What personal information do we collect?
We may collect the following types of personal information:
- mailing or street address;
- email address;
- telephone number and other contact details;
- age or date of birth;
- credit card information;
- your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
- details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
- any additional information relating to you that you provide to us directly through our website or app or indirectly through your use of our website or app or online presence or through other websites or accounts from which you permit us to collect information;
- information you provide to us through customer surveys; or
- any other personal information that may be required in order to facilitate your dealings with us.
We may collect these types of personal information either directly from you, or from third parties. We may collect this information when you:
- register on our website or app;
- communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites;
- interact with our sites, services, content and advertising; or
- invest in our business or enquire as to a potential purchase in our business.
Why do we collect, use and disclose personal information?
We may collect, hold, use and disclose your personal information for the following purposes:
- to enable you to access and use our website and applications
- to operate, protect, improve and optimise our website and applications, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
- to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
- to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
- to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and
- to consider your employment application.
We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.
Do we use your personal information for direct marketing?
We and/or our carefully selected business partners may send you direct marketing communications and information about our products and services. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).
To whom do we disclose your personal information?
- our employees and related bodies corporate;
- third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
- professional advisers, dealers and agents;
- payment systems operators (eg merchants receiving card payments);
- our existing or potential agents, business partners or partners;
- our sponsors or promoters of any competition that we conduct via our services;
- anyone to whom our assets or businesses (or any part of them) are transferred;
- specific third parties authorised by you to receive information held by us; and/or
- other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Using our website and cookies
We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we have an internal security procedures process we follow. However, we cannot guarantee the security of your personal information.
Accessing or correcting your personal information
You can access the personal information we hold about you by contacting us using the information below. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information. If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.
Making a complaint
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
GDPR – European grounds for processing personal data
This section applies if you are based in the European Economic Area (EEA) during your interactions with us and sets out the additional information that we are required to provide to you under the GDPR.Under European data protection law, use of personal information must be based on one of a number of legal grounds and we are required to set out the grounds in respect of each use. We can only process personal data when the processing is permitted by the specific legal ground set out in the law. In the table below, we have set out the relevant grounds that apply to each purpose of data processing that is mentioned in this Privacy Statement. You can find an explanation of each of the legal grounds for use of personal information below.
|Purposes of the data processing||Use bases|
|to enable you to access and use our website and applications.||contract performance legitimate interests (to allow us to perform our obligations and provide services to you)|
|to provide you with information about the service and App.||contract performance legitimate interests (to allow us to perform our obligations and provide services to you)|
|to operate, protect, improve and optimise our website and applications, business and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;||contract performance legitimate interests (to allow us to maintain and improve the quality of our services and products)|
|to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you.||contract performance legal obligation legitimate interests (to allow us to correspond with you in connection with our services)|
|To ensure website content is relevant, including ensuring that content from our websites is presented in the most effective manner for you and for your device.||contract performance legitimate interests (to allow us to provide and improve our services)|
|to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting.||consent (which can be withdrawn at any time)|
|to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners.||consent (which can be withdrawn at any time)|
|We may also combine the information that we collect and hold about you for the purposes of creating insights about you and customer segmentation.||contract performance legitimate interests (to allow us to perform our obligations and provide services to you)|
|to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.||contract performance legal obligation legal claims legitimate interest (to allow us to guard against fraud and other unlawful activity)|
Other rights available under European Law
If you are based in the EEA during your interactions with us in addition to the rights outlined above, under certain conditions, you may have the right under the GDPR to ask us to:
- provide you with further details on how we use and process your personal information;
- delete personal information we no longer have grounds to process; and
- restrict how we process your personal information whilst we consider an inquiry you have raised.
In addition, under certain conditions, you have the right to:
- where processing is based on consent, withdraw the consent;
- lodge a complaint with a supervisory authority;
- object to any processing of personal information that we process on the “legitimate interests” or “public interests” grounds, unless our reasons for the underlying processing outweighs your interests, rights and freedoms; and
- object to direct marketing (including any profiling for such purposes) at any time.
You can exercise these rights by contacting us. These rights are subject to certain exemptions to safeguard the public interest and our interests. We will respond to most requests within 30 days.
Retention period under GDPR
Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. When personal data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.
Disclosure of information outside the EEAWhere we transfer personal information from inside the EEA to outside the EEA, we may be required by law to take specific measures to safeguard the relevant personal information. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions. In countries which have not had these approvals, we will use appropriate safeguards to protect any personal information being transferred, such as EU Commission-approved model contractual clauses or binding corporate rules permitted by applicable legal requirements.
GDPR – Legal grounds for use of personal information
Use of personal information under the GDPR must be justified under one of a number of legal bases or grounds and we set those out here. The principle legal grounds that justify our use of your personal information are as follows:
- Consent: where you have consented to our use of your information (you will have been presented with a consent form in relation to any such use and may withdraw your consent by contacting us on the details below).
- Contract performance: where we are required to collect and handle your personal information in order to provide you with the services that we have contractually agreed to provide to you.
- Legal obligation: where we need to use your personal information to comply with our legal obligations.
- Vital interests: where we need to process your personal information in order to protect the vital interests of you or another natural person, e.g. where you require urgent assistance.
- Public interest: where we need to process your personal information in order to carry out a task that is in the public interest.
- Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
- Public interest in area of public health: where we need to process your personal information for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health, set out in EU law or the laws of the member state in which you are based
Effective: [May 15th, 2018]