Privacy Policy – Giftbee Australia Pty Ltd

This Privacy Policy applies to Giftbee Australia Pty Ltd ACN 673 340 719 and its related bodies corporate (as that term is defined in the Corporations Act 2001 (Cth) (Giftbee, we, us, our) when we collect personal information about you.  

Giftbee provides a digital platform at www.giftbee.com (Website) that supplies gift tokens (Tokens) that can be:  

• spent on branded digital gift cards or specific products;
• swapped to another branded digital gift card or a specific product;
• gifted to another person; or  
• donated to charity,  

(Token Services).  

We provide Token Services directly to individuals and to corporate clients for their customer and employee incentive and loyalty programs.  

We are committed to maintaining the privacy of your personal information. We have developed this Privacy Policy to inform you of how we manage the personal information that we collect about you.

You are under no obligation to provide us with your personal information, but if you do not, we may not be able to provide you with the products, services or information you have requested, or any of our information, services or products.  

By providing personal information to us or by visiting our Website you are taken to have read this Privacy Policy, and consent to the collection, use, disclosure and handling of your personal (including sensitive) information in accordance with this Privacy Policy.  

How we collect your personal information

In this Privacy Policy, personal information has the meaning given to that term in the Privacy Act 1988 (Cth) (Privacy Act) and includes information or an opinion (whether true or not) about an identified individual, or an individual who is reasonably identifiable.  

In general, we collect personal information:  

• directly from individuals who acquire Token Services;
• about individuals where a person purchases a Token for the purpose of gifting that Token to the individual;
• about individuals from our corporate customers who acquire Token Services;
• about suppliers, contractors and consultants to Giftbee;
• about individuals who enquire about our services for the purposes of:  

• using Token Services;  
• purchasing Token Services; or  
• wishing to join the program as a participating brand; and  

• any person who applies to become an employee or contractor of Giftbee.  

We aim to collect personal information only if it is reasonably necessary to provide Token Services, products or information you have requested from us.  

In the course of providing you with services, we collect personal information in a variety of ways. Unless it is unreasonable or impracticable to do so, we collect your personal information from you directly. In some cases however, we will collect information about you from a third party. For example, if you are an employee or a customer of one of our corporate clients to whom we provide Token Services we may collect your personal information from our client.  

At the time of collection, or as soon as practicable after we have collected it, we will take such steps as are reasonable in the circumstances to notify or make you aware of the collection and of any matters relevant to the collection, unless it is obvious from the circumstances that you would know or would expect us to have the information.

Giftbee may collect personal information about you when you:

• create an account on our Website;
• acquire Token Services via our Website;
• are gifted or issued with a Token by a third party (including one of our corporate customers);
• make an enquiry with us by phone, email or on our Website;
• engage with us in the course of receiving Token Services or other products, services or information from us or enquiring about our services, information and products;
• redeem your token and request physical product to be delivered to your designated address;
• visit our Website;  
• subscribe to receive newsletters or information from Giftbee;
• apply as a candidate for a position of employment with us; and  
• supply goods or services to us.

What kind of personal information we collect about you

The types of personal information that we collect from you will depend on your interactions with us, what you share with us or whether the law requires us to collect it.  

For example, we may collect the following information about you:

• your name;  
• your email address, phone number, address and other contact details;
• your internet protocol (IP) address, unique device identifiers, device model and name, operating system;  
• date of birth and gender;  
• details of Token Services or other products or services we have provided to you or the products or services that you have acquired or donated to using Tokens or otherwise enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;  
• details about you to assist in managing our relationship with you and providing you with Token  Services including behavioural and statistical information;  
• your financial information such as bank or credit card details; and
• your geolocation information.  

If you are a prospective employee, we may collect details about your employment history and other details about you to assist with the recruitment process. We may collect this information from you directly, or from a recruiter.  

Information collected on our Website

We may use cookies when you access our Website.  This allows us to recognise your browser, IP address and track the web pages you have visited. Some of these cookies also help improve your user experience on our Website, assist with navigation and your ability to provide feedback and assist with our promotional and marketing efforts. It is generally not possible to identify you personally from our use of cookies. You can switch off cookies by adjusting the settings on your web browser  

Use and Disclosure of Personal Information

We collect your personal information primarily to:

• provide Token Services to you, your employees or your customers;
• enable you to use and access Tokens and Token Services;
• communicate with you generally in relation to our services and products;
• promote, advertise and market Token Services, including to invite you to events or activities hosted by Giftbee or third parties;
• communicate with you about research opportunities relating to our products and services;
• help us manage our products and services;

• provide you with information or advice;  
• process payments by or to you in connection with Token Services;  
• create accounts, tax invoices and/or receipts;  
• provide your information to third parties retailers so that they can supply digital gift cards or products to you;
• inform you of developments at Giftbee and other services, products or information that we can provide;
• consider and respond to complaints made by you; and
• otherwise manage our relationship with you.

If it is reasonable to expect that we would use or disclose your personal information for purposes which are related to the above primary purposes, we may also use or disclose your personal information to:

• assist you with enquiries or complaints;  
• investigate and prevent fraudulent transactions and other illegal activities;
• to send notifications regarding important changes to the Website;
• comply with our legal obligations (including to comply with any law or any lawful request of a law enforcement agency or government authority) or resolve any disputes.

We may use your personal information in de-identified form to assist us in running our business. We may also provide, including by way of sale, de-identified information in aggregated form, to third parties.

Generally, we will not direct market to anyone unless they are given an opportunity to opt out of receiving future direct marketing communications. However, if we contact you for the purpose of direct marketing without having obtained your consent first because it is impracticable for us to do so, we will at that time provide you with the opportunity to decline receiving any further marketing communications from us.  

Sharing of your personal information

We may disclose your personal information to organisations or people outside of our business for the purposes of assisting us to run our business and to provide Token Services to you.  

The third parties to whom we may disclose your personal information include:

• external providers of services that we may use to operate our business and manage our business systems (database, CRM and mail and email service providers, marketing and e-commerce service providers, couriers, providers of accounting and payment processing services) and IT technicians who may need access when providing support and other professional service providers as required from time to time;  
• parties to whom you gift a Token as part of the Token Services;
• retailers with whom you can redeem Tokens as part of the Token Services;  

• charities with whom can you donate Tokens as part of the Token Services;
• third parties that may provide or assist us with events or services at Giftbee;
• if you are an employee of one of our corporate customers, retailers, contractors or suppliers, we may also disclose your personal information to your employer; and
• our professional advisors and agents.

The privacy and collection practices of entities to whom we disclose personal information are governed by their own privacy policies and collection notices.

We may disclose your personal information to our employees located in India and Belgium.  

We will not otherwise disclose information about you unless the disclosure:

• is required or authorised by law; or
• you have consented to our disclosing the information about you.

Security of Personal Information

We will take reasonable precautions to protect your information from misuse, interference and loss, as well as from unauthorised access, modification or disclosure.  

We will retain your information as required by law, and then take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.  

Quality of Personal Information and Accessing and Updating Information

We aim to ensure the personal information that we hold about you is accurate, complete and up to date, but we need your help with this. You need to provide true, accurate, current and complete information about yourself as requested and properly update the information with us to keep it true, accurate, current and complete.  

If you believe that the information we hold about you is inaccurate or incomplete, please contact us at the details below and we will use all reasonable efforts to correct the information.  

If we do not believe the information to be incorrect, we will take reasonable steps to add a statement to the information noting that you believe the information is inaccurate, incomplete, out of date.  

You have rights to access your personal information held by us subject to the provisions of the Privacy Act. If you would like more information about this, please contact us at the details below. 

Changes to this Privacy Policy

We reserve the right to make amendments to this Privacy Policy at any time for any reason. We will publish any updated Privacy Policy on our Website.  

Change in control of Giftbee

If we sell or otherwise transfer part or the whole of our business to another organisation (including in the course of a transaction like a restructure, sale, merger or acquisition or as part of a bankruptcy, dissolution, liquidation, administration, receivership or other form of insolvency), you agree that your personal information that is collected by Giftbee may be disclosed to a third party, prospective buyer, transferee or insolvency practitioner and that this is reasonable to enable that party to continue or manage the business.

Complaints

If you have a complaint about our collection, use or disclosure of your personal information, or you wish to make a complaint about a breach of the APPs, please contact us at the details set out below.  

In your complaint, please set out the details of your complaint and your contact details. We will contact you to acknowledge your request and ask for any other applicable information. We will then investigate the issue and advise you in writing of the outcome.  

You can also make a complaint to the Office of the Australian Information Commissioner. Further information is available at www.oaic.gov.au.

Marketing

When you make a purchase, register to hold an account with Giftbee or receive a Token, we may send you commercial electronic messages and tailored advertising via various channels with your consent.

You can opt out of receiving such notifications by unsubscribing to such content.  

Opting out of such notifications on one specific channel (such as email) will not cease notifications from any other channels (such as sms).  

If you do not consent to marketing messages, you will still receive information that Giftbee is required by law to provide to you or service based communications.

Connecting via a social network

You may be able to access our Website by signing into social networks. These platforms provide the option of posting and sharing information with others within your social network. If you stop using the network from which you have signed in to use the service, you agree that we will still retain the personally identifiable information from the social network that you provided us access to in accordance with this policy.  

Social media features may also collect your IP address and set a cookie to enable the feature to function properly. Your interaction with these features is under the privacy policy of the company providing them.

How to update and/or access your information

You can update your information by contacting us with the contact details below. You may be asked to verify your identity to ensure that the personal information we hold is not improperly accessed.  

Deleting your account or personal data

Please contact us if you want us to delete any personal information we hold about you. Customers who delete their account while still having Tokens attached to their account will forfeit any money attached as Tokens cannot be converted to cash. Giftbee will use its reasonable endeavours to delete your personal information on request within 1 business day of the written request.

Contacting us

If you have any questions about this Privacy Policy or our privacy practices, would like to make a complaint or request access to or correction of your personal information, please contact us using the following details:

• Attention: Privacy Officer
• by email at support@giftbee.com.au
• by phone on 0449 923 551

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Collection Notice – Giftbee Australia Pty Ltd

This Collection Notice applies to Giftbee Australia Pty Ltd ACN 673 340 719 (Giftbee, we, us, our) when we collect personal information about you.

You are under no obligation to provide us with your personal information, but if you do not, we may not be able to provide you with the information you have requested, or any of our services or products. By providing your personal information to us, you consent to the collection, use, storage and disclosure of that information as described in our Privacy Policy available at www.giftbee.com (Privacy Policy) and this Collection Notice.

In some circumstances we may collect personal information about you from a third party. Those third parties and the circumstances in which we collect your personal information from third parties is set out in our Privacy Policy.

1. Purpose of Collection

We collect your personal information primarily to:

• provide our services, products and information to you;
• communicate with you generally in relation to our services and products;
• help us manage our products and services; and
• otherwise manage our relationship with you,

and for purposes otherwise set out in our Privacy Policy.

2. Sharing of your personal information

The information you provide may be disclosed to third parties that we may use to operate our business and help us provide our products and services to you and to other third parties that are described in our Privacy Policy.  

We may disclose your personal information to organisations or people overseas in India and Belgium to assist us to run our business and provide Token Services to you, as outlined in our Privacy Policy.  

3. Privacy Policy

Our Privacy Policy contains information about how you may access the personal information that we hold about you, seek correction of such information if you believe it to be incorrect, how you may complain about a breach of Giftbee’s privacy obligations and how we will deal with such a complaint.

4. Contact Us

Our contact details in respect of any issues in relation to privacy are:

• by email at support@giftbee.com; or
• by phone on 0449 923 551

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