All organisations that collect personal or sensitive data must do so in compliance with standard Privacy Principles. This includes your consent for Loyalty Innovation Pty Ltd – ABN 18 161 673 427 (“Loyalty Innovation ”) use of your personal details to process and fulfil your order as well as service your account.
- implement practices, procedures and systems that will ensure that we comply with all relevant privacy codes; and
- be able to deal with privacy related inquiries and complaints in a prompt manner.
Note: ‘Personal information’ is defined as information or an opinion about an identified individual, or an individual who is reasonably identifiable:
- whether the information or opinion is true or not, and
- whether the information or opinion is recorded in a material form or not.
Security of your Personal Information
Kind of personal information Loyalty Innovation collects and holds
Loyalty Innovation collects and holds personal information such as your name, email address and computer cookies. This information is only collected for identification & communication purposes, including when you subscribe to our e-newsletter, (where name and email address only is retained). Loyalty Innovation does not retain credit card or bank account details on our platform, however these are stored on our payment gateway providers platforms in accordance with PCI compliance standards.
How personal information is collected and held
Loyalty Innovation collects and stores your personal information whenever:
- you create an account
- you subscribe to our newsletter
- you earn & redeem stamps or Ether
- or you send us an email
Your personal information is stored and secured using our third party data storage provider. Purposes for which Loyalty Innovation collects, holds, uses and discloses personal information Loyalty Innovation collects, holds, uses and discloses your personal information for the primary purpose of:
- maintaining your account
- properly managing and fulfilling any earn & redemption issues or errors
- receiving and resolving complaints
- marketing activities conducted by Loyalty Innovation (specifically our e-newsletter) and
- our professional advisers, accountants, lawyers and auditors.
Any offers sent to you by Loyalty Innovation will contain a clear and easy-to-read “opt-out” button which you can use to stop LoyaltyInnovation from sending you such offers in the future.
This website uses “cookies” to help you personalise your online experience. A cookie is a text file or a packet of information that is placed on your hard disk by a web page server to identify and interact more effectively with your computer. There are two types of cookies that may be used on this website: a persistent cookie and a session cookie. A persistent cookie gets entered by your web browser into the “Cookies” folder on your computer and remains in this “Cookies” folder after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. This website may also use web “beacons” (also called “clear GIFs” or “pixel tags”) in conjunction with cookies for the same reasons. Web beacons are small strings of code that are placed in a Web page. Cookies cannot be used to run programs. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalise Loyalty Innovation pages, the cookie helps Loyalty Innovation record your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same website, information you previously provided can be retrieved, so you can easily use the Loyalty Innovation features that you customised. You can configure your internet browser (such as Microsoft Internet Explorer, Chrome, Mozilla Firefox or Safari) to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browsers instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies, if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Loyalty Innovation websites you visit.
Accessing and seeking correction of your personal information
Members can gain access to or seek the correction of the personal information that Loyalty Innovation holds. Unify Rewards members have a right to Loyalty Innovation a reasonable request for access to their personal information and to request its correction. Requests to access or seek to correct your personal information can be made by email to the Privacy Officer at email@example.com. When we receive such a request, we have the right to ask for and obtain your position title, telephone number and email address in order for you to access and correct personal information.
A person can deal with Loyalty Innovation by not identifying themselves or using a pseudonym. The circumstances under which a customer can use only a pseudonym are when submitting a support request which is not order or account related.
Loyalty Innovation’s access to your information
Third Party Access to your information
The following third party recipients may have access to your personal information for the primary purposes noted above:
- payment gateway providers
Length of time Personal Information is retained
Loyalty Innovation will keep and retain your personal information for a period of 10 years, or such other period of time as is required by Law.
Consequences for you if your personal information is not provided to us
If some or all of the personal information that we request is not provided to us, the main consequence is that we may not be able to transact earn or redemption activities. Other consequences may include that we might not be able to resolve any complaint you have against Loyalty Innovation or Unify Rewards.
Loyalty Innovation may use or disclose personal information about you for the purpose of direct marketing if
Loyalty Innovation collected the information from you. You would reasonably expect Loyalty Innovation to use or disclose the information for that purpose.
Loyalty Innovation provides you with an option to ‘opt-out’ of receiving direct marketing communications from us, and you have not made such an ‘opt-out’ request to us.
Requests by you to stop direct marketing communications
If Loyalty Innovation uses or discloses your personal information for the purpose of direct marketing, you may request not to receive direct marketing communications from us. Loyalty Innovation will not charge you for making or giving effect to your data and we will stop sending direct marketing communications within a reasonable period after your request is made (usually within 5 working days from receiving your request).
You may also ask us to identify the source of the personal information. Loyalty Innovation will notify you of the source, unless this is impracticable or unreasonable, which will depend on a number of factors, including:
- the consequences for you if you are not notified of the source
- the length of time that has elapsed since the personal information was collected by us
- the time and cost involved.
Destroying or de-identifying personal information
Loyalty Innovation will take reasonable steps to destroy or de-identify personal information it holds if it no longer needs the information for any purpose for which it may be used or disclosed under this policy. The requirement to take reasonable steps to destroy or de-identify does not apply if personal information is contained in a Commonwealth record, or if an Australian law or a court/tribunal order requires it to be retained.
Verifying your identity
Loyalty Innovation must be satisfied that a request for personal information made by the individual concerned, or by another person who is authorised to make a request on their behalf, for example, as a legal guardian or authorised agent. It would generally be extremely difficult for Loyalty Innovation to deal with an anonymous request for personal information. However, it may be practicable to deal with a pseudonymous request, for example, where you have previously transacted under that pseudonym and can establish your identity as that individual. The steps required for Loyalty Innovation to verify your identity will depend on the circumstances. In particular, whether you are already known to or readily identifiable by Loyalty Innovation. The minimum amount of personal information needed to establish your identity will be sought. In a telephone call Loyalty Innovation may request information that can be checked against records held by us.
Refusal to give Access
Whilst every effort will be made by Loyalty Innovation to provide access in a manner that is as prompt, uncomplicated and inexpensive as possible, Loyalty Innovation may refuse to give you access to your personal information. There are a number of grounds upon which Loyalty Innovation can refuse to give you access to your personal information. These reasons may include (without limitation):
- if Loyalty Innovation reasonably believes that giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety
- giving access would have an unreasonable impact on the privacy of other individuals
- the request for access is frivolous or vexatious
- the information relates to existing or anticipated legal proceedings between you and Loyalty Innovation , and would not be accessible by the process of discovery in those proceeding
- giving access would reveal the intentions of Loyalty Innovation in relation to negotiations with you in such a way as to prejudice those negotiation
- giving access would be unlawful
- denying access is required or authorised by or under law or a court/tribunal order
Loyalty Innovation has reason to suspect that unlawful activity, or misconduct of a serious nature, that relates to Loyalty Innovation’s functions or activities has been, is being or may be engaged in and giving access would be likely to prejudice the taking of appropriate action in relation to the matter
- giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body; or
- giving access would reveal evaluative information generated within Loyalty Innovation in connection with a commercially sensitive decision making process.
All complaints are required by the Act to be made in writing to Loyalty Innovation and Loyalty Innovation is then allowed a reasonable time (usually 30 days) to respond to complaints. We may ask you to participate in a dispute resolution scheme (such as mediation) in order to resolve your complaint.
An individual can complain about an alleged breach by Loyalty Innovation of the APPs by sending an email to the Privacy Officer at firstname.lastname@example.org setting out details of the complaint.