1. Our commitment to privacy

QWest Rewards Australia Pty Ltd (ACN 684 428 439), its subsidiaries and affiliates in Australia (collectively QWest Rewards, we, us, our) is committed to protecting your personal information in accordance with this Privacy Policy.

This Privacy Policy sets out how and why we use your personal information when you access and use our website, services and/or otherwise communicate and engage with us (our Services) in accordance with the Privacy Act 2001 (Commonwealth) (Privacy Act).  It also explains certain legal rights that you have under privacy and data protection laws.

Please read this Privacy Policy along with our Terms and Conditions.  Capitalised terms not defined in this Privacy Policy have the meaning set out in our Terms and Conditions.

This Privacy Policy applies to our websites, social media accounts and communications only, and does not apply to any third-party websites, plug-ins or applications that are linked to in the Services. Third-party websites may be governed by their own terms and conditions and privacy practices.  We will not be liable for the privacy practices of any third parties.  Your use of third-party websites is at your own risk.

If you have any questions about this Privacy Policy, you are welcome to contact us through the details in paragraph 11.

2. Collection of personal information

• What personal information we collect

We may collect and hold the following types of personal information:

1. Contact information: name, address, email address, phone number, and other similar contact details.
2. Identifying information: date of birth, driver’s licence number or other identification numbers.
3. Financial information: We use a third-party payment provider, Stripe, to collect and process credit card, billing and bank information.  This information is held by and managed by the third-party payment provider and the relevant bank, held on the third-party payment provider or bank servers and systems and is not held, collected or controlled by us.  You must ensure that you agree to Stripe’s terms and conditions and policies before using their payment system, including via the Services.
4. Transaction Information: Information related to purchases, orders, or services requested, activity details of any purchases, preferences, interactions and details of your communications with us.
5. Usage Information: Information about how you use our website, products, and services.
6. Other Information: Any other information you voluntarily provide to us.

• How we collect personal information

We may collect and hold personal information in the following ways:

1. directly from you, when you provide it to us, including where you contact us, enquire about our Services, sign up for our mailing list, post a review or rating, attend our events, register for an account with us, make a purchase or otherwise use our Services;
2. automatically through use of cookies, which is a small data file transferred to your device by websites for the purposes of Service functionality and to provide more relevant information to users of the Services, which you can disable via your browser preferences – this may affect functionality of our Services;
3. automatically through use of tracking technologies and analytics tools;
4. from third parties, such as third-party background screening providers, Government websites, registers and authorities, service providers, business partners;
5. if you attend an event with, managed, delivered or held by us, we may take images or audio-visual records which identify you; and
6. from publicly available sources, including social media platforms.

1. Anonymity

Where possible, you may contact us anonymously or using a pseudonym, such as if you call us with a general enquiry or email, however for the function of most of our Services, you will need to provide true and accurate contact details. If we do not collect personal information about you, you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.

• Analytics

This website may collect personal data to power our site analytics, including:

1. information about your browser, network, and device;
2. web pages you visited prior to coming to this website; and
3. your IP address.

This information may also include details about your use of this website, including: clicks, internal links, pages visited, scrolling, searches and timestamps.

1. Cookies

The Services use cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app.

You can use the settings in your browser to control how your browser deals with cookies. However, in doing so, you may be unable to access certain pages or content on our website.

3. Purposes for collecting, holding and using Personal Information

• Purposes

We collect personal information reasonably necessary to carry out our business, to assess and manage our user’s needs, and to provide our Services. We may also collect information to fulfil administrative functions associated with these services, for example billing.

We may use personal information for the following purposes:

1. providing the Services, products or information requested by you;
2. processing transactions, registering and managing your account;
3. communicating with you, including responding to enquiries and providing support;
4. sending promotional materials, newsletters, and other marketing communications;
5. planning, managing, advertising and administering programs, events, trade promotions and competitions;
6. improving our Services and products, services, facilities and website and enhancing your user experience, including tracking usage and behaviour of our Services to improve functionality and user experience;
7. for identification or verification purposes, including to comply with our legal obligations and to prevent fraud, money laundering and terrorism;
8. recruitment purposes, if you applied for a job with us;
9. to manage and work with our service providers;
10. conducting research and analysis to enhance our business operations, including for the purpose of improving customer satisfaction, tailor products and promotional offers to you;
11. to conduct investigative, fraud and scam prevention activities;
12. complying with legal obligations, requests from Governmental or regulatory bodies and agencies, and protecting our rights and interests; and
13. other purposes as expressly provided at the time of collection or which are authorised under law, for which you have provided consent.

If we do not collect the aforementioned personal information, we may not be able to perform our Services, purposes or related functions.

In general, the legal ground for which we collect your personal information is for the legitimate purpose of offering, providing and/or tailoring our Services to, and otherwise engage and communicate with you. 

• Direct marketing

You expressly consent to our use of your personal information, except sensitive information within the meaning set out in the Privacy Act, for direct marketing purposes and for us to contact you for the purposes of direct marketing, including future trade promotions.  We may contact you in a variety of ways, including by email, phone in accordance with relevant laws, social media, mail, SMS, MMS and telephone.

You may opt-out of receiving marketing communications at any time by clicking ‘Unsubscribe’ on our promotional emails or using the opt-out facility included in our other electronic messages (such as SMS or MMS) or by contacting us using the details provided in paragraph 11.

If you unsubscribe from direct marketing communications, we may still communicate with you for non-direct marketing purposes, including as required for your use of the Services.

• Trade promotions

If you provide us with personal information for the purpose of entering into a trade promotion operated or managed by us, you are required to consent to the disclosure of some of your personal information in accordance with the terms and conditions of that trade promotion, including that we may publish your full name (or initials and last name), State and postcode, for the purpose of announcing you as a winner of the trade promotion and for promotional/marketing purposes in connection with the trade promotion.

4. How we hold and keep your personal information secure

All personal information we collect may be held in paper-based files or on secure electronic storage services located in Australia.

We take reasonable steps to ensure personal information we hold about you is kept secure in accordance with the Privacy Act.  This includes taking appropriate physical and technological security measures, including using password-protected encrypted servers, careful selection of staff and third-party service providers.

While we endeavour to protect your personal information, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.  You understand and agree that your disclosure of personal information to us is at your own risk.

We recommend that you take measures to protect your personal information, including by keeping your account details confidential, setting a unique and strong password, limit and monitor access to your devices and log out after use.  If you become aware of any unauthorised access to your account, please let us know as soon as possible.

• How long do we keep your personal information for

We destroy or de-identify personal information in a secure manner when we no longer need it. We may aggregate anonymous data for statistical analysis.

• Purposes for disclosing your personal information

• Who we may disclose to

We may disclose personal information to the parties below for the following reasons:

1. Our directors, officers and employees: Your personal information may be disclosed to and accessible by our directors, officers and employees for the for the purposes set out in paragraph 3.1.
2. Our related bodies corporate: We may disclose your personal information to entities that are considered our ‘related body corporate’ under the Corporations Act 2001 (Commonwealth) for the purposes set out in paragraph 3.1.
3. Service providers: We may disclose, or the following parties may have access to, your personal information to our trusted third-party service providers who assist us in operating our business and services for the purpose of performing their services to us.  Such service providers may include our website provider, accountants, financial advisors, tax advisors, legal advisors, translators, administrative support providers and IT service providers. The purposes for which these parties may use your personal information may include:
   1. administering billing and payments and debt recovery;
   2. planning, managing, monitoring and evaluating our services;
   3. training staff, contractors and other workers;
   4. risk management and management of legal liabilities and claims (for example, liaising with insurers and legal representatives);
   5. responding to enquiries and complaints regarding our services;
   6. receiving business advice; and/or
   7. responding to subpoenas and other legal orders and obligations.
4. Parties required by, or reasonably necessary to comply with law or government requests: We may disclose your personal information to parties, such as government authorities, legal or regulatory authorities, where we are required to comply with laws, regulations, legal processes or government requests or otherwise where reasonably necessary for us to comply with law or government requests.
5. Successors: Your personal information may be transferred to the acquiring entity or organisation in the event of a merger, acquisition, sale of all or a portion of our business for the purpose of effective that transaction.

• Third party links

Our Services may contain links to third-party websites. We are not responsible for the content or privacy practices of websites that are linked to our Services.

Some parts of our Services may include share buttons which enable you to share pages or other content from this site to the third party services such as social media platforms.  If you click a share button, these third parties may receive your personal data, including:

1. information about your browser, network and device;
2. details about the web page or content you shared or proposed to share; and
3. your IP address.

• How you may access and correct Personal Information held by us

You have the right to request access the personal information we hold about you and seek corrections if necessary. To exercise these rights, please contact us using the details provided in paragraph 11.

We may ask you to verify your identity before providing you with access to personal information. We may decline your request to access or correct your personal information in certain circumstances in accordance with the Australian Privacy Principles. If we do refuse your request, we will provide you with a reason for our decision and, in the case of a request for correction, we will include a statement with your personal information about the requested correction.

We may charge you the reasonable cost for giving access in accordance with Australian Privacy Principle 12.

• How you can make a complaint

You may make a complaint about our privacy practices, by contacting us using the details provided in paragraph 11.  

All complaints will be dealt with in a fair and timely manner, taking into account the circumstances of the complaint.  We endeavour to investigate and provide a response to complaints within 30 days of receipt of the complaint, however if further time is required due to the complexity of the complaint, we will inform you.

If you are dissatisfied with the outcome of the complaint or the way in which the complaint was handled, you may contact the Office of the Australian Information Commissioner.

• Changes to this Privacy Policy

We may change this Privacy Policy from time to time by updating this page, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes.

• Contact us

If you have any concerns, complaints or requests in relation to this Privacy Policy or your rights under the Privacy Act or other relevant privacy law, please contact us at support@qwestrewards.com.au.