PRIVACY POLICY

Introduction

iProximity Pty Ltd (we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This includes existing and prospective customers of our clients, potential and existing employees and contractors from whom iProximity collects personal information or is provided such information by our clients.

This document is our privacy policy and it tells you how we collect and manage your personal information.

We respect your rights to privacy under the Australian Privacy Act 1988 (Cth) (Act) and we comply with all of the Act’s requirements in respect of the collection, use, management, disclosure, quality, security, access, and correction of your personal information.

What is your personal information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Act. In general terms, this is any information that can be used to personally identify you. This may include your name, address, telephone number, email address, credit card details, account number, and profession or occupation. If the information can identify you, it will be considered personal information.

What personal information do we collect and hold?

We may collect the following types of personal information:

• name, mailing or street address;
• email address and telephone and facsimile number;
• age or birth date;
• system access passwords;
• profession, occupation or job title;
• details of products and services you have purchased or enquired about;
• credit card details;
• details of your credit worthiness and credit history;
• account password and app usage information for our APP, iProximity Enabled;
• any additional information that you provide us directly or indirectly;
• information collected through customer surveys or visits by our representatives.

Privacy Policy

It is important to appreciate that much of the personal information we collect and hold is done when we act as the “agent” or service provider for our customers. For example, we operate proximity-marketing services on behalf of various companies. When you interact with our iProximity Enabled App or with any of our customers’ APPs, you may not be aware that we are operating on behalf of our customer. We have set out in the Annexure to this policy some more detail around the information we may collect and hold.

How do we collect your personal information?

Personal information is collected only by lawful and fair means in accordance with the Act. We collect your personal information directly from you, including through:

• your access and use of our websites;
• our Apps or third-party Apps that feature our Software Development Kit (SDK);
• telephone communications;
• conversations with our representatives;
• correspondence with our representatives;
• completion of applications, contracts or purchase orders.

We may also collect your personal information through the use of cookies, which help us recognize your computer or device and enhance your experience.

What happens if we can’t collect your personal information?

If you do not provide us with the required personal information, we may not be able to:

• give you access to the iProximity Enabled App;
• provide the requested products or services;
• tailor website content to your preferences;
• provide our clients with the services they require.

For what purposes do we collect, hold, use and disclose your personal information?

We collect personal information to perform our business activities and provide quality services. This includes:

• providing our products and services;
• answering enquiries about products or services;
• administering competitions or promotions;
• conducting business processing functions;
• assessing and providing credit;
• direct marketing in accordance with marketing laws;
• updating contact details and responding to complaints.

To whom may we disclose your information?

We may disclose your personal information to:

• employees, clients, contractors, or service providers for business operations;
• suppliers and third parties for marketing and related purposes;
• any organisation for any authorized purpose with your express consent.

How can you access and correct your personal information?

You may request access to any personal information we hold about you. We may charge a fee to cover our administrative costs in providing that information, typically $30 per hour.

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us with details of the incident so we can investigate it.

Do we disclose your personal information to anyone outside Australia?

We may disclose personal information to overseas suppliers and service providers. We take reasonable steps to ensure that the overseas recipients do not breach the privacy obligations.

Security

We take reasonable steps to protect your personal information from misuse or loss. We cannot guarantee the security of information transmitted online.

iProximity Enabled App

If you use our iProximity Enabled App:

1. Linking to social media may make your account name, username, and display image public.
2. Your comments and uploads become public information.
3. Even after cancelling your account, your content may remain available.

Links

Our website or communications may include links to third-party websites. We are not responsible for their privacy practices, and they are responsible for informing you about their practices.

Contacting us

If you have questions or concerns about this policy, please contact our Privacy Officer at iProximity Pty Ltd, PO. BOX 169 Elwood, Victoria Australia 3184, Phone: 1300 477 694, Email: privacy@iProximity.net.

Changes to our privacy policy

We may update this privacy policy periodically, and any changes will be posted on our website. This privacy policy was last updated on 20 March 2014.

ANNEXURE

Specific examples of Personal Information held by iProximity