Privacy Policy

1. Introduction

Panoma Supply (ABN: 11650623259) ("we", "us", "our") is committed to protecting your privacy and handling your personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) contained in Schedule 1 of that Act.

This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when you interact with us through our website (panoma.com.au), sample request forms, direct communications, or as part of an existing or prospective supply relationship.

By submitting your information to us, you consent to the practices described in this Privacy Policy.

2. Who we are

Panoma Supply is a Melbourne-based business supplying premium nut spreads and pastes to professional kitchens, gelaterias, patisseries, and specialty bakeries across Victoria, Australia.

Our primary contact for privacy matters is:

Privacy Officer

Panoma Supply | Melbourne, Victoria, Australia | Email: info@panoma.com.au

3. What personal information we collect

We collect personal information that is reasonably necessary for our business functions. The types of personal information we may collect include:

3.1 Identity and contact information

• First name and last name

• Business name and business type

• Email address

• Phone number

• Suburb, delivery address, or postcode

3.2 Business and commercial information

• Products of interest or products ordered

• Order history and transaction records

• Feedback and correspondence relating to our products or services

3.3 Marketing preferences

• Your opt-in or opt-out status for marketing communications

• Source of referral (how you heard about us)

3.4 Technical information (website)

• IP address and browser type (collected via standard web analytics)

• Pages visited and time spent on our website

• Device type and operating system

We do not collect sensitive information (as defined under the Privacy Act 1988) such as health, racial, political, or financial information, unless you voluntarily provide it and we have a lawful reason to collect it.

4. How we collect personal information

We collect personal information in the following ways:

• Directly from you when you complete a sample request form on our website

• Through email, phone, or in-person communications

• Through your ongoing supply relationship with us (orders, feedback, correspondence)

• From referrals made by existing customers, where you have been referred to us

• Through our website analytics tools (passive collection, see Section 8)

We will only collect personal information by lawful and fair means, and not in an unreasonably intrusive way, in accordance with APP 3.

5. Why we collect and use your personal information

We collect and use your personal information for the following primary purposes:

• To process and respond to your sample request or product enquiry

• To manage and fulfil orders and delivery logistics

• To communicate with you about your account, orders, or supply relationship

• To provide technical support and usage guidance for our products

• To send you marketing communications, product updates, or industry news, where you have given us your explicit consent (opt-in)

• To improve our products and services based on feedback

• To comply with our legal obligations under Australian law

• To maintain business records in accordance with applicable retention requirements

We will not use your personal information for any purpose that is unrelated to the above without your consent, except where permitted or required by law.

6. Marketing communications

We will only send you marketing communications (including product updates, recipe suggestions, or promotional offers) if you have opted in to receive them by ticking the relevant checkbox on our sample request form or otherwise providing explicit consent.

You may withdraw your consent and unsubscribe from marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email we send

• Contacting us directly at info@panoma.com.au

We comply with the requirements of the Spam Act 2003 (Cth). We will not send commercial electronic messages without your consent, and we will honour all unsubscribe requests promptly (within five business days).

Please note that even if you opt out of marketing communications, we may still send you transactional or service-related communications necessary to fulfil your orders or manage your account.

7. Disclosure of personal information

We do not sell, rent, or trade your personal information to third parties for their own marketing purposes.

We may disclose your personal information to the following categories of recipients, only to the extent necessary for the purposes described in this Privacy Policy:

7.1 Service providers and technology platforms

• HubSpot, Inc. — our customer relationship management (CRM) platform, used to store and manage contact records, sample requests, and marketing preferences. HubSpot stores data on servers that may be located outside Australia, including in the United States. HubSpot participates in applicable data transfer mechanisms. For more information, see HubSpot’s Privacy Policy at hubspot.com/legal/privacy-policy.

• Website hosting and analytics providers — for the operation and performance monitoring of our website.

7.2 Legal and regulatory disclosure

• We may disclose personal information to law enforcement, regulators, or courts where required or authorised by Australian law.

We take reasonable steps to ensure that any third-party service providers we engage are bound by privacy obligations consistent with Australian law, including through contractual arrangements where applicable, in accordance with APP 11.

8. Overseas disclosure

Some of our service providers, including HubSpot, may store or process personal information outside of Australia. Where this occurs, we take reasonable steps to ensure that the overseas recipient handles your personal information in a way that is consistent with the Australian Privacy Principles, in accordance with APP 8.

By submitting your personal information to us, you acknowledge that your information may be transferred to, stored, and processed in countries outside Australia, including the United States.

9. Storage and security of personal information

We take reasonable steps to protect the personal information we hold from misuse, interference, loss, unauthorised access, modification, and disclosure, in accordance with APP 11.

Our security measures include:

• Storage of contact and customer data within HubSpot CRM, which employs industry-standard security controls including encryption at rest and in transit

• Access to personal information limited to authorised personnel only

• Regular review of our data handling practices

While we take reasonable precautions, no data transmission over the internet or electronic storage system is completely secure. We cannot guarantee absolute security of your personal information.

In the event of a data breach that is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches (NDB) scheme under Part IIIC of the Privacy Act 1988.

10. Data retention

We retain personal information only for as long as is reasonably necessary for the purposes for which it was collected, or as required by law.

• Sample request and enquiry records: retained for up to 2 years from the date of last contact, or for the duration of the supply relationship

• Customer order and transaction records: retained for 7 years in accordance with Australian taxation and business record-keeping obligations

• Marketing preference records: retained until you withdraw consent or request deletion

When personal information is no longer required, we will take reasonable steps to destroy or de-identify it securely.

11. Your rights: access and correction

Under the Privacy Act 1988, you have the right to:

• Request access to the personal information we hold about you (APP 12)

• Request correction of personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading (APP 13)

To make an access or correction request, please contact us at info@panoma.com.au. We will respond to your request within a reasonable time (ordinarily within 30 days).

We will not charge a fee for making an access or correction request, however we may charge a reasonable fee to cover the cost of providing access where this involves significant time or resources.

We may decline an access or correction request in limited circumstances permitted by the Privacy Act 1988, such as where providing access would unreasonably impact the privacy of another individual, or where we are legally required to retain the information. If we decline your request, we will provide written reasons.

12. Complaints

If you believe we have breached the Australian Privacy Principles or otherwise mishandled your personal information, you may lodge a complaint with us in the first instance.

To lodge a complaint:

• Contact us at info@panoma.com.au with details of your concern

• We will acknowledge your complaint within 5 business days and respond substantively within 30 days

If you are not satisfied with our response, or if you would prefer to escalate your complaint directly, you may contact the Office of the Australian Information Commissioner (OAIC):

Office of the Australian Information Commissioner

Website: www.oaic.gov.au

Phone: 1300 363 992

Post: GPO Box 5218, Sydney NSW 2001

13. Cookies and website analytics

Our website (panoma.com.au) may use cookies and similar tracking technologies to improve your browsing experience and understand how visitors use our site. Cookies are small text files stored on your device.

We may use:

• Essential cookies — required for the website to function (e.g. form submissions)

• Analytics cookies — to understand site traffic and usage patterns (e.g. Google Analytics or equivalent). These may collect anonymised or pseudonymised data about your visit.

You can disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our website.

We do not use cookies to serve third-party advertising.

14. Links to third-party websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites. We encourage you to read the privacy policies of any external sites you visit.

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or business operations. When we make material changes, we will update the effective date at the top of this policy.

We encourage you to review this policy periodically. Continued use of our website or services after any changes constitutes your acceptance of the updated policy.

16. Contact us

For any questions, requests, or concerns relating to this Privacy Policy or our handling of your personal information, please contact us at:

Panoma Supply | Melbourne, Victoria, Australia | Email: info@panoma.com.au

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