Privacy Policy

Hospitality Shield Group Pty Ltd, ABN 70 700 608 386, 28/140 St Georges Terrace Perth WA 6000 Australia, Version 1.0

Hospitality Shield is committed to handling personal information responsibly and transparently and securely. This policy explains what information we collect and why we collect it and how we use and disclose it and the choices and rights available to individuals.

1. About this Privacy Policy

This Privacy Policy describes how Hospitality Shield Group Pty Ltd trading as Hospitality Shield (Hospitality Shield, we, us or our) manages personal information in connection with our website, software platform, mobile applications, compliance services, client onboarding, customer support and business operations.

We intend to manage personal information consistently with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) and the Notifiable Data Breaches scheme where applicable and contractual privacy obligations and other applicable Australian laws. Where the Privacy Act does not legally apply to a particular activity we will nevertheless seek to follow the privacy practices described in this policy as a matter of good governance subject to lawful exceptions.

This policy applies to individuals whose information we handle including venue owners and operators, directors, managers, employees, contractors, Hospitality Compliance Support Officers (HCSOs), compliance officers, auditors, inspectors, training participants, website visitors, prospective customers, suppliers, job applicants and authorised platform users.

Important distinction. This policy explains Hospitality Shield’s own handling of personal information. Where a venue or council or regulator or other client uses our platform and determines why personal information is collected that organisation may have its own privacy policy and legal responsibilities. Hospitality Shield may act as a service provider processing information on that client’s instructions.

2. Who we are

• Legal entity: Hospitality Shield Group Pty Ltd
• Trading name: Hospitality Shield
• ABN: 70 700 608 386
• Business address: 28/140 St Georges Terrace Perth WA 6000 Australia
• Website: www.hospitalityshield.com.au
• Privacy contact: Privacy Officer
• Email: info@hospitalityshield.com.au
• Telephone: +61 8 6189 4947

3. What is personal information?

Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable whether the information is true or recorded in a material form. Sensitive information is a more protected category and may include health information, biometric information, racial or ethnic origin, religious beliefs, sexual orientation, political opinions, professional or trade association memberships and criminal records.

Many compliance records concern a venue or business rather than an individual. However a record may still contain personal information where it identifies a staff member or manager or contractor or complainant or visitor or customer or HCSO or inspector or other person.

4. Personal information we may collect

Depending on how you interact with Hospitality Shield we may collect and hold the following categories of information:

• Identity and contact information: name and preferred name and position and employer or venue and business address and postal address and telephone number and email address and username and profile information.
• Account and authentication information: user ID and role and permissions and account status and multi factor authentication details and login timestamps and security events and password reset records. We do not intend to store passwords in readable form.
• Business and venue information: venue name, Australian Business Number, licence or registration details, operating information, locations, authorised contacts, subscription details and contractual records.
• Food safety and compliance records: inspection checklists and temperature logs and allergen records and cleaning records and corrective actions and incident reports and audit findings and uploaded photographs and notes and approvals and sign offs and timestamps.
• Professional and training information: qualifications, Food Safety Supervisor certificates, training completion, competency records, role history and professional credentials.
• Workforce information: staff names and work roles and roster related information and task assignments and compliance acknowledgements and workplace communications entered by authorised users.
• Customer support and communications: emails, telephone records, meeting notes, support requests, complaints, feedback, survey responses and communications through the platform.
• Billing and transaction information: billing contact and invoices and payment status and subscription plan and transaction references. Payment card details may be handled by an external payment provider rather than stored directly by us.
• Technical and usage information: IP address, device and browser information, operating system, approximate location derived from IP, cookies, log data, feature usage, crash reports, audit trails and security telemetry.
• Marketing information: communications preferences and campaign interactions and event registrations and information supplied through enquiries or demonstrations.
• Recruitment and contractor information: resumes, qualifications, references, work eligibility, interview notes, background checks where lawful and bank and tax details where a person is engaged.
• Sensitive information: only where reasonably necessary and lawful and appropriately authorised such as information within an incident report or accessibility requirement or medical emergency record or other compliance record. We seek consent where required unless an exception applies.

5. How we collect personal information

We may collect personal information:

• directly from you when you contact us or create an account or request a demonstration or sign a contract or complete a form or upload records or attend training or communicate with our team;
• from the venue, employer, council, regulator, organisation or account administrator that authorises your use of Hospitality Shield;
• from authorised users who create compliance records or incident reports or audit notes or photographs or corrective actions or training records;
• from service providers such as identity, payment, communications, analytics, hosting, cybersecurity and customer support providers;
• from publicly available sources and professional registers and business directories and government registers where lawful and relevant;
• automatically through cookies, logs, audit trails, security tools and similar technologies when you use our website or platform; and
• from third parties with your consent or where collection is authorised or required by law.

We generally collect personal information directly from the individual where reasonable and practicable. Where information is collected from another person or organisation we may rely on that party to have authority to provide it and to give any necessary privacy notices.

6. Why we collect, hold, use and disclose personal information

We may handle personal information for purposes including:

• providing and operating and maintaining and improving the Hospitality Shield website and platform and mobile applications;
• creating and administering user accounts and roles and permissions and secure access;
• supporting hospitality compliance, food safety supervision, audits, inspections, risk management, incident management, corrective actions, training, communications and records management;
• onboarding venues and clients and councils and regulators and partners and contractors and authorised users;
• producing reports, dashboards, reminders, alerts, certificates, audit trails and compliance evidence;
• providing technical support and customer service and implementation and training and account management;
• processing payments and subscriptions and invoices and business transactions;
• protecting the platform and detecting misuse and investigating security incidents and preventing fraud;
• complying with legal, regulatory, insurance, contractual and record keeping obligations;
• handling complaints and disputes and claims and investigations and enforcement matters;
• conducting analytics, research, quality assurance and product development using de-identified or aggregated information where reasonably practicable;
• communicating about service changes and security notices and renewals and material platform updates;
• sending promotional communications where you have asked for them with each carrying a way to unsubscribe (see section 16);
• recruiting and engaging and managing employees and contractors; and
• other purposes that are notified at collection or authorised by consent or reasonably expected and related to the primary purpose or permitted or required by law.

7. Compliance records and photographs

The platform may allow authorised users to upload photographs, videos, documents and notes as evidence of venue conditions, corrective actions, incidents, food safety practices or audit findings. Users should avoid capturing unnecessary personal information and should not upload images of individuals unless relevant and proportionate and authorised and lawful.

Photographs can carry more than the picture. A photo taken on a phone may contain the location where it was taken and details of the device recorded inside the image file. We remove that data from every photo we store. Where we cannot remove it we do not store the photo: HEIC and AVIF files are the default camera format on many current phones and keep that data in a part of the file we are not able to edit without risking the picture itself so we refuse them and ask you to upload the photo in another format. On an iPhone the setting Settings › Camera › Formats › Most Compatible makes the camera save photos as JPEG. Switching your camera’s location tagging off is worth doing regardless.

Videos are stored as you upload them. We do not currently strip location or device details from a video file the way we do from a photo so a clip filmed on a phone may carry where it was taken. Anyone who can open the training library at that venue can download the file as it was uploaded. If that matters for a particular recording turn your camera’s location tagging off before filming it.

Clients are responsible for configuring access permissions and informing their personnel about workplace record keeping and ensuring that records entered into Hospitality Shield are accurate and relevant and lawfully collected. Hospitality Shield may remove or restrict or quarantine content that appears unlawful or unsafe or malicious or outside the agreed service scope.

8. Artificial intelligence and automated features

Hospitality Shield may use artificial intelligence or machine learning or rules based automation or analytical tools to assist with functions such as document classification, risk identification, anomaly detection, summaries, reminders, recommendations, compliance workflow support and customer service.

Where these features process personal information we seek to apply appropriate access controls and data minimisation and testing and human oversight. Automated outputs may be incomplete or incorrect and should not replace professional judgment or legal obligations or regulatory decisions or a venue’s responsibility for food safety and compliance.

We will not knowingly use customer confidential information to train a publicly available general purpose AI model unless authorised by the customer and permitted by applicable law and contract. Third party AI providers may process information where necessary to provide an authorised feature and subject to appropriate contractual and security controls.

Who receives it and where. When the assistant in the app is switched on for your account the questions you type and the records the assistant reads to answer them are sent to Anthropic PBC in the United States which operates the language model. Those records can include the free text your team has written into incident reports and corrective actions and record notes and the names of the people who wrote them. If a question needs current information from the web the model’s provider may also run a search on our behalf. Nothing is sent to it unless the assistant is switched on for your venue. Other parts of the platform do send some information overseas for their own purposes: our email provider receives the full text of every message we send you and our payment provider receives billing details. Section 10 lists each one and what it receives.

If you would rather your venue’s records were not processed this way tell us and we will turn the assistant off for your account. Do not type information about a named person’s health into the assistant. Describe the situation without identifying them.

Assistant conversations are saved. Both sides of every conversation are kept against the account that had it and Hospitality Shield staff can read them: we use them to see what the assistant was asked and whether it answered correctly and to look into an answer somebody has reported. Treat it as a work tool rather than a private one. Section 13 covers how long they are kept.

Decisions the platform makes automatically. Three things are worked out by the software rather than by a person:

• A venue’s compliance status which is derived from its own records: which daily tasks were completed or missed and temperature readings against each unit’s safe range and overdue corrective actions and inspection results and required documents. This is the status shown in the account and in the pack a council environmental health officer may be shown.
• A venue’s score and percentile and tier which are calculated from those same records and compared with other venues on the platform.
• Locking an account. After a large number of failed sign in attempts an account is locked automatically for a period. While it is locked that user cannot record anything and a day that goes unrecorded cannot be recorded later.

None of the three is a decision about a person’s legal rights and none of them results in a penalty from us. If you think one of them is wrong write to the Privacy Officer or your account administrator and a person will look at it: statuses and scores are recalculated from the underlying records and an administrator can unlock an account immediately.

9. Disclosure of personal information

We may disclose personal information to:

• your employer or venue or client organisation or account administrator or authorised users within the relevant account;
• HCSOs, compliance officers, auditors, inspectors, contractors and professional advisers involved in authorised services;
• local councils or regulators or government agencies or law enforcement bodies or emergency services where authorised or requested or required by law;
• cloud hosting, software, communications, identity, analytics, cybersecurity, payment, customer support and professional service providers;
• our employees and contractors and related entities and approved development or support personnel who need access for their duties;
• actual or proposed investors or financiers or insurers or purchasers or advisers in connection with a genuine corporate transaction subject to confidentiality protections;
• any person you authorise us to disclose information to; and
• other recipients where disclosure is permitted or required by law.

We do not sell personal information as a standalone commercial product. We do not disclose customer records for unrelated advertising without appropriate authority.

10. Overseas disclosure and cloud services

Hospitality Shield may use cloud infrastructure and service providers that store or support or process information outside Australia. Countries may vary depending on the providers selected and their backup arrangements and the location of authorised support personnel. Possible locations may include Australia, the United States, European Union member states, the United Kingdom, Singapore and other jurisdictions disclosed by relevant service providers.

Who they actually are. The providers we use today and what each one receives:

• Amazon Web Services hosts the platform and its backups in Sydney. Your records are stored here in Australia.
• Cloudflare, based in the United States, stores the files uploaded to the platform such as photographs and documents and training videos. It holds them in its Asia Pacific region, which may be outside Australia. A copy of each file is also kept with our backups in Sydney.
• Resend, based in the United States, sends our email. It receives the address we are writing to and the full text of the message which for an invoice or an invitation or an alert names the venue and the person.
• Anthropic PBC, based in the United States, operates the language model behind the assistant in the app. Section 8 sets out what is sent and how to switch it off.
• Stripe, based in the United States with operations in Australia, takes card and bank payments. It receives the billing contact’s email address and the venue or business name and the amount. We do not see or store card numbers.
• Cal.com, based in the United States, runs the demonstration booking calendar embedded on our site. When you open it we pass the name and email address and any note you have typed into the booking form and it receives your IP address as any embedded page would. A booking you confirm is stored with them as well as with us.
• Google, based in the United States, runs Google Tag Manager and Google Analytics on our public website. They receive the pages you visit, your IP address and details of your browser and device, as analytics tools do. They are not loaded inside the platform once you have signed in.
• YouTube, run by Google, serves the training videos embedded in the platform. Playing one tells YouTube your IP address and what you are watching as it would on any website.

If we add or change a provider that receives personal information we will update this list. Before using a material overseas provider we seek to consider the nature of the information and contractual protections and security practices and access controls and applicable legal requirements. Overseas recipients may be subject to laws that differ from Australian privacy law.

Client configuration. Enterprise and government customers may request agreed data location or access or retention or subcontractor arrangements. Any specific commitment must be recorded in the applicable customer agreement or data processing schedule.

11. Data security

We take reasonable steps appropriate to our size and systems and risk profile to protect personal information from misuse and interference and loss and unauthorised access or modification or disclosure. Measures may include:

• access controls and role based permissions;
• multi factor authentication for privileged access where available;
• encryption in transit and where appropriate at rest;
• secure password handling and credential management;
• logging and monitoring and audit trails;
• backup and recovery and business continuity arrangements;
• vendor and third party risk assessment;
• secure software development and vulnerability management and patching;
• staff and contractor confidentiality obligations and privacy training;
• incident response procedures; and
• deletion or de-identification or secure destruction when information is no longer required subject to legal and operational retention requirements.

No internet based service can guarantee absolute security. Users must protect their login credentials and use appropriate access permissions and keep devices secure and promptly report suspected compromise.

12. Data breaches

We maintain processes for identifying and containing and assessing and responding to suspected data breaches. Where the Notifiable Data Breaches scheme applies and an eligible data breach is likely to result in serious harm we will notify affected individuals and the Office of the Australian Information Commissioner as required by law.

Customers and users should immediately report suspected unauthorised access or lost devices or exposed credentials or unintended disclosures or other security incidents to info@hospitalityshield.com.au.

13. Retention and deletion

We retain personal information only for as long as reasonably required for the purposes for which it was collected and our contractual obligations and legal and regulatory requirements and dispute management and security and backup cycles and legitimate business needs.

Retention periods vary according to the record type. Compliance and audit records may need to be retained for periods determined by the customer or applicable food safety laws or council requirements or contractual obligations or limitation periods. Account and billing and corporate records may be retained for taxation and legal record keeping periods.

Some information is destroyed on a schedule. Revoked sessions and spent two factor confirmations and expired trusted devices are removed automatically each night once they can no longer be used. Used or lapsed invitation and password reset and email change links are removed thirty days afterwards which is long enough that a question about how an account was set up can still be answered and no longer.

The text of an email we sent you is removed after ninety days. We keep the record that it was sent and to which address because that is how we can tell whether something we owed you actually reached you.

Food safety records are the exception and deliberately so. Temperature readings and checklists and inspection results and corrective actions and incident reports and training records and the documents and photographs attached to them are the evidence a council environmental health officer may ask a venue to produce so we keep them for as long as the account exists and do not delete them on request. A record that is withdrawn or corrected is marked as such and kept rather than removed and that is what makes the rest of the record trustworthy. If you close your account tell us what you need done with them.

For anything else (account details and billing records and our log of emails sent to you and assistant conversations and the audit trail) we keep it while it is needed for the purposes above and destroy or de-identify it when it is not. If you want to know what is held about you the Data & privacy page in your account will produce a copy and you can ask us to correct or remove anything that is not part of the food safety record. Residual copies may remain in secure backups until they are overwritten through normal backup cycles.

14. Access and correction

You may request access to personal information we hold about you and ask us to correct information that is inaccurate or out of date or incomplete or irrelevant or misleading. To make a request contact the Privacy Officer using the details in section 23.

We may need to verify your identity and authority before responding. Where information is controlled by a venue or employer or council or other client we may refer the request to that organisation or respond in consultation with it. Access may be refused or limited where permitted by law including where disclosure would unreasonably affect another person’s privacy or reveal commercially sensitive information or prejudice an investigation or be unlawful.

We will respond within a reasonable period and aim to do so within 30 days of receiving your request and verifying your identity and will explain any lawful refusal. We generally do not charge for making a request but may charge reasonable costs where permitted and notified in advance.

Asking us to delete something. Our collection notices say you may ask us to delete information so here is what that means in practice. Australian privacy law gives no general right to erasure and food safety records are the part we will not delete: temperature readings and checklists and inspection results and corrective actions and incident reports and training records and their attachments are the evidence a venue may have to produce to a council and section 13 explains why they are kept and marked rather than removed. Anything outside that record (your contact details or an enquiry you sent us or an account we no longer need or assistant conversations) we will delete or de-identify on request unless we are required to keep it. Write to the Privacy Officer and we will tell you which category each item falls into and what we have done.

15. Anonymity and pseudonyms

Where practicable you may interact with us anonymously or using a pseudonym such as when making a general enquiry. Identification will usually be required where necessary to provide an account or verify authority or maintain compliance records or provide contracted services or process payments or address security or meet legal obligations.

16. Direct marketing

We may use contact details to communicate about Hospitality Shield products and services and events and updates where permitted by law. We send promotional email only where you have asked for it: by ticking the newsletter box when you create an account, by entering your email in a newsletter box on our website and then confirming it by the link we email you, or by ticking the optional box on our compliance visibility check and confirming it the same way. We record what you agreed to, when and where. Our newsletter comes about once a month. Every such message carries an unsubscribe link at its foot which opens a page where one press stops them; you can also ask us and we will stop. Messages about an account you hold such as an invitation or a password reset or a sign in confirmation or an invoice or a notice that your price is changing or a reply to something you sent us are service messages rather than marketing and continue for as long as you have the account.

We do not use sensitive information for direct marketing without consent or another lawful basis.

17. Cookies, analytics and online tracking

Our website and platform may use cookies and local storage and pixels and software development kits and analytics tools to:

• keep users signed in and maintain sessions;
• remember preferences;
• measure website and feature usage;
• improve performance and usability;
• detect fraud and security threats;
• support customer service; and
• measure marketing effectiveness where permitted.

You can control some cookies through browser or device settings. Blocking essential cookies may prevent parts of the website or platform from functioning. Where required we will provide additional cookie choices or notices.

18. The Hospitality Shield app

The Hospitality Shield app for Android and iPhone shows the same account and records as our website, and the information in section 4 is collected in the app as it is on the website. The app itself adds the following, and nothing else.

• Staying signed in. When you tick This is a personal device at sign in, the app keeps a key on the phone so it opens straight to your account. We keep a record of that phone against your account (a scrambled form of the key and when it was last used). Signing out, or signing out your other devices in Settings, ends it, and removing the app deletes the key from the phone.
• Notifications. If you turn notifications on, we keep the phone’s notification address against your account. On an iPhone, notifications are sent through Apple’s push notification service, which receives the title and short text of each one. On Android, the app asks our server for new notifications from time to time, and no other service is used. You can turn notifications off, or choose which kinds arrive, in Settings.
• Location. Only where your venue has switched on the location check at clock in, and only with your permission. The location is taken once, when you clock in or out, and is never tracked. Depending on the venue’s setting we keep either the distance from the venue or the location itself with that clock in. Declining does not stop you clocking in.
• Camera, photos, microphone and files. Only when you choose to take or add a photograph, a video or a document for a record. They are handled as section 7 describes. A file you download is saved on your phone.

The app contains no advertising, no advertising identifiers and no analytics or tracking tools, and we do not sell personal information. You can delete your account in the app, under Settings, and on our website. Section 13 explains what is kept afterwards and for how long.

19. Children and young people

Hospitality Shield is designed primarily for businesses and authorised workplace users and professionals. It is not directed to children. We do not knowingly create platform accounts for children without appropriate authority. If information about a child is entered into an incident or compliance record the client and authorised user must ensure the collection is necessary and proportionate and lawful. Contact us if you believe a child’s information has been provided improperly.

20. Third party websites and integrations

The platform may contain links to third party websites or integrate with external services. Those services operate under their own privacy policies and security practices. Hospitality Shield is not responsible for a third party’s independent handling of personal information except to the extent required by law or contract.

21. Complaints

You may make a privacy complaint by contacting our Privacy Officer. Please provide enough detail for us to understand the issue including relevant dates and account or venue details and the outcome you seek.

We will acknowledge the complaint within a reasonable period and investigate it fairly and aim to provide a response within 30 days. Complex matters may require more time in which case we will provide an update where practicable.

If you are not satisfied and the Privacy Act applies you may be able to complain to the Office of the Australian Information Commissioner. Information about privacy complaints is available through the OAIC website.

22. Changes to this policy

We may update this Privacy Policy to reflect changes to law or technology or our products or service providers or business practices. The current version will be published on our website with the effective date. Where a change materially affects how existing customer information is handled we may provide additional notice through the platform or email or contractual channels.

23. Contact us

Privacy Officer at Hospitality Shield
Hospitality Shield Group Pty Ltd
28/140 St Georges Terrace Perth WA 6000 Australia

Email: info@hospitalityshield.com.au
Telephone: +61 8 6189 4947
Website: www.hospitalityshield.com.au

24. Client responsibilities when using Hospitality Shield

A client organisation using Hospitality Shield should:

• provide appropriate privacy notices to its staff and contractors and customers and other individuals;
• ensure it has lawful authority to collect and upload personal information;
• collect only information reasonably necessary for legitimate compliance and business purposes;
• configure user roles and permissions appropriately;
• keep user accounts current and promptly remove access for departing personnel;
• avoid uploading unnecessary sensitive information;
• tell us the retention periods its own legal and operational obligations require so we can apply them because the platform deliberately does not let a client delete or expire records itself as a record that can be removed from the inside is not evidence (see section 13);
• respond to access and correction and complaint requests for records it controls;
• notify Hospitality Shield promptly of suspected security incidents; and
• comply with applicable workplace surveillance, employment, health, records, food safety and privacy laws.

25. Legal framework and policy interpretation

This policy is intended to be read consistently with applicable law and the relevant customer agreement. It does not create rights or obligations beyond those imposed by law or expressly accepted in contract. If a customer agreement contains stronger privacy or data protection commitments those commitments apply to that customer to the extent of any inconsistency.

The Privacy Act generally covers organisations with annual turnover above the statutory threshold and certain other organisations and activities. Hospitality Shield’s legal coverage may evolve as the business grows or enters contracts or undertakes regulated activities. This policy reflects our intended privacy standard and should be reviewed when the platform or business model or providers or applicable laws materially change.

26. Reference sources

This policy was prepared with reference to the following official Australian privacy materials current as at the effective date:

• Office of the Australian Information Commissioner: Australian Privacy Principles and APP Guidelines, updated 13 May 2026.
• Office of the Australian Information Commissioner: Guide to developing an APP privacy policy.
• Office of the Australian Information Commissioner: Small business privacy guidance and startup guidance.
• Office of the Australian Information Commissioner: Notifiable Data Breaches scheme and data breach response guidance.
• Privacy Act 1988 (Cth) including the Australian Privacy Principles and Part IIIC.

Document control: Hospitality Shield Privacy Policy, Version 1.0, Effective 6 Aug 2026, Owner: Privacy Officer, Approved by: Founder & Director