Legal
Privacy Policy
This Privacy Policy (“Policy”) outlines the collection, utilization, and disclosure of your information when you engage with or utilise our Services, as described in our Member Terms and Conditions. The collection, use, and disclosure of this information adhere to the regulations stipulated in the Privacy Act 1988 (Cth).
This Policy is an integral part of our Terms of Service and is thus referenced therein. By accessing or utilising our Services, you implicitly agree to abide by all provisions outlined in the Member Terms and Conditions, including this Privacy Policy.
1. Information Collected
- a.When you access or utilise our Services, we gather Personal Information which includes Sensitive Information as defined by the Privacy Act.
- b.We collect your information through the use of our Services, as well as via other channels used to communicate with us. The types of Personal Information we collect encompass your contact details, such as your name, email address, organisation, address, and contact number.
- c.We retain the right to maintain, store, and utilise any information or data when we reasonably deem it necessary to comply with legal or regulatory obligations, to prevent criminal or other unlawful activities — whether imminent or prospective — or when we have a legitimate business rationale to do so. This may include the collection of outstanding payments, resolution of disputes, enforcement of our Membership Terms and Conditions, or ensuring the integrity of record-keeping processes.
- d.Our Services may utilise small data files known as cookies to identify users who interact with our platform and to compile records of their engagement history. These cookies are stored by a user’s browser while they navigate our Website. Generally, cookies do not contain information that personally identifies individuals. However, each time a user revisits the Website, the browser sends the cookie data back to the server to inform the system of the user’s previous activity. Should you wish to disable cookies, you may adjust your browser settings accordingly. However, this may result in certain functionalities of our Website becoming unavailable to you.
- e.We automatically capture information from your device and its software when you interact with our Services. This includes your IP address, browser, device type, internet service provider, mobile phone carrier, platform type, referring website, the destination website upon leaving our Services, date and time stamp, and cookies that may uniquely identify your browser or account. When accessing our Services through a mobile device, we may additionally receive and gather identification numbers linked to your device, mobile carrier details, device type, and manufacturer, and, if enabled, geographical location data (such as GPS coordinates). There may be particular information we collect (i.e. IP address) that may occasionally be used to estimate a device’s location.
- f.We also use Meta Pixel (Facebook) to gather data through cookies regarding actions you take on our Website, such as viewing a page or clicking on specific links. This enables us to track conversions from Facebook advertisements, optimise ads for users, and construct targeted audiences for advertising purposes. Additionally, we may utilise various services and functionalities provided by Meta Pixel Business Tools. Meta Pixel’s collection of data is governed by their own set of terms. We are not responsible for how Meta utilises your information, and it is your responsibility to familiarise yourself with Meta Pixel’s terms.
- g.We utilise third-party payment processors and gateways (i.e. Stripe) to handle payments made to us in the provision of our Services. All Personal Information, including any financial details (i.e. credit card details) is directly collected and managed by these third-party payment processors and gateways. Their utilisation of your Personal Information is regulated by their respective terms and conditions and privacy policies. We do not store or retain any sensitive financial or billing information, such as credit card numbers or bank account details, obtained during the processing of such payments.
- h.When gathering your Personal Information, we strive to permit interaction and contact anonymously or by using a pseudonym whenever reasonably feasible, except in the following circumstances:
(a) when we are compelled or authorized by a law or a court or tribunal order to engage with identified individuals, or (b) when it is impractical for us to interact with individuals who have not identified themselves.
2. Purpose of Collection
We collect your Personal Information for various purposes, including but not limited to:
- a.Providing you our Services;
- b.Communicating with you and providing messaging and communications related to the functionalities and features of our Services;
- c.Communicating your Personal Information with Suppliers to facilitate the direct provision of Services, enabling them to contact you directly;
- d.Analysing, monitoring, developing, and enhancing our Services, as well as other products or services;
- e.Sending marketing communications, such as promotional offers, contests, upcoming events, and news about our products and services;
- f.Performing other functions described at the time of collection or consented to in relation to our Services;
- g.Safeguarding the Services and our property from abuse, fraud, unauthorised access, or potentially illegal activities, and ensuring the safety and rights of ourselves and our users;
- h.Communicating announcements, updates, security alerts, technical notices, support, and administrative messages; and
- i.Complying with relevant laws and regulations.
Information Commissioner.
3. Protection of your Information
- 3.1.We employ reasonable measures to safeguard your Personal Information in accordance with this Privacy Policy. The Personal Information we collect from you is securely transferred and electronically stored via a secured SSL connection on our servers located in Australia, via secured Stripe servers (subject to potential changes as required by Stripe), or via our password-protected servers. By using our Services, you consent to the storage of your Personal Information on such servers. Our third-party payment processor is Stripe. The Stripe Privacy Policy governs the collection, storage, and processing of Personal Information on Stripe servers. Additionally, we may utilise this Personal Information for the purposes outlined in our Policy and in accordance with its terms. It is your responsibility to familiarise yourself with Stripe’s terms.
- 3.2.Our employees, contractors, suppliers, and third-party service providers, including our website host and technical support providers may access your Personal Information. Additionally, we may retain your Personal Information in password-protected email databases specifically for sending communications and marketing emails, adhering to the guidelines outlined in this Privacy Policy.
- 3.3.We will undertake the destruction or de-identification of your Personal Information after a period of 2 years if it is no longer necessary for the purposes delineated in this Policy. Nevertheless, certain legal obligations may necessitate the retention of some of your Personal Information for designated durations, such as those mandated by laws governing corporations, financial reporting and money laundering.
- 3.4.While we take extensive measures to protect your Personal Information, no electronic transmission or storage method can claim 100% security. As such, you acknowledge that the transmission of Personal Information over the Internet carries inherent risks, and you should only input or authorise the input of Personal Information into our Services within a secure environment. Safeguarding your Personal Information is your responsibility, including the maintenance of up-to-date software to prevent breaches of your security.
4. Disclosure of Personal Information
Individuals and companies may receive disclosure of your Personal Information for the purposes outlined in this Policy, as described below:
- a.Collective Trades Discount Group (trading as Collective Sparkies Discount Group), including our directors, employees, officers, suppliers, and contractors, may access your Personal Information. By using our services, you consent to the sharing of your Personal Information, including Sensitive Information, with our Related Bodies Corporate, as defined in the Corporations Act 2001 (Cth).
- b.We may disclose your Personal Information to any party as required by law or permitted under the Australian Privacy Principles. This includes situations where we reasonably believe that disclosure is necessary to comply with court orders, subpoenas, legal processes, or investigations, including those conducted by tax authorities. We will make reasonable efforts to notify you if we are required by law to disclose your Personal Information, whenever possible and appropriate.
- c.We reserve the right to share your Personal Information with third parties as necessary for the provision of our Services. These third parties may include suppliers, consultants, contractors, credit agencies, debt collection agencies, and other service providers who perform Services on our behalf. These services may include collaborating for contests or promotions, identifying and distributing advertisements, enforcing our Membership Terms and Conditions, administering fraud detection and prevention measures, handling payments, or furnishing analytics services.
- d.We reserve the right to disclose your Personal Information to third parties, with your consent as stipulated in a separate agreement, in conjunction with any corporate transactions including but not limited to merger, asset or share sale, reorganisation, financing, change of control, or acquisition of all or part of our business by another company or third party, bankruptcy, dissolution, divestiture, or any related or similar proceedings.
- e.We may also disclose your Personal Information if we have reason to believe that it is necessary to identify, contact, or take legal action against anyone who is causing damage, injury, or interference – intentionally or unintentionally – with our rights or property, users, or anyone else who could be harmed by such activities.
- f.We reserve the right to disclose your Personal Information to further third parties when, in our sole discretion, it becomes necessary to investigate and defend against any claims or allegations from third parties; identify, prevent, or address criminal activities, including fraud or stalking, as well as security or technical concerns; and safeguard our rights, property, or safety, as well as the rights, property, or safety of our users or the public, as mandated or allowed by law.
5. Marketing and Promotions
By utilising our Services, you provide express and indefinite consent for us to use or disclose your Personal Information (excluding Sensitive Information) for the purpose of keeping you informed about our products and services, as well as other offerings that we believe may be of interest to you. Such disclosure may involve our third-party service providers.
We may engage with you through various channels, including phone, email, social media, SMS, or regular mail. If you have a preferred communication method, we will endeavour to accommodate that preference whenever possible.
You may opt-out of our direct marketing communications activities at any time. This can be done by clicking the “unsubscribe” or “opt-out” link included in email communications, replying ‘Stop’ to promotional SMS messages, or by reaching out to us via phone or email.
6. Third Party Websites
Our Services may contain links to websites owned or operated by third parties. You acknowledge and agree that we are not responsible for the privacy practices or content of these third-party websites, and thus, cannot be held liable for them.
We make no representation regarding the privacy practices of any third-party websites, whether or not they are linked from or accessed through our Services. It is your responsibility to review the privacy policy of any such websites and applications to understand how they manage your Personal Information.
7. Social Media
We maintain pages on various social media platforms, such as Facebook and Instagram (Social Media). When accessing, interacting with, and using our Social Media, you agree to abide by the terms and privacy policy of such Social Media. You acknowledge and agree that such Social Media may collect your information, and that their privacy practices are not under our control. We do not guarantee, nor do we bear responsibility for their respective privacy practices.
These Social Media may allow public access to certain aspects of your social media profile, such as your username, age, country, list of friends, language, or other publicly available information. You understand that such information may be accessible to us if you interact with our Social Media.
We may occasionally have access to statistics regarding the number of views, navigation patterns, and user interactions with our Social Media, including likes, comments, and shares. We may use this information for marketing and promotional purposes. We may utilise this information for the purpose of our marketing and promotion.
8. Updating Your Personal Information
You have the right to request access to your Personal Information which we have collected.
We endeavour to maintain the accuracy, completeness, and currency of your Personal Information through reasonable measures. If you find any inaccuracies in the information we have collected, you have the right to request its deletion or correction by contacting us.
You may submit a written request for accessing, updating, deleting, or correcting any of your Personal Information.
We will process your request as soon as reasonably practicable, unless we are otherwise prevented from doing so by legal grounds. If we are unable to fulfill your request, we will provide an explanation for the decision.
9. Requests and Complaints
- 9.1.Any requests for access to or corrections of your Personal Information should be directed to our Privacy Officer. When submitting a request, please ensure to include your full details, any supporting documentation, and send it to our Privacy Officer via email at interested@csdgroup.com.au or via mobile at +61418295313.
- 9.2.If you wish to lodge a written complaint on how we handle your Personal Information, you can do so by contacting our Privacy Officer via email at interested@csdgroup.com.au or via mobile at +61418295313. If you are not satisfied with our handling of your complaint, or if we have not responded to you within a reasonable period of time, then you are entitled to make a complaint to the Office of the Australian Information Commissioner.
