In this Privacy Statement, we explain how we collect, use and protect your information.
What information do we collect?
The types of information we collect depends on you use the Service as well as the relationship we have with our Participating Retailers through the Swappay Program.
This can include straightforward information like your name, date of birth, contact details (including address, email address, phone number or mobile telephone number), username or password.
We may also collect more in-depth information including:
- Financial information related to your financial relationship such as history of use of Coins, payment history and your service history.
- Information about how you use our services such as:
- Your Swappay Account usage including time and duration;
- How you use our services to access the internet, such as information about websites visited;
- Your location or the location of your devices when you are using the Service;
- Information that allows us to identify you for verification purposes.
You might also need to provide personal information about other individuals to us e.g. about your authorised representative. If so, we rely on you to have informed those individuals that you are giving their personal information to us and have advised them about this statement.
How do we collect your information?
There are three ways that we can collect your information:
- You give it to us when you or your representative interacts with either of us or a Participating Retailer. This might happen when you are setting up a Swappay Account or using the Service.
- We obtain information from outside sources like marketing mail lists, and public information (including public posts to social networking sites) and commercially available personal, identity, geographic and demographic information. This can include information gained from our Participating Retailers if you have interacted with them.
We understand that you might not want to give us particular personal information. If so, that may mean we are not able to provide you with the Service.
How do we keep your information?
We may store your information in hard copy or electronic format, and keep it in storage facilities that we own and operate ourselves, or that are owned and operated by our service providers.
We endeavour to ensure that personal information is kept as current as possible and that irrelevant or excessive data is deleted or made anonymous as soon as reasonably practicable. However, some personal information may be retained for varying time periods in order to comply with legal and regulatory obligations and for other legitimate business reasons.
How do we use our information?
We will only use your information if we have a lawful reason to do so such as when it’s our legal duty or we have your consent and when it’s in our legitimate interest to do so. These include:
- Administration – to help us properly manage the Service and your Swappay Account and to maintain and update our records. For example, we need to be able to verify your identity to detect, prevent and address fraud. We also use your information to identify breaches of our Terms of Service.
- Communication – we need to be able to communicate with you in order to provide you the Service. We might do this on mediums such as email, SMS, social media, search engines and web pages you may visit.
- Improvement – we are constantly working to not only maintain and improve the Service but to develop new ones. We use information we hold to help us do this in a number of ways.
- Development and analysis – it’s important we understand your information and communication needs. One of the ways we do this is through analysis and business intelligence techniques. This gives use high level insights into things like usage patterns, demographic trends and other types of behavioural data. In many cases this information is aggregated and de-identified when analysed. In some cases, we may create insights with your information on an identified basis but would only do so in compliance with privacy laws (such as, with your consent).
Please rest assured – we will not sell your personal information or any data related to the use of Coins to any other party
- Direct marketing – we want to make sure that you know about the Service, exciting opportunities and new products and services and special offers that are relevant and are of interest to you. We may use the information we hold to market and promote directly to you. This also may include products, services and offers provided by our Participating Retailers. In some cases this marketing activity can continue after you have stopped using the Service, unless you opt-out. You can stop us using your information for direct marketing by updating your preferences by logging into your Swappay Acccount online at https://swappay.com/ or by contacting Swappay using Contact Us service https://swappay.com/swappay/contactus/.
- Compliance – There are a number of circumstances where we are required or authorised by law to collect, use or disclose information. These include:
- as required or authorised by legislation;
- as required by or in accordance with any industry code.
When do we share your information?
We may share your information with other parties who provide services to us, including organisations, agents, partners and contractors that assist us with providing our business processes and the Services. These services include:
- providing, managing or administering the Service including customer enquiries and support services;
- mailing operations;
- information technology and network services;
- fraud, crime or misconduct identification, investigation and prevention services;
- development, analysis and business intelligence functions;
We may also disclose your information to:
- your authorised representatives or advisers;
- other parties when you ask us to do so or when you consent to that disclosure for the purposes of fraud, crime or misconduct identification, investigation and prevention services;
- our Participating Retailers;
- law enforcement and national security agencies, and other government and regulatory authorities as required or authorised by law; and
- for the purposes of facilitating or implementing a transfer/sale of all or part of our assets or business.
How can you access or correct your personal information?
It’s important that you make sure the personal information we hold about you is accurate, up-to-date and complete. If any of your details change, you can update them yourself using your Swappay Account or you may contact us using the contact details below so that we can consider and respond to your request. You also have the right to request a copy of the information that we hold about you. There is no charge to submit a request or to correct information, however we may apply an administrative charge for providing access to your personal information on request.
How can you make a privacy complaint?
You can also use our contact details to notify us of any privacy complaint you have against us. We are committed to acknowledging your complaint in a prompt manner and will give you an estimated timeframe for when we will respond to your complaint.
While we hope that we will be able to resolve any complaints you may have without needing to involve third parties, you may also be able to lodge a complaint with a relevant regulator such as the Australian Information Commissioner.