PRIVACY POLICY

1. In this Privacy Policy (Policy):

   1.1. a reference to us, our or we is to a member of the Romeo Retail Group being any entity trading a store or stores under the name “Romeo Retail Group”.

   1.2. Act means the Privacy Act 1988 (Cth) (as amended).

   1.3. Credit Information includes identification information, historical details of credit (including type and amount of credit sought or obtained) and repayment history, information about defaults and payment arrangements, insolvency proceedings, information relating to activities and credit worthiness in Australia and external Territories, information recorded on the National Personal Insolvency Index and opinions of credit providers regarding serious credit infringements.

   1.4. Personal Information means information (including an opinion) about an individual whose identity is apparent or can reasonably be ascertained from the information whether true or not and whether or not recorded in a material form.

   1.5. Sensitive Information has the meaning given by the Act and includes Personal Information which relates to an individual’s racial or ethnic origins, religious beliefs or affiliations, trade association, trade union membership, sexual orientation, criminal record and information as to an individual’s health or biometric information.

   1.6. Website means all of the pages located on the website you are currently viewing being (as applicable) all of the pages located at www.localibyromeos.com.au.

2. Privacy Commitment

   2.1. Thank you for visiting our Website and for reviewing our Policy. We respect the importance of your privacy and the Personal Information in our care. We have created this Policy in order to demonstrate our firm commitment to your privacy. Please see clause 11 below as to some special rules as to how we collect, use and disclose Personal Information in respect of your participation in the Romeo Rewards Card program and the SUPA CLUB loyalty program.

   2.2. All personal information collected by us will be handled in accordance with all applicable laws including the Australian Privacy Principles contained in the Act.

   2.3. This Policy also includes our Credit Reporting Policy which sets out how we collect, hold, use and disclose Credit Information to comply with our credit reporting obligations under the Act and the Credit Reporting Code registered under section 26S(1) of the Act (Code).

   2.4. You should be aware that participation in a loyalty program or other promotional offers may be subject to additional terms and conditions. You should familiarise yourself with those terms and conditions before agreeing to participate in a loyalty program or other offers.

3. Collection of Personal Information

   3.1. We collect Personal Information which is reasonably necessary for our business (including to provide goods and services to you (e.g. online sales), improve the way we service your needs, keep you informed of promotions and specials each week, offer you the benefits associated with our promotional programs, respond to your feedback and surveys, assesses and reassesses the granting or withdrawal of any credit account and process payments). We also collect personal information to assist in investigating and dealing with any complaints you may have.

   3.2. If you are a member of a loyalty program in which we participate including our Romeo Reward Card program, it is necessary for us to collect and keep Personal Information about you to enable:

      3.2.1. you to participate in such programs and enjoy program benefits;

      3.2.2. us to have a better understanding and gain insights into store and campaign performance, shopper trends and to plan future developments, member offers and campaigns; and

      3.2.3. organisations that operate or administer such loyalty programs to perform their functions in relation to that program, including to undertake analysis on retailer performance and trends, and to provide aggregated, anonymous statistics on these matters to other program participants.

   3.3. Personal Information we may collect about you includes:

      3.3.1. your name, address, telephone numbers, email address details and other information necessary to carryout our business and to provide you with goods and services;

      3.3.2. payment and transaction details/history;

      3.3.3. details/history of preferences, interests and behaviour relating to transactions, products, services and activity with our digital services; and

      3.3.4. if you are a member of a loyalty program in which we participate, your membership details (e.g. member number) for that loyalty program and details relating to your use or acquisition of products, services or benefits from organisations that operate, administer or provide products and/or services in connection with that loyalty program.

   3.4. We collect Personal Information as well as non-personally identifiable information that you voluntarily provide.

   3.5. We will only collect Personal Information about you:

      3.5.1. from you (including via online enquiry forms you submit, our direct discussions with you, any emails or other correspondence you send to us and any negotiations we have with you as to the supply of goods or services to you, forms and application which you complete and provide to us);

      3.5.2. as part of the process of appointing you as a supplier of goods or services to us;

      3.5.3. if you have created an online account with us, from your use of that online account or our website;

      3.5.4. from any person authorised by you to provide such Personal Information to us;

      3.5.5. from third party contractors and suppliers we engage to help us provide services;

      3.5.6. from external sources where the information is publicly and readily available;

      3.5.7. from third parties where it is otherwise unreasonable or impractical to collect such Personal Information from you directly. In such cases, we will inform you before, or as soon as reasonably practicable after, we collect such Personal Information; and

      3.5.8. as otherwise set out in this Policy.

   3.6. Through technology we may automatically record details including your internet address, domain name and the date and time of your visit to our Website (including the web pages viewed), your browser and operating system. If you link to our Website from another website then that information may also be recorded. We may also use cookies (small files exchanged between a website server and your computer) on our Website. If you do not want to allow cookies to be used to collect information, you can disable cookies on your computer by changing the security and privacy settings in your browser. Where you provide us with Personal Information of third parties you warrant to us that the relevant individuals have consented to you disclosing their Personal Information to us.

   3.7. We may also collect Personal Information from you via feedback you provide us or surveys or competitions and promotions we conduct from time to time.

   3.8. We may also collect personal information about you indirectly, for example through:

      3.8.1. providers who support transactions that you make in store, including credit card providers and point of sale systems providers;

      3.8.2. organisations that operate, administer or provide products and/or services in connection with any loyalty program in which you and we participate in;

      3.8.3. our related bodies corporate;

      3.8.4. our business partners; and

      3.8.5. third parties who supply services to us, e.g. point-of-sale terminal vendors who report transaction data to us.

4. Use and Disclosure of Personal Information

   4.1. We will only use your Personal Information for:

      4.1.1. the primary purposes for which the Personal Information was collected (for example, to contact you to respond to your query or provide you with goods or services); or

      4.1.2. a secondary purpose related to the primary purpose that you have consented to or would reasonably expect us to use or disclose the Personal Information for.

   4.2. How we use your Personal Information varies based on the services we are providing. Generally, we may use your Personal Information:

      4.2.1. as necessary to provide goods and services to you;

      4.2.2. for recruitment purposes;

      4.2.3. to negotiate a contract for the provision of goods and services to you and to carry out and deal with you in respect of the same;

      4.2.4. to engage you to provide goods and services to us and to manage such relationships with you;

      4.2.5. for customer relationship management purposes and to respond to your queries;

      4.2.6. to analyse client needs and improve the services we provide;

      4.2.7. for accounting and administrative purposes; and

      4.2.8. for other purposes related to our provision of goods and services to you.

   4.3. We may disclose your Personal Information to:

      4.3.1. other members of the Romeo Retail Group, contractors, agents and service providers of the Romeo Retail Group but only to provide goods and services to you and/or for the purposes of storage of your Personal Information;

      4.3.2. our professional advisers but only so they can advise us in respect of the same;

      4.3.3. Metcash Trading Limited (ACN 000 031 569) or its related entities (Metcash), who send communications on our behalf including in relation to the SUPA CLUB loyalty program;

      4.3.4. organisations that participate in, operate or administer any loyalty program in which you and we participate in; and

      4.3.5. third parties who work with us in our business to provide, promote or improve the products or services you have requested or are interested in, such as couriers and delivery contractors.

   4.4. Information other than Personal Information collected from your visit to our Website may be used to assist us in monitoring usage of and deciding how to improve and promote our Website, products and services (including online advertising).

   4.5. We may also use and disclose your personal information to send direct marketing to you, including electronic direct marketing, from our related bodies, Metcash or the operator or administrator of a loyalty programs in which you and us participate in.

   4.6. The direct marketing may relate to:

      4.6.1. our products and services;

      4.6.2. the products and services of other parties;

      4.6.3. your membership of, and benefits associated with, loyalty programs in which you and us participate in; and

      4.6.4. new developments we believe may be of interest to you.

   4.7. You may opt-out of receiving direct marketing through the unsubscribe function that will be made available to you with each direct marketing communication. You should be aware that if you opt out, you may not receive important notifications about your benefits, for example, the expiry of your program points.

   4.8. We may de-identify your Personal Information and aggregate and use the same with other de-identified personal information to produce anonymous data to determine general shopping patterns.

5. Anonymity, pseudonymity and requirement to provide information

In general, you are not required to provide personal information to us. However, if you wish to receive information about our services, or goods events, industry updates or to apply for employment, you acknowledge that it may not be practical for you to use a pseudonym or otherwise not identify yourself and that we may require you to provide certain Personal Information or Credit Information. If you do not provide some or all of the Personal Information or Credit Information requested, we may not be able to provide you with some or all of the services you request including provision of online shopping or your participation in our Romeo Rewards Card program or other loyalty programs we participate in such as the SUPA CLUB loyalty program).

6. Collection, use and disclosure of Sensitive Information

      6.1.1. We will not collect Sensitive Information without your consent.

      6.1.2. If we collect Sensitive Information, we will collect such Sensitive Information directly from you and only to the extent reasonably necessary to provide services to you.

      6.1.3. Sensitive Information will only be disclosed in accordance with the Act as follows: (a) for the primary purpose for which it was collected, (b) for a secondary purpose that is directly related to the primary purpose, or (c) as required by law.

7. Collection of Credit Information

      7.1.1. If we agree in writing to provide a customer credit from time to time (for example, giving the customer time to pay our account for our goods or services) this may involve the collection of Credit Information.

      7.1.2. We may collect Credit Information about you directly from you or persons acting on your behalf (including via application forms submitted by you or on your behalf). We may also collect Credit Information from third parties, including credit reporting bodies and other credit providers, to assist us in determining whether we will provide credit to you.

8. Use and Disclosure of Credit Information

      8.1.1. We may use or disclose the Credit Information we have collected with your express consent, as required by law or court order and otherwise in accordance with Part IIIA of the Act and the Code.

      8.1.2. We may use or disclose Credit Information we have collected about you to decide whether or not to provide credit to you and to collect outstanding debts and enforce guarantees in relation to credit we have provided. We may also use Credit Information have hold about you for internal management purposes and to respond to complaints about our treatment of your Credit Information.

      8.1.3. Subject to the Code and applicable law, we may disclose your Credit Information to credit reporting bodies if you fail to make payments to us or if you commit a serious credit infringement.

      8.1.4. The credit reporting policies for the above credit reporting bodies will be available on their websites. You may request that the above credit reporting bodies do not use your Credit Information for the purposes of pre-screening for direct marketing or share your credit information if you reasonably believe you have been or are likely to be the victim of fraud.

9. Holding and Security of your Personal Information and Credit Information

      9.1.1. We may store your Personal Information and Credit Information in hard copy or electronic format, in storage facilities that we own and operate ourselves, or that are owned and operated by our service providers.

      9.1.2. We take reasonable steps to:

      9.1.3. ensure that any Personal Information or Credit Information we hold or disclose about you is up to date, complete and correct; and

      9.1.4. protect your Personal Information and Credit Information from misuse, interference, loss, and unauthorised access, modification and disclosure.

      9.1.5. We will destroy or delete any of your Personal Information or Credit Information which we no longer need to retain. If you email us any information (including Personal Information or Credit Information), it is sent at your own risk as it may not necessarily be secure against interception.

10. Accessing and Correcting Personal Information and Credit Information

      10.1.1. We rely on the accuracy of the Personal Information and Credit Information you provide to us.

      10.1.2. On your request, except to the extent that we are lawfully able to refuse such a request, we will provide you with access to Personal Information and Credit Information that we hold about you.

      10.1.3. If you satisfy us that Personal Information or Credit Information that we hold about you is misleading, inaccurate, out of date or incomplete, except to the extent that we are lawfully able to refuse such a request, we will correct the Personal Information and Credit Information that we hold about you.

      10.1.4. All requests about the Personal Information or Credit Information that we hold should be made by email or in writing to us (see clause 16 of this Policy for our contact details). We will try to respond to your request within a reasonable period.

      10.1.5. If it is reasonable and practicable to do so, we will give you access to your Personal Information and Credit Information in the manner that you request. We do not generally charge for providing such access but may do so in certain circumstances.

      10.1.6. In the event that we deny access to or refuse to correct your Personal Information or Credit Information that we hold, we will provide you with written reasons and the mechanisms available to complain about such refusal.

      10.1.7. If you are registered on our Website or with a loyalty program in which we participate in, you may be able to update certain Personal Information by logging into your account or contacting the operator of that loyalty program.

11. Romeo Reward Card program and SUPA CLUB loyalty program

      11.1.1. We engage a third party (Worldsmart Retech Pty Ltd ACN 107 563 511) (Worldsmart) to provide our Romeo Rewards Card program (see www.rewards.romeosrewards.com.au) (Program Website). Worldsmart owns and maintains the Program Website. Set out in our terms for the Romeo Rewards Card program is Worldsmart’s privacy policy which details how Worldsmart will collect, use and disclose Personal Information (including to us) in respect of carrying out the Romeo Rewards Card program (see paragraph 5 at www.rewards.romeosrewards.com.au/About.aspx). We may use Personal Information you disclose to Worldsmart via the Program Website as set out in Worldsmart’s privacy policy and as set out in this Policy.

      11.1.2. We engage Metcash to provide our SUPA CLUB loyalty program (see www.supaclub.com.au) (SUPA CLUB Website). Metcash owns and maintains the SUPA CLUB Website. Metcash’s privacy policy can be found on the SUPA CLUB Website and details how Metcash will collect, use and disclose Personal Information in respect of carrying out the SUPA CLUB loyalty program. We may use Personal Information you disclose to Metcash via the SUPA CLUB Website as set out in Metcash’s privacy policy and as set out in this Policy.

12. Cross-border disclosure

Some of the Personal Information and Credit Information we collect may be disclosed to our contractors, agents and service providers located outside of Australia for storage purposes. We take such steps as are reasonably necessary in the circumstances to ensure that any overseas third-party service providers we engage do not breach the Australian Privacy Principles. You consent to your information being disclosed to a destination outside Australia for this purpose, including but not limited to United Kingdom, the United States of America and India. We may also make personal information held in Australia, New Zealand or the other countries listed above remotely available for processing by service provider personnel located in other countries, such as China and Thailand. We take reasonable steps to ensure that overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

13. Third Party Websites

When you leave this Website, you will be going to websites that are beyond our control. Our Policy does not apply to third party websites. We encourage you to read the privacy policies of those third party websites.

14. Changes to Policy

We may amend this Policy from time to time without prior notice. The revised Policy will take effect when it is uploaded on our Website.

15. Complaint

   15.1. If you believe that we have breached our privacy or credit reporting obligations, you can make a complaint by emailing or writing to us (see clause 16 of this Policy for our contact details).

   15.2. We will attempt to complete our investigation and resolve your complaint within 28 days from the date you lodge your complaint. If we think it will take longer to resolve your complaint, we will inform you.

   15.3. If we do not resolve your complaint to your satisfaction or you are dissatisfied with the action we have taken, you can make a complaint to the Office of the Australian Information Commissioner. For further information about how to do this, please contact the Office of the Australian Information Commissioner on 1300 363 992 or visit www.oaic.gov.au.

16. Contact Us

If you have any queries in respect of our Policy or to request access to your information or make a complaint, please contact us by email or in writing as detailed below: Attention: Alan Jones Romeo Retail Group 71-79 O’Connell Street North Adelaide SA 5006 Ph: (08) 8276 5055 Email: info@romeosretail.com.au