Privacy Policy

Wholly Franchise Limited ("Wholly Bagels") respects the privacy of individuals. This policy sets out the way in which Wholly Bagels and its franchisees ("we" or "us") collect, hold, use, disclose and protect your personal information.

By visiting any of our websites, placing an order with any of our stores (including franchisee stores) or providing us with your personal information, you agree to your personal information being collected, held, used and disclosed as set out in this policy.

You do not have to provide us with your personal information but, if you do not provide us with the information we require, we may not be able to assist you or process your order.

Revisions to this policy

We may revise this policy from time to time whenever necessary so check this website regularly to stay informed of any updates. If we make material changes to this policy, we will put a notice on the homepage www.whollybagels.co.nz of our websites.

Your continued use of our websites, placement of an order with any of our stores or the provision of further personal information to us after this policy has been revised constitutes your acceptance of the revised policy.

What Information we collect

We collect information necessary for us to process your orders or provide you with other services and/or the assistance you have requested. Where practicable, we will give you the option of interacting with us anonymously.

The personal information which we collect from you and hold ("Information") includes information such as your first and last name, postal address, telephone and mobile number(s), email address and credit card details. In respect of your credit card details, we only hold some information, as detailed further below.

When you apply for a job with us or to become a franchisee we also collect some sensitive information from you for the purposes of assessing your suitability as a Wholly Bagel's employee or franchisee (to which you have consented). The sensitive information we collect in these circumstances is further set out under the heading 'Sensitive Information' below. When you place an order with us online using the Wholly Bagel’s internet ordering system, we collect additional Information from you such as:

• your IP address as part of your order;
• your feedback;
• your entries into our competitions and draws;
• your menu preferences and previous order information;
• any delivery instructions or comments;
• if you use an eVoucher we collect your order details, if you have used it, when you used it.

How do we collect Information?

We collect your Information in various ways, including when you:

• visit any of our websites;
• when you "Like" our Facebook page or participate in any surveys, promotions and competitions through our Facebook page;
• place an order via online ordering;
• interact with our franchise recruitment website or participate in the franchise recruitment process;
• interacting or following our social media pages/profiles like Google+, Twitter, Facebook and Instagram;
• use our mobile apps and eClub subscriber app;
• enter into a competition or promotion through any medium;
• subscribe to our eDM mailing list;
• participate in a survey;
• participate in focus groups, polling and market research activities;
• register as an eClub member;
• apply for a job with us;
• request information regarding our franchise system;
• submit website feedback;
• submit any query to the Privacy Officer; or
• place an order via a store, telephone or the Wholly Bagels Pizza internet ordering system and mobile site.

Wherever possible, Wholly Bagels or its franchisee will collect your Information directly from you. However, there may be occasions when your Information is collected from someone else (for example, Wholly Bagels may collect your Information from its franchisees). Where Wholly Bagels or its franchisee collects your Information from someone else, Wholly Bagels or the franchisee will take reasonable steps to inform you of this. Irrespective of the source, your Information is collected, held, used and disclosed by us in accordance with this policy.

How do we use Information?

We use your Information for the purpose for which it was provided to us, other related purposes and as permitted or required by law. Such purposes include, but are not limited to, the following:

• providing you with email and/or SMS confirmation of your order;
• providing you with the assistance, products and/or services you have requested;
• allowing you to participate as an eClub member;
• processing any job application you may submit;
• processing any franchise application you may submit via our franchise recruitment team or our website;
• providing you with any franchise information you may request;
• processing any orders you place with us;
• determining the number of visitors to our websites and conducting reviews of our websites;
• judging competitions, fulfilling prizes, awards and purchases;
• keeping you informed about any changes to our websites as well as good and/or services;
• conducting market research (including focus groups, panels and surveys) so that we can better understand the needs of our customers and tailor our future products and services accordingly;
• sending you offers or information on products or services that we consider will be of interest to you (if you have consented to receiving such);
• any other purposes identified at the time of collecting your Information;
• used to assist in the delivery of your order to your door and to verify your credit card payment;
• stored to help you remember and re-order from our menu in future;
• used to provide you with an SMS to inform you when your order is on its way or ready for pick-up from one of our stores;
• requesting your feedback on our products and/or services;
• responding to any complaints, enquiries and feedback;
• unsubscribing your details from our databases.

Credit card details

Wholly Bagels does not store any credit card details for in-store orders.

Internet orders can be paid by cash in store, debit cards, gift voucher or e-voucher, or pre-paid via a valid credit card which must be presented upon receipt of your order. Your credit card details are required to process payment on the internet order system however they are not saved once the order is processed.

The credit card details we hold are: the name on the card, expiry date and the masked version of the code (ie first 6 digits and last 4 digits).

eVouchers

Most Wholly Bagels vouchers carry an eVoucher number which can be redeemed via the Wholly Bagels internet ordering system. Simply enter this number on the right hand side of your screen when ordering online. This information is then processed by Wholly Bagels in order to verify and provide your discount.

Third Party disclosure of your Information

Where appropriate, Wholly Bagels and its franchisees will share your Information between themselves and with other third parties, including:

• to meet the purpose for which it was submitted to us;
• our related entities and third parties who provide services to us or on our behalf (for example third parties processing your online payments, IT and cloud storage service providers and processors, third party suppliers providing our SMS service and mailing houses);
• entities which you have expressly allowed us to disclose your Information to;
• any entities that we or our franchisees are required or permitted by law to disclose your Information to;
• if your Information is collected in connection with a joint promoter or service provider, to that joint promoter or service provider for marketing and research purposes;
• if you place an order via our website, mobile site or app, your details will be passed on to our credit card processor who will receive your credit card details for such orders. Presently DPS provides this service and DPS is a secure internet payment gateway that secures your credit card number during transmission.
• we may share Information with agents, affiliates or service providers who act for or on behalf of us in connection with our business, or for further processing, in accordance with the purpose(s) for which the Information was originally collected;
• any other third parties notified to you at the time of collecting your Information or after the collection of your Information.

Some of our related entities and third party service providers are located in countries outside of New Zealand (including but not limited to the United Kingdom, Australia, United States, Germany, The Netherlands, France, Belgium and Ireland). Our contracts with these parties generally include an obligation for them to comply with New Zealand privacy law and this policy. However you acknowledge that, by agreeing to the disclosure of your Information to these entities outside of New Zealand, we will no longer be required to take reasonable steps to ensure the overseas recipient's compliance with the New Zealand privacy law in relation to your Information and we will not be liable to you for any breach of the New Zealand privacy law by these overseas recipients and, on this basis, you consent to such disclosure.

eClub membership

eClub is Wholly Bagels electronic communications database which our customers may join by opting-in. During your order via the Wholly Bagel’s internet ordering system, you will be asked if you would like to become an eClub member . To become a member you need to tick the box electing to become an eClub member. (Not yet established)

You may also provide your Information to join as an eClub member at the point-of sale in store, through the front page of our websites, sign up in store or via an eClub kiosk in store or otherwise.

The database is utilised to send emails containing information such as promotions, targeted offers (including third party suppliers/partners), survey information, user feedback, value offers, news and competitions to subscribers (members). eClub members also have the choice to opt-in to receive communication via SMS and, if they opt-in to this service, Wholly Bagel’s may send offers via SMS to these members from time to time. Members are able to opt-out from receiving further email communication or SMS at the bottom of each eClub email and SMS.

Access, accuracy and security

We will take reasonable steps to ensure that your Information that we collect and hold is accurate, complete and up-to-date. However, we rely on you to advise us of any changes to your Information to help us maintain accurate, complete and up-to-date information. Please let us know if you believe that any of your Information requires updating or correction.

You can request access to and correction of your Information that we hold at any time. Any such requests should be made directly by contacting us (see "Contact Us" section below).

We will take reasonable steps to protect your Information from misuse, loss and unauthorised access, modification or disclosure. However, no data protection or security measure is completely secure and we cannot guarantee the security of your Information, particularly in relation to online transmissions. You must take care to ensure you protect your Information (for example, by protecting your usernames and passwords) and you must notify us as soon as possible after you become aware of any security breaches.

Sensitive Information

With the exception of when you apply for a job or franchise with us, we will not collect, use or disclose sensitive information (such as health information or information about racial or ethnic origins or political or religious beliefs).

When you apply for a job with us through www.whollybagels.co.nz, we collect the following details from you: full name, date of birth, whether you are legally allowed to work in New Zealand, whether you are a New Zealand citizen, home address, contract telephone numbers, email address, employment records and your gender. If you are applying as a driver in our stores, we also collect your driver's licence number, the make and model of your motor vehicle and your registration number.

When you apply for a franchise with us, we will collect the following details from you: full name, address, marital status, language skills, health, criminal history, education, work experience, business experience, employment, financial position and credit check information.

Where applicable, you acknowledge consent has been provided for us to collect and use the sensitive information above for the purpose of assessing your suitability as a Wholly Bagel’s employee or franchisee at the time of making your application.

Clickstream data

Each time you visit the our websites our server collects some anonymous information, known as click-stream data, including the type of browser and system you are using; the address of the site you have come from and move to after your visit; the date and time of your visit; and your server's IP address.

Wholly Bagels may collect this information for statistical purposes to find out how the websites are used and navigated, including the number of hits, the frequency and duration of visits, most popular session times. Wholly Bagels may use this information to evaluate and improve the Wholly Bagels websites.

Cookies

A Cookie is a piece of information that our web server may send to your machine when you visit one of our websites. A Cookie helps us to recognise you when you re-visit our sites and to co-ordinate your access to different pages on the sites. We also use Cookies to track online advertising performance and eDM movement.

For example, once you have placed a new pizza order you will be offered the opportunity to personalise your order so that the system remembers it for future use. A Cookie will be set on your machine that enables us to recognise your computer when you return to order your favourite pizza next time.

With most internet browsers, you can erase Cookies from your computer hard drive, block all Cookies, or receive a warning before a Cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more. If you disable all Cookies, you may not be able to take advantage of all the features of our sites.

Links to other sites

Our website may contain links to other websites of third parties. A link to a third party website is not an endorsement of the accuracy or trustworthiness of that website or its content and any information collected by such website will be subject to that website's privacy policy.

How to stop receiving communication from us

• To stop receiving the SMS service reply to any SMS with the word "STOP".
• To stop receiving any email correspondence from us, simply click on the link to unsubscribe.
• To remove your details from any of our marketing and communication databases simply email enquiries@whollybagels.co.nz

Complaints Procedure

If you wish to make a complaint about a breach of this policy or the privacy principles of the Privacy Act 1993 or any other applicable laws, you can lodge a complaint to the Wholly Bagel’s Privacy Policy Co-ordinator using the contact details below. You will need to provide sufficient details regarding your complaint as well as any supporting evidence and/or information.

The Wholly Bagel's Privacy Policy Co-ordinator will investigate your complaint and determine the steps that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the Wholly Bagel’s Privacy Policy Co-ordinator's determination. If you are not satisfied with the determination, you can contact us to discuss your concerns or complain to the Privacy Commissioner: enquiries@whollybagels.co.nz

Contact Us

If you have any queries regarding this policy please email enquiries@whollybagels.co.nz