Dated: May 2017
“Personal Information” means information or an opinion about an identified individual, or about 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.
We comply with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act), as well as other applicable laws protecting privacy. All Personal Information that we handle is managed in accordance with those laws.
2 Personal Information collected by us
When you create your Clipp Account we will ask you for a variety of Personal Information including your name, date of birth, gender, email address, phone number, and credit card information. We may ask you about or collect further Personal Information about you on a case by case basis including as required or permitted by law.
3 How we collect Personal Information
Generally, we will collect information directly from the individuals to whom it relates, but may also collect information about an individual from a third party such as a Vendor, contracting company or providers of Third Party Services.
We may collect Personal Information:
· via our application or website;
· directly from you, when you provide it to us or our agents or contractors;
· from publicly available resources; and
· from third parties (where appropriate) including from Vendors.
4 Use of Personal Information
Each time you open a tab at a Vendor location using Clipp, you authorise us to exchange your Personal Information, together with your pre-authorisation credit card limit (your tab limit), with the point-of sale system operator for the venue (POS operator) and the Vendor for the purpose of establishing the tab service and processing your tab at the Vendor location. We will use reasonable endeavours to ensure that the POS Operator and the Vendor only use your Personal Information for this purpose.
The Personal Information we collect, hold, use and disclose is primarily gathered for:
· providing you with products and/or services;
· establishing your personalised Clipp Account;
· sharing with you any updates, including any software updates;
· improving our services, including addressing any issues or problems with your use of Clipp;
· answering any of your queries or otherwise contacting you regarding the Customer Information you have provided and your use of Clipp; and
· any other purpose disclosed to you at the time your Customer Information is collected, including when you choose to redeem any Clipp reward points in which case we will share your Personal Information with the Vendor to fulfil the redemption process.
Where appropriate, we may handle Personal Information relying on exemptions that are available under the Privacy Act and other applicable laws.
By opening a tab at a Vendor location using the Clipp application, you also authorise us to collect, hold, use and disclose your Personal Information for the purpose of direct marketing, and to share that Personal Information with the Vendor for the purpose of receiving Product Representations including special offers and other promotions, products and services from the Vendor via Clipp.
On receipt of such direct marketing, you will receive instructions on how to unsubscribe from receiving any future Product Representations from that Vendor. You may unsubscribe from receiving marketing materials at any time by contacting the Vendor or by electing to opt-out when you receive the materials. Please contact a Vendor directly if you have any questions or concerns with the offers you receive from them.
If you enter into a competition or other promotion you authorise us to collect, hold use and disclose the Personal Information you provide to enable your participation in the competition or other promotion.
When we contact you, we may do so via Clipp, electronic messaging (including SMS and email), by mail, by phone or in any other lawful manner.
5 Disclosure of Personal Information
· to our related bodies corporate (as appropriate);
· to our suppliers, service providers, professional advisers and agents including the following service providers:
- IT development;
- Maintenance providers;
- professional advisors such as lawyers, accountants and auditors;
- data storage providers;
- POS operators; and
· to government agencies or regulatory bodies where required;
· to third parties for the purpose of facilitating direct marketing;
· in the event of a reorganisation, merger or sale of our business (or any part thereof), we may transfer any and all Personal Information we collect to a relevant third party for the purpose of the arrangement;
· where necessary to protect the rights or safety of any of its employees or a third party;
· where an individual to whom the Personal Information relates has consented to the disclosure; or
· where we are allowed or required to by law or have a public duty to do so, including compelled by a court or law enforcement.
However, in certain circumstances, we may be required or permitted by law or Court or Tribunal order to release certain personal information about you.
We will not disclose your Personal Information overseas.
6 Cookies and IP address tracking
To provide location-based services through the Clipp, we and our service providers may collect, hold, use and disclose precise location data, including the real-time geographic location of the device that Clipp is downloaded and stored on. This location data is collected anonymously in a form that does not personally identify you and is used by us and our service providers to provide and improve location-based services.
Location-based services may be switched off through Clipp or device settings however this may limit the service we are able to provide to you.
7 Links to other sites
Clipp may contain links to other websites. We do not make any representations about any third party websites that may accessible through the application.
8 Storage and security
We have security protocols to safeguard Personal Information you share with us against loss, theft and misuse, as well as against unauthorised access, modification or disclosure of the Personal Information under our control. We will destroy or de-identify any information that we no longer require.
Please note however that the internet is not a secure environment and although care is taken, we cannot guarantee the security of information provided to it via electronic means.
Where it has been determined under the Privacy Amendment (Notifiable Data Breaches) Bill 2016 that an eligible data breach event has occurred, Clipp will notify you with all information pertaining to the event as soon as reasonably possible.
9 Access and correction
You can access the Personal Information we collect in your account. You can help ensure that your information is accurate, complete and up to date by logging in to your account. Please email us at firstname.lastname@example.org to request access to any personal information you believe we may hold about you.
We encourage you to not share your log in details including any password or personal identification details with anyone else.
10 Complaints handling
If a complaint is made, please include your name and contact details such as an email address and telephone number and clearly describe the complaint. We will investigate the complaint and respond promptly. Resolution of your complaint may be delayed if we are unable to contact you.
If the complainant considers that we have failed to resolve the complaint satisfactorily, the complainant can complain to the Office of the Australian Information Commissioner (they can be contacted via email at: email@example.com).
For further information about our privacy policies or practices please contact us by email at firstname.lastname@example.org.