This Privacy Policy explains how Togga Social collects, uses, stores, discloses and protects personal information.
Togga Social is a curated business-to-business hospitality platform designed to help hospitality operators and suppliers discover, understand and connect with one another through supplier profiles, supplier readiness indicators, waitlists, onboarding forms, content, samples, activations, rewards, events and community-led opportunities.
This Privacy Policy applies to information collected through:
- our website at www.toggasocial.com;
- our forms, waitlists and onboarding flows;
- supplier and operator profiles;
- samples, activations, rewards, events and community features;
- email, direct communications and enquiries;
- our internal administration, review, scoring, matching and platform-development pinfo@rocesses.
Although Togga Social operates primarily in a business-to-business context, some information we collect may identify individuals, including founders, supplier representatives, account managers, chefs, procurement professionals, venue managers, operators, event participants and other hospitality professionals.
Togga Social is committed to handling personal information responsibly and in a way that is aligned with the Australian Privacy Principles under the Privacy Act 1988 (Cth), where applicable.
## 1. Who we are
In this Privacy Policy, “Togga Social,” “Togga,” “we,” “us,” or “our” means SIU, SAU WAI trading as Togga Social, ABN 14 656 047 616.
Contact details
SIU, SAU WAI trading as Togga Social
ABN: 14 656 047 616
Email: info@toggasocial.com
Website: www.toggasocial.com
## 2. Information we collect
We collect information that is reasonably necessary for our platform, community, supplier discovery, operator matching, onboarding, communication, safety, administration and business-development activities.
The kinds of information we may collect include the following.
### 2.1 Account, identity and contact information
This may include:
- first name and surname;
- business name, trading name, venue name or legal entity name;
- job title, role group or authority to represent a business;
- business email address;
- phone number;
- preferred contact method;
- backup or alternate business contact details;
- business address, general location or service region;
- account login information managed through our website or service providers;
- confirmation that you are at least 18 years old.
Togga does not access plain-text passwords where authentication is managed by a third-party platform.
### 2.2 Business, venue and operator information
For operators, venues and hospitality businesses, we may collect information about:
- operator or venue type;
- industry group, sub-category, service style or venue format;
- customer, guest or stakeholder segments;
- number of sites, venues or service locations;
- role, buying influence and approval stakeholders;
- supplier categories of interest;
- procurement process, buying needs, supplier pain points and priority areas;
- ordering methods, delivery expectations, compliance requirements and operational constraints;
- sample, trial, demo, training, activation and event preferences;
- reward, challenge, leaderboard, referral, content or community participation preferences.
### 2.3 Supplier profile and readiness information
For suppliers, we may collect information about:
- business identity, registration, ownership, service regions and company background;
- product, service, category and brand information;
- catalogues, product lists, product images, brand assets or service materials;
- operator fit, venue fit, customer segments and service coverage;
- ordering, delivery, logistics, lead times, stock availability and issue-resolution processes;
- commercial information such as pricing model, payment terms, sample costs, discounts, rebates, market support or commercial conditions;
- compliance, quality, insurance, certifications, food safety, product assurance, WHS, data, cyber, privacy, recall or risk-related information;
- ESG, responsible sourcing, packaging, carbon, community or social impact information;
- training, account management, equipment, maintenance, support and onboarding capability;
- marketing, activation, content, events, sampling and promotional support;
- references, case studies, performance indicators, awards, accreditations or self-assessment information;
- permissions, disclosure choices, confidentiality flags, document uploads and accuracy declarations.
Unless expressly stated otherwise, supplier profile and readiness information is based on supplier-submitted information and information provided by users or third parties.
A Togga readiness score, profile indicator, profile summary, completeness indicator, matching signal or discovery output is not a certification, endorsement, procurement recommendation, guarantee of performance, guarantee of compliance, guarantee of pricing, or substitute for an operator’s own due diligence.
### 2.4 Rewards, samples, activations, events and community information
If you participate in Togga rewards, challenges, samples, events, activations or community features, we may collect:
- participation records;
- points, badges, leaderboard display names or challenge activity;
- reward eligibility and redemption information;
- sample, tasting, demo or trial requests;
- event registrations and attendance records;
- dietary, accessibility or logistical preferences where relevant;
- feedback, survey responses or experience comments;
- records needed to manage capacity, fairness, eligibility, fraud prevention, misuse prevention or platform integrity.
### 2.5 Content, feedback and media information
We may collect information you provide through:
- feedback forms;
- surveys;
- reviews, ratings or comments;
- testimonials, case studies or story features;
- interviews, quotes, written content, images, audio or video;
- social media interactions;
- reports, complaints or platform support requests.
Separate consent or approval may be requested where Togga captures, edits, publishes or reuses identifiable photos, video, audio, quotes or business stories.
### 2.6 Technical, analytics and usage information
When you visit or use our website, forms, emails or platform features, we and our service providers may collect technical and usage information, such as:
- IP address;
- browser type;
- device type;
- operating system;
- pages visited;
- referral source;
- session information;
- interaction data;
- approximate location derived from technical data;
- cookies or similar technologies;
- error logs;
- security and fraud-prevention signals.
### 2.7 Payment and billing information
If Togga offers paid subscriptions, paid supplier services, sponsorships, event tickets, activations, promotions or other paid products, we may collect billing and transaction information through payment processors or platform payment tools.
We do not intend to store full credit-card details directly.
## 3. How we collect information
We may collect information:
- directly from you when you complete a form, join a waitlist, register interest, create a profile, request a sample, register for an event, contact us, subscribe to updates or communicate with us;
- through our website, forms, account features, member features, cookies, analytics or embedded tools;
- through technology providers that support forms, databases, automation, communication, analytics, AI, scoring, matching, hosting, payment, security or platform administration;
- from your business, employer, colleague or authorised representative;
- from suppliers, operators, event partners or community participants;
- from public business sources such as company websites, public social media profiles, business directories, ABN records or professional profiles;
- through social media, events, activations, interviews, community activities or business-development conversations.
We aim to collect personal information by lawful and fair means.
Where we collect personal information from someone other than you, we will take reasonable steps to notify you where required and practicable.
## 4. Why we collect, use and disclose information
We may collect, hold, use and disclose information to:
- operate, maintain, secure and improve Togga Social;
- manage waitlists, onboarding, profiles, accounts and expressions of interest;
- support supplier discovery, operator matching and business introductions;
- create, structure, summarise, categorise, score or display supplier and operator information;
- generate profile-completeness indicators, readiness indicators, matching signals, discovery outputs or visibility signals;
- administer samples, rewards, activations, events, challenges and community participation;
- manage user permissions, disclosure choices, consent preferences and communication preferences;
- communicate with you about your account, profile, submission, enquiry, event, reward, sample request, activation or platform activity;
- send service-related communications;
- send marketing communications where permitted by law;
- moderate content, investigate reports and protect platform integrity;
- prevent fake accounts, impersonation, reward-gaming, scraping, spam, fraud, misuse or unauthorised access;
- produce aggregated or de-identified insights;
- conduct internal reporting, testing, analytics, product development and business planning;
- comply with legal obligations;
- enforce our Terms of Service, resolve disputes and protect legal rights.
## 5. Profile visibility and sharing
Some information you provide to Togga may be visible to other users, businesses, suppliers, operators, event partners or service providers, depending on the feature used, the nature of the information, your settings or choices, and the purpose for which the information was provided.
For example, business profile information, product or service categories, general service areas, capability information, profile summaries, participation indicators, content, feedback or public-facing materials may be displayed or shared through Togga where relevant to supplier discovery, operator matching, activations, samples, events, rewards, community features or platform operations.
Personal contact details, private commercial information, documents, internal notes, complaint records, verification materials and other restricted information are not intended to be publicly displayed unless you have chosen to provide them for that purpose, consented to disclosure, or disclosure is otherwise permitted by this Privacy Policy, our Terms of Service or applicable law.
Users should not submit confidential, commercially sensitive or personal information unless they are authorised to do so and comfortable with the way that information may be used for the relevant platform feature.
## 6. Automated tools and AI-assisted processing
Togga may use automated tools, AI-assisted systems, scoring logic, matching logic, workflow automation and third-party technology providers to help operate, improve, personalise, moderate and develop the platform.
These tools may assist with tasks such as:
- profile summaries;
- supplier categorisation;
- operator categorisation;
- readiness indicators;
- profile-completeness indicators;
- matching suggestions;
- ranking or visibility signals;
- reward eligibility;
- fraud-prevention or misuse-prevention checks;
- moderation support;
- content support;
- internal administration;
- platform analytics.
The kinds of personal information that may be used in automated or AI-assisted processing include account, identity and contact information; business, venue and operator information; supplier profile and readiness information; preferences, permissions and disclosure choices; participation records; feedback; content; technical and usage information; and other information submitted to or generated through Togga.
The kinds of decisions, outputs or actions that may be made, supported or influenced by automated or AI-assisted tools include profile creation, profile summaries, profile-completeness indicators, supplier readiness indicators, matching suggestions, ranking or visibility signals, eligibility indicators, reward or challenge participation indicators, moderation signals, fraud-prevention signals and platform-administration actions.
Automated or AI-assisted outputs may be incomplete, inaccurate, outdated, biased, unsuitable, or based on information provided by users or third parties. Unless Togga expressly states otherwise in writing, automated or AI-assisted outputs should be treated as decision-support information only and not as verified facts, professional advice, certification, endorsement, or a guarantee of supplier or operator performance.
Togga may review, edit, remove, restrict, correct, or rely on automated or AI-assisted outputs, but is not obliged to manually review every output, profile, score, recommendation, ranking, match, summary or piece of content before it is used or displayed.
Users remain responsible for checking information before relying on it, including before entering into commercial arrangements, purchasing products or services, attending events, accepting samples, participating in activations or making business decisions.
## 7. Sharing and disclosure of information
We may disclose information to:
- suppliers, operators, event partners, activation partners or community participants where relevant to a feature, request, match, event, sample, activation, reward or business opportunity;
- technology, hosting, database, form, automation, analytics, email, AI, payment, security, support and administration providers;
- professional advisers such as lawyers, accountants, insurers and consultants;
- regulators, courts, law enforcement bodies, government authorities or other parties where required or permitted by law;
- a buyer, investor, successor or relevant party in connection with a merger, sale, restructure, financing, acquisition, insolvency or business transfer.
We do not sell personal contact lists.
Where we share information, we aim to share only what is reasonably relevant for the purpose.
## 8. Overseas storage and processing
Togga may use service providers, technology platforms, cloud infrastructure, analytics providers, automation tools, AI tools, communication providers and other third-party providers located in Australia or overseas.
Your information may be stored, accessed or processed outside Australia. This is likely to include the United States, the European Union or European Economic Area, the United Kingdom, Israel and other locations where our service providers, affiliates, contractors, subprocessors or infrastructure providers operate.
Where required by applicable law, Togga will take reasonable steps in relation to overseas disclosures.
## 9. Marketing and service communications
We may send service-related communications and, where permitted by law, marketing communications such as platform updates, event invitations, supplier/operator opportunities, surveys, editorial updates and community news.
Each commercial electronic message will identify Togga Social as the sender and include a way to unsubscribe.
You may opt out of marketing communications using the unsubscribe option provided in the relevant message or by contacting info@toggasocial.com.
We will action unsubscribe requests within the timeframe required by Australian spam laws, which is currently within 5 working days.
You may still receive service-related communications that are reasonably necessary for your account, platform use, transactions, safety, legal notices, security notices or policy updates.
## 10. Cookies and similar technologies
We and our service providers may use cookies, pixels, tags, analytics tools and similar technologies to:
- operate the website;
- remember preferences;
- understand website usage;
- improve user experience;
- monitor performance;
- protect security;
- measure marketing effectiveness;
- detect misuse or suspicious activity.
You can manage cookies through your browser settings. Some parts of the website may not work properly if cookies are disabled.
If Togga uses advertising pixels, remarketing tools or advanced analytics, additional notices, consent tools or settings may be provided where required or appropriate.
## 11. Security
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure.
These steps may include access controls, permission settings, authentication, administrative controls, limiting access on a need-to-know basis, using reputable technology providers, and maintaining internal privacy and security practices.
No online platform, email system, database, automation tool, AI tool or cloud service can be guaranteed to be completely secure. Users should take care when deciding what information to submit.
## 12. Retention
We keep personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
Retention periods may depend on:
- whether you have an active account or profile;
- whether your information is needed for an event, sample, activation, reward, supplier match, operator match or business opportunity;
- whether we need the information for legal, tax, insurance, accounting, audit, fraud-prevention, dispute-resolution or business-record purposes;
- whether deletion is technically possible in all systems, backups and service-provider environments.
If you close your account or ask us to delete personal information, we will take reasonable steps to delete, de-identify or archive the information, subject to legal, operational and record-keeping requirements.
Public profile information will generally be removed within 30 business days of a valid account-closure or profile-removal request, subject to practical and legal limitations.
Some records may be retained for up to 7 years where reasonably required for business, legal, accounting, tax, audit, fraud-prevention, dispute-resolution or insurance purposes.
## 13. Access, correction and deletion requests
You may contact us to request access to, correction of, or deletion of personal information we hold about you.
Please email info@toggasocial.com.
We may need to verify your identity before responding to a request.
We will respond within a reasonable period. In some cases, we may be unable to provide access, correction or deletion where an exception applies, such as where information must be retained for legal, security, fraud-prevention, dispute-resolution or business-record purposes.
## 14. Data breaches
If we become aware of a data breach, we will take steps to assess and contain the incident.
Where the Privacy Act applies and a data breach is likely to result in serious harm, we will notify affected individuals and the Office of the Australian Information Commissioner where required.
## 15. Third-party websites and services
Togga may link to third-party websites, supplier websites, operator websites, social media platforms, payment providers, event platforms, forms or other external services.
Those third parties have their own privacy policies and terms. Togga is not responsible for how third parties handle your information once you leave our website or interact directly with their services.
## 16. Children
Togga Social is designed for business users and hospitality professionals.
Our platform is not intended for children under 18.
We do not knowingly collect personal information from children. If you believe a child has provided personal information to Togga, please contact info@toggasocial.com so we can review the matter.
## 17. Complaints
If you believe we have mishandled your personal information, please contact us first at info@toggasocial.com.
Please include enough detail for us to understand and investigate your concern.
We will aim to acknowledge privacy complaints within a reasonable time, generally within 10 business days, and respond within 30 days where practicable.
If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner.
## 18. Changes to this Privacy Policy
We may update this Privacy Policy from time to time.
The latest version will be published on www.toggasocial.com.
If we make material changes to how we collect, use, disclose or store personal information, we will take reasonable steps to notify users where appropriate.
## 19. Contact us
For privacy questions, access requests, correction requests, deletion requests, complaints or unsubscribe requests, please contact:
SIU, SAU WAI trading as Togga Social
Email: info@toggasocial.com
Website: www.toggasocial.com