PRIVACY POLICY 

1. Purpose 

The purpose of this privacy policy is to describe the types of personal information that Cornetts (the Company) collects, holds, uses and discloses. It outlines our personal information handling practices and notify whether we are likely to disclose personal information to overseas recipients and, if necessary, how complaints can be made for inappropriately handled of private information. 

2. Scope 

This policy covers all Cornetts team members, the general public, suppliers and customers to the business and is subject to the Privacy Act 1988 (the Privacy Act) and to the requirements of the Australian Privacy Principles (APPs) contained in the Privacy Act and the Information Privacy Act 2009 (QLD). 

This policy is also a public document available to parties who provide personal information to the Compan

3. Definitions 

4. Process 

Adcome Pty Ltd (ABN 99 110 315 681) and all associates entitles, trading as Cornetts Supermarkets and Everfresh Fresh Markets (the Company), is committed to the protection of personal privacy within the scope of applicable law. This Privacy Policy covers the Company’s treatment of personal information that is collected, held, use and disclosed. 

Anyone covered by this policy should be aware that the handling of personal information by third parties will be subject to those third parties' own privacy policies, and participation in a loyalty program or other promotional offers may be subject to additional terms and conditions. Individuals should familiarise themself with those policies and terms and conditions before providing personal information or agreeing to participate in a loyalty program or other offers. 

The Company may update this Privacy Policy from time to time. The most current version is located Company websites at https://cornetts.com.au and https://everfreshfoodmarket.com.au . 

Types of personal information collected 

The types of personal information that collected, and held will vary depending on dealings conducted with the Company. This information may include any or all of the following: 

• name, address(es), telephone number(s) and other contact details; 
• electronic address(es); 
• transaction details relating to customer purchase of products, services or benefits; 
• participation in a loyalty program:
  - membership details (e.g. member number) for that loyalty program; and
  - details relating to the use or acquisition of products, services or benefits from organisations that operate, administer or provide products and/or services in connection with that loyalty program;
  - name, address, email address and contact information. 
• payment information (such as credit card or bank details); 
• company information (such as ACNs, ABNs, email addresses) 
• personal data (such as copies of driver’s licenses, birth certificates, passport, past employment history, qualifications, date of birth, address, phone numbers and gender) 
• Electronic images captured on CCTTV, and; 
• any other personal information which you provide to us. 

Cornetts may collect sensitive information from team members, customers and suppliers, but only if individuals or entities agree to provide it. The types of sensitive information that may be collected may include criminal checks, work related reference checks, biometric information, health reports, credit history and/or company data. If an induvial or business agrees to provide us with sensitive information, it will only be used it in accordance with the Privacy Act 1988 (Cth) and/or the Information Privacy Act 2009 (QLD). 

From time to time, individuals provide the Company, or the Company may collect, personal information of a third party (for example, for delivery purposes). Where anyone provides personal information of a third party, it is the individuals responsibility to ensure that those persons are aware of this Privacy Policy, understand it and agree to accept it. 

Individuals do not have to provide the Company with any personal information. However, if they do not do so, the Company may not be able to provide the products, services or benefits requested. 

How is personal information collected? 

Generally, the Company collects personal information directly, by: 

• electronic submission of information through the website or employee management systems; 
• in person or on a form provide to the Company; 
• in the course of the Company providing information with a requested product, service or benefit, where contact details are required; 
• in the course of applying for credit with the Company; 
• where entering a promotion or competition conducted by the Company or an associated entity; 
• in relation to a job application; 
• through CCTV surveillance cameras used at stores and in the support office; 
• when individuals or entities have other dealings with the Company. 

The Company may collect personal information indirectly, for example through: 

• transactions enter into in stores; 
• providers who support transactions in stores, including credit card providers and point of sale systems providers; 
• CCTV footage; 
• organisations that operate, administer or provide products and/or services in connection with any loyalty program into which individuals participate; 
• related bodies corporate; 
• business partners; and 
• third parties who supply services to the business, e.g. point-of-sale terminal vendors who report transaction data to us. 

Consequences of not provide personal information 

If an individual does not provide personal information, the Company may not be able to provide products, services or benefits as requested. For example, if an individual does not provide the Company with personal information requested in connection with registration for a loyalty program, Cornetts and/or the organisation operating and administering the program may not be able to provide program benefits and/or administer membership. If an individual or business does not provide the Company with information to facilitate the payment of credit accounts, fulfilment of orders may be impacted. Where contractor or employment documentation is not provided in total, payment for services or wage may be delayed. 

When and why personal information is collected, held, used and disclosed 

The Company will use and disclose the personal information collected for the purpose disclosed at the time of collection, or otherwise as set out in this Privacy Policy. The Company will not use or disclose personal information for any other purpose without first seeking consent, or where authorised or required by law. 

The Company may collect, hold, use and disclose personal information for the following purposes: 

• to establish and maintain a relationship with the Company; 
• to provide the products, services or benefits as requested by an individual or another business; 
• in the case of loyalty program membership, to enable: participation in the program, and enjoyment program benefits; 
• to better understand and gain insights into store and campaign performance, shopper trends and to plan future developments, member offers and campaigns; and, 
• for organisations that operate or administer the loyalty program, to perform their functions in relation to that program, including to undertake analysis on retailer performance and trends, and to provide aggregated, anonymous statistics on these matters to other program participants; 
• to answer any inquiry individuals or businesses make directly to the Company; 
• to register parties for events or promotions, 
• to make payment for services, and 
• to otherwise enable us to perform our business activities and functions. 

The Company may disclose personal information to organisations that participate in, operate or administer any loyalty program supported by the Company. The Company may also disclose personal information to other third parties who work with us in our business to provide, promote or improve the products or services individuals have requested or are interested in, such as: 

• couriers and delivery contractors; 
• consultants and professional advisers; 
• training and service providers; 
• parties where explicit consent has been provided; 
• if subpoenaed or required to provide information in a matter of law. 

Direct marketing 

The Company may also use and disclose personal information to send direct marketing, including electronic direct marketing, from: 

• the Company; 
• related bodies corporate and Metcash Trading Limited; 
• the operator or administrator of the loyalty program in which individuals participate; and 
• third parties who provide services to the Company, related bodies corporate, Metcash Trading Limited or the operator or administrator of a loyalty program in which individuals and the Company participate. 

The direct marketing may relate to: 

• membership of, and benefits associated with, loyalty programs in which individuals and the Company participate; 
• the Company’s products and services; 
• the products and services of other parties; and 
• new developments the Company believe may be of interest to loyalty program participants. 

Loyalty participants may opt-out of receiving this direct marketing through the unsubscribe function that will be made available with each direct marketing communication. Where the opt out option is taken, participants may not be able to receive benefits otherwise receive, that is, not be able to receive all the benefits of participating in the loyalty program. 

CCTV and Surveillance 

The Company uses CCTV systems to record images to assist in the provision of a safe and secure environment and for the protection of Company assets, property, team members and customers. CCTV cameras are located in the Company’s stores and support office and are used to: 

• maintain public safety; 
• maintain the security of Company property; 
• assist in the prevention of crime; 
• reduce the fear of crime and offer reassurance to team members; and 
• facilitate the apprehension and prosecution of offenders in relation to crime. 

CCTV footage or images will only be accessed by persons authorised to do so, that is, Managers and Assistant Managers overseeing a Company store and/or Senior Managers or above at support office. 

CCTV footage and images may only be viewed for the following purposes: 

• the investigation of an alleged crime; or 
• the investigation into team member breach of policy or procedure, 
• the investigation of a safety or security incident. 

CCTV footage or images may be used by the Company after an incident to assist in the identification and detection of offenders or in the investigation team member breach of policy or dishonesty, of a safety or security incident. 

Should an incident occur, footage may be provided to the Queensland Police Service for law enforcement purposes on approval from a Senior Manager or above. Images or footage from CCTV will not be given to any other person or agency unless authorised or required by law. 

How is personal information stored and protected 

The Company stores personal information in a combination of computer storage facilities, paper-based files and other records. In so doing, the Company takes reasonable steps to protect personal information from misuse, interference and loss, and unauthorised access, modification or disclosure. 

CCTV footage and images are retained for as long as is required for the stated purpose. In general, footage is overwritten every 30 days, unless saved and stored securely by the Company. 

The Company takes reasonable steps to destroy or permanently de-identify personal information no longer need it. 

Is personal information sent overseas? 

Members of the IGA Rewards program may have personal information disclosed to or accessed by overseas recipients as described in the IGA Rewards privacy policy (www.igarewards.com.au/privacy) for purposes connected with that program. 

Requesting to access or correct personal information 

The Company will take reasonable steps to make sure that the personal information collected, held, use or disclose is accurate, complete and up to date. 

Loyalty program details can be updated on the Company website using the “contact” option or by contacting the operator of the loyalty program at www.igarewards.com.au. Please refer to the IGA Rewards privacy policy (www.igarewards.com.au/privacy) for details of how to request access or correct information held by the operator or administrator of the IGA Rewards program. 

At the explicit request of an individual, the Company may provide a copy of any personal information relating to that individual which the Company holds, unless an exception under the Privacy Act 1988 or Information Privacy Act 2009 applies. The Company may charge a reasonable fee for retrieving this information, in which case the Company will inform the individual of the fee and obtain agreement to that fee before providing the information. 

The Company will promptly acknowledge and investigate any complaint about the way the Company manages personal information. 

Digital Technologies 

The Company and third parties may use digital technologies such as cookies, web server logs and web beacons in connection with the use of websites and other online services. Some of these technologies may operate without collecting or using any personal information. Please note this privacy policy applies to the Company’s collection, use, disclosure and storage of personal information only. 

The Company website may use cookies to track user traffic patterns and to better serve users who revisit the website. A cookie is a small data file that a website may write to an individual’s or company’s hard drive. A cookie file can contain information, such as a user ID which the website uses to track the pages you have visited. Individuals can refuse all cookies by turning them off in the browser. However, full functionality for the Company’s websites requires the use of cookies. 

Information is also generated whenever a page is accessed on the Company’s website that records information such as the time, date and specific page. The Company collects such information for statistical and maintenance purposes that enables the business to continually evaluate website performance. 

How to contact us or make a complaint 

Questions or complaints about this Privacy Policy, to update information the Company holds or to register a complaint about the collection, use or disclosure of personal information under this Privacy Policy, can be made through the following contact means: 

Website: https://cornetts.com.au/contact/ or 

https://cornetts.com.au/whistleblower/whistleblower/ 

Email: reception@cornetts.com.au 

Phone: (07) 3293 6600 

A complaint regarding a third party's handling of personal information can be made directly to the third party at the details set out in their privacy policy, e.g. please refer to the IGA Rewards privacy policy (www.igarewards.com.au/privacy) for details of how to make a complaint to the operator or administrator of the IGA Rewards program. 

The Company will take reasonable steps to remedy any issues resulting from failure to comply with this privacy obligations. If the Company’s response to a complaint does not address the concerns to a satisfactory level, an individual or business may have the right to make a complaint to the Office of the Australian Information Commissioner, whose website is located at www.oaic.gov.au. 

1. References 
2. Privacy Act 1988 (Cth) 
3. Information Privacy Act 2009 (QLD) 
4. Australian Privacy Principles 
5. Freedom of Information Act 1982 (Cth) 
6. Right to Information Act 2009 (QLD) 

1. Associated Documents 

Policy 

• Cornetts Code of Conduct 
• Whistleblower Policy 

Procedure 

• Grievance Procedure 

Last Reviewed: October 2024
Last Updated: 3 October 2024
Version Number: 2.0