Privacy - Fresho
Privacy

Privacy

Overview – the key information you should be aware of

 

Overview

(A) Who we are: We are Fresho Pty Limited, a leading software provider for the food, beverage and flower industries. If you need it, our company number is 605 060 277 and our registered office is c/- Blue Rock (Aust) Pty Ltd, Level 16, 414 Latrobe Street, Melbourne, Victoria, 3000, Australia. Fresho Pty Ltd is the controller of your personal information, and is responsible for your personal information. All references in this policy to “Fresho”, “our”, “us” or “we” refer to Fresho Pty Ltd and any of its group companies. All references in this policy to “our website”, refer to the websites owned by Fresho at fresho.com and fresho.com.au, any other website that we operate or own and any application through which you access our website or software. All references to “our software”, refer to the software owned by Fresho as accessed via our website.

(B) Our values and what this policy is for: We value your privacy and want to be accountable and fair to you as well as transparent with you in the way that we collect and use your personal information. We also want you to know your rights in relation to your information, which you can find here.

In line with these values, this privacy policy tells you what to expect when we collect and use personal information about you. We have tried to make it easy for you to navigate so you can find the information that is most relevant to you and our relationship with you. We are always looking to improve the information we provide to our customers and contacts so if you have any feedback on this privacy policy, please let us know using our contact details in Section 13.

(C) Who this policy applies to:

This policy applies to:

  1. Visitors to our website;
  2. Users of our software (Users of our software (who may be suppliers in the food, beverage or flower industry and their customers), and employees of such users;
  3. Prospective customers (to whom we send marketing communications);
  4. People who contact us with enquiries; and
  5. Our service providers, and employees of our service providers.

Depending on our relationship, we will collect and use your information in different ways.  Please click on the links above to find out the information that we collect about you and how we use this information.

(D) What this policy contains:

This privacy policy describes the following important topics relating to your information (you can click on the links to find out more):

  1. How we obtain your personal information;
  2. What personal information we collect and how we use it;
  3. Our legal basis for using your personal information;
  4. How and why we share your personal information with others;
  5. How, and how long, we store your personal information;
  6. Your rights;
  7. Children;
  8. Marketing;
  9. Where we may transfer your personal information;
  10. Risks and how we keep your personal information secure;
  11. Links to other websites;
  12. Changes to this privacy policy; and
  13. Further questions and how to make a complaint.

(E) Your rights to object: You have various rights in respect of our use of your personal information as set out in section 6.  Two of the fundamental rights to be aware of are that:

  1. You may ask us to stop using your personal information for direct-marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.
  2. You may ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our, or another person’s, legitimate interest.

You can find out more information in section 6.

(F) What you need to do and your confirmation to us: Please read this privacy policy carefully to understand how we handle your personal information. By engaging with us in the ways set out in this privacy policy, you confirm that you have read and understood the entirety of this privacy policy, as it applies to you.

 

The details – the key information you should be aware of

 

1. How We Obtain Your Personal Information

1.1 You may provide us with your personal information voluntarily. We may also receive information about you from third parties such as your employer or your employer’s company website if your employer is a user of our software, other users of our software, contractors and consultants, group companies, public websites, public agencies and other publicly-available sources, which we refer to as “third party sources” throughout this policy.

1.2 You may give us personal information about yourself by using the online forms provided on our website, our software, setting up an account with us, or by contacting us by phone, email or other means. This includes, for example, where you provide your personal information to us in order to receive information or services from us.

1.3 If you are a service provider, you may also give us personal information about you when you are offering or providing services to us.

2. What Personal Information We Collect and How We Use It

Please go to the section or sections below that best describes our relationship with you to find out the information that we collect about you and how we use this information.  We refer to this as “personal information” throughout this policy.

2.1 Visitors to our website

(a) What personal information we collect about you

We, or third parties on our behalf, may collect and use any of the following information about you:

(i) your name including your title;

(ii) your postal address;

(iii) your email address;

(iv) your telephone number;

(v) information provided when you correspond with us;

(vi) any updates to information provided to us;

(vii) the following information created and recorded automatically when you visit our website:

(A) Technical information. This includes: the Internet Protocol (IP) address used to connect your computer to the internet address; the website address and country from which you access information; the files requested; browser type and version; browser plug-in types and versions; operating system; and software. We use this personal information to administer our website, to measure the efficiency of our systems and to undertake an analysis on the locations from which people access our webpages; and

(B) Information about your visit and your behaviour on our website (for example, the pages that you click on). This may include the website you visit before and after visiting our website (including date and time), time and length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, traffic data, location data, weblogs and other communication data and information provided when requesting further service or downloads.

(b) How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

(i) to receive enquiries from you through the website about our software;

(ii) for improvement and maintenance of our website and to provide technical support for our website;

(iii) to ensure the security of our website;

(iv) to recognise you when you return to our website, to store information about your preferences, and to allow us to customise the website according to your individual interests; and

(v) to evaluate your visit to the website and prepare reports or compile statistics to understand the type of people who use our website, how they use our website and to make our website more intuitive. Such details will be anonymised as far as reasonably possible and you will not be identifiable from the information collected.

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

(C) A word about cookies

(i) Some pages on our website use cookies, which are small files placed on your internet browser when you visit our website. We use cookies in order to offer you a more tailored experience in the future, by understanding and remembering your particular browsing preferences.

(ii) Where we use cookies on our website, you may block these at any time. To do so, you can activate the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies), you may not be able to access all or parts of our website or to use all the functionality provided through our website.

(iii) For detailed information on the cookies we use and the purposes for which we use them, please refer to our cookies policy here.

(d) Special categories of data. We do not collect special categories of data. Special categories of data include information about physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.

2.2 Users, and employees of users

(a) What personal information we collect about you

We (via our software), or third parties on our behalf, may collect and use any of the following information about you:

(i) your name (including your title);

(ii) your postal address;

(iii) your email address;

(iv) your telephone number;

(v) information provided when you correspond with us;

(vi) any updates to information provided to us;

(vii) information about our software and associated services we provide to you:

(A) information needed to provide the services to you (including information on joining forms, order details, order history and payment details);

(B) customer services information; and

(C) customer relationship management and marketing information;

(viii) user name and password for access to our software or our app;

(ix) personal information that we obtain from the third party sources described in section 1.1;

(x) information you provide to help us provide you with improved service, for example if we ask you to fill in a survey or questionnaire.

(b) How we use your personal information

We will collect, use and store the personal information listed above for the following reasons:

(i) to provide you with access to our software and associated services;

(ii) to deal with any enquiries or issues you have about our software or associated services;

(iii) to send you certain communications (including by phone, email or post) about our services such as administrative messages (for example, setting out feature updates);

(iv) to carry out statistical analysis, surveys and market research on people who may be interested in our services;

(v) if it is in our legitimate interests for business development and marketing purposes, to contact you (including by telephone, email or post) with information about our software and associated services or the products or services of users or potential users which either you request, or which we feel will be of interest to you; and

(vi) if you are a sole trader or a non-limited liability partnership and the address you used to register as a user is in the United Kingdom and if you have consented, to contact you by phone or email with information about our software and associated services or the products or services of users or potential users which either you request, or which we feel will be of interest to you.

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

(c) Special categories of data. We do not collect special categories of data. Special categories of data include information about physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.

(d) Information we need to provide services to you. We need certain types of personal information so that we can provide services to you and perform contractual and other legal obligations that we have to you. If you do not provide us with such personal information, or if you ask us to delete it, you may no longer be able to access our software or associated services.

2.3 Prospective customers to whom we send marketing communications

(a) We, or third parties on our behalf, may collect and use any of the following information about you:

(i) your name including your title;

(ii) your postal address;

(iii) your email address;

(iv) your telephone number;

(v) information provided when you correspond with us;

(vi) any updates to information provided to us; and

(vii) personal information that we obtain from the third party sources described in section 1.1.

(b) How we use your personal information

We will collect, use and store the personal information listed above, if you have consented or, otherwise, if it is in our legitimate interests, for business development and marketing purposes, to contact you (including by telephone, email or post) with information about our services which either you request, or which we feel will be of interest to you (including newsletters).

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

(c) Special categories of data. We do not collect special categories of data. Special categories of data include information about physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.

2.4 People who contact us with enquiries

(a) We, or third parties on our behalf, may collect and use any of the following information about you:

(i) your name including your title;

(ii) your postal address;

(iii) your email address;

(iv) your telephone number;

(v) information provided when you correspond with us;

(vi) any updates to information provided to us; and

(vii) personal information that we obtain from the third party sources described in section 1.1 (excluding contractors and consultants).

(b) How we use your personal information

We will collect, use and store the personal information listed above to deal with any enquiries or issues you have about our services, including any questions you may have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes.

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

(c) Special categories of data. We do not collect special categories of data. Special categories of data include information about physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.

2.5 Our service providers, and employees of our service providers

(a) We, or third parties on our behalf, may collect and use any of the following information about you:

(i) your name including your title;

(ii) work contact information (phone number, postal address, mailing address, email address);

(iii) your job title;

(iv) your gender;

(v) your date of birth;

(vi) information provided when you correspond with us;

(vii) any updates to information provided to us;

(viii) personal information that we obtain from the third party sources described in section 1.1 (excluding other users of our software);

(ix) CVs, pitch and tender information;

(x) proof of identification and address;

(xi) visa or work permit documentation;

(xii) details of compensation, expense claims and bank details;

(xiii) information required to access company systems and applications (such as system ID); and

(xiv) work hours (overtime and hours worked).

(b) How we use your personal information

We will collect, use and store the applicable personal information listed above for the following reasons:

(i) to enable us to purchase and receive products and services from you (including service provider due diligence, payment and expense reporting and financial audits);

(ii) to assess your working capacity;

(iii) to deal with enquiries from you;

(iv) to confirm information on CVs and performance reference checks, to assess you or your employer’s suitability to work for us;

(v) for equal opportunities monitoring;

(vi) for health and safety records and management; and

(vii) for security vetting and criminal records checks (where applicable and allowed by law).

Please see sections 2.6 and 2.7 for more details about how we use your personal information.

(c) Special categories of data. We do not collect special categories of data. Special categories of data include information about physical and mental health, sexual orientation, racial or ethnic origin, political opinions, philosophical belief, trade union membership and biometric data.

(d) Information we need to receive services from you or grant you access to our services. Please note that we need certain types of personal information so that you or your employer can provide services to us. If you do not provide us with such personal information, or if you or your employer asks us to delete it, you may no longer be able to provide services to us or access our services

2.6 Whatever our relationship with you is, we may also collect, use and store your personal information for the following additional reasons:

(a) to deal with any enquiries or issues you have about how we collect, store and use your personal information, or any requests made by you for a copy of the information we hold about you. If we do not have a contract with you, we may process your personal information for these purposes where it is in our legitimate interests for customer services purposes;

(b) for internal corporate reporting, business administration, ensuring adequate insurance coverage for our business, ensuring the security of company facilities, research and development, and to identify and implement business efficiencies. We may process your personal information for these purposes where it is in our legitimate interests to do so;

(c) to comply with any procedures, laws and regulations which apply to us – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others to comply, as well as where we are legally required to do so; and

(d) to establish, exercise or defend our legal rights – this may include where we reasonably consider it is in our legitimate interests or the legitimate interests of others, as well as where we are legally required to do so.

2.7 Further processing

Before using your personal information for any purposes which fall outside those set out in this section 2, we will undertake an analysis to establish if our new use of your personal information is compatible with the purposes set out in this section 2. Please contact us using the details in section 13 if you want further information on the analysis we will undertake.

3. Legal Basis For Use of Your Personal Information

3.1 We consider that the legal bases for using your personal information as set out in this privacy policy are as follows:

(a) our use of your personal information is necessary to perform our obligations under any contract with you (for example, to provide access to our software and associated services and/or to comply with our contract to receive services from you or your employer); or

(b) our use of your personal information is necessary for complying with our legal obligations; or

(c) where neither (a) nor (b) apply, use of your personal information is necessary for our legitimate interests or the legitimate interests of others (for example, to ensure the security of our website). Our legitimate interests are to:

(i) run, grow and develop our business (as well as the businesses of our group companies Fresho Pty Ltd (Australia), Fresho Limited (New Zealand), Fresho UK Ltd (UK) and Fresho LLC (USA));

(ii) operate our website and/or our software;

(iii) facilitate transactions between users and address any issues that arise in connection with the use of our software or associated services;

(iv) carry out marketing, market research and business development; and

(v) for internal group administrative purposes.

If we rely on our (or another person’s) legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection of the personal information.  You can ask us for information on this balancing test by using the contact details at section 13.

3.2 We may process your personal information in some cases for marketing purposes on the basis of your consent (which you may withdraw at any time after giving it, as described in section 8 below).

3.3 If we rely on your consent for us to use your personal information in a particular way, but you later change your mind, you may withdraw your consent by contacting us at info@fresho.com and we will stop doing so. However, if you withdraw your consent, this may impact the ability for us to be able to provide access to our software and our associated services to you.

4. How and Why we Share Your Personal Information With Others

4.1 We may share your personal information with our group companies where it is in our legitimate interests to do so for internal administrative purposes (for example, for corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).

4.2 We will share your personal information with the following third parties or categories of third parties:

(a) to other users, and employees of other users of our software and associated services, where you or the other user intend to enter into or have entered into online transactions with each other using our software. Other users may also share your personal information with us;

(b) we may share your personal information with other users where we have identified that your products and services may be of interest to the other user or other users’ products and services may be of interest to you;

(c) Squarespace who hosts our website. Squarespace will also share your personal information with us;

(d) Amazon Web Services (AWS), which hosts our software in Sydney, Australia, and which may access personal data stored within our software when providing support and maintenance services;

(e) we may share anonymised and aggregated statistical information with users who are food, beverage and flower industry suppliers to demonstrate what interest there has been in any marketing campaigns we have assisted them in carrying out;

(f) our service providers and sub-contractors, including payment processors, utility providers, suppliers of technical and support services, insurers, logistic providers, and cloud service providers;

(g) public agencies and the emergency services;

(h) companies that assist in our marketing, advertising and promotional activities, such as the marketing automation platforms MailChimp and SurveyMonkey; and

(i) analytics and search engine providers that assist us in the improvement and optimisation of our website.

4.3 Any third parties with whom we share your personal information are limited (by law) in their ability to use your personal information. We will always ensure that any third parties with whom we share your personal information are subject to privacy and security obligations consistent with this privacy policy and applicable laws.

4.4 We will also disclose your personal information to third parties:

(a) where it is in our legitimate interests to do so to run, grow and develop our business:

(i) if we sell or buy any business or assets, we may disclose your personal information to the prospective seller or buyer of such business or assets;

(ii) if substantially all of our or any of our affiliates’ assets are acquired by a third party, in which case personal information held by us will be one of the transferred assets;

(b) if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity;

(c) in order to enforce or apply our terms of use, our terms and conditions for customers or any other agreement or to respond to any claims, to protect our rights or the rights of a third party, to protect the safety of any person or to prevent any illegal activity; or

(d) to protect the rights, property, or safety of Fresho, our staff, our customers or other persons. This may include exchanging personal information with other organisations for the purposes of fraud protection and credit risk reduction.

4.5 We may also disclose and use anonymised, aggregated reporting and statistics about users of our website or our goods and services for the purpose of internal reporting or reporting to our group or other third parties, and for our marketing and promotion purposes. None of these anonymised, aggregated reports or statistics will enable our users to be personally identified.

4.6 Save as expressly detailed in this privacy policy, we will never disclose, share, sell or rent any of your personal information to any third party without notifying you and, where necessary, obtaining your consent. If you have given your consent for us to use your personal information in a particular way, but later change your mind, you should contact us using the contact details in section 13 and we will stop doing so.

5. How, and How Long We Store Your Personal Information

(a) We store your personal information electronically in secure data centres operated by Amazon Web Services (AWS).

(b) We keep your personal information for no longer than necessary for the purposes for which the personal information is processed, to comply with applicable law, to establish, exercise or defend our legal rights or to enable us or other users to comply with tax, accounting or financial reporting obligations. The length of time for which we retain personal information depends on the purposes for which we collect and use it and/or as required to comply with applicable laws, to establish, exercise or defend our legal rights or to comply with reporting obligations. Where we retain your personal information we do so in accordance with any limitation periods imposed by applicable law.

6. Your Rights

6.1 You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any of them, please contact using the contact details in section 13 at any time. You have the following rights:

(a) Right of access.  You have a right of access to any personal information we hold about you. You can ask us for a copy of your personal information; confirmation as to whether your personal information is being used by us; details about how and why it is being used; and, if you are located in the UK, details of the safeguards which are in place if we transfer your information outside of the European Economic Area (“EEA”).

(b) Right to update your information.  You have a right to request an update to any of your personal information which is out of date or incorrect.

(c) Right to delete your information.  You have a right to ask us to delete any personal information which we are holding about you in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the contact details in section 13.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort.  You can ask us who the recipients are, using the contact details in section 13.

(d) Right to restrict use of your information: You have a right to ask us to restrict the way that we process your personal information in certain specific circumstances. You can ask us for further information on these specific circumstances by contacting us using the details in section 13.

We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. You can ask us who the recipients are using the contact details in section 13.

(e) Right to stop marketing: You have a right to ask us to stop using your personal information for direct marketing purposes. If you exercise this right, we will stop using your personal information for this purpose.

(f) Right to data portability: You have a right to ask us to provide your personal information to a third party provider of services.

This right only applies where we use your personal information on the basis of your consent or performance of a contract, and where our use of your information is carried out by automated means.

(g) Right to object.  You have a right to ask us to consider any valid objections which you have to our use of your personal information where we process your personal information on the basis of our or another person’s legitimate interest.

6.2 We will consider all such requests and provide our response within a reasonable period (and in any event within the lesser of: (a) 20 working days; or (b) one month, of your request unless we tell you we are entitled to a longer period under applicable law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances, for example if we need to keep using the information to comply with our own legal obligations, to establish, exercise or defend legal claims or to comply with reporting obligations.

6.3 If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.

7. Children

7.1 You must be aged 18 or over to purchase products or services from us or from another user using our software. Our website, software and services are not directed at children and we do not knowingly collect any personal information from children.

7.2 If you are a child and we learn that we have inadvertently obtained personal information from you from our websites, or from any other source, then we will delete that information as soon as possible.

7.3 Please contact us at info@fresho.com if you are aware that we may have inadvertently collected personal information from a child.

8. Marketing

8.1 We may collect and use your personal information for undertaking marketing by email telephone and post. We may also share your personal information with our suppliers who may also use this information to send marketing communications to you.

8.2 We may send you certain marketing communications (including electronic marketing communications) if it is in our legitimate interests to do so for marketing and business development purposes or, if you are a sole trader or a non-limited liability partnership and the address you used to register as a user is in the United Kingdom if you have consented to receive such electronic marketing information.

8.3 However, we will always obtain your consent to direct marketing communications where we are required to do so by law.

8.4 If you wish to stop receiving marketing communications from us, you can

(a) unsubscribe from our email communications and/or text communications by clicking the “Unsubscribe” link in any marketing email or text received or by emailing us at info@fresho.com;

(b) unsubscribe from receiving marketing communication by post or by telephone by emailing us at info@fresho.com.

Once you have unsubscribed from the applicable marketing communication, you will be removed from the corresponding marketing list as soon as is reasonably practicable.

9. Where we May Transfer Your Personal Information

9.1 Your personal information may be used, stored and/or accessed by other members of our group, other users of our software with whom you have had online transactions, or service providers. Depending on your location, your personal information may be disclosed to the following countries in which members of the Fresho group and/or their service providers and other users of our software currently operate:

(a) Australia;

(b) New Zealand;

(c) Philippines;

(d) United Kingdom; and

(e) United States of America.

Further details about to whom your personal information may be disclosed are set out in section 4.

9.2 If you are located in the United Kingdom, and we provide any personal information about you to any non-EEA members of our group or service providers, we will take appropriate measures to ensure that the recipient protects your personal information adequately in accordance with this privacy policy. These measures may include the following permitted in Articles 45 and 46 of the General Data Protection Regulation:

(a) in the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield (see further www.privacyshield.gov/welcome); or

(b) in the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.

9.3 Further details on the steps we take to protect your personal information, in these cases is available from us on request by contacting us by email at info@fresho.com at any time.

10. Risks and How We Keeping Your Personal Information Secure

10.1 The main risk of our processing of your personal information is if it is lost, stolen or misused. This could lead to your personal information being in the hands of someone else who may use it fraudulently or make public, information that you would prefer to keep private.

10.2 For this reason, Fresho is committed to protecting your personal information from loss, theft and misuse. We take all reasonable precautions to safeguard the confidentiality of your personal information, including through use of appropriate organisational and technical measures, such as using password protected access to both the front end and the back end of the software and encrypting credit card details.

10.3 In the course of provision of your personal information to us, your personal information may be transferred over the internet. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your personal information transmitted to our website or software and that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access to it.

10.4 Where we have given you (or where you have chosen) a password which enables you to access your online account, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. However, in limited circumstances we may provide your password to another user to facilitate the onboarding process, where you are a new user of the software. We will always notify you that we are doing this to facilitate the on-boarding, and advise you to change your password subsequently to prevent the other user from continuing to have access to your account.

11. Links to Other Websites

Our website may contain hyperlinks to websites that are not operated by us. These hyperlinks are provided for your reference and convenience only and do not imply any endorsement of the activities of such third-party websites or any association with their operators. This privacy policy only applies to the personal information that we collect or which we receive from third party sources, and we cannot be responsible for personal information about you that is collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

12. Changes to Our Privacy Policy

We may update our privacy policy from time to time. Any changes we make to our privacy policy in the future will be posted here and, where appropriate, notified to you by post or email. Please check back frequently to see any updates or changes to our privacy policy.

13. Further Questions and How to Make a Complaint

13.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information:

(a) if you are located in the United Kingdom, please contact our Privacy Officer via email at info@fresho.com, by post at 10 John Street, London, United Kingdom, WC1N 2EB or by telephone on 074 7064 3164; or

(b) if you are located outside the United Kingdom, please contact our Privacy Officer via email at info@fresho.com, by post at Level 1, 49-51 Stead Street, South Melbourne, Victorian, 3205, Australia or, if you are located in Australia, by telephone on 1300 37 37 46.

We will investigate and attempt to resolve any such query or complaint regarding the use or disclosure of your personal information.

13.2 If you are not happy with the way in which we have handled your complaint, or the outcome of the complaint, you can make a complaint to the relevant data protection or privacy regulator in your country details of which we provide below.

(a) Australia: After contacting our Privacy Officer about your complaint, if you wish to pursue the matter further, your complaint can be made to the Office of the Australian Information Commissioner here.

(b) New Zealand: Without needing to first make a complaint directly to us, you may make a complaint to the New Zealand Privacy Commissioner in the following ways.

(i) Online here

(ii) By email – enquiries@privacy.org.nz

(iii) By phone – 0800 803 908

(iv) By post – Office of the Privacy Commissioner, PO Box 100894, Wellington 6143

(c) United Kingdom: Without needing to first make a complaint directly to us, you may make a complaint to the Information Commissioner’s Office, the UK supervisory authority for data protection issues (www.ico.org.uk). Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

(d) United States of America: Without needing to first make a complaint directly to us, you may make a consumer complaint regarding breaches of this privacy policy or the mishandling of personal information online to the Federal Trade Commission at www.ftccomplaintassistant.gov/ or with the Attorney General Office of the U.S. state in which you reside. Alternatively, you may seek a remedy through the courts if you believe your rights have been breached.

The practices described in this privacy policy statement are current as of 16 April 2020.