Privacy Policy

Avidity Rewards ABN 92 632 499 284

Privacy Policy

  

Background

We recognise and value:

  1. the protection of your personal information; and 

  2. that you have an interest in our collection and use of your personal information. 

We have implemented this Privacy Policy in accordance with the Privacy Act 1988 (Cth) (Privacy Act), Australian Privacy Principles (APP) and other data protection rules in order to be open and transparent about how we collect, hold, and use your personal information, and under what circumstances we may disclose or transfer it. 

Please note that this Privacy Policy forms part of the Avidity Rewards ABN 92 632 499 284 (Avidity, “us”, “we”) terms and conditions of our various agreements with you (if any).

Disclaimer

While your privacy is very important to us, nothing in this privacy policy constitutes a voluntary opt-in to any privacy laws, anywhere in the world, which we are not statutorily bound to comply with. 

Categories of information that we collect and hold

Why we collect personal information

The personal information that we collect and hold is utilised for us to reasonably deliver proper performance of our functions and activities and maintain a high level of excellence as a rewards platform.

The information that is collected is likely to differ depending on whether you are a Member or a Partner. See clauses 3.3 and 3.4 below.


What is personal information?

Personal information is any information that can be used to identify you. This includes any personal information or opinions about you, whether true or not, no matter how the information or opinions are recorded. Personal information held by us may include (but not be limited to) your: 

  1. name and date of birth;

  2. residential and business postal addresses, telephone/mobile/fax numbers and email addresses;

  3. bank account and/or credit card details for agreed billing purposes;

  4. any information that you provided to us by you during an account creation process or added to your user profile;

  5. preferences and password for using our software and services; 

  6. your computer and connection information; and

  7. any information that you otherwise share with us.

Sensitive information is a special category of personal information and includes information about your health, race or ethnic origin, political or religious beliefs, membership of a trade union or association, sexual preferences or criminal record. We will not disclose your sensitive information without your consent unless there is a need to disclose such information in accordance with relevant laws and privacy acts.


Members

A Member is a member of the Avidity rewards program or any other rewards program we operate, and for the purposes of this Privacy Policy also includes individuals who wish to apply to become Members.

The type of information that we typically collect and hold about Members is necessary to provide the rewards services, which may involve determining which of our rewards partners may be relevant to you.

Information collected in relation to Members includes but is not limited to:

  1. information about interests and spending preferences;

  2. information about the business of the Member (if applicable);

  3. information about purchases;

  4. information about your comments and messages;

  5. information which may assist the platform in providing relevant information to you regarding deals and partner promotions; and

  6. information which may pre-qualify or exclude you from certain partner offerings.

Information that is collected, held and disclosed about Member is typically utilised for many purposes, including (but not limited to):

  1. assisting us to ensure that the partners engaged on the platform will be relevant to you;

  2. assisting you to place orders through this site;

  3. processing any purchases of services that you may make through this site, including charging, billing and collecting debts;

  4. making changes to your account;

  5. responding to any queries or feedback that you may have;

  6. conducting appropriate checks for creditworthiness and for fraud;

  7. preventing and detecting any misuse of, or fraudulent activities involving, this site;

  8. conducting research and development in respect of our services;

  9. gaining an understanding of your information and communication needs or obtaining your feedback or views about our services in order for us to improve them;

  10. maintaining and developing our business systems and infrastructure, including testing and upgrading of these systems,

  11. marketing services to you, but only where this is permitted;

  12. statistical purposes and statutory compliance requirements.

  13. obtaining new partnerships and deals to increase the positive experience for Members on the platform; 

  14. matching a Member with rewards and deals which may be relevant to them; and

  15. for any other purpose reasonably considered necessary or desirable by us in relation to the operation of our business.


Partners

A Partner is someone (including an organisation) who offers deals, promotions and other rewards on the platform, and for the purposes of this Privacy Policy also includes prospective Partners.

Information that we typically collect and hold about Partners is necessary to help us list, promote, advertise and connect Partners with Members.

Information collected in relation to Partners includes but is not limited to:

  1. information about the Partner’s business;

  2. information about the pricing of the Partner’s products and services;

  3. information about which Members show interest in the products and services of the Partner;

  4. personal details and other business information;

  5. metrics on offerings, promotions and advertisements of the Partner; and

  6. any other information necessary to ensure that Partners can properly utilise the platform.

Information that is collected, held and disclosed about Partners is typically utilised in a similar manner to that listed in clause 3.3 above, and also to ensure that the platform can offer an effective outlet for the Partners to promote their products and services.

 

Direct marketing

We may use your personal information for the purposes of direct marketing except where you have specifically requested that we don’t. We market to Members and Partners using a variety of methods including email alerts, phone, SMS and print.

We provide Members and Partners the option to opt out of receiving marketing material from us. Upon receipt of this request their marketing preferences are updated on our systems.

If you do not wish to have your personal information used for direct marketing purposes, you may contact us and request not to receive direct marketing communications from us, at which time your marketing preferences will be updated on our systems.

We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information. This does not include Partners and other trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.

 

How your personal information is collected

Collection of personal information

The means by which we will generally collect your personal information are likely to differ depending on whether you are a Member or a Partner.

We may sometimes collect information from third parties and publicly available sources when it is necessary for a specific purpose such as checking information that you have given us or where you have consented or would reasonably expect us to collect your personal information in this way.

Members

Personal information will be collected from you directly when you fill out and submit one of our application forms or any other information in connection with your application to receive membership in Avidity Rewards.

Personal information is also collected when:

  1. you provide us with any additional information about you; and

  2. electronically through our telecommunications and technology systems.

We may also collect personal information about you from a range of publicly available sources including newspapers, journals, directories, the Internet and social media sites. When we collect personal information about you from publicly available sources for inclusion in our records we will manage the information in accordance with the Privacy Act, APPs and this privacy policy.

Partners

Personal information about you may be collected:

  1. when you provide it to us for business or business-related purposes;

  2. in setting up your promotions or providing us details of your business to ensure your promotions are offered correctly within the platform;

  3. when you complete any ‘sign-up’ forms or sign other contracts with us from time to time; and

  4. in your use of the platform ‘back-end’.

We may also collect personal information about you from a range of publicly available sources including newspapers, journals, directories, the Internet and social media sites. When we collect personal information about you from publicly available sources for inclusion in our records, we will manage the information in accordance with the APPs and this privacy policy.

Photos & Images 

We may request proof of identification from you including copies of your passport, visa and or driver’s license and will only do so for the performance of our functions and activities as a rewards platform.

We will not request that you supply photographs, scan photo ID, or capture and retain video image data of you in cases where simply sighting photographs or proof of identity documents would be sufficient in the circumstances.

Internet Browsing

When browsing the platform, our website host makes a record of the visit and logs the following information for statistical purposes such as Google Analytics. The information that is recorded in server logs are;

  1. your server address;

  2. your top-level domain name (for example, .com, .gov, .org, .au);

  3. the pages you accessed and documents downloaded;

  4. the previous site you visited; and

  5. the type of browser being used.

We do not identify users or their browsing activities except, in the event of an investigation, where a law enforcement agency may exercise a warrant to inspect the Internet service provider’s server logs.

We do not accept responsibility for the privacy policy of any other site to which our site has a hyperlink, and it is advisable to look at the privacy policy of other sites before disclosing personal information.

Cloud Services

In cases where we utilise cloud services, we will take reasonable measures to ensure that disclosure of your personal information to the cloud service provider is consistent with our disclosure obligations under the APP and other laws.

Emails

Our integrated technology systems are designed to log emails received and sent and may include read and receipt notifications to enable tracking.

On receiving your email address through direct correspondence by you, the email address will only be used or disclosed for the purpose for which you have provided it and direct marketing as outlined in our privacy policy. It will not be added to any external mailing list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

Call & Message Logs

Our integrated telephone technology logs telephone calls, messages received and sent and enables call number display, which may include your profile picture if you have provided it.

When we receive your contact number through your direct contact via phone or message, the number (and profile picture) will only be used or disclosed for the purpose for which you have provided it and direct marketing as outlined in our privacy policy. It will not be added to any external phone list or used or disclosed for any other purpose without your consent other than as may be permitted or required by law.

Teleconferences & Videoconferences

Teleconferences and videoconferences may be recorded with your consent. In cases where it is proposed that they be recorded, we will tell you first the purpose for which they are to be used and retained.

Database

We use a cloud-based database to log and record certain information. This database contains the information and documentation you have provided us.

This database operates from servers that permit disclosure to cross-border recipients. As far as we can reasonably control, your information will only be used or disclosed as reasonably necessary for the performance of our functions and activities as a rewards program operator.

Mobile Technology & Access

Avidity Rewards staff use laptops, tablets, phones and other portable electronic devices that allow them to access, retrieve and store your personal information.

 

Use

The personal information you provide is used for purposes related to our primary business operations, which is providing software and services to third party organisations, government bodies and associated individuals. Examples of when your information may be used include:

  1. providing you with the products and services you have requested;

  2. administration needs in relation to providing you with products and service, including your account;

  3. dealing with requests, enquiries or complaints and other customer care related activities;

  4. verifying your identity;

  5. informing you about products and services from third-party suppliers;

  6. assisting you to use functionality on the website or services;

  7. processing any purchases of services that you may make through us or this site, including charging, billing and collecting debts;

  8. making changes to your account(s);

  9. responding to any queries or feedback that you may have;

  10. conducting appropriate checks for credit-worthiness and for fraud;

  11. preventing and detecting any misuse of, or fraudulent activities involving, this site, the services or software;

  12. conducting research and development in respect of our services;

  13. gaining an understanding of your information and communication needs or obtaining your feedback or views about our services in order for us to improve them; 

  14. maintaining and developing our business systems and infrastructure, including testing and upgrading of these systems,

  15. marketing our products and services generally; and

  16. carrying out any activity in connection with a legal, governmental or regulatory requirement imposed on us or in connection with legal proceedings, crime or fraud prevention, detection or prosecution;

and for any other purpose reasonably considered necessary or desirable by us in relation to the operation of our business.

We may also use personal information for purposes (as would be reasonably expected by you) in connection with those activities described above. We will not use your information for purposes other than as described in this privacy policy unless we have your consent, or there are specific law enforcement, public health or safety reasons.

Our use of Cookies, Pixels and Web Beacons 

What are cookies?

The platform, this website, and our products and services may use “cookies” to help 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 by us: a persistent cookie and a session cookie.

A persistent cookie is entered by your web browser into the “Cookies” folder on your computer and remains in that folder after you close your browser and may be used by your browser on subsequent visits to this site. A session cookie is held temporarily in your computer’s memory and disappears after you close your browser or shut down your computer. 

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. In some cases, cookies may collect and store personal information about you. We extend the same privacy protection to your personal information, whether gathered via cookies or from other sources.

You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Please refer to your internet browser’s instructions to learn more about these functions. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of this site.

Why we use cookies

The platform, this website, and our other services may use cookies in order to:

  1. remember your preferences;

  2. recognise you as logged in while you remain so (if applicable). This avoids your having to log in again every time you visit a new page;

  3. show relevant notifications to you (e.g., notifications that are relevant only to users who have, or have not, created an account or subscribed to newsletters or email or other subscription services); and

  4. remember details of data that you choose to submit to us (e.g., through online contact forms or by way of comments, forum posts, chat room messages, reviews, ratings, etc).

Many of these cookies are removed or cleared when you log out, but some may remain so that your preferences are remembered for future sessions.

Third party cookies

In some cases, third parties may place cookies in the platform, this website, or any other services we provide. For example:

  1. Google Analytics, one of the most widespread and trusted website analytics solutions, may use cookies de-identified data about how long users spend on this site and the pages that they visit;

  2. Google AdSense, one of the most widespread and trusted website advertising solutions, may use cookies to serve more relevant advertisements across the web and limit the number of times that a particular advertisement is shown to you; and

  3. third party social media applications (e.g., Facebook, Twitter, LinkedIn, Pinterest, YouTube, Instagram, etc) may use cookies in order to facilitate various social media buttons and/or plugins in this site. Log files track actions occurring on the websites, and collect data including your IP address, browser type, internet service provider, referring/exit pages, and date/time stamps. 

Google Analytics

In the case of Google Analytics information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. 

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. 

By using the platform, you consent to the processing of data about you by Google in the manner described in Google’s Privacy Policy and for the purposes set out above. You can opt out of Google Analytics if you disable or refuse the cookie, disable JavaScript, or use the opt-out service provided by Google.

 

Interacting with Us

If you contact us with a general question, we may interact with you anonymously or through the use of pseudonyms.

However, you are required to provide true and accurate details when requesting the supply of products or provision of support services. You agree you will provide accurate information if so required.  

Sharing your Personal Information

General Disclosures

Avidity Rewards may disclose your personal information for any of the primary purposes for which it is held for or any related purpose where it is lawfully permissible.

We may disclose your personal information to:

  1. our Partners;

  2. employees, a related company and professional advisors such as our lawyers;

  3. law enforcement agencies to assist in the investigation and prevention of criminal activities;

  4. credit-reporting and fraud-checking agencies;

  5. credit providers (for credit-related purposes such as creditworthiness, credit rating, credit provision and financing);

  6. government and regulatory authorities and other organisations, as required or authorised by law;

  7. organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions; and

  8. third party contractors or service providers with whom we have a business association, including: 

    1. integration providers; 

    2. marketing service providers; 

    3. accounting service providers; and 

    4. information technology service providers including cloud application providers.

Overseas Disclosure

We may disclose your personal information third party contractors, service providers or customers with whom we have a business association.   

While we do not otherwise actively disclose your personal information to overseas entities (unless provided for in a separate agreement with you), we do engage service providers (such as cloud data services or communications providers) who may have international data centres, hardware and disaster recovery sites. Consequently, these providers may have access to your information. 

We rely solely on reputable organisations for such cloud services.


Security of your Personal Information

We store your personal information using servers which have built-in measures to combat unauthorised access, modification or disclosure.

While we endeavour to only hold personal information that is accurate, complete and up-to-date, if you become aware your information is no longer accurate, complete or up-to-date please contact us.

Disposal of personal information

If we hold personal information about you, and we do not need that information for any purpose, we will take reasonable steps to destroy or de-identify that information, in accordance with the APP, unless we are prevented from doing so by law.

You may make a request to us in writing to remove your personal information and, where permitted, we will do so in accordance with the APP.

Under Australian law, financial records, such as those relating to financial transactions, must be retained for 7 years after the transactions contemplated by those records are completed.

How to access your Personal Information

Upon your request and after satisfying ourselves of your identity, we will provide access to your personal information we hold except in certain prescribed circumstances which include, where:

  1. we believe giving access would pose a serious threat to the life, health or safety of any individual, or to public health or public safety;

  2. giving you access would be unlawful;

  3. granting that access would have an unreasonable impact on the privacy of other individuals;

  4. we would be in breach of our obligations under a Technical Assistance Notice (TAN), Technical Capability Notice (TCN) or Computer Access Warrant (CAW) from an Australian Government agency;

  5. the request for access is frivolous or vexatious; or

  6. there are anticipated legal proceedings.

We will amend any personal information about you that is held by us and that is inaccurate, incomplete or out of date if you request us to do so. If we disagree with your view about the accuracy, completeness or currency of a record of your personal information that is held by us, and you ask us to associate with that record a statement that you have a contrary view, we will take reasonable steps to do so.

 

Third Party Websites

You may click-through to third party websites from the platform, in which case we recommend that you refer to the privacy statement of the websites you visit. This Privacy Policy applies to the platform only and we assume no responsibility for the content of any third-party websites.


GDPR

We welcome the General Data Protection Regulation (GDPR) of the European Union (EU) as an important step forward in streamlining data protection globally.  Although we do not operate an establishment within the EU and do not target any offering of services towards clients in the EU specifically, we intend to comply with the data handling regime laid out in the GDPR in respect of any personal information of data subjects in the EU that we may obtain.

GDPR rights

The requirements of the GDPR are broadly similar to those set out in the Privacy Act and include the following rights:

  1. you are entitled to request details of the information that we hold about you and how we process it.  For EU residents, we will provide this information for no fee;

  2. you may also have a right to:

    1. have that information rectified or deleted;

    2. restrict our processing of that information;

    3. stop unauthorised transfers of your personal information to a third party;

    4. in some circumstances, have that information transferred to another organisation; and

    5. lodge a complaint in relation to our processing of your personal information with a local supervisory authority; and

  3. where we rely upon your consent as our legal basis for collecting and processing your data, you may withdraw that consent at any time.

If you object to the processing of your personal information, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations.  However, please be aware that:

  1. such objection or withdrawal of consent could mean that we are unable to provide our services to you, and could unduly prevent us from legitimately providing our services to other clients subject to appropriate confidentiality protections; and

  2. even after you have chosen to withdraw your consent, we may be able to continue to keep and process your personal information to the extent required or otherwise permitted by law, in particular:

    1. to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and which does not materially impact on your rights, freedoms or interests; and

    2. in exercising and defending our legal rights and meeting our legal and regulatory obligations.

Compliance with Australian Assistance and Access Legislation

In Australia, there are laws which compel companies to share data with Australian intelligence agencies and law enforcement or build in data sharing mechanisms which may report directly to these agencies. While we endeavour to protect your data and our technology from vulnerabilities wherever possible, we can’t break the law, nor can we inform you when we’ve been issued with a notice under this legislation. 

By using our platform or website, you expressly release and indemnify us from any liability to you which arises from sharing data or building data sharing mechanisms (including ‘back-doors’ and vulnerabilities) into our technology at the direction of Australian Government and its agencies, including where those mechanisms are later exploited by a third party.


Member Security

New digital threats are emerging all the time, and the online environment is more hostile than ever. To protect your data online, including any data or material transmitted by you to us, we recommend reading, implementing and observing any relevant procedures and safety tips recommended by the Department of Industry, Innovation and Science (see – https://www.business.gov.au/Risk-management/Cyber-Security) and the Australian Cyber Security Centre (see – https://www.acsc.gov.au/ and https://cyber.gov.au) from time to time.


Complaints procedure

Your privacy is important to us. If you have a complaint or concerns about our information handling processes as they relate to your personal information, we ask that you first contact our privacy officer whose contact details are listed below.

If, after we have conducted our investigations you are still not satisfied then we ask you consult with:

The Office of the Australian Information Privacy Commissioner

GPO Box 5218

Sydney NSW 2001 

Telephone: 1300 363 992 

Email: enquiries@oaic.gov.au


How to contact us

If you have any queries, questions, concerns or wish to make a complaint regarding how we deal with your personal information please contact us: 

Privacy Officer 

Afroze Hassan

Australia

Telephone: 0430 157 095

Email: afroze.hassan@avidityrewards.com.au


Amendments to this Privacy Policy

We are obligated to regularly review and update this policy. We therefore reserve the right to amend this Privacy Policy at any time. Should any significant amendments occur, notification will be provided on the website after the changes have been made. Your continued use after you receive the notification indicates your consent to be bound by the amended Privacy Policy.

For further information about privacy in general, please refer to the Office of the Australian Information Commissioner’s website located at http://www.oaic.gov.au

Alternatively, please contact our Privacy Officer using the details provided above. 

Last amendment date: 12th June 2021

 

Retain, engage, reward and recognise.

Request a quick demo and see how easy it can be to reward and retain your cohort with Avidity Rewards.

No obligation interactive demo