- Overview
At flybuys (“Loyalty Pacific Pty Ltd”), we respect the privacy of Personal Information in our care. This commitment is set out here in our Privacy Policy which describes how we deal with Personal Information. Personal Information means information which identifies you as an individual or from which you can be reasonably identified.
This Privacy Policy relates to Personal Information we collect and handle about flybuys members and visitors to our website, apps, social media and other digital services, including those of our Participants. Our personnel and job applicants should contact our People and Sustainability team for details about the privacy of their Personal Information.
The flybuys program is a loyalty marketing program provided by us in collaboration with Coles, Wesfarmers and other Participants (as defined in the flybuys Terms and Conditions). ‘Participants’ refers to those companies (and other persons) which have agreed with us to issue points to flybuys members under the flybuys program and/or provide rewards in exchange for points. flybuys is not responsible for the privacy practices or policies of Coles, Wesfarmers, and other Participants, and we recommend that you visit their websites for more information about their privacy practices and policies.
If you do not agree to the terms of this Privacy Policy you may terminate your flybuys membership at any time.
- Types of Personal Information Collected
The types of personal information we collect include:
- Name;
- Contact Details (e.g. address);
- Identification information (e.g. date of birth);
- Household details (e.g. the number of people living at a household and their ages);
- Payment and transaction details/history (including information about payment cards linked to flybuys and associated transactions);
- Points accrual and reward details;
- Authorisations;
- Records of your communications and interactions with us and the flybuys program; and
- Details and history of preferences, interests and behaviour relating to transactions, products, services, and activity with our digital services.
We may not be able to provide our services without your personal information. For example, we may not be able to issue points, let you redeem points for awards, manage your membership, or contact you.
Where you provide us with Personal Information about someone else you must have their consent to provide their Personal Information to us based on this Privacy Policy.
- How Personal Information is collected and held
We may collect your personal information, and that of additional members, from your interactions and transactions with us, Participants, Coles and Wesfarmers group companies. This includes:
- Using your flybuys card or number or associated identifiers such as payment cards;
- Making a purchase in store;
- Placing an order online;
- Making a non-cash payment;
- Participating in a promotion, competition, or survey;
- Registering for services; including services provided by Participants, and
- Using related digital services.
We may monitor and record your communications with us (including email and telephone) for security, dispute resolution, and training purposes. We may also collect personal information from third parties including:
- Public sources;
- Information service providers (e.g. for data integrity purposes);
- Providers who administer Coles-branded products and services such as payment cards and insurance;
- Anyone authorised to act on your behalf; and
- Participants, Coles and Westfarmers group companies.
We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers. We implement a range of measures to protect the security of that personal information. Examples of these measures include:
- Access to Personal information is controlled through Identity and access management systems;
- Team members are bound by internal information security policies and are required to keep Personal Information secure at all times;
- We take steps to protect Personal Information in accordance with the Office of the Australian Information Commissioner’s Guide to securing personal information;and
- We also take measures in respect of destroying or de-identifying Personal Information that is no longer needed for any lawful purpose.
- Purposes for handling Personal Information
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 products, services and promotions (including direct marketing);
- To help us improve our products and services, including conducting product and market research;
- To improve our operational processes to enhance your customer experience;
- To respond to your feedback, queries or concerns;
- Working with our service providers;
- Investigative, fraud and loss prevention activities;
- Interacting with Regulators and relevant government entities;
- Any of our related companies and brands including the Coles and Wesfarmers group companies; and
- As otherwise required or permitted by law.
Using Personal Information, we endeavour to improve our understanding of your interests, suitability, and behaviour in relation to products, services, and offers.
We may also handle your Personal Information to protect our lawful interests and facilitate purchases and potential purchases of our businesses.
We may provide marketing communications and targeted advertising to you on an ongoing basis by telephone, electronic messages (e.g. email), through our digital services, 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 may be of interest to you. You can call us on 131116 or login to your flybuys account at flybuys.com.au at any time to opt out of electronic and telephone direct marketing communications. We need to be able to contact you by post to manage your membership. If you do not want us to send you any postal communications, you may terminate your flybuys membership.
Where you provide us with Personal Information about someone else, you must have their consent to provide their Personal Information to us based on this Privacy Policy.
- Sharing of Personal Information
To make it easy for you to deal with Participants, including Coles, and Wesfarmers group companies, we may exchange and combine Personal Information with them for the purposes described in our respective privacy policies. You can find their privacy policies of their respective company websites.
flybuys may exchange your Personal Information with service providers engaged to assist with services including, working with a number of suppliers that carry out specific functions on our behalf, and include companies that assist us with:
- Technology services including application, development and technical support, processing, storing, hosting,and analysing data;
- Processing Payments;
- Communicating our offers and promotions to you;
- Product development and market research;
- Administrative services, including mailing services, printing, archival, and contact management services.;
The third parties to whom we disclose Personal Information may be located in Australia and other countries including South Africa, the Philippines, and the United States of America. We take steps to ensure that all our service providers are obliged to protect the privacy and security of your Personal Information in accordance with the standards that apply in Australia including that they only use Personal Information for the purpose for which it is disclosed.
- Digital services
We provide information and services through a range of digital and online services, including:
- Websites (e.g. flybuys.com.au);
- Apps;
- Email;
- Online advertisements;
- IPTV; and
- Social media profiles.
These services may be operated by us as flybuys Digital Services to provide a consistent experience, personalise your use of each of those services and provide targeted marketing.
flybuys Digital Services may use “cookies”. A cookie is a piece of information which allows the server to identify and interact more effectively with your device. The cookie assists us in maintaining the continuity of your browsing session (e.g. to maintain a shopping cart) and remembering your details and preferences when you return. Other technologies that may be used with flybuys Digital Services include web beacons (which may operate in conjunction with cookies), Flash local stored objects, and JavaScript. Some of these cookies and other technologies are consistent across various flybuys Digital Services, allowing us and the other providers of these services to understand you better and provide a more consistent experience across these services. You can configure your web browser to reject and delete cookies and block JavaScript, but you may find some parts of flybuys Digital Services then have limited functionality. You can control your preferences regarding Flash local stored objects at Flash player help - Website Storage Settings panel.
Our systems record a variety of information in relation to interactions with our online services. This can include 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.
In some cases, third parties may use cookies and other technologies, such as those described above, as part of flybuys Digital Services. These technologies may be used in connection with activities like surveys, online behavioural advertising, website analytics, and email campaign management. The services we may use from time to time include those offered by Google (including Analytics, Display Network, AdSense, and DoubleClick), Yahoo!, Adobe (including Marketing Cloud, and Analytics), Responsys, Microsoft, and Signal Digital, Inc. You can find more details in the individual privacy policies of those services, including information on how to opt-out of certain functions. You may need to opt out separately from each service. The website youronlinechoices.com.au also allows you to opt out of some online behavioural advertising and provides further information about how online behavioural advertising works. You can contact us to request further details of the services we use. Many of these services operate without collecting or using any Personal Information.
Some information we collect in relation to flybuys Digital Services 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 flybuys Digital Services over time with your Personal Information, for example, when on any occasion you have logged in, followed a link sent to you by email, or we have otherwise been able to identify you.
Our online services may contain links to other sites. We are not responsible for the privacy practices or policies of those sites and recommend that you review their privacy policies.
- Procedures for access and correction of your Personal Information
If you wish to access or correct any personal information we hold about you, please contact us as set out below.
When making an access request, please provide as much detail as you can about the particular information you seek in order to help us retrieve it. Under the Privacy Act and other relevant laws, we are required to provide a written response outlining our reasons if we refuse your request.
Where we decide not to make a requested correction and you disagree, you may ask us to add a note of your requested correction to the information that explains your correction request.
- Questions and complaints
If you have any complaints or concerns about this Policy, or our handling of your Personal Information, you can contact us as set out below.
Once a complaint or concern has been lodged, we will let you know who will be handling your matter and when you can expect a full response within 30 days. If you are not satisfied with our response, please let us know and we will investigate further and respond to you.
Complaints should be directed to us in the first instance. If you are still not satisfied, you can contact the Office of the Australian Information Commissioner, whose contact details are set out below.
Contact us
Queries regarding privacy should be directed to the flybuys Privacy Officer:
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13 11 16 - Monday to Friday, 9am-7pm AEST, excluding national public holidays |
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PO Box 12125, A’Beckett Street |
The flybuys Privacy Policy can be found on www.flybuys.com.au or by calling our flybuys Service Centre on 13 11 16 Monday to Friday between 9.00am and 7.00pm AEST (excluding public holidays).
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Office of the Australian Information Commissioner |
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GPO Box 5218, Sydney NSW 2001 |
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- Additional Privacy Information
In addition to this Privacy Policy, our Participants, Coles, and Wesfarmers group companies have their own privacy statements and other terms which provide further information about the handling of your Personal Information that has been shared with these third parties. We are not responsible for the privacy practices or policies of these third parties and recommend that you review their respective privacy policies.
For information about privacy generally, you may contact the Office of the Australian Information Commissioner on the contact details noted above.