Soul Origin (Australia) Pty Ltd (ACN 168 629 061) and its related body corporates (referred to as “we”, “us”, “SO”, and “our”) operates as franchisor of the Soul Origin system in Australia. As part of operating the franchise, Soul Origin manages the websites located at https://www.soulorigin.com.au and https://www.catering.soulorigin.com.au (Websites) and the Soul Origin Loyalty App (App), which provide information about our goods and services, store locations, promotions, menu, franchising opportunities and other information.
We are committed to protecting your privacy and personal information. This Privacy Policy outlines how we collect, use and handle your personal information in connection with the franchise system, the Website, the App and other interactions. In this Privacy Policy, personal information has the meaning as defined in the Privacy Act 1988 (Cth) (Privacy Act).
We collect, use and disclose personal information in accordance with this Privacy Policy, the Privacy Act and the Australian Privacy Principles as set out in the Privacy Act.
This Privacy Policy also serves as a collection notice, informing you about how we collect your personal information.
We may update this Privacy Policy from time to time. We will publish the revised version on the Websites and the App. We may also notify you directly where appropriate. If you do not agree with any changes, you may discontinue your use of our goods, services, the Website, the App or other interactions with us.
All personal information we collect, use and hold will be managed in accordance with the latest version of our Privacy Policy.
By interacting with us, using the Website, the App or otherwise supplying us with your personal information, you consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy.

1. HOW WE COLLECT PERSONAL INFORMATION
We collect personal information only when necessary for our business operation or activities and do so by lawful and fair means.

Direct Interactions
Where you directly interact with us, we may collect various types of personal information, including but not limited to:
(a) When you place an order in store, by telephone, via our Websites or App;
(b) When you create an online account via our Websites or sign up to our Soul Origin Loyalty program;
(c) When you download or use our App;
(d) When you interact with or follow our social media accounts;
(e) When you access our Websites via links in an email we have sent;
(f) When you participate in a promotion, competition, promotional activity, survey, or market research;
(g) If you contact our Support Centre;
(h) If you are applying for a position with Soul Origin;
(i) If you are applying to become a Soul Origin franchisee;
(j) In you use our ‘Store Locator’ feature, location data will be temporarily stored then deleted to help you find the nearest Soul Origin store; and
(k) If you upload anything to our Websites.

Financial Transactions
All purchases made through our Websites and App are processed securely and externally by Shopify and Shift8. Unless you expressly consent otherwise, we do not see or have access to any personal information that you provide to Shopify or Shift8, other than information that is required to process your order and delivery your purchased goods to you, such as your name, email address and delivery address.

Automatic Collection
When you visit our Websites or App, we may use automated technologies (such as cookies, usage monitoring software and session tracking) to collect and store certain information about your visit. This may include, without limitation:
(a) the IP address and domain name your device uses to connect to the internet;
(b) the operating system, browser type and search engine used to access our Websites or App;
(c) the date, time and duration of your visit;
(d) the pages you visit on our Websites or App;
(e) your location (based on your device location settings); and
(f) any personal information you provide, such as your name, email address and phone number.

Cookies and Web Beacons
Our Websites and App uses temporary cookies – small alphanumeric identifiers transferred to your device’s hard drive – to maintain active sessions after user login. These cookies assist with website and app administration, usability improvements by helping us recognise returning visitors and tracking user navigation patterns. These cookies do not store personal information or provide access to any information stored on your device. Additionally, they do not interact with cookies from other websites. The information collected is used solely for the purposes mentioned above and to enhance the functionality of our Websites and App. While some browsers allow you to block cookies, however, doing so may negatively affect your user experience on our Websites and App.

Information from Third Parties
We may collect personal information provide third parties, including publicly available sources or data provided by delivery partners, payment processors, marketing agencies and customer engagement platforms. This information helps us supplement and enhance the personal data we hold about you to provide better services.

Social Media
When you interact with us through social media platforms, we may collect personal information associated with your social media account. If you contact us via email, we may store your email address and any content you share. This information will be used only as outlined in this Privacy Policy and in compliance with the Privacy Act. Please note that personal information or comments you voluntarily post on our website or social media pages become publicly accessible. Your name may be visible to other users when you post comments or messages. Content you share publicly is not covered by this Privacy Policy.

CCTV
Soul Origins locations may use CCTV surveillance to monitor and investigate incidents, ensuring the safety, security, and wellbeing of staff, customers, and visitors. We take all reasonable measures to safeguard this information against loss, tampering, misuse, and/or unauthorised access.

Combining and Using Your Information
We may combine information collected from cookies, third parties, social media interactions, and other sources with personal data we already hold. This helps us personalise your experience, improve our services, determine what products, promotions and services are likely to be of interest to you; and ensure the security and functionality of our Websites and App.

2. WHAT PERSONAL INFORMATION IS COLLECTED
Soul Origin may collect personal information that is reasonably necessary for us to carry out our business and activities. The specific information we collect will depend on who you are and the context of your interaction with us.
For customers and prospective customers, including members of our Loyalty program, we may collect a range of personal information to enhance your experience and provide our goods and services. This includes your contact details, such as your name, email address, phone number and geographical information. We may also collect your date of birth, preferred store and payment information.
Information collected when you apply to become a franchisee or an employee of Soul Origin is outlined below at clauses 10 and 11.

3. HOW WE USE AND MANAGE YOUR PERSONAL INFORMATION
Soul Origin may use your personal information, including but not limited to:
(a) process your order and provide customer support;
(b) conduct direct marketing, sales and promotions of Soul Origin goods and services;
(c) improve our product offerings and services;
(d) administer our Loyalty program;
(e) analyse customer trends and behaviours, enabling us to develop effective marketing and sales strategies;
(f) assess your eligibility to purchase and operate a Soul Origin franchise;
(g) evaluating and managing employment applications;
(h) enforcement of our Websites, App and Loyalty program terms and conditions;
(i) fulfilling our obligations under the Franchising Code of Conduct, which includes the storage and disclosure of personal information about former franchise directors (such as their name, location and contact details) with their written consent;
(j) supporting our internal operations, including meeting legal and regulatory requirements, such as those related to our franchise network disclosure obligation; and
(k) for any purpose for which you give your consent.
We may use or disclose your personal information in accordance with section 16A of the Privacy Act. Permitted General Situations, as defined in the Privacy Act, include, but are not limited to, using or disclosing information for evidentiary purposes in establishing or defending legal or equitable claims or addressing serious threats to public health or safety. In addition, we may be legally required to disclose information about you, including your identity and contact details, as compelled by law enforcement agencies.

4. HOW YOUR PERSONAL INFORMATION IS STORED AND PROTECTED
We store your personal information in both physical and digital formats across various systems, including customer databases for processing orders, inquiries, or feedback, marketing communications databases, and databases for managing our franchise network administration. Personal information is held at our offices, on our servers, and, in some cases, on third-party cloud storage servers.
To safeguard your personal information, we employ a range of physical, electronic, and procedural measures designed to protect it from loss, misuse, and unauthorised access. However, no data transmission over the internet can be guaranteed to be completely secure, and you use our online services at your own risk. In the event of a significant data breach, we will notify you and the Office of the Australian Information Commissioner as required by law.
We retain your personal information only for as long as necessary to fulfill its intended purpose or as required by law. When it is no longer needed, we will securely destroy or de-identify it. Protecting your personal information remains a priority for us.
Soul Origin operates a network of stores across Australia and New Zealand. Due to the scale of our operations, it is occasionally necessary to share and store your personal information with our related companies and third-party service providers. When stored electronically, your information is hosted by a third-party cloud service provider, which may store back up data in locations such as Australia, New Zealand or other locations determined by the provider.
Your data may be transferred to and stored on these servers or processed by organisations operating in other countries that work for or are engaged by Soul Origin or our suppliers. We will take reasonable measures to ensure that any disclosure of personal information to an overseas recipient complies with the Privacy Act. This means that we will require the overseas recipient to handle the personal information in a manner consistent with the Australian Privacy Principles.

5. DISCLOSURE OF PERSONL INFORAMATION TO THIRD PARTIES
We may disclose your personal information to:
(a) related companies, suppliers and agents of Soul Origin for purposes related to our business operations;
(b) marketing providers, market research and data analytics companies to perform direct marketing activities;
(c) franchisees for handling inquiries, complaints or feedback; and
(d) others with your consent or as required by law.
When engaging third-party suppliers to manage personal information, we will take reasonable measures to ensure that the third party use the information solely for the intended purpose for which it was provided.

6. PUBLIC INFORMATION AND THIRD PARTY DATA COLLECTION
Please be aware that any personal information or comments you voluntarily share on our Websites, social media, comment pages or forums become publicly accessible. Your name will be visible to other users when you post messages or comments. Content that you post is considered public and is not covered by this Privacy Policy as personal information.

7. HOW WE USE PERSONAL INFORMATION FOR DIRECT MARKETING
With your consent, we may periodically send you direct marketing communications about our products, services and promotions. These communications may be delivered via email, SMS, mail and other channels, in compliance with the Spam Act 2003 (Cth) and the Privacy Act. You can opt out of receiving these materials at any time by using the opt-out options provided (such as an unsubscribe link) or by contacting us using the details provided at clause 19.

8. GOOGLE ANALYTICS
We use Google Analytics to understand how our websites are used and identify how we can make the websites more effective. For information on how Google Analytics collects and processes data please see refer to Google at https://support.google.com/analytics/answer/6004245.

9. THIRD-PARTY LINKS
Our Websites may contain links to third party websites. Soul Origin is not responsible for the privacy practices or policies of these third parties. Privacy policies on other websites may differ significantly from ours. We encourage you to review their policies before using those sites. If you choose to disclose your personal information to any third party websites, it will not be covered by this Privacy Policy.

10. EMPLOYMENT APPLICATIONS
For prospective employees, we collect, use and store the following types of information:
(a) contact information, including names, email addresses, phone numbers, postal address and other location-based details;
(b) personal details such as date of birth, gender, referees, employment history, salary expectations, job titles and qualifications;
(c) media assets, including photographs and video recordings;
(d) information obtained through background and reference checks;
(e) additional personal information that may be voluntarily provided to assist us in evaluating suitability for employment.
We will retain your employment application for consideration in future job opportunities with us unless you request otherwise.

11. FRANCHISE APPLICATIONS
We collect personal information about current, former and prospective franchisees. The type of personal information includes:
(a) contact details, including name, email address, phone numbers, office and postal addresses and other location-related information;
(b) information about their employees, directors, guarantors, agent and representatives, such as dates of birth, gender, email and home addresses, phone number, job titles and qualifications;
(c) legal information, including ongoing proceedings and any criminal records;
(d) media assets, including photographs and video recordings;
(e) financial details, such as current income, net worth, assets and liabilities, monthly profit and loss statements, sales, reports, banking information and business registrations; and
(f) any additional personal information voluntarily provided to us in connection with a franchise application or operation of a franchise.
In compliance with Item 6.5 of Schedule 1 of the Franchising Code of Conduct (Code), we may list the names, locations and contact details of franchisees in our disclosure document if they are involved in events outlined under Item 6.4 of Schedule 1 of the Code. This may include personal details of both current and former franchisees.
As per the Code, former franchisees have the right to request in writing that their personal information not be included in the disclosure document.
In addition, we will retain franchisee applications to assess future franchise opportunities with us unless you request otherwise.

12. BDC FRANCHISE RECRUITMENT PARTNERS
Soul Origin may use the services of BDC Franchise Recruitment Partners in the process of recruiting, screening, and selecting Franchisees on its behalf. Your data will only be shared with BDC Franchise Recruitment Partners to allow us to deliver the services agreed to between Soul Origin and you. For more information, we recommend you review the BDC Franchise Recruitment Partners Privacy Policy at https://bdcpartners.com.au/privacy-policy.

13. FRANCHISEES
Several Soul Origin businesses are owned and operated by franchisees. Soul Origin’s franchisees are required to follow this Privacy Policy. If you are concerned that there may have been a breach of this Privacy Policy by a franchisee, please contact the relevant franchisee entity or Soul Origin directly.

This privacy policy does not apply to our franchisee’s conduct on websites or mobile apps they operate.

14. CHILDREN’S PRIVACY NOTICE
It is the policy of Soul Origin not to collect personal information from any person under the age of 13 unless collection is for a specific activity and that person’s parent or guardian has provided us with written consent to collect their personal information for that specific activity.

Whilst some of our Soul Origin products are targeted towards children, we do not intend for our online services to be used by anyone under the age of 16. If you are a child under the age of 16, please do not provide any personal information to us. If you are a parent or guardian and believe we may have collected information about your child, please contact us.

15. OPT-OUT OF MARKETING COMMUNICATIONS
We may communicate with you electronically through SMS, email, via direct mail or other forms of communication in compliance with the Spam Act 2003 (Cth) and the Privacy Act.
By using our services, you consent to receive these communications. If you wish to opt-out of marketing communications, you can do so by contacting us at privacy@soulorigin.com.au or by using the unsubscribe option provided in electronic marketing messages. Please note that opting out of SMS or email may affect your Soul Origin experience and limit our ability to reach you.

16. TRANSFERRING OF PERSONAL INFORMATION
In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganisation or liquidation, Soul Origin reserves the right to transfer or assign the personal information we have collected to one or more relevant third parties, at our sole discretion.

17. INTERNATIONAL USERS
If you access our services or Websites from a region with privacy and data protection laws different from those in Australia, please be aware that your personal information will be transferred and used in accordance with the Australian Privacy Act. By using our services, you consent to this transfer and the processing of your personal information in Australia.

18. ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
You may access or correct your personal information via:
(a) your Soul Origin loyalty profile; or
(b) contacting our Privacy Officer.

To process a request, we may ask you to verify your identity and submit your request in writing for security purposes. We may charge a reasonable administration fee for processing your request.

19. OUR CONTACT DETAILS
If you have any questions about this Privacy Policy, need to access, update or correct your personal information, or wish to raise any privacy concerns, please contact us using the following details:
The Privacy Officer
Soul Origin (Australia) Pty Ltd
580 Parramatta Road, Petersham NSW 2049
Email: privacy@soulorigin.com.au
Telephone: 02 8565 5400

We have a formal complaints process for concerns about the use or misuse of your personal information. If you believe we have breached this Privacy Policy or the Australian Privacy Principles, please contact us first in writing via email or post. We will work with you to resolve the issue.
If you are not satisfied with our response, you may refer the matter to the Office of the Australian Information Commissioner at https://www.oaic.gov.au.

20. PRIVACY POLICY UPDATES
This Privacy Policy was last updated in January 2025.