Flybuys Privacy Policy

Effective date: 1 May 2025

Last reviewed date: 1 May 2025

What's New

At Flybuys, your privacy is important to us. We want to provide you with a clear and current explanation of how we collect, use and share your personal information.

Some of the key changes to the Privacy Policy are:

Improved readability and navigation - we’ve updated the layout, introduced clearer headings, tables, definitions for key terms.
More details on data collection and use - we’ve provided additional information about the personal information we collect, how we collect it, and how we share it with partners and service providers.
Service provider locations - we’ve updated the countries where our third-party service providers may be located.
Clarified information for job applicants – if you apply for a role with us, we’ve outlined what personal information we collect, and how it may be used.

1.About Flybuys

The Flybuys program is a loyalty marketing program provided by Loyalty Pacific Pty Ltd in collaboration with our partners.

“Partners” means those companies which have agreed with us to provide Flybuys members with certain benefits (including issuing Flybuys points to Flybuys members under the Flybuys program). A full list of our current partners can be found on our website.
Loyalty Pacific Pty Ltd is a joint venture between Coles Group Limited and Wesfarmers Loyalty Management Pty Ltd (our “shareholders”).

At Flybuys we collect, use and store personal information in accordance with all applicable Australian privacy laws. This includes the Australian Privacy Principles.

“Personal information” means information or an opinion about you, or another person, and from which you, or the other person, can be reasonably identified.

2.About this Privacy Policy

This Privacy Policy provides you with information about how we collect, use and store personal information of:

Flybuys members.
Visitors to our website, app, social media profiles, and other digital services.
Job candidates.

This Privacy Policy is current as of the effective date noted above. We may make changes to this Privacy Policy from time to time and will notify you of the changes by displaying an updated version on the Flybuys website. We may also notify you of these changes by sending you a notification via email.

If you do not agree to the terms of this Privacy Policy, you may close your Flybuys membership at any time. If you are a member of another member’s Flybuys account, closing your membership may not close that account.

In this Policy we use the following terms:
- Flybuys membership; this is held by an individual.
- Flybuys account; this may be made up of one, or more, members.

3.What personal information does Flybuys collect?

Depending on how you interact with us and our partners, as well as your marketing and contact preferences, the types of personal information we collect may include:

When you:	We may collect:
Register for a Flybuys membership.	Your name. Your contact information (such as email, mobile number, address). Your personal details (such as date of birth, gender).
Add another member to an account or accept an invite to be added to an account.	Connection between memberships.
Scan or link your Flybuys with an eligible partner.	Transaction details (such as time, date, item(s) purchased, value of the transaction and store location). The details of any offers you activate and qualify for in that transaction (such as bonus point offers). The details of any rewards you redeemed points for in that transaction (such as when you redeem points to receive instant money off at participating retailers).
Redeem points for a reward.	Reward details (such as product reward type, fulfilment address).
Interact with us through an online channel, such as emails, our website or Flybuys app.	Details and history of preferences, interests and behaviour relating to transactions, products and services. This includes activation of offers, and your communication and marketing preferences. Partner reward preferences (such as in-app rewards goals, if you have opted into redeeming points to receive money off at participating retailers, or turned on an automated points transfer option). Information collected by cookies, pixels and other online technologies (including IP addresses, device information), browsing patterns and behaviour (including clicks, how you navigated to our website, and where you landed on our website from) and usage statistics (such as app download, common activities, conversions).
Participate in a Flybuys promotion, survey or competition.	Your survey or competition responses.
Interact with us through our support channels (via our Service Centre, LiveChat or other).	The details of your contact (such as your query, complaint or request, and if you are not a member your name and contact details). Details of your interaction (such as date, time, channel you contacted us on). A record of the contact (which may include a voice recording if you do not request that the call is not recorded, a transcript of the call or chat contact, form inquiry, or email). Any authorisations you may provide us (such as for a third party to act on your behalf).
Use a payment method that has been previously associated with your Flybuys, but do not scan your Flybuys.	Our partners may share with us anonymised information which allows us to identify whether a Flybuys member who had previously used their Flybuys at a partner, has subsequently made a purchase without using their Flybuys. We do this by matching previous transaction records which show the use of a Flybuys and a particular payment card with later transactions where the same payment card was used. We do not in any circumstance collect or store credit card or debit card numbers. We use this information on an anonymised, aggregated basis for modelling and research purposes (for example to understand whether a large proportion of members are not using their Flybuys at certain partners).
Apply for a role with Flybuys.	Your name and contact details (such as phone number and email address). Details about your professional experience (such as your resume, references, and any assessment or interview responses). Any reasonable accommodations you may require.

3.1 Can I remain anonymous?

You can choose to engage with us anonymously.

We can only offer anonymity where it is practical to communicate with you anonymously, for example, for general queries raised with the Flybuys Service Centre which don’t require identity verification to safeguard the security of your account.

If you choose to interact with us anonymously, we may not be able to provide the full range of member experience benefits and services to you. For example, we may not be able to issue points, let you redeem points for rewards, manage your membership, or contact you.

3.2 Providing us with information about someone else

We may collect the information of third parties from you. When we do so, you must have their consent to provide their details to us. We collect this information, for example, when:

You provide us with the details of any third party authorised to act on your behalf in relation to your account (this excludes other members of your Flybuys account).
You redeem Flybuys points for a reward, and this reward is sent to a third party (such as digital gift cards) when this option is available.
You apply for a role with us and provide us with your references.

3.3 Unsolicited personal information

You must not send any personal information to us unless we’ve requested it from you. If we receive unsolicited personal information, we’ll handle it in accordance with applicable privacy laws.

4.How does Flybuys collect personal information?

We collect your personal information from a variety of sources including the following:

Our source:	We collect:
Your interactions with us.	We collect personal information when you: Register for a Flybuys account. Interact with us through our service channels. Participate in a Flybuys promotion, competition, or survey. Use Flybuys’ online channels. Redeem points for a reward.
Your interactions with our partners.	We collect personal information when you: Scan your Flybuys, Provide your Flybuys membership number, or Use associated identifiers, such as a payment card that you have linked to your Flybuys (e.g. a qualifying Coles Mastercard) at a partner. This includes when you do any of the following: Link your Flybuys account with the account or service of a partner. Use a card of a partner service where your account or subscription with that partner is linked with your Flybuys account (such as a OnePass or Coles Plus card). Make a purchase in-store or online. Make a non-cash payment (such as gift cards). Make a payment with a digital wallet where you have linked your Flybuys (such as Coles Pay). Participate in a promotion, competition, or survey. Register for services, including services provided by partners. Redeem points for a reward (such as redeem points for money off at participating retailers).
Third parties.	We collect personal information from: Public sources and registers. Information service providers (e.g. to help us ensure that the personal information we hold is accurate, up to date and complete; for data integrity purposes; and to inform our service proposition, including by creating marketing insights). Providers who administer Coles-branded products and services such as payment cards and insurance. Anyone authorised to act on your behalf. Service providers who help us to administer the Flybuys program.
Online technologies, such as cookies, pixels or tags.	Information about how we use these online technologies to collect, use and disclose personal information is set out below in Section 8.
Your interactions with us or our service providers as a job candidate.	We collect personal information when you: Apply for a role with Flybuys (this includes information about you from your application, references, employment status verification, and security checks).

5.How does Flybuys store and keep my personal information secure?

We hold personal information electronically and in some cases our service providers may hold hard copies. We implement a range of measures to protect the security of that personal information. Examples of these measures include:

Access to personal information being controlled through identity and access management systems, including multi factor authentication (MFA).
Staff members being bound by internal information security policies and being required to keep personal information secure at all times.
We take steps to protect personal information in accordance with the Office of the Australian Information Commissioner’s Guide to securing personal information.
We take measures to destroy or de-identify personal information that is no longer needed for any lawful purpose.

6.Why does Flybuys collect, use and disclose personal information?

We primarily collect, use and disclose personal information to provide, administer, improve and personalise the Flybuys program, Flybuys’ products and services, and those provided by partners.

We may collect, use and disclose personal information to:

Purpose:	Examples:
Register and service your account.	Creating your Flybuys account. Keeping your personal information up to date. Verifying your identity. Allocating Flybuys points. Enabling redemption of points for rewards.
Communicate with you, including via Email. SMS. In-app messages. Push notifications. Ads you may see on Flybuys’ and third-party websites.	Sending you: Information about Flybuys’ and partner’s products, services, promotions and direct marketing that may be of interest to you. Information about your reward redemption. Service messages (such as product recall notices or notification of updates to our Terms and Conditions).
Improvement of products and services.	To improve understanding of your interests and behaviour in relation to products, services, and offers. To improve operational processes to enhance your customer experience. Reviewing and testing systems, products and services, (such as reviewing call recordings or using AI to determine the reason for your call). Analysis and reporting, including reviewing preferences and transaction patterns of our members, grouping members into segments for personalisation and targeted digital marketing or the generation of insights.
Providing you with support.	Investigating and responding to your feedback, queries or concerns. We may monitor and record your communications with us (including email and telephone) for security, dispute resolution, quality control and training purposes.
System and account security, fraud detection, and investigations.	To safeguard member accounts and our infrastructure from malicious, dangerous, or illegal activities. To detect and monitor suspicious behaviours and potential security threats. To conduct investigations, implement fraud detection measures, and help with loss prevention strategies.
Corporate services.	Recruitment of team members. To protect our lawful interests. To facilitate purchases and potential purchases of our businesses.
As required or permitted by law.	Complying with our regulatory obligations, including any requests for information from a regulator, court, government department, or authorised authorities.

7.Who does Flybuys share my personal information with?

7.1 Sharing with partners

We may share and combine personal information with partners (and partners may share and combine such personal information with other partners that are part of the same corporate group). Flybuys shares your personal information with a partner after you first scan your Flybuys or a partner card linked to your Flybuys at that partner, or when you link your Flybuys with an eligible partner (including the provision of your Flybuys member number).

We may share and combine personal information with partners for:

Purpose of sharing:	Examples:
Communication and marketing.	To allow partners to engage with you and provide you with more personalised and targeted advertising when you use the partner’s website, third-party websites, social media, apps and other platforms. To allow partners to personalise the communications, marketing offers, customer surveys and trading updates that it sends to you. To enable partners to improve product offerings, service offerings, advertising and offers based on member shopping and browsing habits.
Analytics and insights.	To develop aggregated insights about the preferences of Flybuys members who shop at a partner. For analytics including for insights, and strategic and operational decision-making.
Safety and security.	For product safety-related matters (such as recalls). To conduct investigations, implement fraud detection measures, and help with loss prevention strategies.
As required or permitted by law.	Where you have provided express or inferred consent to us or a partner. For any other purpose described in this Privacy Policy.

Partners may also:

Collect personal information directly from you (and from other sources set out in their respective privacy policies).
Combine the personal information that they receive from Flybuys with other personal information they collect from or about you. That combined personal information may be shared by a partner with us, and we may share that combined personal information with other partners when you use your Flybuys with them.

Our partners handle your personal information in accordance with their privacy policies (which can be located on their respective company websites). Your personal information may be held by a partner after you have ceased to be a Flybuys member (or after the partner has ceased to be a partner) as permitted by law, and as set out in their privacy policy.

7.2 Sharing with service providers and third parties

We may share your personal information with service providers and other third parties engaged to assist us with running the Flybuys program, or providing services and products, including companies that assist us with:

Technology services, including application, development and technical support, processing, storing, hosting, and analysing data.
Processing payments.
Communicating our offers and promotions to you.
Providing rewards.
Product development and market research.
Administrative services, including mailing services, printing, archival, and contact management services.
Team member recruitment and candidate screening services.

We may also share your personal information with our shareholders for governance purposes, any potential purchaser of the Flybuys business (or part of the Flybuys business) and related professional advisors.

7.3 Shared Flybuys accounts

If you’ve chosen to add one or more additional members to your Flybuys account, or be added to another account, some of your personal information and that of the additional members may be visible to all members under the account in certain circumstances (such as when members view the shared Flybuys account details via online channels). The personal information that may be shared includes:

Names of all account members.
Total points balance of the account.
Transaction details (such as time, date, value of the transaction, store location, and points earned).
Details of any offers activated and qualified for in that transaction (such as bonus point offers).
Details of any rewards redeemed on the account (such as when you set in-app rewards goals, if you have opted into redeeming points to receive money off at participating retailers, turned on an automated points transfer option, or made a redemption on the Rewards Store).

7.4 Sharing with regulators and courts

We may share your personal information with law enforcement, regulators, courts, government entities for regulatory and enforcement purposes including:

To respond to lawful information requests from courts, regulators, law enforcement, government entities and authorised bodies.
To protect our lawful interests.

7.5 Sharing overseas

Personal information we collect may be stored in Australia, Singapore and the United States of America. The third parties to whom we disclose personal information may be located in Australia and other countries including Bangladesh, Canada, China (including Hong Kong), the European Union, India, Indonesia, Japan, New Zealand, the Philippines, Singapore, United Kingdom, and the United States of America. From time to time, the countries to which we send personal information may change.

We take steps to ensure that all our service providers are obliged to protect the privacy and security of your personal information in accordance with the standards that apply in Australia, including that they only use personal information for the purpose for which it is disclosed.

7.6 Links to third-party sites

Our website, social media pages, and apps may contain links to other sites. We are not responsible for the privacy practices or policies of those sites and recommend that you review their privacy policies.

8.Offers, direct marketing and online targeted advertising

8.1 Offers and direct marketing by Flybuys

We may provide offers, marketing communications and targeted advertising to you on an ongoing basis by electronic messages (e.g. email); telephone (e.g. SMS); in the Flybuys app (e.g. push notifications); via websites, social media and other online channels and by other means. These communications may relate to the products and services we and partners provide, and other products which we think may be of interest to you.

If you wish to opt out of direct marketing communications from Flybuys you can use any of the methods listed in section 8.5.

If you elect to opt out, you will still receive service-based communications relating to your Flybuys membership and account, as well as other information that we are required to send you by law, such as changes to our terms and conditions and notifications relating to your transactions and rewards purchases.

8.2 Offers and direct marketing by partners

If you have purchased a product or service from a partner and scanned or linked your Flybuys, that partner may also provide you with offers and marketing communications, including by email or other forms of electronic messages. These communications may relate to products or services that the partner provides and which the partner thinks may be of interest to you.

To opt out of any marketing communications received directly from partners, refer to their email communications or company website for further information.

8.3 When you interact with Flybuys online

You may interact with us, our service providers or partners through a range of digital and online channels (“online channels”), including:

Websites (e.g. flybuys.com.au or the websites of partners).
Flybuys app.
Email.
SMS.
Online advertisements.
Social media profiles.

We and our suppliers (such as Google, Adobe, LiveRamp, Pinterest, TikTok, and Meta) use technologies such as cookies, tags, and pixels (“online technologies”) on online channels to personalise and improve your experience, and to provide targeted marketing.

A cookie is a small piece of information stored on your device or computer when you interact with online content (e.g. websites, apps and emails). Cookies are used to identify and interact more effectively with your device, as well as to collect and store data.

These online technologies may be used to do the following:

Purpose:	Example:
Improve the way our websites and mobile apps work.	These technologies allow us to improve the way our websites and mobile apps work so that we can personalise your experience and allow you to use many of their useful features. For example: To maintain the continuity of your browsing session (such as to remember the items in your shopping bag on the Rewards Store). To remember your details and preferences when you return.
Measure the effectiveness of our marketing communications, including online advertising.	These technologies can help us to understand how our websites and mobile apps are being used, for example telling us: If you get an error message as you browse. How easy it is for you to navigate our website or app to find what you need. What version of our app you are using.
Communicate relevant advertising, including via third-party platforms and social media.	Marketing communications and online advertising may be in different forms, including: Email. SMS. Push notification through our app. Web notifications through our website. Display banners on external websites. Social media platforms. We may use these technologies to collect information about your online behaviour, such as your IP address, the website you arrived from and your actions on our website (such as registering for the Flybuys program or redeeming points for a reward). To help us and our service providers deliver online advertising that is relevant to you, we may also combine data we collect through these technologies on your devices with other data that we have collected, for example your transaction history.

Purpose:

Example:

Improve the way our websites and mobile apps work.

These technologies allow us to improve the way our websites and mobile apps work so that we can personalise your experience and allow you to use many of their useful features. For example:

To maintain the continuity of your browsing session (such as to remember the items in your shopping bag on the Rewards Store).
To remember your details and preferences when you return.

Measure the effectiveness of our marketing communications, including online advertising.

These technologies can help us to understand how our websites and mobile apps are being used, for example telling us:

If you get an error message as you browse.
How easy it is for you to navigate our website or app to find what you need.
What version of our app you are using.

Communicate relevant advertising, including via third-party platforms and social media.

Marketing communications and online advertising may be in different forms, including:

Email.
SMS.
Push notification through our app.
Web notifications through our website.
Display banners on external websites.
Social media platforms.

We may use these technologies to collect information about your online behaviour, such as your IP address, the website you arrived from and your actions on our website (such as registering for the Flybuys program or redeeming points for a reward).

To help us and our service providers deliver online advertising that is relevant to you, we may also combine data we collect through these technologies on your devices with other data that we have collected, for example your transaction history.

Some of these cookies and other technologies are consistent across various online channels, allowing us and the other providers of those online channels to understand you better and provide a more consistent experience across those online channels.

Some of the information we collect using these technologies is not related to an individual, for example the number of visitors to our website. Where this information is of an aggregated or statistical nature, we will have no way of knowing the identity of the user. In other cases, we may associate information about your use of online channels over time with your personal information, for example, when you have logged in to your Flybuys account or followed a link sent to you by email.

In addition, Flybuys may also share your personal information with Coles, who may on-provide it to third-party media, technology and advertising companies so those parties can then provide you with offers and targeted digital advertising. For more information on how Coles uses your information, refer to their Privacy Policy.

8.3.1 Data collection from third parties

In some cases, we may receive personal information and anonymised information from our service providers which is collected via these technologies for the purposes set out above. This information is collected directly by the relevant third parties and is subject to the individual privacy policies of those third parties.

In some cases, Flybuys may be able to connect anonymised data back to individual Flybuys members, meaning that we will handle this data as personal information in accordance with this Privacy Policy.

8.4 Sharing information for targeted advertising

Flybuys may provide your personal information to third-party media, technology and advertising companies so those parties can provide targeted offers and digital advertising on behalf of Flybuys or our partners to you. When we do so, we share a ‘hashed’ email address and/ or other contact details along with information on which advertisement to display, or information associated with an order you make with us to our advertising partners for the purpose of displaying relevant advertisements to you on our websites and on other organisations’ websites.

An email and/ or other personal information is “hashed” by applying a formula to an email address which produces a string of numbers and letters that is impossible for a human to read. If two organisations use the same formula against a list of email addresses or information they hold, it generates the exact same string of numbers and letters. This enables us to specify to external platforms which individual to show an advertisement to, without sending personal information in plain text.

This enables you to receive more personalised and targeted advertising when you use our business partners’ websites, social media and other platforms operated by these third-party media, technology and advertising companies.

Flybuys previously operated a business called ‘Unpacked’ under which we may have shared your personal information with third-party advertising partners outside our program so they could show you targeted digital ads when you use their websites and apps. Unpacked has recently transitioned to Coles. Flybuys may share your personal information with Coles (including your targeted marketing preferences) who may use this to on-provide your personal information to third-party media, technology and advertising companies so those parties can then provide offers and targeted digital advertising.

8.5 Limiting or restricting the use of online technologies or direct marketing

If you wish to limit the use of these technologies or block direct marketing by Flybuys you can:

Configure your web browser or device to reject and delete cookies, block JavaScript, disable location services, and anonymise your usage patterns. If you do so, you may find some parts of Flybuys’ online services are not accessible or have limited functionality.
Sign into your Flybuys account and select “Account details - Communication Preferences – Manage targeted digital ads” to prevent your information being used for targeted marketing. If you opt out, this preference may be passed to Coles for use in the transitioned Unpacked business (Coles 360) for targeted advertising as detailed in their privacy policy.
Sign into your Flybuys account and select “Account Details - Communication Preferences - Manage Flybuys communication” to unsubscribe from emails sent by Flybuys.
Click unsubscribe within a marketing email sent by Flybuys.
For SMS messages – follow the instructions in the SMS message.
For Push notifications – refer to your device settings.
Contact our service centre on the details listed in Section 10.

Depending on your device, within the Flybuys app you may be given an option of allowing Flybuys to track your online activity across that application as well as other companies’ applications and websites. If you indicate that you do not wish to be tracked, then Flybuys will remove tracking technologies from your Flybuys app.

If you wish to limit the use of direct marketing by our partners, you can:

Sign into your Flybuys account and select “Account Details - Communication Preferences - Partner Email Sharing” to prevent your email being shared with partners for the purpose of sending you marketing communications. You must do this prior to your first scan with each partner - if you have not opted out of Partner Email Sharing, then your email address will be shared with a partner shortly after your first scan with that partner and subsequently cannot be unshared.
To opt out of any marketing communications received directly from partners, refer to their email communications or website for further information on your unsubscribe options.

9.Your rights

You have rights in relation to how we collect, hold and use your personal information. If you wish to exercise these rights, contact us using the details in Section 10 - Contact Us. We may require proof of your identity before we can action a request.

Once a query, request, or complaint has been received, we will acknowledge receipt and aim to respond within 30 days. If you are not satisfied with our response, please let us know and we will investigate further and respond to you.

Right to access.	You have the right to request access to the personal information we hold about you. When making a request, please provide as much detail as you can about your request to help us assist you. In certain circumstances we may refuse all or part of your request in accordance with our rights under the Privacy Act. If we do so, we will provide you with a written response outlining our reasons.
Right to correction.	You have the right to request the correction of personal information about you that we hold that is incorrect. When making a request, please provide as much detail as you can about your request to help us assist you. In certain circumstances we may refuse all or part of your request in accordance with our rights under the Privacy Act. If we do so, we will provide you with a written response outlining our reasons. Where we decide not to make a requested correction and you disagree, you may ask us to add a note of your requested correction to the information that explains your correction request.
Opting out of marketing communications.	If you would like to opt out of direct marketing communications and promotions from Flybuys, see the instructions in section 8.5 above.
Privacy queries and complaints.	Flybuys is committed to protecting the personal information we have been trusted with. If you have any queries or complaints about this Policy, or our handling of your personal information, you can contact us as set out below in section 10. Complaints about this Policy or how we have handled your personal information should be directed to us in the first instance. If you are still not satisfied, you can contact the Office of the Australian Information Commissioner, whose contact details are set out below in section 10.

10.Contact us

The Flybuys Privacy Policy can be found on www.flybuys.com.au or by contacting our Flybuys Service Centre as detailed below.

Queries regarding privacy should be directed to the Flybuys Privacy Officer.	Email: privacy@flybuys.com.au Phone: 13 11 16 – Flybuys Service Centre operates Monday to Friday, 9am-7pm AEST, excluding national public holidays Post: PO Box 12125, A’Beckett Street, Melbourne, VIC 8006
If you are not satisfied with our response, or for information about privacy generally, you may contact the Office of the Australian Information Commissioner.	Post: GPO Box 5218, Sydney NSW 2001 Phone: 1300 363 992 Email: enquiries@oaic.gov.au Web: www.oaic.gov.au

11.Additional privacy information

In addition to this Privacy Policy, our partners and shareholders have their own privacy policies and other terms which provide further information about how they may handle the personal information that has been shared with them. Flybuys is not responsible for the privacy practices or policies of these third parties, and we recommend that you review their respective privacy policies.