Privacy Policy

1.Definitions

1.1In this Privacy Policy:

App means the Loyalty App mobile device application.

Australian Privacy Principles means the Australian Privacy Principles contained in Schedule 1 of the Privacy Amendment (Enhancing Privacy Protection) Act 2012 which amended the Privacy Act 1988 (Cth).

Loyalty AppmeansLoyalty App Pty Ltd (ACN 601 570 567).

Loyalty App Platformmeans the platform managed by us that you may access through the App and the Website and under which you may earn, purchase, transfer and redeem Points in transactions with us, Merchants and other Users.

Merchant means a third party business that has agreed with us to offer Rewards to you for goods and/or services through transactions in-store or online using the Loyalty App Platform.

Personal Informationhas the meaning given in section 6 of the Privacy Act 1988 (Cth).

Points means the virtual currency or credit used by you, Merchants and other Users which can be earned, claimed or redeemed by you for goods and/or services from Merchants, applied in payment (in whole or in part) for goods and/or services from Merchants, shared between Users and purchased from us, through the Loyalty App Platform.

User means a person who has established an account with us for the use of the App and the Loyalty App Platform.

User Content means all content that is generated, posted or shared by Users on the Loyalty App Platform including, but not limited to, reviews, opinions, advice, ratings, discussions, comments, messages, survey responses and other communications, as well as files, images, photographs, videos, sound recording, musical works and any other content or material.

Websitemeans

We,ouror usmeans Loyalty App and its related bodies corporate and related entities.

Youor yourmeans you,the user of the Loyalty App Platform.

2.Our privacy objective

2.1This Privacy Policy describes how we collect, use and manage Personal Information we collect from you when you use or browse the Loyalty App Platform or otherwise provide Personal Information to us.

2.2We understand that you are concerned with the use, management and disclosure of your Personal Information. We are committed to collecting and using your Personal Information in accordance with the Australian Privacy Principles.

2.3By providing us with Personal Information, you consent to our collection, use, storage, disclosure and transfer of the Personal Information or any other information received by us as a result of your use of the Loyalty App Platform in accordance with this Privacy Policy.

2.4We may changeour Privacy Policy at any time and without notice to you. You should review the Privacy Policy from time to time. If you continue to use the Loyalty App Platform after a change is made to the Privacy Policy, you are deemed to have accepted the Privacy Policy as amended.

3.What kind of Personal Information do we collect and how do we collect it?

3.1You may visit and browse the Website anonymously without providing us with any Personal Information. To use the Loyalty App Platform, however, you will need to provide us with Personal Information.

3.2The Personal Information that we collect will depend on your use of the Loyalty App Platform. We may collect, store and use Personal Information:

(a)provided to us from you when you register to use the Loyalty App Platform. When registering for the Loyalty App Platform you may be asked to enter Personal Information, such as your name and email address. You will be required to provide further Personal Information if you wish to make purchases from a Merchant or enter into transactions with us other than by using Points accrued on previous cash purchases or transferred from another User or earned by you when you refer another User to a Merchant; and

(b)sent to us by your mobile device or computer when you use the Loyalty App Platform, including your transactions with Merchants and other Users and any User Content. We may collect this Personal Information from you, or from Merchants or other third parties who provide services in relation to the Loyalty App Platform.

3.3Personal Information includes:

(a)your name and date of birth;

(b)your contact details, including your email address, telephone number, mobile telephone number and physical contact information;

(c)payment and transaction details and history, including the accrual of Points;

(d)details and history of your preferences, interests and behaviour relating to transactions with us, Merchants and other Users;

(e)information, comments, questions or other enquiries you provide to us via the Loyalty App Platform;

(f)User Content;

(g)additional Personal Information we ask you to submit in order for us to contact your or answer your queries; and

(h)any other information relating to your interaction with the Loyalty App Platform.

3.4We may also collect cookies from your mobile device or computer to monitor your usage of the Loyalty App Platform, enable us to recognise you as a browser of the Website, customise services and content, and promote trust and safety across the Loyalty App Platform and any services we provide through the Loyalty App Platform.

3.5You may, at any time, choose to decline cookies by modifying your browser settings. If you do so, the standard of service we are able to provide you may be affected.

4.What do we do with your Personal Information and why?

4.1We collect your Personal Information to understand your needs and to provide you with the best service experience possible on the Loyalty App Platform. Without the Personal Information the standard of service we are able to provide you may be affected.

4.2We may use your Personal Information to:

(a)manage your account with us and your use of the Loyalty App Platform;

(b)contact you via the contact details you have provided or we have collected;

(c)periodically send you promotional emails;

(d)respond to your comments, questions or other enquiries and provide you with other services requested by you;

(e)refer you to associated websites, Merchantsor other third parties;

(f)prevent, detect and investigate potentially prohibited or illegal activities;

(g)troubleshoot problems and customise, measure and improve our services and the content, layout and operation of the Loyalty App Platform; and

(h)combine your Personal Information with information we have collected from other Users and use it for a purpose described within this Privacy Policy.

4.3From time to time we may also use your Personal Information to contact you for market research purposes. We may contact you by email, telephone or via the contact details you have provided. We may use the information collected to customise the Loyalty App Platform according to your interests.

4.4You may elect to restrict the use of your Personal Information by notifying us via our contact details that you do not consent to the use of your Personal Information for direct marketing purposes.

4.5We may also use your Personal Information to protect our lawful interests and to facilitate transactions that occur throughthe Loyalty App Platform.

5.Who will we disclose your Personal Information to?

5.1We will not disclose your Personal Information for a purpose other than one which is set out in this Privacy Policy unless:

(a)you consent to the use or disclosure of the Personal Information;

(b)the use or disclosure of the Personal Information is required or authorised by or under an Australian law or a court/tribunal order;

(c)a permitted general situation (as defined in the Act) exists in relation to the use or disclosure of the Personal Information by us;

(d)a permitted health situation (as defined in the Act) exists in relation to the use or disclosure of the Personal Information by us;

(e)we reasonably believe that the use or disclosure of the Personal Information is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or

(f)there is a purpose allowed by the Australian Privacy Principles.

5.2We may display your Personal Information and User Content on the Loyalty App Platform. Please refer to the Terms and Conditions for further information in relation to User Content.

5.3We may disclose Personal Information to our service providers who assist us in operating the Loyalty App Platform(for example payment gateway providers and website hosting companies) and to our related corporate entities. We may also exchange your Personal Information with Merchants or our service providers to provide you with a more tailored and consistent experience. Personal Information may be shared with service providers, related corporate entities and Merchants that are outside Australia.

5.4Our service providers and Merchants may collect Personal Information about you when you use the Loyalty App Platform. These service providers and Merchants will have separate privacy policies and cookie policies. We are not responsible for the privacy practices of those service providers or Merchants and recommend that you review their privacy policies and cookie policies.

5.5If we are involved in a merger or acquisition, your Personal Information may form part ofthe transferred assets.

6.How do we store your Personal Information?

6.1We may store your Personal Information electronically in our IT systems and databases and in hard copy files.

6.2We take reasonable precautions to protect your Personal Information and follow the industry best practices to ensure your Personal Information is not lost, misused, accessed, disclosed, altered or destroyed. We do this by encrypting or masking your Personal Information. We do not store certain Personal Information that you provide to us, such as your credit or debit card information and bank account details. This Personal Information is captured by and stored in the database of our third party payment gateway provider. We only store the expiry date of your credit card and the last four digits of the credit card. We cannot guarantee, however, that your Personal Information will not be lost, misused, accessed, disclosed, altered or destroyed.

7.Access to information and your rights

7.1You may request access to, or correction of, the Personal Information we hold about you by contacting us via our contact details set out below.

7.2In accordance with the Australian Privacy Principles we may deny access or refuse to correct Personal Information we hold about you. In those circumstances we will provide you with reasons for that denial or refusal and will advise you of how you may make a complaint about that denial or refusal.

7.3Any complaint or concern about the Personal Information we hold about you, or a complaint or concern about a breach or suspected breach of the Australian Privacy Principles, should be directed to us in writing via our contact details. If we receive a complaint about the Personal Information we hold about you, we will respond to your complaint within 30 days. If you are not satisfied with our response, you may refer the matter to the Office of the Australian Information Commissioner.

8.Contact us

8.1If you have any questions in relation to this Privacy Policy or in relation to the manner in which we collect or hold your Personal Information (including if you would like to access, correct, amend or delete any Personal Information we have about you, or complain about a breach of the Australian Privacy Principles), please contact us via the following contact details:

Email:

Address:Level 1, 180 Newcastle Street, Perth WA 6000

Office hours:Monday to Friday 8:30am to 5:00pm

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