Updated as at: 19 May 2015
By visiting and/or using our websites, joining our Carnival Card loyalty program or otherwise providing us with your personal information, you agree to your personal information being collected, held, used and disclosed as set out in this policy.
We reserve the right to may make changes or updates to this policy from time to time. Should we do so, we will update the policy on this website accordingly. Consequently, please check this website regularly to stay informed of any updates. Your continued use of our websites, participation in the Carnival Club loyalty program, or the provision of further personal information to us after this policy has been revised constitutes your acceptance of the revised policy.
All personal information that we gather is collected in a fair and non-intrusive manner, with your consent, in order to be able to meet any orders, provide our services and/or provide any assistance you have requested. Personal information means information or an opinion about you from which your identity is apparent or can reasonably be ascertained. This is whether the information or opinion is true or not and whether it is recorded in material format or not.
We will only collect personal information from you that is necessary for us to be able to meet any orders, provide our services and/or provide any assistance you have requested. We will seek to ensure that we do not collect information from you in any way that is unlawful or unreasonably intrusive.
The personal information that we may collect from you and hold (“Information”) may include information such as your first and last names, address, telephone and mobile number(s), mac addresses, email address and credit card details (if you are making an online payment). In respect of your credit card details we will only hold some information and this is only where you have directed us to take a payment from such credit card.
In respect to situations when you make an application to become an employee we also may collect some sensitive information from you for the purposes of assessing your suitability (to which you have consented).
If you respond voluntarily to our surveys or other interactive communications, we collect the responses and use the information to improve the quality and range of our own and/or our supplier’s products and services, or for the purposes of meeting any Carnival Club Card program terms and/or competition terms you have first agreed to.
We collect your Information in various ways, including when you:
visit any of our websites (including any application managed by us and/or for us);
apply or participate in the employment process;
interact or follow our social media pages/profiles;
enter into a competition or promotion through any medium;
become a Carnival Club Card member;
when you “Like” our Facebook page or participate in any surveys, promotions and competitions through our Facebook page;
participate in a survey or in focus groups, polling and/or other market research activities; or
request information from us or submit any feedback or query.
We do not collect information about your political, philosophical, religious beliefs or sexual preferences.
Whenever it is reasonable and practicable to do so, we will collect that information directly from you, however, you acknowledge and consent to us receiving information from our suppliers, and/or entities we sponsor and/or are affiliated with. In such instances we will encourage such parties to act in accordance with the principals set out in this policy. If we otherwise have to collect personal information about you from someone else, we will take reasonable steps to ensure that you are aware of that fact.
We will seek consent for the use of your personal information at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (for example when we want to use information for a use not previously identified). The form of consent we seek, whether it is express or implied will depend on the sensitivity of the information and the reasonable expectations of the individual in the circumstances. You may withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice. If you wish to withdraw consent, please contact our Privacy Officer in the manner described below. We will inform you of the implications of withdrawing consent at or before the time of withdrawal.
Use and Disclosure
We use your Information for the purpose for which it was provided to us, other related purposes and as permitted or required by law. Such purposes include, but are not limited to, the following:
providing you with the assistance, products and/or services you have requested;
allowing you to participate as a Carnival Club loyalty program member;
enhancing our services;
processing any job application you may submit;
providing you with any employment you may request;
processing any orders you place with us;
judging competitions, fulfilling prizes, awards and purchases;
conducting market research so that we can better understand the needs of our customers and tailor our future products and services accordingly;
sending you offers or information on products or services that we consider will be of interest to you (if you have consented to receiving such);
keeping you informed about any changes to our websites as well as goods and/or services;
determining the number of visitors to our websites and conducting reviews of our websites;
any other purposes identified at the time of collecting your Information;
to notify you of upcoming events and/or promotions by us; and
Monitor and address complaints, other feedback and/or to resolve disputes.
Personal information you provide is considered a company asset and may be included among transferred assets if we merge, combine or divest part of our business unless prohibited from doing so by law.
International and Third Party disclosure of your Information
We may share personal information within the Lapa Brazilian Barbecue network, which includes the Lapa Brazilian Barbecue Operating Company, our franchisees, affiliated companies and these parties’ related entities.
Where appropriate, we may share your Information between ourselves, our related entities and with other third parties, including:
to meet the purpose for which it was submitted to us;
entities you have expressly allowed us to disclose your Information to;
any entities that we are required or permitted by law to disclose your Information to;
entities that supply domain name services, website design, SEO and other services;
we may share Information with agents, affiliates or service providers who act for or on behalf of us in connection with our business, or for further processing in accordance with the purpose(s) for which the Information was originally collected;
our related entities and third parties who provide services to us or on our behalf (for example third parties processing your online payments, IT and cloud storage service providers and processors, third party suppliers providing our SMS service and mailing houses);
if your personal Information is collected in connection with a joint promoter or service provider, to that joint promoter or service provider for marketing and research purposes;
if you place an order via any electronic means your details will be passed on to our credit card processor who will receive your credit card details for such orders; and
any other third parties notified to you at the time of collecting your Information or after the collection of your Information.
We do not sell personal information to third parties. However, with your permission, we will on occasion send marketing information on behalf of one of our business partners and/or sponsored entities about products or services they provide that may be of interest to you. You may be asked if you wish to receive marketing materials from these parties. If you elect to receive such materials, we will not share your personal information with these parties, but rather will send a mailing or e-mail on behalf of these parties.
We reserve the right to use or disclose any information as needed to satisfy any law, regulation or legal request, to protect the integrity of the site, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.
Accuracy of Personal Information
We will take reasonable steps to ensure that the personal information held by us about you is accurate, complete and up to date. To assist us, we ask that you notify us promptly if there are any changes to your personal information. You may ask us to correct any inaccurate information we hold about you and we will address your concerns within a reasonable period.
We will take reasonable steps to protect your personal information from misuse, loss, unauthorised access, unauthorized modification and/or unauthorized disclosure. However, constant changes to the Internet and technology means that we cannot guarantee that data transmission will be 100% secure or safe from attack from unauthorised intruders and no data protection or security measure is completely secure, particularly in relation to online transmissions. You must take care to ensure you protect your Information (for example, by protecting your usernames and passwords) and you must notify us as soon as possible after you become aware of any security breaches.
Your personal information, where not stored electronically, is stored in our secure office premises with restricted access or with an offsite secure storage facility. If we no longer require the use of your personal information, we will take reasonable steps to destroy or permanently de-identify it.
Access to Personal Information
We will provide you with access to your personal information upon request. We will endeavour to provide the information to you in a timely manner. You may be charged a fee for servicing your request which we will advise you at the time. There is no fee for lodging a request for access.
There may be circumstances in which we cannot provide you with access; for example, where this is required or authorised under the law, would have an unreasonable impact upon the privacy of other individuals or the request for access is frivolous or vexatious. We will advise you of the reasons if we deny you access.
If you need to update your personal information, please contact our Privacy Officer in the manner described below.
With the exception of when you apply for a job or franchise with us, we will not collect, use or disclose sensitive information (such as health information or information about racial or ethnic origins or political or religious beliefs).
When you apply for a job with us through any electronic or internet application, we generally collect the following details from you: full name, date of birth, whether you are legally allowed to work in Australia, whether you are an Australia citizen, home address, contact telephone numbers, email address, employment records, your gender, contact details of next of kin and any factors that may impact your ability to undertake the relevant role. We may also require and collect a copy of your passport, driver’s license and/or an equivalent identification card to confirm your identity.
Where applicable, you acknowledge consent has been provided for us to collect and use the sensitive information above for the purpose of assessing your suitability as a Lapa Brazilian Barbecue employee at the time of making your application.
Each time you visit our websites our server may collect some anonymous information, known as click-stream data, including the type of browser and system you are using; the address of the site you have come from and move to after your visit; the date and time of your visit; and your server’s IP address.
We may collect this information for statistical purposes to find out how the websites is used and navigated, including the number of hits, the frequency and duration of visits, most popular session
Links to other sites
In common with most websites, we use “cookies”. A cookie allows us to identify and more effectively interact with your computer. A cookie does not identify the individual User although they do identify the User’s browser type and Internet service provider. Cookies allow us to provide better customer service and enhance our relationship with our customers via collection of statistical information on website activity such as the number of Users who visit the Lapa Brazilian Barbecue website, the date and time of visits, the number of pages viewed, time spent on website, navigation patterns and origin of the User. You may be able to configure your browser so that it does not receive cookies but in doing so some of the functionality of the Lapa Brazilian Barbecue website may be lost.
How to stop receiving communication from us
To stop receiving any SMS service or email correspondence, simply visit the Carnival Club website and cancel your membership. If you are not happy with this outcome, please email the Privacy Officer at firstname.lastname@example.org
How to contact us
If you have any queries or wish to make a complaint about a breach of this policy or the privacy principles of the Privacy Act 1988 (Cth), you can contact or lodge a complaint to The Lapa Brazilian Barbecue Privacy Officer using the contact details below. You will need to provide sufficient details regarding your complaint as well as any supporting evidence and/or information.
The Lapa Brazilian Barbecue Privacy Offer will respond to your query or if a complaint has been made investigate your complaint and determine the steps that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing (which includes electronic communication via email or fax) of the relevant determination. If you are not satisfied with the determination, you can contact us to discuss your concerns or complain to the Australian Privacy Commissioner via www.oaic.gov.au.
The Privacy Officer
Lapa Brazilian Barbecue
PO Box 1952
SUBIACO WA 6904
If you contact us via telephone, you will need to answer a few security questions before any personal information is revealed or amended.