What information do we collect?

Personal information is information that identifies you, or from which you may reasonably be identified. The types of personal information that we may collect include, but are not limited to:

• your name and contact details including, but not limited to, your address, email address and phone number;
• information which you provide to us when making an application to become a member of one of our Sites;
• information you provide to us when you manually update your member account on one of our Sites;
• information which you provide to us in response to, or by participating in, one of our surveys, promotions, competitions or events (Activity);
• your credit card and/or banking details;
• details of the services that we have agreed to provide to you, you have purchased from us, or that you have otherwise engaged us to undertake (Services);
• records of our communications with you, including any complaints, requests, service issues or queries;
• information about your visits to and activities on our Site or partner sites in connection with our Services or an Activity;
• if you apply for a job with us, any information contained in your CV or any other information that you may otherwise provide to us in connection with making any such application; and
• information in any review or comment that you post online, including via the Site or social media,

(Personal Information).

You can always decline to provide any Personal Information that we request. However, if you choose not to provide us with such Personal Information, we may be unable to provide you with the products or Services that you want, or we may not be able to respond to any inquiry made by you.

How do we collect your Personal Information?

We collect Personal Information for the purposes of providing you with our Services. We collect Personal Information in a number of ways, including:

• when you make enquiries or engage our Services;
• when you respond to or participate in an Activity;
• when you enter your personal details on our Site for any reason, including as part of an application to become a member of the Site;
• when you provide information via any electronic means including email, fax or over the telephone;
• when you provide feedback on our Services;
• when you engage with us online, including via social media;
• when we obtain de-identified information matched to you by third party data enrichment providers; and
• when you submit a job application to us, or enquire with us about submitting a job application to us.

We generally collect Personal Information directly from you – over the phone, by email, via our Site, or in person. Any third party software or storage service provider we engage to provide our Services may collect Personal Information from you on our behalf and for the same purposes as the purposes that are described in paragraph 6 below.

We may also use technology to collect information about you derived from your use of the Site. We collect this information to allow us to customise your user experience, for example, by filtering the content that is presented to you. Examples of technology that we use to collect this information include: tracking codes; cookies (that are placed by us or by third party platforms); and Google Analytics. You can control the use of these technologies to limit our collection of this information via the device you use to access the Site, however this may limit the availability of some features of the Site, including your participation in Activities.

Sensitive Information

Sensitive information is information that relates to topics such as your health, racial or ethnic origin, political opinions, religious beliefs or sexual orientation (Sensitive Information). Depending on the nature of the Activity, we may collect Sensitive Information from you. Sensitive Information will only be collected with your prior consent and only if it is directly related to, or reasonably necessary for, the Activity that is being conducted. Your decision to be involved in an Activity that requires you to give Sensitive Information is entirely at your discretion.

What do we do with your Personal Information?

We collect Personal Information that is reasonably necessary for our business functions. We may collect, hold, use and disclose your Personal Information to:

• identify you and assist you in your use of our Services;
• respond to your requests for information and other general inquiries;
• respond to enquiries, comments and complaints;
• administer and manage the Services we provide;
• communicate with you about activities, events, promotions, competitions, partner offers and Services that are relevant to you based on the information you have provided to us;
• research, develop and improve our Services; and
• process any job application submitted by you.

Anonymity

Where practical and lawful, and if not required for any Activity, you can deal with us anonymously or use a pseudonym, for example when you post a product review. However, in many instances, if we cannot identify you or if you do not provide us with the Personal Information we request, we may not be able to provide you with our Services, assist you to participate in the Activity or respond to your enquiry or claim.

How your Personal Information is stored

We take great care to protect your privacy. We understand the importance of your Personal Information and we have appropriate procedures in place to safeguard and secure this information, prevent unauthorised access or disclosure and maintain data accuracy. We also take measures in respect of destroying or de-identifying Personal Information when required by Privacy Laws.

While we aim to use our best efforts to secure and protect your Personal Information that is held by us, we cannot guarantee the security of any such Personal Information that is provided or transmitted to us by you. Any such provision of information to us is at your own risk.

We have internal procedures for responding to any data breach, or suspected data breach, in compliance with the requirements under Privacy Laws.

When we disclose your Personal Information

We may disclose your Personal Information to organisations outside of ours and those organisations may be located (and your Personal Information may be disclosed) overseas. Organisations to which we may disclose your Personal Information that are located overseas are principally our software-as-a-service platform provider, ‘Market Cube’, who we understand has servers located in the United States, the United Kingdom and India. These disclosures are made subject to suitable protection for privacy and confidentiality of your Personal Information. Organisations to which we may disclose your information could include:

• third party organisations who have been retained by us to assist us in facilitating, operating, developing and otherwise maintaining the Site (for example, ‘Market Cube’);
• third party organisations who we engage to supply and deliver vouchers, prizes and other benefits in connection with your use of the Site or your participation in any Activity;
• third party organisations, for the purpose of providing you with opportunities to participate in an Activity;
• our professional advisers, for example, our financial advisors, auditors, lawyers, other professional consultants that we may engage from time to time, as well as our insurers; and
• government, regulatory or other organisations to whom we are required to disclose your Personal Information by law.

We may provide third party organisations who engage our Services with your feedback in response to a Survey or Activity, which may include Personal Information. It is important to note that, where possible, we aim to share this information on a de-identified basis. There may be opportunity to provide further Personal Information directly to a third party via your participation in a Survey. Any such Personal Information provided under such circumstances will be provided by you directly to that third party at your discretion and we do not have any control over the information you provide to third party organisations in such instances. From time to time, we may disclose your Personal Information to our related bodies corporate.

We may disclose your information to a purchaser or successor entity in connection with the sale of our company or a related body corporate, or the sale of substantially all of the assets of our company or a related body corporate.

We may also use and disclose your Personal Information for other purposes explained at the time of collection.

From time to time, there may be opportunities to participate in competitions or events that are run by third parties. It is important to be aware that the information that you provide to third parties is not within our control and is subject to the third party’s own Privacy Policy.

Accessing and correcting your Personal Information

You are entitled to access your Personal Information held by us on request. To request access to your Personal Information please contact our Privacy Officer using the contact details in paragraph 12 below. You will not be charged for making a request to access your Personal Information, but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.

We will take reasonable steps to ensure that your Personal Information which we collect, use or disclose is accurate, complete and up-to-date. If you consider any Personal Information we hold about you to be inaccurate, out-of-date, incomplete, irrelevant or misleading, you are entitled to request correction of the information. After receiving a request from you, we will take reasonable steps to correct your information.

We may decline your request to access or correct your Personal Information in certain circumstances, provided that those circumstances are pursuant to the Privacy Laws. If we do refuse your request, we will provide you with a reason for our decision.

How you may make a privacy-related complaint

How you may make a privacy-related complaint You may contact us at any time if you have any questions or concerns about our Privacy Policy or about the way in which your Personal Information has been handled. Please contact our Privacy Officer in writing by using the contact details set out in paragraph 12 below.

All enquiries or complaints will be taken seriously and handled with impartiality and discretion. We will investigate any complaint that you may submit to us and we will endeavour to provide you with our response within a reasonable timeframe. If after receiving our response, you still consider that your privacy complaint has not been resolved, you may refer your complaint to the Office of the Australian Information Commissioner: