- Privacy Statement
This privacy policy (“Policy’’) explains how Confectionery Trading Co Pty Ltd (ACN 002 397 266) (“CTC”), and its subsidiaries, affiliates and personnel (collectively referred as “we”, “us” or “our”) collect, use, disclose, and otherwise process Personal Information. The Policy applies to the processing of Personal Information of customers who make use of one of our platforms and products, including any applicable website, app, platform and/or product of CTC (collectively, the “Services”) to place orders or make enquiries with CTC or with any of its other business partners (“Partner(s)”), who offer CTC products via our Services. CTC is bound by the Australian Privacy Principles (‘APP’) contained in the Privacy Act 1988 (Cth)
- What Personal Information we process and why
Personal Information, in this Statement also referred to as “your data”, means any information or set of information from which we are able, directly or indirectly, to personally identify you, in particular by reference to an identifier, e.g. name and surname, email address, phone number, etc. It does not include data where the identity has been removed (anonymous data).- Ordering CTC goods
We process the Personal Information you provide to us if and when you place an order with CTC. This Personal Information is necessary to execute your order, confirm your order, and to assess your order, payment, and a possible refund. Your information allows us to process your order and send you an accurate bill. It also helps us and any Partner you order with contact you where necessary. Some Partners on our platform may use your information to provide you with status updates on the delivery of your order. Depending on the circumstance, we may rely on your consent or the fact that the processing is necessary to fulfil a contract with you, or to comply with law. We may process the following Personal Information in the ordering process:- Name
- Address data
- Contact data
- Order and transaction data
- Payment data
As part of our Services we may sell products that may reveal sensitive Personal Information, such as health-related information (allergies or dietary requirements), information about your religion (such as if you only eat halal food), information about your medical condition (e.g. drugs, medicines, medical devices, medicated creams, food supplements or herbal/homoeopathic products) or about your sexual orientation via our Partners. We will collect and process this data with your consent as part of your order.
- Customer Services and Support
When you contact CTC or our customer services support, we will use the Personal Information you provide to answer your question or handle your complaint. We may collect Personal Information under call recordings to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.
We may also collect your Personal Information if you submit us a notice in relation to presence of any suspected item in our Services which you may consider as ‘’illegal content’’ under any law or statute of Australia or internationally. We may also provide you with an access to internal complaint handling system and/or to take required measures and protection against misuse of our Services.Depending on the circumstance, we may rely on your consent or the fact that the processing is necessary to fulfil a contract with you, or to comply with law. We may process the following Personal Information for customer service purposes:- Name
- Address data (if applicable)
- Contact data
- Order and transaction data
- Payment data (if applicable)
- Comments (if applicable)
- Content of correspondences between you and customer services department
Any other content that may be required for compliance with any applicable statute or law.
- Customer Accounts
If you interact with our Services you may be given the opportunity to create an account with us either via our various platforms or via third-party social login portals (e.g. Apple, Google, Facebook Connect or other platforms) where a separate privacy statement of the relevant third-party will also be applicable to you in addition to this Statement.. Depending on the circumstance, we may rely on your consent or the fact that the processing is necessary to fulfil a contract with you, or to comply with law. You may withdraw your consent and/or delete your account by contacting us. The withdrawal or deletion of your account may have negative consequences on your user experience. We may process the following Personal Information for customer account purposes:- Name
- Address data
- Contact data
- Customer research
To make sure that our Services are aligned with your preferences and to improve our Services and platforms, CTC may approach you to conduct customer research; such as but not limited to, surveys, questionnaires, and telephone calls. We only send you these types of communications with your prior consent unless this is not necessary according to the applicable law. Participation in the customer satisfaction surveys is completely voluntary. If you do not wish to receive these surveys you can unsubscribe from them in the messages itself. We may process the following Personal Information for research purposes:- Name
- Address data
- Contact data
- Order and transaction data
- Payment data
- Marketing
We also process your Personal Information to be able to send you marketing communications and notifications to administer, support, improve and develop our Services. Such messages may include news, discounts, and updates about new Partners, and other communications that may be subject to direct marketing. We rely on your consent unless your consent is not necessary according to the applicable law. Whenever you want to change your preferences with respect to receiving such communications, you may elect to unsubscribe from our messages by contacting us. We may process the following Personal Information for marketing purposes:- Name
- Address data
- Contact data
- Order and transaction data
- Review(s) and feedback (if any)
- Cookie and Technology data
In order to enable us to personalise your user experience with CTC and optimise our Services offered to you, we may use automated decision making and profiling for marketing purposes.
There may be cases where CTC may process your Personal Information for promoting third-party offers, products and services. The legal basis for this processing of Personal Information is your consent unless your consent is not necessary according to the applicable law. Whenever you want to change your preferences with respect to receiving such communications, you can unsubscribe by contacting us.
- Cookies
CTC uses cookies or similar technologies for functional, analytical, and marketing purposes. Data processed for cookie purposes defer per purpose (functional, analytical or marketing) and depend on the preferences set by you.
Please refer to our Cookie Statement for further information about our use of cookies and/or similar technologies. You can always change your cookie settings via the device you use to browse. Please note that disabling cookies may deny you the ability to use some of the Services and/or features on the website or impair your user experience.
- Fraud prevention
We may also process Personal Information to prevent fraud and other forms of misuse on and via our Services. Depending on the circumstance, we may rely on your consent or the fact that the processing is necessary to fulfil a contract with you, or to comply with law. We may process following Personal Information for fraud prevention purposes:- Name
- Order and transaction data
- Payment data
- Device information
- IP address
- Browser information
- Analytics
CTC uses your Personal Information to be able to improve our websites and our range of products and Services and to be able meet our reporting obligations towards third parties which may also include advertisers or Partners. Depending on the circumstance, we may rely on your consent or the fact that the processing is necessary to fulfil a contract with you, or to comply with law. We will make sure the reports do not contain any Personal Information so that the information cannot be traced back to you.
- Campaigns
CTC may launch specific campaigns in connection to its Services. Joining or participating in CTC campaigns or contests will always be voluntary. We may rely on your consent unless your consent is not necessary according to the applicable law. You can always withdraw your consent via the contact data provided to you within the campaign or by contacting us.We may process the following Personal Information for campaigning purposes:- Name
- Contact data
- Order and transaction data
- Campaign data
- Additional purposes
We will only use your Personal Information for the purposes described. If we want to use the data for a different purpose, we will take appropriate measures to inform you, consistent with the significance of the changes we make. Depending on the circumstance, we may rely on your consent or the fact that the processing is necessary to fulfil a contract with you, or to comply with law.
- How we collect your Personal Information
- We acquire, process and retain your Personal Information, as well as Personal Information about devices you use to navigate CTC platforms (e.g. your computer, mobile or other means), which you provide to us by ordering, creating an account or otherwise by contacting
- We process Personal Information that you provide voluntarily, that we collect automatically and that we obtain from third party sources for the purposes outlined in this statement:
- Personal Information that you provide voluntarily: We may receive Personal Information provided from you when you place your order, create an account with us or provide for your marketing preferences or customer reviews in connection to our Services.
- Personal Information that we collect automatically: With your prior consent or when permitted by applicable law, when you browse our platforms, we may automatically collect technical data about your equipment, browsing activities and We use this Personal Information by using cookies, server logs and other similar technologies. These self-learning algorithms generate content that they use to personalise your user experience, selecting in particular those items that you are interested in, as well as to support the overall optimisation of our Services. For our cookie policy, please refer above (Cookies) for more information.
- Personal Information that we obtain from third-party sources: We may receive Personal Information from third party sources, including advertising networks and social media platforms such as Facebook or technical payment and delivery services providers which may be located outside of Australia for purposes such as to support procurement of our Services, to measure the performance of marketing campaigns for our Services; and better understand your preferences so that we can customise our marketing campaigns and Services Where we may receive such Personal Information, we have checked that these third parties either have your consent to process the information or are otherwise legally permitted or required to share your Personal Information with us.
- Age
Our Services are not intended for persons defined as underage by applicable local laws, nor do we intend to collect Personal Information of visitors who are under the defined legal age.However, we are unable to verify visitors’ ages. We therefore advise parents and/or legal guardians to monitor their children’s online activities, to prevent their Personal Information being collected without parental consent. If you feel that we have collected Personal Information of a minor without consent, please contact us. We will then proceed to erase this data.
- Automated decision-making and profiling
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. In the performance of the contract with you, and/or to the extent necessary to fulfil our obligations or where necessary to improve our platforms and Services for our legitimate interest, CTC may use automated decision making and profiling. For example, CTC may use your address data and/or location data to select available Partners in your local area. We may also use automated decision- making in complying with our legal obligations to prevent money laundering, terrorism financing, and other criminal offences.
You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you. If you want to object to this type of processing, you can contact us. We will then proceed to reassess the situation and/or provide you with more information about why and how such automated decision was made.
- How long we keep your data
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, tax, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymise your Personal Information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
- Sharing Your Person Information
- Sharing your Personal Information with Partners – If you order through our Services, CTC may share your personal information (order, name, address, or contact data) with the Partner you selected so that the Partner can deliver your order and where necessary services, for instance to resolve your complaint. Partners may process your Personal Information to contact you if it is necessary to fulfil the contract with you.
You are a direct customer of the Partner, and therefore the Partner bears its own responsibility and obligations for the processing of your Personal Information. For questions about how the Partner handles your data, we suggest you contact the Partner directly. - Sharing your Personal Information with others
CTC may work with other companies and/or other third parties in order to carry out the processing described in this Statement and/or to comply with legal obligations.
These companies and third parties will process your Personal Information on behalf of us as data processors or as autonomous data controllers (or in a position as so defined or referred under applicable data protection law including concepts as the equivalent of controller or processor), and have access to your Personal Information for the purposes described in this Statement. We require companies and third parties to protect your Personal Information in accordance with the standards set out in this Statement and we take appropriate measures pursuant to the applicable data protection law to guarantee the same level of protection and confidentiality.
We may also share your data with other third parties where appropriate or required by applicable law or regulation (including a court order or legal authority request) or where we believe disclosure is necessary to comply with legal obligations, to exercise, establish or defend legal rights or to protect the vital interests of any person. Such third party controllers may include law enforcement agencies. - We may also disclose your Personal Information to any company or prospective buyer of all or substantially all of our assets in connection with any sale or transfer of those
- Your Personal Information may be shared with the following parties:
- CTC’s affiliates, subsidiaries and/or group companies of CTC
- Software providers such as providers for software, hosting, application support, delivery, logistics, information security, etc
- Third parties who undertake various activities to promote, market or support our This includes social media platforms like Facebook, offshore customer support agents, marketing service providers, eCRM partners who manage our marketing emails and push notifications, partners who send you text messages when your order is on its way, delivery companies who deliver your order to you.
- Implementation partners
- Merchants, payment and card service providers
- Customer satisfaction survey firms and/or market research companies
- Loyalty shop partners
- Professional consultants
- Law enforcement, governmental or regulatory authorities (including insurance companies, visa and tax authorities)
- Any other third party provided that you have given your consent to the disclosure
- Third-party websites
Our website may include links to third-party websites. When accessing such third-party websites, please note that each of these websites has its own privacy statement. Although CTC takes great care in selecting websites to link to, we cannot take responsibility for the way in which they handle your Personal Information. - Where your data gets sent
If you are in the European Economic Area (EEA), Israel, Australia, New Zealand and Canada, please be aware that we may process and/or transfer your Personal Information outside of the EEA Israel, Australia, New Zealand and Canada. This may include transferring it to or accessing it from other jurisdictions, including jurisdictions that may not provide a level of protection equivalent to the your local- and/or data protection laws (“Non-Adequate Country”). Where we transfer Personal Information outside the EEA, Israel, Australia, New Zealand and Canada we will take into account any applicable statutory obligations relevant to Personal Information transfers, and in Non-Adequate Country, we will rely on appropriate safeguards, including EC approved standard contractual clauses or other lawful binding transfer mechanism pursuant to the applicable data protection law. - Personal Information rights, questions or complaints
We inform you that, with regard to the Personal Information, you can exercise the rights provided for by applicable data protection laws, which may include: the right to request access to, rectification of, or erasure of Personal Information or restriction of processing, and to object to processing, the right to data portability, to withdraw your consent at any time (without prejudice to the lawfulness of the processing based on the consent given prior to the withdrawal) as well as to lodge a complaint with a supervisory authority directly. To exercise your rights please contact us.
We will do our best to address your request in time and free of charge, except where it would require an excessive and disproportionate effort. In certain cases, we may ask you to verify your identity before we can act on your request.
If you have any other questions or complaints about the processing of your Personal Information, we will be happy to contact you. We would also like to hear from you if you have tips or suggestions on how to improve our Statement.
- Security
CTC takes Personal Information protection very seriously and we therefore take appropriate measures to protect your Personal Information against misuse, loss, unauthorised access, unwanted disclosure, and unauthorised alteration. If you feel that your Personal Information are not adequately protected or there are indications of misuse, please contact us. - How to Contact Us
Unless otherwise indicated, CTC is the controller of your Personal Information.
If you need to contact us to make requests or if you have any questions and concerns about this Statement and/or our privacy practices and processing activities, please contact us at:
5 Epic Place, Villawood, NSW 2163
(02) 9743 8631
- Updates to this Policy
We may update this Statement from time to time in response to changing legal, technical or business developments. When we update our privacy Statement, we will take appropriate measures to inform you, consistent with the significance of the changes we make. Where required by applicable data protection law, we will obtain your consent to any material changes to this Statement.
For clarification, it should be noted that the use of the term “Partner” or any similar expression in this Statement does not imply or establish a partnership, employer-employee, or agency relationship of any kind between the mentioned party and CTC.
We encourage you to periodically review this Statement for the latest information on our privacy practices.
To the extent we have local language versions, the English version of this Statement shall prevail in case of conflicts between the different language versions.
This Statement may be updated and was last updated on 19/01/2024