We have made a number of changes to our Privacy Policy – this will make it even easier for our members to access information about the flybuys programme. We have combined the privacy statement and privacy policy into one document; we have described in more detail what data we collect and why, how it is used, who we work with, and the countries where your data may be sent.

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.

By continuing to use your flybuys card or any payment card linked to your flybuys card, you are consenting to the terms of the new policy. Please read our new Privacy Policy and if you have any questions, our Privacy Officer’s contact details are included in the policy.

Overview

At flybuys, we respect the privacy of your personal information in our care. This commitment is set out here in our Privacy Policy which describes how we deal with personal information.

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 human resources team for details about the privacy of their personal information.

The flybuys program is a loyalty marketing program provided by us in collaboration with other Wesfarmers group companies (including Coles) and Participants (as defined in the flybuys Terms and Conditions).

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, 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.

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 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.

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, 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.

Coles/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 Coles/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 Coles/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 Coles/flybuys Digital Services then have limited functionality. You can control your preferences regarding Flash local stored objects at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html.

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 Coles/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 Google Analytics, Google Display Network, Google AdSense, DoubleClick, Yahoo!, Adobe Marketing Cloud, Responsys, and Microsoft. You can find more details in the individual privacy policies of those services, including information on how to opt-out of certain functions (e.g. Google’s Ads Preferences Manager),. 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 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.

Contact

Queries regarding privacy should be directed to the flybuys Privacy Officer:

Email:privacy@flybuys.com.au
Phone:13 1116
Post:PO Box 12125, A’Beckett Street
Melbourne, VIC 8006

Last updated: March 2014

Loyalty Pacific Pty Ltd (‘flybuys’)

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Phone

Call us on 131116

Monday to Friday between 9 am – 7 pm AET

Mail

PO Box 12125, A'Beckett Street
Melbourne, VIC 8006

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