Privacy Policy

Introduction

What is your personal information?

What personal information do we collect and hold?

1. We may collect the following types of personal information:

   • your name;
   • your contact information, such as your email address, telephone number or postal address;
   • your age or birth date;
   • details you provide to establish and manage your account to use and receive the Pointrs, including credit card and other payment information;
   • details of your loyalty programs, credit cards and other similar information required to provide you with relevant Pointrs and information;
   • the products and services to which you have subscribed or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries; and
   • any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites, social media or online presence, through our representatives or otherwise.

2. We may also collect some information that is not personal information because it does not identify you or anyone else. We collect aggregated information about how users use our websites including through the use of cookies to measure and analyse traffic patterns. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. Please note that some services or features of our website will not function so well if cookies are disabled. We may log IP addresses (that is, the electronic addresses of computers connected to the internet), device information and browser information to analyse trends, administer the website, track users movements, and gather broad demographic information.

How do we collect your personal information?

1. We collect your personal information directly from you unless it is unreasonable or impracticable to do so.  When collecting personal information from you, we may collect in ways including:

   • through your access and use of our websites;
   • through your access and use of our social media platforms;
   • through your use of our chat services; and
   • during interactions between you and our representatives.

What happens if we can’t collect your personal information?

1. If you do not provide us with the personal information described above, some or all of the following may happen:

   • we may not be able to provide you with the requested products and services, either to the same standard or at all; or
   • we may not be able to provide you with information that you may want to hear.

For what purposes do we collect, hold, use and disclose your personal information?

1. We collect personal information about you so that we can perform our business activities and to provide best possible quality of customer service.  In particular, we collect, hold, use and disclose your personal information for the following purposes:

   • to provide products and services to you;
   • to send communications requested by you
   • to answer enquiries and provide information or advice about our products or services;
   • to assess the performance of our websites and to improve the operation of the websites;
   • to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties
   • for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes;
   • to provide your updated personal information to our related bodies corporate, contractors or service providers;
   • to update our records and keep your contact details up to date
   • to process and respond to any complaint made by you; and
   • to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.

2. Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

To whom may we disclose your information?

1. We may disclose your personal information to:

   • our employees, related bodies corporate, contractors or service providers for the purposes of the operation of our websites or our business activities, fulfilling requests by you, and to otherwise provide products and services to you. For example, we may disclose to, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
   • suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and
   • any organisation for any authorised purpose with your express consent.

2. We may combine or share any information that we collect from you with information collected by any of our related bodies corporate (within Australia).

Direct marketing materials

1. We may send you direct marketing communications and information about our products and services that we consider could be of interest to you.  These communications may be sent in various forms, including mail, SMS and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth).

2. You consent to us sending you those direct marketing communications by any of those methods.  If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.  In addition, at any time you can opt-out of receiving marketing communications from us by using opt-out facilities provided in the marketing communications, or by making the necessary changes in your personal profile on our website, and we will then ensure that your name is removed from our mailing list.

3. We do not provide your personal information to other organisations for the purposes of direct marketing. 

How can you access and correct your personal information?

1. Most information we hold about you can be accessed and if need be, corrected, at any time after logging in as a user on our website.

2. If you believe we hold other personal information about you, you can request access to this  information at any time by contacting us (see the details below).  Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We will not charge for simply making the request and will not charge for making any corrections to your personal information.

3. There may be instances where we cannot grant you access to the personal information we hold.  For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality.  If that happens, we will give you written reasons for any refusal.

4. If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, and you cannot amend it yourself by logging in as a user on our website, then you may request us to amend it. We will consider if the information requires amendment.  If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

Do we disclose your personal information to anyone outside Australia?

1. We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above.

2. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

3. We may disclose your personal information to entities located outside of Australia, including Microsoft, our hosting entity located in the United States of America.

Security

1. We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure.  We may hold your information in either electronic or hard copy form.  Personal information is destroyed or de-identified when no longer needed.

2. As our websites are linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online.  We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.

Links

Complaints

1. If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.

2. We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint.  We will treat your requests or complaints confidentially.  Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved.  We will aim to ensure that your complaint is resolved in timely and appropriate manner.

3. After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint.  If we receive a response from you, we will assess it and advise if we have changed our view.

Contacting us

1. If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our websites or contact our Privacy Officer using the details set out below.

2. Please contact our Privacy Officer at:[email protected]

Changes to our privacy policy

1. We may change this privacy policy from time to time.  Any updated versions of this privacy policy will be posted on our websites.  Please review it regularly.