Privacy Policy

The privacy of your Personal Data is important to Soul IV Pty Ltd and its related affiliates (referred to collectively as “SOUL IV”, “we”, or “our”), and we are committed to ensuring that your Personal Data is handled responsibly, in accordance with the applicable Data Protection Legislation. We adhere to the Privacy Act 1988 (Cth) (“Privacy Act”), including the Australian Privacy Principles (“the APPs”) (hereinafter jointly referred to as the “Australian requirements.

SOUL IV’s system for complying with Australian privacy requirements includes:

• Our commitment to compliance with privacy requirements
• Our policy and approach to privacy, as explained in this information
• Our resources allocated to privacy, including our technology systems and services
• Our people and the training and education we undertake\

1. Collection of information

The types of information that SOUL IV collects from you will depend on the circumstances of collection and on the service that we are providing to you.

1.1 Personal information

The type of personal information collected will be directly related to the specified purpose it has been collected for. How much of your personal information that you choose to disclose to us is completely up to you. Generally, the only way we know something about you personally is if you provide it to us. However, failure to provide certain information may result in SOUL IV being unable to provide you with the relevant product or service. We will make you aware of the purpose for which we collect the personal information and, where possible, the consequences of not providing it at the time of collection.

For example:

• If you request products or services from us, we may collect information such as your name and contact details (i.e. billing and/or postal address, phone/mobile number(s) or email address), date of birth and/or credit card details.
• If you sign up to use a particular service such as email or mailout marketing (about product updates and developments, special events or promotions), loyalty or rewards program(s) or enter into a competition operated by us, we may collect information such as your
  • date of birth and your interests and any other information required to provide that service to you (in addition to your name and contact details).
• If you participate in any surveys we, or a third party service provider acting on our behalf, may conduct from time to time gather personal information relating to your survey responses.
• If you make an inquiry, provide feedback or make a complaint to us, we may collect your name and contact details.
• If you are applying for employment with us, we may collect any information that is relevant to such employment including:
  • Your name and contact details (i.e. residential address, phone number(s) and/or email address); and
  • Any other information relevant to the recruitment process (including any information contained in the application form and your resume).

You acknowledge that the personal information we collect from you is your own information or information which you have been authorised to provide us.

1.2 Sensitive information

SOUL IV does not generally collect sensitive information as defined under the Australian Privacy Act, such as racial or ethnicity information, political opinions or associations or criminal records. However, subject to your health needs, with your prior consent, we may collect sensitive information from you in the course of considering the best product or service for you.

1.3 Unsolicited information

Where unsolicited information is received by us, we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information under the APPs/IPPs. If it would not be permitted for us to collect the information, we will destroy the information or ensure it is de-identified as soon as practicable. Otherwise, we may retain the information in accordance with the terms of this policy.

1.4 Anonymous information

We may also collect information about visitors to our website(s). For example, we may collect:

• Statistical information about the number of visitors to the websites and the date, time and duration of visits;
• The name of the domain/URL from which you access our websites; and
• The internet protocol address.

However, we do not collect information about the identity of the visitors unless they voluntarily provide that information.

2. Method of collection

This personal information will only be collected through lawful and fair means and not in an unreasonably intrusive way. SOUL IV collects your personal information when you deal with us directly, including via our website(s), via forms or correspondence (i.e. by mail or email), over the phone or in person.

We may also collect personal information through our related bodies corporate and our third-party service providers (such as data relating to survey responses) so that we may provide a better or more relevant product or service to you.

Credit card information we collect from you will go directly to our processor or bank. If you choose to purchase a product from us, our third-party payment processors will collect your payment information, and none of our personnel will have access to this data.

3. Use of information

3.1 Use of personal information

We will use the personal information you have chosen to provide us for the purpose for which you provided it or a related secondary purpose which you would reasonably expect. We will not use it for any other purpose without your consent, unless permitted or required by law.

Generally, we will use your personal information for the following purposes:

• Providing the products and/or services you have requested from SOUL IV;
• To process sales transactions;
• To deliver the products or services to you;
• To register you for a service requested by you, such as our newsletter(s) and e-newsletters, mailouts, rewards program(s) or competitions and administering such services;
• To respond to any inquiries, feedback or complaints made by you;
• Direct marketing of products and services which we believe may interest you, including product updates and developments, special events or promotions;
• Assisting us to improve our products and services and making them more relevant to you;
• Assisting us to improve our website(s);
• Processing and assessing employment applications for current and future positions; and
• Otherwise managing our internal business operations and processes.

SOUL IV will provide you with the opportunity to “opt-out” of receiving marketing materials at the time of collection and/or at any time afterwards by either unsubscribing from the email service or contacting our Privacy Officer via the contact details provided below.

3.2 Use of anonymous information

SOUL IV gathers anonymous information to:

• Monitor the use of our website(s);
• Help us make improvements to the website(s); and
• Offer relevant information and services to as many users as possible.

4. Disclosure

There will be occasions where it will be necessary for SOUL IV to disclose your personal information to third parties.

SOUL IV may disclose your personal information to:

• Contractors and third-party service providers on a confidential basis that we use in the ordinary course of our business to assist with the delivery of the product or service;
• Other members of SOUL IV’s corporate group for marketing purposes (subject to obtaining your prior consent, if necessary);
• Government authorities or other third parties as required by law, and relevant health or government authorities related to pandemic (COVID-19) or other serious public health issues;
• or any other purpose that you have consented to.

5. Transfer of information outside Australia

SOUL IV may transfer your personal information to our related entities and third-party service providers who will hold your information on a cloud computing system, which may hold your data on servers located outside of Australia. However, where your personal information is disclosed to an overseas recipient or a cloud computing system, we will take adequate measures to ensure that your personal information is handled in accordance with, or to a comparable safeguard to, the APPs (the Australian Privacy Act) and our instructions in accordance with this Privacy Policy. By providing us with your personal information, you consent to your personal information to be stored or sent overseas for the purposes set out in this Policy. Other than as stated above, we do not disclose personal information that you may give us to any organisation or person outside of SOUL IV unless you have authorised us to do so.

6. No sale of personal information

Under no circumstances will SOUL IV sell or receive payment for licensing or disclosing your personal information.

7. Security

The security of your information is important to us. SOUL IV operates secure data networks that are designed to protect your privacy and security. When we have collected information about you it cannot be seen or modified by anyone else. SOUL IV has implemented generally acceptable standards of technology and operational security to ensure personal information (in both physical and electronic form) is protected against loss, misuse, interference and unauthorised access.

Only authorised SOUL IV personnel and contractors are provided access to personal information and have agreed to ensure the confidentiality of this information. Reasonable steps are taken to destroy or permanently de-identify any personal information that is no longer required.

We review and update our security measures in light of current technologies. You should however be aware that the internet is not a secure environment and information sent via the internet (including email) cannot be guaranteed to be totally secure.

8. Data quality, access and correction

Under both Australian Privacy Act you have certain rights of access to correct your personal information.

8.1 Access

If you access one of our online services or products, you may access your personal information at any time by accessing your subscriber/account details via the relevant facility on our websites. Otherwise, you may at any time, request access to personal information that SOUL IV holds about you by making a request to our Privacy Officer at the address or email address below.

We will endeavour to process any requests for access to personal information within a reasonable period of time. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested, or providing you with a summary of the information held. If we need to deny your request for access we will let you know why and inform you how you may lodge a complaint regarding this decision. Generally, this will only be in cases where providing access would be unlawful or is subject to a potential legal claim or proceeding.

SOUL IV may charge a nominal fee for supplying personal information.

8.2 Correction

We will try to ensure that all information we collect, use or disclose about you is accurate, complete, up-to-date and relevant to the service or products being provided. If you discover or suspect that there is an error or information is missing, please forward your request for correction to our Privacy Officer in writing at the address or email address below. Our Privacy Officer will consider your request as soon as practicable, manage the correction of your personal information and will update you in writing. If your correction request is refused, our Privacy Officer will provide you within a reasonable period of time the reasons for such refusal and inform you of the complaint process (see below).

9 Use of Cookies

If you sell products online or via apps, you need to specify what the cookies mean and what type is being used.

10. Complaints about privacy and our complaint handling procedure

If you have any complaints relating to the management of your personal information or if you believe there has been a breach of the APPs by SOUL IV, please forward your complaint in writing to our Privacy Officer at the address or email address below. Our Privacy Officer will consider the complaint and advise you of their decision in writing within a reasonable time from receipt of the complaint.

If our Privacy Officer determines that there has been a breach of the APPs or this Privacy Policy, s/he will endeavour to ensure that the breach is rectified as soon as practicable but within 30 days from the date of the decision and will update you in writing. If the breach has not been rectified within 30 days, then our Privacy Officer will inform SOUL IV’s Director in order to resolve the matter. If a breach is of such a nature that SOUL IV is required under the Australian Privacy Act to notify you or the Office of the Australian Information Commissioner, SOUL IV will provide this notice in accordance with the relevant Privacy Act.

If you are unhappy with the handling of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner (visit www.oaic.gov.au for more information).

Australia: Office of the Australian Information Commissioner by:

• Phone: 1300 363 992 (local call cost but calls from mobile and pay phones may incur higher charges).
• TTY: 1800 620 241 (this number is dedicated to the hearing impaired only, no voice calls.)
• Post: GPO Box 2999 Canberra ACT 2601 Fax: +61 2 9284 9666
• Email: enquiries@oaic.gov.au

11. Contact Privacy Officer

If you believe your Personal Data has not been treated consistently with this Privacy Policy or the Privacy Act, please contact us (see “Contact us” via our website or details below). We will investigate your privacy complaint and respond to you as soon as practicable. We aim to resolve all complaints we find are justified.

Please contact:

• Post: Privacy Officer, 1 Oxley Road, Hawthorn VIC 3122
• Phone: 1300 467 685 (local call cost but calls from mobile and pay phones may incur higher charges).
• E-mail: privacy@souliv.com.au

12. Changes to this Privacy Policy

We may, from time to time, review and update this Privacy Policy including, to take into account new laws, regulations and technology. Any changes we make to this Privacy Policy in the future will be posted on the website and, where appropriate, notified to you by email.

All Personal Data that we collect, use, hold and disclose will be governed by the most recent Privacy Policy that has been posted on our websites. Please check back frequently to see any updates or changes to this Privacy Policy, which will be effective immediately when posted on this website or notified to you as applicable.