Privacy Policy

Crcle Pty Ltd (ACN 654 876 525) trading as Crcle ("we", "us" or "our") is committed to respecting your privacy.

Our Privacy Policy sets out how we collect, use, store, share and disclose your personal information via our website at ‘crcle.com.au’ (“Website”) and our app (“App”) (collectively our “Platform”).

1. OPENNESS AND TRANSPARENCY

We are committed to protecting your privacy and respecting and upholding your rights under the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act). We will take all necessary and reasonable steps to comply with the APPs and to deal with inquiries or complaints from individuals about compliance with the APPs.

By accessing and using our Platform, products and services, you agree to and consent to the collection, use, storage and disclosure of personal information by us as set out in this Privacy Policy.

2. PERSONAL INFORMATION

Personal information is information or an opinion about an individual whose identity is apparent, or can be reasonably ascertained, from that information or opinion (whether true or not, and whether recorded in a material form or not). The type of personal information we collect from you includes, without limitation, the following:

·        your full name;

·        address;

·        email address;

·        telephone number(s);

·        birthday;

·        user generated & uploaded content, including comments, photographs, videos, information about your events, attendees, and venues and virtual items that you choose to upload;

·        any social media accounts you choose to connect to our Platform;

·        dietary preferences;

·        your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;

·        details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;

·        any additional information relating to you that you provide to us directly through our Platform or indirectly through your use of our Platform or online presence or through other websites or accounts from which you permit us to collect information;

·        information you provide to us through customer surveys;

·        information you provide to us during the course of competitions;

·        event habits (i.e.., the events you like to attend and their locations etc.); and

·          any other personal information that may be required in order to facilitate your dealings with us.

3. COLLECTION

We will collect personal information only by lawful and fair means, and not in an unreasonably intrusive way. Generally, we will collect personal information directly from you, and only to the extent necessary to provide our products and services requested or ordered by you and to carry out our administrative functions or as required by law. We will not collect sensitive information from you.

We may also collect person information from you when you fill in an application form, communicate with us, visit our website, provide us with feedback, complete online surveys or participate in competitions. We may collect personal information about you from our business partners or from third parties.

If you use a pseudonym when dealing with us or you do not provide identifiable information to us, we may not be able to provide you with any or all of our services as requested. If you wish to remain anonymous when you use our Platform do not sign into it or provide any information that might identify you.

We require individuals to provide accurate, up-to-date and complete personal information at the time it is collected.

4. What do we do with your personal information?

We use and disclose your personal information for the purposes for which the information is collected, or for a directly related purpose, including (but not limited to):

·        providing our Platform products and services to you;

·        administering, protecting, improving or optimising the content & functionality of our Platform, products and services (including performing data analytics, conducting research and for advertising and marketing purposes);

·        informing you about our Platform, products, services, rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;

·        responding to any inquiries or comments that you submit to us;

·        verifying your identity;

·        providing Personal Information including your full name, social media handle, contact number, and email address to any brands that we partner with on our Platform that you can freely choose to enter into (“Brands”);

·        contacting you if you have been successful in winning a competition;

·        creating industry reports from de-identified data;

·        any other purpose you have consented to; and

·        any use which is required or authorised by law.

We use Places API, a service developed by Google LLC, organised under the laws of the State of Delaware, USA, on our App to allow you to search for nearby places based on your geographic location. Any information used or collected by Google will be handled in accordance with Google’s Privacy Policy.

5. Disclosure of personal information

We may disclose your personal information to:

·        third-parties we ordinarily engage from time to time to perform functions on our behalf for the above purposes;

·        any person or entity to whom you have consented to us disclosing your personal information to;

·        any Brands who run competitions in collaboration with or using our Platform.

·        any Brands with which we choose to partner or collaborate with;

·        our external business advisors, auditors, lawyers, insurers and financiers; and

·        any person or entity to whom we are required or authorised to disclose your personal information to in accordance with the law.

6. ACCESS AND MANAGEMENT

Subject to some exceptions provided by law, you may request access to your personal information in our customer account database, or seek correction of it, by contacting us. See section 10: Contact information. Should we decline you access to your personal information, we will provide a written explanation setting out our reasons for doing so.

We may charge a reasonable fee that is not excessive to cover the charges of retrieving your personal information from our customer account database.  We will not charge you for making the request.

If you believe that we hold personal information about you that is not accurate, complete or up-to-date then you may request that your personal information be amended.  We will respond to your request to correct your personal information within a reasonable timeframe and you will not be charged a fee for correcting your personal information. 

If we no longer need your personal information for any of the purposes set out in this Privacy Policy, or as otherwise required by law, we will take such steps as are reasonable in the circumstances to destroy your personal information or to de-identify it.

7. DIRECT MARKETING

If you connect a third party or your social network account with us (including but not limited to Facebook, Instagram and Google accounts), we will collect your personal information from the relevant network.

If we use third parties to collect and process your data (such as through Facebook or Google Analytics), we will do so in accordance with the relevant privacy policies. You can find out how Google uses data with third party websites or applications here and Facebook here.

This information may include your name and user ID, username on the platform, handle on the platform, gender, age, preferred language, list of friends or followers on the platform, images you have shared on the platform or any other information you have shared in line with your privacy settings on that specific platform.

This information is used to create a profile for you on the Crcle platform.

If you agree, your personal information may also be used by us to provide you with personalised updates on the social network.

In the event that we have accessed your personal information through Facebook (or another social platform), you have the right to request a deletion of your personal information that we have obtained through Facebook. You can do this by contacting support@crcle.com.au and detailing the specific information that you would like deleted. Any denial of this request from us will be accompanied by reasons for which we have denied the request.

8. CRCLE PLATFORM

When transmitting personal information from your computer to the Platform, you must keep in mind that the transmission of information over the internet is not always completely secure or error-free. Other than liability that cannot lawfully be excluded, we will not be liable in any way in relation to any breach of security or any unintended loss or disclosure of that information.

Our Platform may use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but if you do so, you may not be able to fully experience the interactive features of the Platform.

9. SECURITY

We may hold your personal information in either electronic or hard copy. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, we leverage encryption & threat detection services.

However, we cannot guarantee the security of any personal information transmitted over the internet and therefore you disclose information to us at your own risk. We will not be liable for any unauthorised access, modification or disclosure, or misuse of your personal information.

10. CONTACT INFORMATION

If you require further information regarding our Privacy Policy or wish to make a privacy complaint, please contact us at support@crcle.com.au

11. MISCELLANEOUS

We reserve the right to modify this Privacy Policy in whole or in part from time to time without notice and amendments will be effective immediately upon posting of the amended Privacy Policy on the Crcle Platform.