What is your personal information
Andrash Management Pty Ltd Trading as X Convenience (ABN: 86 294 937 050) (“We”, “our”, “X Convenience”) are sensitive to privacy issues and fully committed to complying with our obligations under the Privacy Act 1988 (Cth) (the “Privacy Act”). We conduct our business in accordance with the Australian Privacy Principles contained in the Privacy Act. This Privacy Policy outlines how We collect, use and manage your personal information.
What is your personal information
When used in this privacy policy, the term “personal information” has the meaning given to it in the Privacy Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.
What personal information we collect and hold
We only collect personal information that is reasonably necessary for our business functions and activities and to provide you with our products and services.
If you are a customer and you decide not to provide certain personal information to Us, We may not be able to provide you with the product or service you are after.
By acquiring or using a X Convenience product or service or providing your personal information directly to us, you consent to X Convenience collecting, storing, using, maintaining and disclosing your personal information for the purposes set out in this Privacy Policy.
The types of personal information that We collect varies depending on which of our products and services you use and our relationship with you, and includes email address, name, date of birth, image, gender, address, telephone number, birth country, occupation, transaction information about goods and services that you purchase or order through our website or app and driver’s licence or passport number. We may collect your location information if you consent to us using your location information, for example to enable you to find a nearby store and use certain functions of a relevant X Convenience App.
We may also collect information about your device (such as IP address) and information about how you use our products and services and may include records of your communications and interactions with us and details of purchases, preferences, interests and behaviour relating to transactions, products, services and activity with our digital services.
You may also provide us with personal information concerning other individuals. In this case, We rely on you to have informed those individuals that you are giving us their personal information (and obtained their consent) and advised them of this Privacy Policy.
X Convenience may also collect certain sensitive information (as defined in the Privacy Act) (such as health or biometric information or templates) directly from employees of both X Convenience and commission agents, and family members of commission agents, for the purposes of:
- identification and provision of payroll services;
- maintaining and monitoring accurate records of employees and commission agents working hours;
- maintaining photographic identification of all employees captured in the store;
- capturing images and other related data pertaining to an employee’s time and attendance; and
- conducting surveys of employees and meeting reporting obligations,
where you have provided your consent. Information about employees is also treated as personal information under this Privacy Policy.
X Convenience may also collect photographic or biometric information from users of our X Convenience App and visitors to our stores, again, where you have provided your consent. X Convenience collects and holds such information for the purposes of identity verification.
How we collect personal information
Generally, we collect most personal information directly from you, for example, where you:
- order and purchase goods or services through our website and/or apps;
- register for participation in a competition, promotion or survey;
- request customer service or contact us;
- apply for employment;
- make a franchise or other specific enquiry necessitating a response;
- participate in a digital interactive activity;
- use a feedback kiosk from our stores; or
- register for and use a product or service, such as the X Convenience Fuel Card, or a relevant X Convenience App.
We may also collect personal information from our related entities, business partners (such as outsourced service providers) and outside sources, such as marketing mailing lists and public sources.
If X Convenience holds personal information about you that it has collected from different sources (other than through the X Convenience websites and/or apps) such as your interaction with X Convenience through Facebook, any other social media and/or Google, X Convenience may combine this personal information into a single record.
Payment information
The X Convenience website or apps may allow you to make payment for goods or services, and you will be asked to enter your payment method such as credit card or debit card details. X Convenience utilises the services of a third party payment processor (currently CyberSource & The Commonwealth Bank of Australia) to process your payment, and the payment information that you enter on the website or app is sent securely to our processor and processed directly by our processor. X Convenience does not collect or store details of your payment information (but will collect and store information about the transaction). Your payment information will be collected and used for the purposes of processing your transaction, refunds and investigation of incorrect payment or fraudulent activities.
Digital products and services
We also offer services and information across a range of digital channels including the X Convenience website, apps and through social media.
Some but not all of X Convenience services allow you to access information without disclosing who you are or revealing any personally identifiable information to us. For example, the Store Locator on the website can be used without providing personal information but some X Convenience Apps will require you to provide personal information to create an account and access the features offered.
We will collect information about how you use these digital channels so that We can help personalize your online experience. For example, We may use ‘cookies’ and/or other tracking technologies on the X Convenience website or X Convenience Apps. A cookie is a small piece of text that is placed within the memory of a computer and can be later retrieved by web page servers. Cookies are used to enhance your interaction and convenience in using our website. Cookies may record information about your visit, including the type of browser and operating system you use, the pages you access and the information downloaded by you. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. Please note that some services or features of our website of X Convenience Apps will not function so well if cookies are disabled. This anonymous data may be used by us and our online service providers to improve our services, to target relevant online adverts to you as you browse other sites on the internet, to provide our services to you, for our internal management needs, and for any other use which is required or authorised by law. Our servers may also collect other non-personal information about you, including the details of webpages visited and your operating system in use, for the purpose of measuring the use of our website and to improve its content.
The collection of this information assists us to assess what promotions to make to you, when and how. This information allows us to send you tailored advertising about products and services that may interest you. You may receive tailored advertising on the websites you visit in the form of a banner advertising, or on social media platforms you use.
Our online services may contain links to other sites. We are not responsible for the privacy practices or policies of those sites and recommend that you review their privacy policies.
How we hold personal information
We may store your personal information in hard copy or electronic form, whether at our own premises, or at facilities operated by our service providers.
How we use and share personal information
Unless otherwise disclosed during the collection process, personal information which We collect from you is used only for the purposes consistent with the reasons it was provided, for a related purpose, or where otherwise permitted by law.
Examples of how We may use your personal information include:
- to provide products and services to you and provide you with information about them;
- to process your payments or refunds;
- to administer, manage, and improve our products and services, including to perform identity related checks;
- to understand the use of our products, services and digital channels and to make improvements to them;
- to respond to particular requests from you;
- to assist in investigating your complaints and enquiries;
- in general to promote and market to you our various businesses, services, products and special offers and those of our trading partners.
Marketing communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you use a X Convenience App we may also send you direct marketing through in app push notifications.
While We may use your personal information for such marketing purposes, you have a choice as to how We can communicate with you for marketing purposes. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. If you do not wish to receive marketing communications from us, you may opt out of receiving them by forwarding an email to queries@xconvenience.com.au Additionally, any email promotion message which We send to you will also contain instructions on how to unsubscribe. You can manage in app push notifications directly through your mobile device settings.
If you make a request in relation to a product or service provided by or in connection with one of our suppliers, it may be necessary to disclose your personal information to that entity to ensure that your request is satisfied or any issue raised is resolved. We may also outsource some of our internal functions and activities or otherwise use third party service providers to assist with some of our services (such as various IT, consulting and mailing services, including offshore cloud computing service providers). In the course of doing so, We may disclose your personal information to a service provider so that it may undertake the outsourced activity on our behalf.
We may disclose your personal information to:
- our payment processing provider for the purposes of processing your payment or refund;
- your authorised representative, when you ask us to do so;
- our franchisees;
- law enforcement agencies and other government and regulatory bodies as required or authorised by law.
We will not otherwise disclose this personal information except when authorised to do so by law.
We may anonymise and aggregate your personal information. We may do this and use and disclose the anonymous data to determine preferences and shopping patterns. We share this anonymised data with our trusted partners to assist them in understanding the retail markets, and marketing products and services to you that are likely to be relevant to your interests and preferences.
Our sharing of personal information overseas
In some cases, our service providers including technology or data storage providers are located in countries outside Australia. While it is not reasonably practicable to list all of the countries to which your personal information may be disclosed from time to time, it is likely that such countries may include the United States of America, Canada, the Netherlands and New Zealand. Where We share your personal information with such entities, We will do so in compliance with Australian privacy laws and will take reasonable steps to ensure that such entities similarly agree to protect that information.
Access to personal information and correction of personal information
We are concerned to ensure that any personal information We obtain and use is accurate in all respects. You can request access to your personal information or advise us of any required correction to personal information which you believe to be inaccurate by forwarding a request to queries@xconvenience.com. When making an access request, please provide as much detail as you can about the personal information you seek, to help us retrieve it.
Upon a request to correct personal information, We will consider if the personal information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it, if you request such statement.
Upon request for access to personal information, We will provide you with details of any of your personal information that We hold, except in the limited circumstances permitted by law (for example if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality).
Under the Privacy Act and other relevant laws, We are required to provide a written response outlining our reasons if We refuse your access or correction request.
Complaints and concerns
Although We are committed to ensuring that at all times there is strict adherence to the Australian Privacy Principles, in the event that you are dissatisfied in any way with the collection or use of your personal information or believe that there has been a breach of the Australian Privacy Principles, We invite you to contact us as soon as possible.
If you have any complaints or concerns about this Privacy Policy or our handling of your personal information, you can contact our Privacy Officer at queries@xconvenience.com
Alternatively, you can write to “Privacy Officer, X Convenience Pty Ltd, 55 Henley Beach Road, Mile End, South Australia, Australia 5031”.
We may discuss your complaint with our personnel and our service providers as appropriate. Our Privacy Officer will investigate the matter and attempt to resolve it in a timely manner and will inform you in writing of the outcome of the investigation.
If you are not satisfied with the Privacy Officer’s resolution of your complaint, please let us know and We will investigate the matter further and respond to you. If you are still not satisfied with the way We dealt with your complaint, you may refer it to the Office of the Australian Information Commissioner (“OAIC”). You can contact OAIC by:-
- visiting www.oaic.gov.au
- forwarding an email to enquiries@oaic.gov.au
- telephoning 1300 363 992; or
- writing to OAIC at GPO Box 5218, Sydney NSW Australia 2001
Revision in policy
With a view to improving our service to you and ensuring the highest level of compliance with the Australian Privacy Principles, We may revise this Privacy Policy from time to time. It is your responsibility to check when you visit our website or use any applicable X Convenience Apps to ensure that you are aware of the content of the then applicable policy. If you have any queries concerning this Privacy Policy, please contact our Privacy Officer at the email or mail address provided above.
Last updated: December 2020