Privacy Policy - Purposes for handling Personal Information

Submitted by Ben on Thu, 10/28/2021 - 16:25
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5.1 Registration and use of the Flybuys loyalty program

We handle your Personal Information in connection with providing, administering, improving and personalising the Flybuys program, Flybuys products and services, and those provided by Participants, Coles, and Wesfarmers group companies. This can include:

  • to register and service your membership account, including keeping your information up-to-date, and verifying your identity;
  • to communicate with you about our and our Participants’ products, services and promotions (including via direct marketing as described below);
  • to help us and our Participants improve our products and services, including conducting product and market research;
  • to improve our understanding of your interests and behaviour in relation to products, services, and offers;
  • to improve our operational processes to enhance your customer experience;
  • to respond to your feedback, queries or concerns; or
  • investigative, fraud and loss prevention activities.

 

5.2 Offers and marketing communications

We may provide offers, marketing communications and targeted advertising to you on an ongoing basis by telephone, electronic messages (e.g. email), websites, social media and other Online Channels, and by other means. These communications may relate to the products and services we, Participants, Coles, and Wesfarmers group companies provide, and other products which we think may be of interest to you.

If you have purchased a product or service from a Participant and scanned your Flybuys card, that Participant may also provide you with offers and marketing communications, including by email or other form of electronic messages.  These communications may relate to products or services that the Participant provides and which the Participant thinks may be of interest to you.

You can call us on 13 11 16 or login to your Flybuys account at flybuys.com.au at any time to opt out of electronic and telephone direct marketing communications from us. You can also use the unsubscribe facility provided in Flybuys electronic marketing communications. 

If you elect to opt out, you will still receive service based communications relating to your Flybuys membership and account, as well as other information that we are required to send you by law, such as changes to our terms and conditions and notifications relating to your transactions and rewards purchases.

To opt-out of any marketing communications received from Participants, you can use the unsubscribe facility provided in the Participant’s electronic marketing communication.  

 

5.3 When you interact with us online

You may interact with us, Participants, Coles or Wesfarmers group companies, our service providers or our other business partners through a range of digital and online channels, including:

  • websites (e.g. flybuys.com.au or the websites of Participants);
  • apps;
  • email;
  • online advertisements;
  • IPTV; and
  • social media profiles,

(“Online Channels”).

We may collect and handle your Personal Information and other data collected via these Online Channels for a range of purposes, including to provide a consistent experience, personalise your use of each of those Online Channels and to provide targeted marketing.

Some of the information we collect from these Online Channels is not related to an individual. In many cases, the information relates only to a device or is of an aggregated or statistical nature, and we will have no way of knowing the identity of the user. In other cases, we may associate information about your use of Online Channels over time with your Personal Information, for example, when you have logged in to your Flybuys account or followed a link sent to you by email.

How we use cookies and anonymous identifiers

We may use cookies and other technologies to track your access to and use of Online Channels, and to customise and improve your interactions with them. Examples of how we use cookies and other technologies include: 

  • to maintain the continuity of your browsing session (e.g. to remember the items in your shopping cart); 
  • to remember your details and preferences when you return; 
  • to record information about your interactions with the Online Channels including information about software versions used, device types, device identifiers (like IP address), location data (where available and not disabled by the user), dates, times, file metadata, referring website, data entered, and user activity (such as links clicked).

Some of these cookies and other technologies are consistent across various Online Channels, allowing us and the other providers of those Online Channels to understand you better and provide a more consistent experience across those Online Channels. 

Third party cookies and data collection

In some cases, we may receive data from our service providers which is collected via first party cookies, third party cookies and other technologies used on the Online Channels. We may use this data in connection with activities like managing, administering and expanding the Flybuys program, surveys, targeted advertising, website analytics, and email campaign management. 

The data received by these first party, third party cookies and other technologies that are used on Online Channels, is collected directly by the relevant third parties and is subject to the individual privacy policies of those third parties. 

Controlling and deleting cookies

You can configure your web browser to reject and delete cookies and block JavaScript, but you may find some parts of the Online Channels (including the Flybuys website) are not accessible or have limited functionality. You can control your preferences regarding Flash local stored objects at Flash player help - Website Storage Settings panel.

Depending on your device, within the Flybuys app you may be given an option of allowing Flybuys to track your online activity across that application as well as other company’s applications and websites.  If you indicate that you do not wish to be tracked, then Flybuys will remove tracking technologies from your Flybuys app.

 

5.4 Third party targeted advertising

Flybuys may provide your personal information to certain third party media, technology and advertising companies so those parties can provide targeted offers and digital advertising to you.  In addition, Flybuys may also share your personal information with Coles who may on-provide it to third party media, technology and advertising companies so those parties can then provide offers and targeted digital advertising. This enables you to receive more personalised and targeted advertising when you use our business partners’ websites, social media and other platforms operated by these third party media, technology and advertising companies

Flybuys also provides partners and advertisers with anonymised analysis, reporting and insight services related to their use of Flybuys data for advertising. 

We may receive cookie data, device information or other anonymous identifier information from our partners to enable us to provide these services. In some cases, Flybuys may be able to connect this data back to individual Flybuys members, meaning that we will handle this data as Personal Information in accordance with this Privacy Policy. We do not retain or store this data for longer than is necessary for us to provide services to our partners and advertisers, and we do not use this data for any other purpose. 

How to opt out of targeted advertising

The third party platforms that use Flybuys aggregated audience segments include those offered by Google, Adobe, LiveRamp, Pinterest, Tiktok, and Meta

You can find information on how to opt out of receiving targeted advertising on these platforms by reading the individual privacy policies of those platforms. You may need to opt out separately from each platform. The website https://www.youronlinechoices.com/ie/your-ad-choices also allows you to opt out of some online targeted advertising and provides further information about how online targeted advertising works. 

You can call us on 13 11 16 or login to your Flybuys account at flybuys.com.au or on the Flybuys app at any time to opt out of Flybuys sharing your personal information with third party platforms for the purpose of targeted advertising.

If you elect to opt out, this preference may be passed to Coles for use in the Unpacked business for targeted advertising as detailed in their privacy policy.

5.5 Regulatory purposes and to facilitate our corporate activities

We may also handle your Personal Information: 

  • to protect our lawful interests and facilitate purchases and potential purchases of our businesses; 
  • to comply with any request for information made by a regulator, court, government entity, health department or contact tracing agency (including any requests to provide information for COVID-19 contact tracing); or
  • as otherwise permitted or required by law.
     

 

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Purposes for handling Personal Information