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privacy policy

Last Revised: 23.12.2023


1. Purpose

1. Sneaky Wholefoods t/as Sneaky Wholefoods, ABN 46 404 683 840 (“we”, “us” or “our”) distributes content through (“Website”) and through the Website, Online Store, Social Media Channels and through third party email marketing platforms such as Acsend by Wix (“Newsletters”)

2. This Privacy Policy has been adopted to ensure that Sneaky Wholefoods have standards in place to protect the Personal Information that we collect about individuals that is necessary and incidental to:

  1. Providing the system and services that Sneaky Wholefoods offers.

  2. The Distribution of content through our Website or Newsletters; and

  3. The normal day-to-day operations of our business.

3. This Privacy Policy follows the standards of the Australian Privacy Principles set by the Australian Government for the handling of Personal Information under the Privacy Act 1988 (Cth) (Privacy Act).


4. The publication of this Privacy Policy is aimed for the purposes of transparency for our Users and Subscribers and the public to understand what Personal Information is collected and stored, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their Personal Information in our possession.

2. Who and What This Privacy Policy Refers To

1. The aforementioned Privacy Policy deals with how we handle “personal information” as it is defined in the Privacy Act (“Personal Information”).

2. We handle Personal Information in our own right and also for and on behalf of our customers and users.


3. The Privacy Policy applies to all forms of information, physical and digital, whether collected or stored electronically or in hardcopy.

4. If, at any time, an individual provides Personal Information or other information about someone other than himself or herself, the individual warrants that they have that person's consent to provide such information for the purpose specified.

5. Our website and services are available to the general public.

6. If a minor is accessing our Website, it is presumed that they have gained a parental or guardian’s consent.


3. Information Collected

1. In the course of everyday business, it is necessary for us to collect Personal Information. 

2. This information allows us to identify who an individual is for the purposes of our business, share Personal Information when asked of us, contact the individual in the ordinary course of business and transact with the individual. Without limitation, the type of information we may collect is:

  1. Personal Information. We collect personal details such as an individual’s name, age, gender, location, postcode, and other information defined as “Personal Information” in the Privacy Act;

  2. Contact Information. We may collect further information such as an individual’s telephone number, email address, and delivery and billing address.

  3. Financial Information. We may collect financial information related to an individual such as credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our services;

  4. Statistical Information. We may collect information about an individual’s online and offline preferences, habits, movements, trends, decisions, purchases and other information for statistical purposes; and

  5. We may collect other Personal Information about an individual, which we will maintain in accordance with this Privacy Policy.

  6. We may also collect non-Personal Information about an individual such as information regarding their computer, network and browser. This may include their IP address. Where non-Personal Information is collected the Australian Privacy Principles do not apply.


4. How Much Information is Collected

1. Information will be collected when:

  1. An individual subscribes to Sneaky Wholefoods via our Newsletter platform;

  2. An individual contacts or engages with Sneaky Wholefoods via email or social media or Sneaky Wholefood’s blog, or through the Website's contact form either for services or enquiries.

  3. An individual liaises with a representative with Sneaky Wholefoods through the phone.

  4. However we may also receive Personal Information from sources such as advertising, public records, and mailing lists.


2. Where we obtain Personal Information without an individual’s knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information, in accordance with the Australian Privacy Principles.


5. When Personal Information is Disclosed

1. We will retain Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

2. It may be necessary for us to disclose an individual’s Personal Information to third parties in a manner compliant with the Australian Privacy Principles in the course of our business.

3. Information is used to enable us to operate our business, especially as it relates to an individual. This may include:

  1. The provision of goods and services between an individual and us;

  2. Verifying an individual’s identity;

  3. Communicating with an individual about:


  1. Their relationship with us;

  2. Our services;

  3. Our own marketing and promotions to customers and prospects; and

  4. Competitions, surveys and questionnaires.


4. Investigating any complaints about or made by an individual, or if we have reason to suspect that an individual is in breach of any of our terms and conditions or that an individual is or has been otherwise engaged in any unlawful activity; and/or

5. As required or permitted by any law (including the Privacy Act); and

6. in tailoring the experience of the Website and Communication to our Users.

4. There are some circumstances in which we must disclose an individual’s information:

1. Where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;

2. As required by any law (including the Privacy Act);

3. For the purposes of collecting statistical information (which may or may not be used by third parties); and/or

4. In order to sell our business (in that we may need to transfer Personal Information to a new owner).

5. We will not disclose an individual’s Personal Information to any entity outside of Australia that is in a jurisdiction that does not have a similar regime to the Australian Privacy Principles or an implemented and enforceable privacy policy similar to this Privacy Policy. We will take reasonable steps to ensure that any disclosure to an entity outside of Australia will not be made until that entity has agreed in writing with us to safeguard Personal Information as we do.

6. The Safety and Security of Personal Information

1. We will take all reasonable precautions to protect an individual’s Personal Information from unauthorised access.

2. The User agrees that the security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet or by post does so at their own risk. The Cheeky Project cannot accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.

3. If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.

4. We are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information.

7. How to Access and/or Update Information

1. Should Users wish to unsubscribe from Sneaky Wholefoods  newsletter, they are able to do so via email.

2. Subject to the Australian Privacy Principles, an individual has the right to request from us the Personal Information that we have about them, and we have an obligation to provide them with such information within 28 days of receiving their written request.

3. If an individual cannot update his or her own information, we will correct any errors in the Personal Information we hold about an individual within 7 days of receiving written notice from them about those errors.

4. It is an individual’s responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.

5. We may charge an individual a reasonable fee for our costs incurred in meeting any of their requests to disclose the Personal Information we hold about them.

8. Complaints and Disputes

1. If an individual has a complaint about our handling of their Personal Information, they should address their complaint in writing to us via email:

2. If Sneaky Wholefoods have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.

3. If Sneaky Wholefoods becomes aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.

9. Contacting Individuals

1. From time to time, Sneaky Wholefoods may send an individual important notices, such as changes to our terms, conditions and policies. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications.

10. Additions to this Policy

1. If we decide to change this Privacy Policy, we will post the changes on our Website. Please refer back to this Privacy Policy to review any amendments.

2. We may do things in addition to what is stated in this Privacy Policy to comply with the Australian Privacy Principles, and nothing in this Privacy Policy shall deem us to have not complied with the Australian Privacy Principles.

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