Privacy Policy

FCFA Management Pty Ltd


1.  About this Privacy Policy

FCFA Management Pty Ltd (“the Company”), has implemented this Privacy Policy to provide information about what kinds of Personal Information the Company may collect or hold, how the Company collect, hold, use and disclose that Personal Information, choices you have regarding the Company’s use of that Personal Information, and your ability to access or correct that Personal Information.  If you wish to make any inquiries regarding this Privacy Policy, you should contact our Privacy Officer in any of the ways specified in paragraph 15.

From time to time, the Company may be related to other companies and entities (related entities).  This Privacy Policy applies to the use of your Personal Information by the Company and by: (a) any related entity which refers to this Privacy Policy in collecting your Personal Information; and (b) any other related entity to the extent they handle Personal Information that the Company disclose to them, unless otherwise specified by those related entities.  A reference in this Privacy Policy to the Company is also a reference to those related entities.

2.  Personal Information

The Company’s "Personal Information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.

3.  What Personal Information do we collect and hold

The types of Personal Information the Company may collect about an individual will depend upon the nature of our interaction with them.  Personal Information that the Company collect may include (but is not limited to) the following:

  • Name

  • Age and/or date of birth

  • Contact details including telephone numbers (landline and/or mobile)

  • Address (including postal address)

  • Email address

  • Identification information such as driving licence details

  • Payment and account details, such as your credit card or bank account details (for payments to or from us)

  • Occupation and employment details including employment status and any previous work experience

  • Information from or in connection with your resume or job application if you apply for a position with us

  • Geographical location

  • Australian Business Number (ABN)

  • Trade references, credit references or reports from a third party

  • Credit information

  • Commercial credit reports

  • Photographs and/or images of you from camera footage, and

  • Information from social media accounts and profiles.

We collect and record Personal Information about individuals such as:

  • The Company’s portfolio companies, potential portfolio companies and their representatives

  • The Company’s investors and shareholders

  • The Company’s suppliers and potential suppliers and their representatives, directors, partners, proprietors and shareholders

  • Contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to the Company

  • The Company’s tenants to manage leases we provide

  • The Company’s employees past and present, including applicants, and

  • Any other person who comes into contact with the Company.

4.  How and when do we collect Personal Information

The Company collects your Personal Information to allow the Company to conduct the Company’s business functions, to provide, market and sell the Company’s products and services and for the specified purposes set out in paragraph 10.6.  In some circumstances the collection of Personal Information may be required by law.

The Company may collect your Personal Information in the course of providing you with goods or services, or:

  • When you receive or use the Company’s services

  • When you provide the Company, or you offer or apply to supply the Company, with goods or services

  • When you provide information to the Company in any way (including by completing a form, disclosing information over the phone or via email, or providing the Company a business card)

  • When you request information about the Company or the Company’s services

  • When you visit or fill in a form on the Company’s Website (see paragraph 10.5)

  • When you visit premises from which the Company operate

  • When you (or your employer) provide that information to the Company in the course of conducting or administering the Company’s relationship with you, or when you are carrying out activities in connection with the Company’s business operations

  • When you apply for or enter into a lease with the Company

  • When you submit a job application to the Company

  • When you otherwise contact the Company by telephone, fax, email, social media, post or in person, or

  • Where the Company are otherwise required or authorised by law to do so.

Generally, when providing the Company’s products and services, dealing with the Company’s employees, or obtaining goods and services from the Company’s service providers, suppliers or contractors, we collect Personal Information directly from the relevant individual where reasonable and practicable.

The Company may also collect Personal Information about you from third parties and other sources such as:

  • Your nominated representatives (eg spouse accountant, power of attorney, brokers and other professional advisors)

  • Publicly available sources of information

  • Related entities, companies and businesses of the Company, or

  • Credit reporting bodies who provide information about commercial credit worthiness

But the Company will only collect your Personal Information in this way if it is unreasonable or impracticable to collect this information directly from you or if the Company is otherwise permitted to do so.

If the Personal Information the Company collect includes sensitive information, including health information, the Company will ask for your consent to collect sensitive information, unless the law allows the Company to collect it without your consent.

Where the Company engage with you multiple times over a short period in relation to the same matter, the Company may not provide you with a separate notice about privacy each time the Company engage with you.

If you choose not to provide your Personal Information to the Company for the purposes set out in this Privacy Policy, or if we do not or are unable to collect the Personal Information the Company requires, the Company may not be able to provide you with requested information, products or services, or to effectively conduct our relationship with you.

5.  Information collected via our Website

Personal information may be collected by the Company and by our third party service providers who assist us in operating the Company’s website at including its subdomains and any other website the Company operates from time to time (collectively the Website).

The Company may use various technological methods from time to time to track the visiting patterns of individuals accessing the Website, including but not limited to the methods set out in this paragraph 5.

Click Stream Data

When you read, browse or download information from the Website, the Company or the Company’s internet service provider may also collect information such as the date, time and duration of a visit, the pages accessed, the IP address of your computer, and any information downloaded.  This information is used for statistical, reporting and website administration, maintenance and improvement purposes.

Cookies

The Website may use 'cookies' from time to time.  Cookies are small text files that are transferred to a user's computer hard drive by a website for the purpose of storing information about a user's identity, browser type or website visiting patterns.  Cookies may be used on our Website to monitor web traffic, for example the time of visit, pages visited and some system information about the type of computer being used.  The Company use this information to enhance the content and services offered on the Website.

Cookies are sometimes also used to collect information about what pages you visit and the type of software you are using.  If you access the Website or click-through to the Website from a link in an email we send you, a cookie may be downloaded onto your computer's hard drive.

Cookies may also be used for other purposes on the Website.

You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent.  Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

If you disable the use of cookies on your web browser or remove or reject specific cookies from the Website or linked sites then you may not be able to gain access to all of the content and facilities in those websites.

Third party content (eg social media links)

Some of the content on the Website may include applications made available by third parties, such as social media buttons or links that allow you to share content or links to the Website through the relevant third party platforms.  These third party applications themselves may facilitate collection of information by those third parties, through your interaction with the applications and sometimes even if you do not interact directly with them.  The Company are not responsible for the technical operation of these applications or the collection and use practices of the relevant third parties.  Please visit the relevant third party websites to understand their privacy practices and options they may make available to you in relation to their collection of your Personal Information.

6.  How do we use your Personal Information

The Company use the Personal Information the Company’s collects about you for the Company’s business functions and activities, in order to operate the Company’s business efficiently, and to promote the Company’s services for the benefit of portfolio companies and potential portfolio companies.

The Company may collect, hold and use your Personal Information:

  • To identify and communicate with you

  • To enable the Company to provide you with requested information or services

  • To manage leases

  • To enable the Company to manage portfolio companies including trustees/trusts and companies

  • To otherwise assist portfolio companies by providing them with information and support

  • To collect and process payments

  • To help the Company to manage and enhance products or services the Company provides to you

  • To help the Company to manage and enhance goods and services the Company procures from suppliers and subcontractors

  • To help the Company manage and respond to a general or specific shareholder enquiry

  • To process share applications and service shareholders' needs

  • To provide facilities and services a shareholder may request

  • To carry out appropriate administration in relation to shareholders and share registry, including to submit listing applications to, or respond to enquiries from, corporate regulators

  • To manage and administer any account or lease you may hold with the Company

  • To carry out credit checks in respect of the Company’s tenants and potential tenants

  • To carry out debt recovery functions

  • To protect you and the Company from fraud

  • To provide for the safety and security of workers and onsite visitors

  • To help the Company manage business operations

  • For business support purposes including maintenance, backup and audit

  • To process any job application submitted by you

  • To respond to any queries or complaints you may have, or

  • To comply with the Company’s statutory and legal obligations.

The Company may aggregate personal information for reporting, statistical and analysis purposes, and for business, product and service improvement purposes.  This allows the Company to better inform ourselves and anticipate portfolio companies' preferences and requirements, and to monitor and improve the effectiveness of the Company’s business, products and services.  The Company may also de-identify information for inclusion in such aggregated databases or reports.

The Company reserve the right at all times to monitor, review, retain, and/or disclose any information as necessary to satisfy any applicable law, but the Company has no obligation to monitor the use of the Website or to retain the content of any user session.

You consent to the Company using your Personal Information in the above ways and as set out in this Privacy Policy.

The Company may otherwise collect, use or disclose your Personal Information where the collection, use or disclosure is:

  • In accordance with this Privacy Policy or any agreement you enter into with the Company, or

  • Required or authorised by law, including without limitation the Australian Privacy Principles under the Privacy Act 1988 (Cth)Discrimination may occur.

7.  When do we disclose your Personal Information

The Company may disclose, or provide access to, your Personal Information to third parties in connection with the purposes described in paragraph 10.6.  Depending on the circumstances and the nature of your engagement with the Company, the Company may disclose your Personal Information to our related entities, to third parties that provide products and services to the Company or through the Company, or to other third parties (such as your referee(s) in connection with a job application you have submitted).

We may also disclose your Personal Information to:

  • Any of the Company’s internal divisions, business units or departments

  • Your nominated representatives

  • Other organisations or individuals who assist in providing products and services to you

  • Professional service providers and advisors who perform functions on the Company’s behalf, such as lawyers

  • Medical providers including medical and rehabilitation practitioners for assessing insurance claims

  • Representatives, agents or contractors who are appointed by the Company in the ordinary operation of our business to assist us in providing goods or services or administering the Company’s business (such as for data storage or processing, printing, mailing, marketing, planning and product or service development)

  • Credit reporting bodies and mercantile reporting agencies in order to assess credit worthiness of our tenants

  • Debt collecting agencies

  • Banks, lenders, valuers, insurers, brokers, auditors, business consultants and IT service providers, and

  • Government, regulatory authorities and other organisations as required or authorised by law.

The Company may also disclose your Personal Information to the Company’s Website host or software application providers in certain limited circumstances, for example when our Website experiences a technical problem or to ensure that it operates in an effective and secure manner.

As the Company continues to develop the Company’s business, the Company may buy, merge or partner with other companies or organisations, and in so doing, acquire customer Personal Information.  In such transactions, Personal Information may be among the transferred assets.  Similarly, in the event that a portion or substantially all of the Company’s business or assets are sold or transferred to a third party, the Company may also disclose certain information including your Personal Information to a purchaser or potential purchaser in connection with the sale or potential sale of the Company, the Company’s business or any of the Company’s assets, including in insolvency.

8.  Overseas disclosures

Some of your Personal Information may be disclosed, transferred, stored, processed or used overseas by the Company, or by third party service providers.  This may happen if:

  • The Company’s offices or related entities are overseas

  • The Company outsource certain activities overseas

  • Transactions, information, services or products have an overseas connection, or

  • The Company’s computer systems including IT servers are located overseas.

You consent to the collection, use, storage, and processing of your Personal Information outside of Australia as set out in this Privacy Policy.

In particular, your Personal Information may be disclosed to third parties in USA and Canada and such other countries in which those parties or their, or the Company’s computer systems may be located from time to time, where it may be used for the purposes described in this Privacy Policy.

9.  Other uses and disclosures

The Company may collect, use and disclose your Personal Information for other purposes not listed in this Privacy Policy.  If the Company doe so, the Company will make it known to you at the time the Company collect or use your Personal Information.

10.  Marketing

You consent to the Company using your Personal Information for sending you information, including promotional material, about us or our services, as well as the services of our related entities, now and in the future.  You also consent to us sending you such information by means of direct mail, email, SMS and MMS messages.

If you do not want to receive marketing information from us, you can unsubscribe by contacting us using the contact details specified in paragraph 15.

11.  Storage and security of Personal Information held by us

The Company aims to keep your Personal Information secure.  Any Personal Information that is collected via our Website or which is held on the Company’s computer systems is protected by safeguards including physical, technical (firewalls, SSL encryption etc) and procedural methods.

If the Company find that the Company no longer require or have no further need for your Personal Information the Company may de-identify it or remove it from the Company’s systems and destroy all record of it.

12.  You can access and update your Personal Information

You are generally entitled to access Personal Information that the Company holds about you.  If you request access to your Personal Information, in ordinary circumstances the Company will give you full access to your Personal Information.  Depending on the nature of the request, the Company may charge for providing access to this information, however such charge will not be excessive.  However, there may be some legal or administrative reasons to deny access.  If the Company refuse your request to access your Personal Information, the Company will provide you with reasons for the refusal where the Company are required by law to give those reasons.

A request for access can be made by contacting our Privacy Officer in any of the ways specified in paragraph 15.

The Company takes all reasonable steps to ensure that any Personal Information collected and used is accurate, complete and up-to-date.  To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested, and properly update the information provided to us to keep it true, accurate, current and complete.

Please contact us in any of the ways specified in paragraph 15 if you believe that the Personal Information is inaccurate, incomplete or out of date, and the Company will use all reasonable efforts to correct the information.

It would assist the Company to ensure the Company properly understands your request, and allow the Company to respond more promptly, if requests are made in writing and include as much detail as possible.

13.  How do we deal with complaints about privacy

If you feel that the Company have not respected your privacy or that the Company have conducted ourselves inconsistently with this Privacy Policy, please contact our Privacy Officer in any of the ways specified in paragraph 15 and advise us as soon as possible.  We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint.

It would assist the Company to respond to your complaint promptly if it is made in writing.  Please detail information relevant to your complaint.

The Company will notify you of the outcome of our investigation.

14.  Updates to this Privacy Policy

The Company may, from time to time, review and update this Privacy Policy, including to take into account new laws, regulations, practices and technology.  All Personal Information held by the Company will be governed by our most recent Privacy Policy, posted on our Website at www.freshcountryfarms.com.au, where the Privacy Policy will be located.  Any changes to this Privacy Policy may be advised to you by updating this page on our Website.  The Company will aim to provide reasonable advance notice of such changes though this may not always be possible depending on the circumstances.  The Company encourage you to check this page from time to time for any changes.

15.  What to do if you have a question or complaint about this Privacy Policy

If you:

  • Have a query or concern about this Privacy Policy or the Company’s Personal Information handling processes

  • Wish to make a complaint in relation to a breach of your privacy

  • Would like to access your Personal Information held by the Company

  • Would like to update or correct your Personal Information held, or

  • Would like to opt out of receiving promotional material,

please contact your usual business contact within the Company (for our suppliers and portfolio companies), or our Privacy Officer in any of the following ways:

  • Email Address: [email protected]

  • Mailing Address: GPO Box 261, Sydney NSW 2001, or

  • Phone: +612 8024 6950

This Privacy Policy was last updated on 11 June 2021.