1.Solotel and privacy
Solotel is one of Australia’s leading hospitality groups. In operating our restaurants, bars, events and related hospitality businesses, Solotel collects and handles personal information.
Solotel understands the importance of protecting the privacy of an individual’s personal information and being open and transparent in how we handle and deal with personal information.
(a) Privacy Act means the Privacy Act 1988 (Cth);
(b) Solotel means
(i) Solotel Management;
(ii) Together with Solotel; and
(c) Solotel Events means any public, corporate, private or other events conducted or organised by Solotel or any events sponsored by Solotel;
(d) Solotel Management means Solotel Management Pty Limited ACN 613 396 179;
(e) Solotel Venue means the restaurants, bars and other venues operated by Solotel;
(f) Together with Solotel means the Trustee for Events Sol Trust & The Trustee for the Mash Meadow Trust ABN 36 932 517 098, trading as ‘Together with Solotel’; and
(g) We, us, our means Solotel;
3. Compliance with Privacy Act
In collecting, holding, using, disclosing and otherwise managing personal information, Solotel will comply with the Privacy Act and the Australian Privacy Principles in the Privacy Act.
4. Collection of personal information
Under the Privacy Act, personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of our hospitality and related services or as a result of our other interactions or dealings with you, Solotel may collect your personal information.
Solotel provides a diverse range of hospitality services and experiences. As a result, the kinds of personal information that Solotel collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information Solotel collects may include:
(a) contact and identification information such as your name, address, telephone number and email address (for example where you make a reservation at a Solotel Venue or join one of our mailing lists);
(b) information regarding your ordering history, food or beverage or other dining preferences, to assist us to provide a more customised dining experience;
(c) payment information, such as credit card or other payment details;
(d) where you organise or conduct an event using Together with Solotel, information regarding the event, your guests and any relevant requirements;
(e) information regarding your experience at a Solotel Venue (for example as part of our guest feedback activities or where you contact us with feedback); and
(f) where you apply for employment with Solotel (in addition to contact and identification information detailed above) information relevant to us considering your application for employment including information in relation to your CV, employment history, qualifications and references.
Depending on the Solotel Venue you attend, we may also collect identification information, such as drivers licence or passport information and biometric information (for example face scanning). We generally collect this information because we are required to do so by law and/or for venue, patron and employee security purposes. Specific information regarding the collection and handling of this type of personal information will be available at the relevant venue.
Solotel also collects CCTV footage at many of Solotel Venues, including for venue, patron and employee safety purposes. Details of suspected or actual illegal or improper conduct (including CCTV footage relating to that conduct) may be shared with relevant law enforcement or regulatory bodies.
At some Solotel Venues or Solotel Events, we may also take photographs or other images or content (such a video or audio recordings). Where we do so, we will provide as much detail as possible regarding why the photographs, images or other content are being taken and the purposes for which they are being used. By attending such a Solotel Venue or Solotel Event, you consent to us taking such photographs, images or other content and using those photographs, images or other content, including at the venue and on Solotel websites and social media sites.
Solotel may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.
Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. There may be circumstances where Solotel does collect sensitive information, for example where we need to collect health information regarding your allergies or in a medical emergency. If we do collect sensitive information about you, we will only do so with your consent or where we are required or authorised to do so by law.
5. Collection of personal information by Solotel
Generally, Solotel collects your personal informati
on directly from you. For example, Solotel may collect your personal information where:
- you make a reservation for a Solotel Venue or a Solotel Event;
- you join one of our mailing lists, fill out a survey, enter a promotion, request services or otherwise provide us with your details;
- you dine at or attend a Solotel Venue;
- you stay at any Solotel Venue that provides accommodation services;
- you organise an event using Together with Solotel or participate in or attend an event organised by Together with Solotel;
- you sign up to or participate in any Solotel loyalty program;
- you provide feedback to us regarding your experience at a Solotel Venue or your other interaction with Solotel;
- you post information to any of our social media sites;
- you attend a Solotel Event; or
- you apply for or express an interest in employment with us.
We generally collect personal information directly from you. However there may be occasions when Solotel collects your personal information from someone other than you, for example from:
- other entities within Solotel;
- our service providers or contractors (for example where we appoint a service provider/contractor to assist with conducting an event);
- an information services provider;
- a publicly maintained record or other publicly available sources of information including social media and similar websites; or
- a referee or previous employer where you apply for employment with Solotel.
6 Purposes for which personal information is used
Generally speaking, Solotel collects and uses personal information so that we can provide our hospitality services, interact with you in relation to our services and venues and administer and manage our business and our venues.
Some examples of the purposes for which Solotel collects, holds, uses and discloses your personal information include to:
- take bookings for Solotel Venues or Solotel Events;
- provide dining and other hospitality experiences at Solotel Venues;
- provide our event services to you;
- manage and administer the provision of our services and our relationship with you;
- verify your identity;
- maintain venue, patron and employee safety;
- enable us to supply you with information you request from us;
- conduct promotions, competitions, giveaways and events;
- contact you to obtain your feedback regarding our products or services or to conduct other market research;
- provide you with marketing information regarding Solotel and our venues (as further detailed in paragraph 7 below);
- analyse information we collect so that we can administer, support and improve and develop our business and the products and services we offer, including by undertaking data analytics and related activities using your personal information;
- comply with the obligations of Solotel under any applicable laws; and
- consider any application you make for employment with us.
In addition to the purposes listed above, Solotel may use your personal information for other purposes which we notify you of when we collect the information and for other purposes permitted or required by law. Where personal information is used or disclosed, Solotel takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed.
You are under no obligation to provide your personal information to Solotel. However, without certain information from you, Solotel may not be able to provide services or information to you or may be limited in how we can interact with you.
7. Direct marketing
In addition to the purposes outlined in paragraph 6 above, Solotel may use and disclose your personal information in order to inform you of promotions, competitions, giveaways, events, products or services that may be of interest to you. Where you make a booking at a particular Solotel Venue or sign up for the mailing list of a particular Solotel Venue, this may include sending you information about that Solotel Venue or other Solotel Venues, Solotel Events or services that may be of interest to you.
In doing so, Solotel may disclose your personal information to the companies within Solotel or other entities with which Solotel has a commercial relationship or arrangement for the purpose of the other entity contacting you for such direct marketing purposes.
These communications may be sent using email, telephone, SMS, social media or other similar forms of communication.
8. Disclosure of personal information
- the companies or other entities within Solotel;
- our service providers and contractors and other third parties that provide products or services to us (including our technology service providers, data analytics service providers, bookings or reservation systems providers, event service providers or other business or administration service providers);
- Solotel’s auditors, tax, insurance, legal or other professional advisors;
- persons or entities considering acquiring an interest in Solotel’s business or assets; or
- Solotel’s insurance providers.
Solotel may also disclose your personal information for other purposes where we notify you of the disclosure at or about the time of collecting the information, with your consent or if the disclosure is required or authorised by law. Examples of disclosure that may be required or authorised by law include disclosure to law enforcement bodies, liquor and gaming regulators or under Anti-Money Laundering and Counter-Terrorism Financing laws.
If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.
9. Overseas disclosures
Some of the parties that Solotel discloses your personal information to may be located outside Australia, including technology service providers located in Canada, the United States and the United Kingdom. . We take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act.
10. Links to other websites
11. Cookies and website statistical information
Solotel may collect statistical information when you access and use our websites and any online platforms available via our websites, by utilising features and technologies of your internet browser, including cookies and pixel tags. We use this information to analyse how our websites and other online services are being used and seek to improve our websites and other online services and provide more user friendly and customised websites and online services. These features and technologies do not specifically identify you unless you expressly provide to us personally identifiable information. You may also elect to turn off the internet browser features which allow us to collect statistical information by selecting certain options on your browser. However, this may slow down or cause certain web pages to be inaccessible to you.
12. Security of personal information
Solotel takes the security and protection of the personal information we hold seriously.
We take steps reasonable in the circumstances to ensure that the personal information we hold is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
Your personal information will be kept on databases held on servers kept in a physically and technologically secured environment, accessed only by authorised personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access.
Solotel will destroy or de-identify personal information in circumstances where it is no longer required, unless Solotel is otherwise required or authorised by law to retain the information.
13. Access and correction
Solotel takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading.
In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Solotel. If at any time you would like to access or correct the personal information that Solotel holds about you, or you would like more information on Solotel’s approach to privacy, please contact Solotel Privacy Compliance Officer using the details set out in paragraph 14 below. Solotel will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
- you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
- Solotel requests that you be reasonably specific about the information you require; and
- Solotel may charge you a reasonable administration fee, which reflects and will not exceed the cost to Solotel for providing access in accordance with your request.
Solotel will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If Solotel refuses your request to access or correct your personal information, Solotel will provide you with written reasons for the refusal and details of complaint mechanisms.
If you are dissatisfied with Solotel’s refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.
14. Contacting Solotel
For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact Solotel’s Privacy Compliance Officer using any of the following contact details:
Privacy Compliance Officer
Phone: 02 9327 6344
Post: Level 2, Golden Sheaf Hotel, 429 New South Head Rd, Double Bay, NSW 2028
15. Privacy complaints
Please direct all privacy complaints to Solotel’s Privacy Compliance Officer. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect your existing obligations or affect the commercial arrangements between you and Solotel.
Solotel will acknowledge your complaint within 7 days of receipt and endeavour to resolve it within 30 days, unless Solotel informs you otherwise and seeks your agreement in writing.
Solotel will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which Solotel will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.
Annexure A: Solotel entities
- Mash Parramatta Pty Limited ACN 626 651 438 as trustee for the Mash Parramatta Trust;
- Liner House Sol Pty Limited ACN 614 834 409 as trustee for the Liner House Sol Trust;
- Bridgeview Operations Pty Limited ACN 158 648 456 as trustee for the Bridgeview Operations Trust.
- Bridgeview Nominees Pty Limited ACN 139 442 345 as trustee for the Bridgeview Unit Trust.
- Quadrabridge Pty Limited ACN 079 475 399 as trustee for The Chatswood Trust.
- Edinburgh Hotel Pty Limited ACN 110 649 593 as trustee for the Edinburgh Trust.
- Ersko Pty Limited ACN 152 205 251 as trustee for the Ersko Trust.
- Sherilyn Pty Limited ACN 075 074 930 as trustee for the Solotrust Unit Trust.
- Mary Street Pty Limited ACN 600 157 515 as trustee for the Mary Street Trust.
- Greensol Nominees Pty Limited ACN 161 503 895.
- Barbru Pty Limited ACN 003 210 884.
- KX Operations Pty Limited ACN 149 334 538 as trustee for the KX Operations Trust.
- Top Ryde Nominees Pty Limited ACN 139 444 778 as trustee for the KX Unit Trust.
- Newington Nominees Pty Limited ACN 602 630 302 as trustee for the Newington Trust.
- Circular Quay Bar Pty Limited ACN 120 723 462 as trustee for the Circular Quay Bar Trust.
- R S Freehold Pty Limited ACN 616 985 909 as trustee for the R S Freehold Trust.
- R S Hotel Pty Limited ACN 614 149 110 as trustee for the Royal Sovereign Hotel Trust.
- Sol Paddo Pty Ltd ACN 624 031 205.
- Tacutu Holdings Pty Limited ACN 003 193 459 as trustee for the Tacutu Unit Trust.
- Ukena Pty Limited ACN 003 002 873 as trustee for The Ukena Unit Trust.
- Albion Hotel UT Pty Ltd ACN 621 385 484.
- Austlen Pty Limited ACN 120 109 962 as trustee for The Courthouse Trust & The Milton Trust Partnership.
- Flotto Holdings Pty Limited ACN 003 868 335 as trustee for The Courthouse Trust & The Milton Trust Partnership.
- Solotel Management Pty Ltd ACN 613 396 179 as trustee for the Solotel Management Unit Trust.
- Events Sol Pty Ltd ACN 618 595 163 as trustee for the Solotel Events Partnership.
- Mash Meadow Pty Ltd ACN 618 639 633.
- MorSol Pty Limited ACN 608 747 977 as trustee for the MorSol Unit Trust.
- Mappi Pty Limited ACN 087 202 962.
- Mash Art Pty Limited ACN 169 668 866.
- Marcas Holdings Pty Limited ACN 152 688 241.
- Mash Group Holdings Pty Limited ACN 165 894 708.
- AQ Nominees Pty Limited ACN 133 624 101.
- Mash Art Pty Limited ACN 169 668 866.
- Sea Headland Pty Limited ACN 098 155 296.
- Mappi Pty Limited ACN 087 202 962.
- Mash Art Pty Limited ACN 169 668 866.
- Barangaroo Pty Limited ACN 604 221 801.
- Mash Barangaroo Pty Limited ACN 606 824 300.
- Chiswick Gardens Pty Limited ACN 147 309 439.
- Moran Corporate Pty Limited ACN 150 848 623.
- Art Exhibition Nominees Pty Ltd ACN 169 622 824.
- Mash Art Pty Limited ACN 169 668 866.
- KX Services Pty Limited ACN 149 459 076.
- Albion Parramatta Pty Limited ACN 131 542 704.
- Bennelong Enterprises Pty Limited ACN 090 886 301.
- Story Services Pty Limited ACN 133 636 174.
- Chiswick Services Pty Limited ACN 155 488 690.
- MorSol Wines Pty Limited ACN 609 269 267.
- Riverbar Services Pty Limited ACN 160 037 114.
- Opera Services Pty Limited ACN 098 933 950.