flybuys does not sell personal data. In order to operate the programme, we share personal data with some trusted operational suppliers and participants in the programme. Again, these companies do not sell your personal data and they are contractually prevented from doing so. Further, all companies with whom we share data can use the data only for these contractually agreed purposes and must handle the data in a confidential and secure manner in accordance with Australian privacy legislation. Currently, we have two suppliers who operate specialist services for us who are located in the USA and South Africa.
Types of personal information collected
The types of personal information we collect include name, contact details, identification information, household details, payment and transaction details/history (including information about payment cards linked to flybuys and associated transactions), points accrual and reward details, authorisations, ages of family members, records of your communications and interactions with us and the flybuys program, and details/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 awards for points, manage your membership, or contact you.
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, 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; 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 Participants, public sources, information service providers, providers who administer Coles-branded products and services such as payment cards and insurance, anyone authorised to act on your behalf, and other Wesfarmers 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. 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 and Wesfarmers group companies. This can include processing payments, delivering orders, managing promotions, providing refunds and discounts, verifying your identity, communicating with you (including direct marketing), conducting product and market research, maintaining and updating our records, dealing with enquiries from you, and working with our service providers. Using personal information, we endeavour to improve our understanding of your interests, suitability, and behaviour in relation to products, services, and offers, including risk assessments for financial products (including credit and insurance).
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 (for example, email), through our digital services, and by other means. These communications may relate to the products and services we, Participants and other 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.
Sharing of personal information
To make it easy for you to deal with Participants and other Wesfarmers group companies (including Coles) and provide you with a more personal and consistent experience, we may exchange and combine personal information with them for the purposes described in our respective privacy policies.
We and Wesfarmers group companies may exchange your personal information with service providers engaged to assist with services including data processing, data analysis, information broking, credit reporting, online computing, printing, contact centre, legal, accounting, business consulting, marketing, research, auditing, archival, delivery, security, investigation, and mailing services, and in the provision of Coles-branded products and services such as payment cards and insurance.
The third parties to whom we disclose personal information may be located in Australia and other countries including South Africa and the United States of America. We take steps to ensure that all our service providers agree to protect the privacy and security of your personal information, and use it only for the purpose for which it is disclosed.
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, Participants or other Wesfarmers group companies (collectively, Coles/flybuys Digital Services) to provide a consistent experience, personalise your use of each of those services and provide targeted marketing.
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.
Some information we collect in relation to Coles/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 Coles/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, correction, and feedback
If you wish to access or correct any personal information we hold about you or have any feedback or concerns about privacy, please contact us as set out below. Where you seek a response from us, we will let you know who will be handling your matter and when you can expect a full response. In the case of access and correction requests, 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 our reasons if we refuse your request. Where we decide not to make a requested correction and you disagree, you may ask us to make a note of your requested correction with the information.
Queries regarding privacy should be directed to the flybuys Privacy Officer:
|Post:||PO Box 12125, A’Beckett Street|
Melbourne, VIC 8006
Last updated: March 2014
Loyalty Pacific Pty Ltd (‘flybuys’)