Strzelecki Privacy Policy
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Privacy Policy

(1 August 2019)

1. About

1.1. This policy applies to the collection, use, disclosure and handling of personal information by
Strzelecki Group, including personal information collected via our Web Services.

1.2. Strzelecki Group is committed to protecting the privacy of individuals in accordance with the
Australian Privacy Principles set out in the Privacy Act 1988 (Commonwealth) (the Act). We
will collect, use, store or disclose personal information in accordance with the Act and this

1.3. Your use of our Web Services is subject to Strzelecki Group’s Web Services Terms of Use as
applicable from time to time.

1.4. Every time you use our Web Services or otherwise provide us with your personal information
you agree to the collection, use, storage and disclosure of information as set out in this policy.
If you do not agree to this policy in its entirety, immediately stop accessing and using our Web

2. Definitions

personal information has the same meaning as set out in the Act, which at the date of this policy is,
information or an opinion, whether true or not, and whether recorded in a material form or nor, about
an identified individual or an individual who is reasonably identifiable.

Strzelecki Group (collectively, “Strzelecki Group”, “we” or “us”) means the group of entities from
time to time based in Australia and known as Strzelecki Group , which includes but is not limited to
Strzelecki Holdings Pty Ltd, Coventry Village Pty Ltd, Poland Superannuation Pty Ltd, WA
Employee Services Pty Ltd, Mycom Investments Pty Ltd, Kreg Pty Ltd, CJH Food and Beverage
Pty Ltd, Coventry Seafoods (Aus) Pty Ltd, Seafood Management Pty Ltd, JDP Holdings (WA) Pty
Ltd, JMP Holdings (WA) Pty Ltd, Two Headed Dragon Pty Ltd and Norfolk Hobbs Pty Ltd and any
related entity of those entities from time to time. If any entity acts as trustee of a trust, a reference to
Strzelecki Group includes that entity in its own right and also as trustee of the relevant trust.

Web Services means any of Strzelecki Group’s websites or mobile device applications, including
but not limited to:,,,,,,,,,, or any
other Strzelecki Group website or mobile device application in respect of which this policy is

3. Collection

3.1. Strzelecki Group collects personal information from you in several ways. We may collect
personal information directly from you, in the course of our dealings with you, or from third
parties authorised by you to share your personal information with us. For example, when you:

3.1.1. use our Web Services (including via cookies);
3.1.2. create an account on our Web Services;
3.1.3. use our booking services on third party websites or mobile device applications;
3.1.4. use a payment gateway to make a purchase from us;
3.1.5. fill in a form on our Web Services, such as subscribing to a newsletter;
3.1.6. contact and correspond with us, including through social media;
3.1.7. provide personal information to us or an authorised third party; and
3.1.8. apply for a position of employment with us or otherwise submit a resume.

3.2. The personal information you provide to one Strzelecki Group entity may be shared by that
entity with other Strzelecki Group entities. By sharing your personal information with one
Strzelecki Group entity you agree to your information being provided by that entity to all
Strzelecki Group entities.

3.3. We may also collect information about you from third parties, such as service providers,
payment gateways, referral partners and recruitment agents, including third party booking
service providers. We may also collect publicly available information about you, for example
information available from government departments and commissions (such as ASIC) and on
social media.

3.4. The personal information we collect about you may include (but is not limited to) your name,
date and place of birth, gender, home address, email address, telephone number, social media
user profile, billing and delivery addresses, payment details, menu preferences, previous
purchases, Internet Protocol address, and information relating to your dealings with Strzelecki

3.5. When you purchase our products online, you do so through a third party payment gateway.
Your information, including your credit card details, will be collected and handled in
accordance with the terms and conditions and policies of the gateway provider. We may receive
some identifying information (including credit card details but excluding card verification code)
and status of payment information, which may be retained to facilitate your future purchases.

3.6. The purposes for which we collect your information may include:

3.6.1. creating an account for you on our Web Services;
3.6.2. contacting you (including via electronic messaging, such as SMS, email and social media,
and by mail or phone);
3.6.3. managing any booking made by you in respect of any of our businesses;
3.6.4. allowing you to use our Web Services and providing you with products, services and
assistance regarding those products and services;
3.6.5. developing and improving our services and obtaining feedback, including sending you
direct marketing material about products, services and promotions relating to Strzelecki
Group businesses (e.g. emails, offers, promotions, newsletters);
3.6.6. allowing you to contact us online;
3.6.7. understanding how our Web Services are used; and
3.6.8. for any other purpose with your consent.

4. Disclosure and Use

4.1. Strzelecki Group may use or disclose your information for the purpose for which is was
collected, and for a secondary purpose that is related to a purpose for which we collected it
where you would reasonably expect us to use or disclose your personal information for that
secondary purpose.

4.2. Strzelecki Group may also use and disclose your personal information where you have
expressly or impliedly consented to use or disclosure; in confidence to third parties to develop
and improve our services, obtain feedback and protect our information (including data storage
services, email filtering, virus scanning and other technology service providers and archival
services providers); and in circumstances authorised or required under an Australian law or
court/tribunal order.

4.3. Some of the third parties to whom we disclose your personal information may be located outside
Australia. For example, we may use overseas services to facilitate email communications, data
collection and processing, and cloud storage of data. The countries in which these third parties
are located will change from time to time, but will ordinarily include: United Kingdom, India,
Hong Kong, New Zealand, United States of America and South Africa.

5. Third Party Websites

Our Web Services may contain links to third party websites or mobile device applications. By
clicking on a link to an external website or application and thereby accessing another website or
application your use (including disclosure of any personal information) will be subject to the third
party’s terms and conditions and privacy policy.

6. Our Communications

Strzelecki Group may contact you via email, SMS or other means to provide updated information
about our Web Services, inform you of offers or events, or to provide other information about our
products and services. If you do not wish to receive any such communications, please contact us
using the details below.

7. Access to Information

You are entitled to request access to or correction of your personal information held by Strzelecki
Group, and you may do so by contacting us using the details below. However, we may refuse access
where the Act permits us to do so.

8. Notifiable Data Breaches Scheme

In the event of any loss, or unauthorised access or disclosure of your personal information that is
likely to result in serious harm to you, Strzelecki Group will investigate and notify you and the
Australian Information Commissioner as soon as practicable, in accordance with the Act.

9. Complaints Handling

9.1. If you have any questions or concerns about our collection, use or disclosure of personal
information, or if you believe we have not complied with this policy or the Act, you may contact
us using the details below. Your query, issue or complaint will be investigated by us to
determine whether a breach has occurred and what action, if any, to take. We will endeavour to
resolve your query, issue or complaint within 28 days and may request relevant information
from you in order to assist us in that regard.

9.2. If you are not satisfied with our handling of your query, issue or complaint, you can complain
to the regulator, the Office of the Australian Information Commissioner via


10. Storage of Information

10.1. Strzelecki Group takes reasonable steps to keep personal information we hold about you secure.
Except to the extent liability cannot be excluded or limited under applicable law, all liability of
Strzelecki Group, our directors, officers and employees to you or any other person for loss or
damage of any kind (however caused, including in negligence) arising from or relating in any
way to any unauthorised access to your personal information, is excluded. Please notify us
immediately if you become aware of any security breach.

10.2. We may store your personal information in hard copy or electronically in Australian-based
cloud servers or the servers of third parties. When we have disclosed your personal information
to third parties, as described in section 4 of this policy, your personal information may be stored
by or transferred to entities located outside of Australia.

10.3. We use a range of approaches to secure personal information against loss, theft and
unauthorised access, disclosure, copying or modification. This includes, but is not limited to,
physical and technical safeguards, such as firewalls, encryption and access controls; and
internal process and policies in respect of access to and use of personal information.

11. Changes to Privacy Policy

This policy was last updated on 1 August 2019. We may review and amend the policy at our
discretion, following which an amended version will be published on our Web Services. By
continuing to use our Web Services, or otherwise continuing to communicate with us, you accept
the version of our privacy policy published on our Web Services as it applies from time to time.

12. Contact Details

Strzelecki Group may be contacted at: PO Box 1172
Nedlands WA 6909