Fable Holdings Pty Ltd – Privacy Policy

We produce and make available delicious tasting meat without animals and we understand that protecting your personal data is important. This Privacy Policy sets out our commitment to protecting the privacy of personal data provided to us, or otherwise collected by us when working with you or providing our website, products and experiences to you (together, our “Services”). In this Privacy Policy “we”, “us” or “our” means Fable Holdings Pty Ltd ABN 32 636 627 542.

This Privacy Policy takes into account the requirements of the General Data Protection Regulation 2016/679 (“GDPR”). Under the GDPR, “personal data” means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

The personal data we collect

Personal data: The types of personal data we may collect about you include:

As a distribution or retail business contact:

your name;
the business you work for and your role at the business;
your contact details, including email address, mailing address and/or telephone number;
your preferences and/or opinions; and
information you provide to us, including as feedback or through surveys.

If you make a purchase on our website:

your name;
your contact details, including email address, mailing address, street address and/or telephone number;
your credit card or other payment details (through our third party payment processor); your preferences and/or opinions;
information you provide to us, including as feedback, as a review or through surveys; and
details of products and services we have provided to you and/or that you have enquired about, and our response to you;

If you use our website:

your email address if you sign up on our website for the newsletter;
your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider; and
additional personal data that you provide to us, directly or indirectly, through your use of our Services, associated applications, associated social media platforms and/or accounts from which you permit us to collect information.

Note: We will also collect any other personal data requested by us and/or provided by you or a third party.

How we collect personal data

We collect personal data in a variety of ways, including:

Directly: We collect personal data which you give to us, such as when you sign up for the newsletter on our website, make a purchase on our website or telephone us.
Indirectly: We may collect personal data which you indirectly provide to us while interacting with us, such as when you use our website, in emails or over the telephone.
From third parties: We collect personal data from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers or your name from your employer if you are named as a business contact or invited to one of our business experiences. See the “Cookies” section below for more detail on the use of cookies.

Purposes of processing personal data

Where we are acting as a controller under the GDPR, we will only process personal data where we can identify a lawful basis to do so.

In providing our Services, we may collect, hold, use and disclose personal data for the following purposes:

Purpose of processing

To enable you to access and use our Services, including our website.

To process your product orders and/or experience purchases.

To coordinate with third party service providers where your experience or order entitles you to a third party service (including any restaurant experiences or order deliveries).

To contact and communicate with you about our Services.

For analytics, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.

For advertising and marketing, including to send you promotional information about our products, offers, experiences and other information that we consider may be of interest to you.

To run promotions, competitions and/or offer additional benefits to you.

If you have applied for employment with us; to consider your employment application.

To comply with our legal Including legal obligation: We may use your information if obligations or if otherwise required or authorised by law.

LEGAL BASIS

Including legitimate interests: We may collect necessary information if you browse or use our website.

Including performance of a contract: We use and disclose personal data to process your order, deliver products ordered and register your attendance at our experiences.

Including Performance of a contract: We may use and disclose your personal data to third party service providers where your purchase entitles you to a third party service (including any restaurant experiences or order deliveries), for the purpose of the provision of that third party service.

Performance of a contract: We may use your information to bill you and accept payment so that we can provide the requested products and services to you.

Legal obligation: We may use your information to keep records where we have a legal obligation to do so, such as company records and tax records.

Including legitimate interests: We may use your information to improve our services and for business development purposes. You may object to our use of your personal data on the basis of legitimate interests at any time (see the “Your Privacy Rights” below).

We and/or our third-party marketing partners may use the personal data you send to us for marketing purposes, if this is in accordance with your marketing preferences.

Consent: If you subscribe to marketing materials you consent to us sending you the marketing you subscribe to. You may withdraw your consent at any time.

Consent: If you subscribe to receive information about promotions, competitions or additional benefits we are offering, you consent to us sending such information to you. If you choose to enter any promotions or competitions or make use of any additional benefits we are offering you provide your consent for us to process your personal data for that purpose. You may withdraw your consent at any time.

Including legitimate interests: If you have applied for employment with us, we may collect your information to consider your employment application.

Including legal obligation: We may use your information if obligations or if otherwise required or authorised to do so by law.

If we will process your personal data for another purpose, which is incompatible with the original purpose, we will notify you of that purpose and the legal basis for our processing prior to further processing your personal data.

If we rely on consent and you are under 16 years of age, you warrant and agree that, and we may seek confirmation that, you have your parent or legal guardian’s consent to process your personal data for that specific purpose

Disclosure of personal data to third parties

We may disclose personal data to:

third party service providers for the purpose of enabling them to provide their services, to us, including (without limitation) technology developers, data storage, web-hosting and server providers, couriers, maintenance or problem-solving providers, marketing or advertising providers, electronic document execution software, professional advisors and payment systems operators;
our employees, contractors and/or related entities; our existing or potential agents or business partners;
sponsors or promoters of any promotions or competitions we run or additional benefits we are offering;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;
courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
third parties to collect and process data, such as Google Analytics (To find out how Google uses data when you use third party websites or applications, please see www.google.com/policies/privacy/partners/ or any other URL Google may use from time to time), Facebook Pixel or other relevant analytics businesses; and
any other third parties as required or permitted by law, such as where we receive a subpoena.

Upon written request, we may agree to provide you with a list of the third parties we use to process your personal data.

Overseas transfers

Where we transfer your personal data to third parties in countries that do not have the same data protection laws as the country in which you initially provided the information:

we will perform those transfers using appropriate safeguards in accordance with the requirements of the GDPR; and

we will protect the transferred personal data in accordance with this Privacy Policy.

Our commitment to you

Your personal data will:

be processed lawfully, fairly and in a transparent manner by us;
only be collected for the specific purposes we have identified in the ‘collection and use of personal data’ clause above and personal data will not be further processed in a manner that is incompatible with the purposes we have identified;
be collected in a way that is adequate, relevant and limited to what is necessary in relation to the purpose for which the personal data is processed;
be kept up to date, where it is possible and within our control to do so (please let us know if you would like us to correct any of your personal data);
be kept in a form which permits us to identify you, but only for so long as necessary for the purposes for which the personal data was collected; and
be processed securely and in a way that protects against unauthorised or unlawful processing and against accidental loss, destruction or damage.

Your rights and controlling your personal data

You may be entitled to certain privacy rights, as detailed below. If you would like to request any of your rights listed below, please get in touch with us using the details at the bottom of this Privacy Policy and we will consider and act upon your request in accordance with the data protection laws applicable to your request. We aim to respond to all requests within 30 days of the date of receipt of the request.

Your choice: Please read this Privacy Policy carefully. If you provide personal data to us, you understand we will collect, hold, use and disclose your personal data in accordance with this Privacy Policy. You do not have to provide personal data to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal data about you from third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal data about somebody else, you represent and warrant that you have such person’s consent to provide the personal data to us.

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us.

Marketing, restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal data that we hold about you. Please note, in some situations, we may be legally permitted to withhold access to your personal data.

Correction/Rectification: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal data.

Objecting to processing: Under the GDPR, you may have the right to object to processing of your personal data that is based on our legitimate interests or public interest. If this is done, we must provide compelling legitimate grounds for the processing which overrides your interests, rights and freedoms, in order to proceed with the processing of your personal data.

Restricting processing: Under the GDPR, you may have the right to request that we restrict the processing of your personal data if (i) you are concerned about the accuracy of your personal data; (ii) you believe your personal data has been unlawfully processed; (iii) you need us to maintain the personal data solely for the purpose of a legal claim; or (iv) we are in the process of considering your objection in relation to processing on the basis of legitimate interests.

Erasure and data portability: Under the GDPR, you may have the right to request details of the personal data we hold about you, or to request that we erase the personal data we hold about you, or that we transfer this information to a third party.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. You also have the right to contact the relevant privacy authority in the country in which you are based.

Storage, security and retention of your personal data

We are committed to ensuring that the personal data we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal data and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means and the applicable legal requirements.

In some circumstances you can ask us to delete your data: see ‘erasure and data portability’ above for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for analytics, research or statistical purposes in which case we may use this anonymised information indefinitely without further notice to you.

Cookies

We may use cookies on our online Services from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online Services and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online Services with personal data, this information may be linked to the data stored in the cookie.

We provide a cookie pop-up when you use our online Services to obtain your consent to use cookies. If you do not consent to us using any cookies (including essential cookies) or you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our online Services.

Links to other websites

Our Services may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal data which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy and we will publish the amended Privacy Policy on our website. If we make any material changes to this Privacy Policy, we will notify you by contacting you through the contact details you have provided to us.

For any questions or notices, please contact our Privacy Officer at:

Fable Holdings Pty Ltd ABN 32 636 627 542 Email: food@fablefood.co