a preference for a method of communication, then 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 by contacting us (see the details below), or by using opt-out facilities provided in the marketing communications.
8.3 With your consent, Pollito may use your personal information for the purposes of direct marketing of products and services on behalf of selected third parties, provided you have agreed to your details being passed on to third parties.
9. Online Forums
9.1 From time to time we may provide opportunities for you to engage with us through written discussions, communications and comments through interactive online forums and social media platforms. Material deemed to be inappropriate or offensive will be removed from these forums and platforms and Pollito reserves the right to determine what comment is inappropriate or offensive in its absolute discretion.
9.2 All statements and opinions expressed in the articles and communications are those of the individual contributors and not the statements and opinion of Pollito.
9.3 Information you disclose to Pollito through such online forums and platforms may be read, collected and used by us. However, as these forums and platforms are public, it may also be read, collected and used by other users, the actions of whom Pollito cannot control and for whom Pollito takes no responsibility. You agree to use your discretion and exercise caution when providing your personal information.
10. Employment Applications
10.1 Generally, the type of personal information that Pollito collects about applicants is the information requested and included in your application for employment, for example your full name, postal address, telephone numbers, email address, residency status, work rights, education details, employment history, references and other information relating to your work experience.
10.2 In considering your application, we may also obtain personal information about you from third parties, for example from your previous education institutions, employers or nominated referees. Subject to your consent, we may also collect sensitive information about you such as information about your health (including any disability) or any criminal record you may have.
10.3 Pollito also collects personal information for any one or more of the following purposes:
a. assessing you for a position with Pollito or one of its related entities;
b. assessing whether you are suitable to progress through each stage of the recruitment process for a vacant position; and/or
c. storing your information for future employment opportunities;
10.4 We may disclose your information to:
a. referees or previous employers;
b. recruitment agencies, agencies or contractors acting on Pollito’s behalf;
c. Pollito’s related entities;
d. employees and contractors of Pollito in other locations or other Pollito entities;
e. government agencies to verify your rights to work; and
f. law enforcement agencies to verify whether you have a criminal record.
10.5 If we engage third party contractors to perform services, which involves the handling personal information, Pollito will take reasonable steps to prevent the contractor from using the personal information, except for the purpose for which it was supplied.
11. How can you access and correct your personal information?
11.1 You may request access to any of your personal information by contacting us (see the details below). Where Pollito holds information that you are entitled to access, Pollito will try to provide you with suitable means of accessing it (for example by mailing or emailing it to you). A reasonable administration fee may be charged to cover the costs of meeting your request. No charges will apply for simply making the request or for making any corrections to your personal information.
11.2 There may be instances where it is not possible to grant you access to the personal information held. For example, access may be refused if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If those circumstances written reasons for any refusal will be given to you.
11.3 If you believe that any personal information that Pollito holds about you is incorrect, incomplete or inaccurate, then you may request to amend it.
11.4 To protect your privacy and security Pollito will take reasonable steps to verify your identity before granting access.
12. What is the process for complaining about a breach of privacy?
12.1 If you believe that this Privacy Policy has been breached, or your personal information has not been collected, stored, used or disclosed appropriately, please contact Pollito using the contact information below, and provide details of the incident for investigation. Pollito requests that complaints about breaches of privacy be made in writing so that we can be sure about the details of the complaint.
12.2 Pollito will attempt to confirm as appropriate and necessary with you, your understanding of the conduct relevant to the complaint and what you expect as an outcome. Pollito will inform you whether an investigation will be conducted.
12.3 Pollito will contact you to advise you of the outcome and invite a response to the conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.
13. Does Pollito disclose your personal information to anyone outside Australia?
13.1 In some cases, Pollito may disclose your personal information to entities located outside of Australia, who require access to collect, use, store and disclose your personal information in connection with fulfilling the requirements of this Privacy Policy, including to the following:
a. related bodies corporate located overseas; and
b. other third parties located overseas.
13.2 Pollito will take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
14. Security
14.1 Where Pollito stores your personal information depends on what interaction you have had with us. Some areas may include servers and databases for processing customer, franchisee and employee enquiries, comments and feedback, mail exchange servers, third party servers or email databases for marketing communications.
14.2 Pollito will take reasonable steps to ensure that your personal information is protected from misuse, interference and loss and from unauthorised access, modification or disclosure. Pollito may hold your information in either electronic or hard copy form. Your personal information is kept for as long as it is required for the purposes for which it was collected or as otherwise required by law. Pollito will take appropriate measures to destroy or permanently de-identify your personal information if it is no longer required to retain it. These measures may vary depending on the type of information concerned, the way it was collected and how it was stored.
14.3 As Pollito’s Website is linked to the Internet, and the Internet can be inherently insecure, Pollito cannot provide any assurance regarding the security of transmission of information you will communicate online. Pollito 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 Pollito online is transmitted at your own risk.
15. Links
15.1 Our Website may contain links to other Websites operated by third parties which may be of interest to you. Pollito makes no representations or warranties in relation to the privacy policies 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.
15.2 Pollito may use third party advertisements on its Website. Third party advertisements are not recommendations or endorsements by Pollito or any of its related bodies corporate or affiliates. To the extent permitted by law, Pollito is not responsible for the content (including representations) of any third party advertisement on the Website. These third parties may view, edit or set their own cookies. The use of these technologies by such third parties is subject to their own privacy policies and is not covered by this Privacy Policy.
16. Changes to this Privacy Policy
16.1 From time to time, this Privacy Policy may be revised. Any updated version of this Privacy Policy will be posted on the Website. Your continued use of the Website, and acceptance of Pollito’s products and services, will be deemed acceptance of any amended Privacy Policy.
17. Contacting us
17.1 If you have any questions or comments about this Privacy Policy, please use the contact link on our website, or use the details set out below:
support@pollito.com.au
POLLITO CHIPOTLE GRILL
Shop 1-2,
Broadway Fair Shopping Centre
88 Broadway
Nedlands WA 6009
Telephone: 08 6424 8648
This Privacy Policy was last updated on 25 June 2020.