Flybuys Privacy Policy

Loyalty Pacific Pty Ltd
ABN 82 057 931 334
Date: December 2021

We’ve recently updated our Privacy Policy to reflect changes to our business.  This updated Privacy Policy takes effect from 1 December 2021.

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Our promises to you

You should read our Privacy Policy in full, but here are a few key points that you should know
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Your privacy is paramount
We’re committed to protecting your privacy and keeping your data secure.
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We'll notify you when things change
We'll update you with changes to our privacy policy and how this may effect your interaction with our program.
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You're in control
Update your Flybuys communication or partner email sharing preferences via the account details section of our website or app.

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:

  • From 1 December, when you shop at a select Flybuys partner and use your Flybuys card or member number, your email will be shared with that partner. Only a select list of partners are included in this change. When your email is shared with a partner, this will allow you to receive tailored email communications and offers direct from them. Before we provide your email, you can opt-out of partner email sharing via the Communication Preferences section of your Account Details on the Flybuys website or app. After your email is shared, you can opt out of communications directly with each partner. 

  • We provide you with more information about how we collect and use information about your purchases (including where you have not swiped your Flybuys card).

  • We describe in more detail how we collect and handle data when you interact with us or our partners via online channels, including websites and social media platforms.  We also describe how we and our partners use cookies and other technologies on those online platforms to collect data.

  • We provide you with more information about how we share your personal information with program partners and the purposes for which they may use it, including so they can provide you with more personalised offers and advertising on their platforms.

  • We describe how our “Unpacked by Flybuys” business uses de-identified data to deliver services to third party advertisers, including to provide you with targeted advertising on their platforms. We don’t share any of your personal information with third parties in connection with these services.

  • We provide updated information about how we handle and share your personal information for law enforcement and regulatory purposes, including to comply COVID-19 contact tracing requests

On this page

1Overview

1.Overview

At Flybuys (“Loyalty Pacific Pty Ltd”), we respect the privacy of Personal Information in our care, and we collect and handle Personal Information in accordance with the Privacy Act 1988 (Cth) (including the Australian Privacy Principles) and all other applicable Australian privacy laws.

Personal Information’ has the meaning given in the Privacy Act, but in broad terms, means information which identifies you as an individual or from which you can be reasonably identified.

This Privacy Policy relates to Personal Information we collect and handle about Flybuys members and visitors to our website, apps, social media and other digital services, including those of our Participants. Our personnel and job applicants should contact our People Experience team for details about the privacy of their Personal Information.

The Flybuys program is a loyalty marketing program provided by us in collaboration with Coles, Wesfarmers and our Participants. ‘Participants’ refers to those companies (and other persons) which have agreed with us to provide Flybuys members with certain benefits (including issuing points to Flybuys members under the Flybuys program and/or providing rewards in exchange for points). Flybuys is not responsible for the privacy practices or policies of Coles, Wesfarmers, and our Participants, and we recommend that you visit their websites for more information about their privacy practices and policies.

If you do not agree to the terms of this Privacy Policy you may terminate your Flybuys membership at any time.

This Privacy Policy is current as of the date noted above. We may make changes to this Privacy Policy from time to time, in which case we will notify you of the change by displaying an updated version on our website and other digital channels, and/or by sending it to you via email.

2.Types of Personal Information Collected

The types of personal information we collect include:

  • name;
  • contact details (e.g. address);
  • identification information (e.g. date of birth);
  • household details (e.g. the number of people living at a household and their ages);
  • payment and transaction details/history (including information about payment cards linked to Flybuys and associated transactions) However, we do not collect or store credit card or debit card numbers;
  • points accrual and reward details;
  • authorisations;
  • records of your communications and interactions with us ; 
  • data related to your activities on Online Channels (as defined in Section 5.3 below) collected via tracking technologies such as cookies and other anonymous identifiers (in many cases, we will not be able to reasonably identify a particular individual from this information but where we can do so, this Privacy Policy applies, as well as our obligations under the Privacy Act); and
  • details and history of preferences, interests and behaviour relating to transactions, products, services.

We collect from Participants information about your purchases when you haven’t presented your Flybuys card, but where we were able to identify from payment card information that you have made the purchase. We use this information on an anonymised, aggregated basis for modelling and research purposes. We do not in any circumstance collect or store credit card or debit card numbers.

Anonymity 
You have the option to engage with us anonymously. However, 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 our services to you without your Personal Information. For example, we may not be able to issue points, let you redeem points for awards, manage your membership, or contact you.

Providing us with information about someone else
Where you provide us with Personal Information about someone else you must have their consent to provide their Personal Information to us. 

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 the Privacy Act.
 

3.How Personal Information is collected

3.1 Collection of Personal Information by us and Participants

We may collect your Personal Information, and that of any additional members that have added themselves to your account with your approval, from your interactions and transactions with us and Participants and Coles and Wesfarmers group companies, including for example when you:

  • use your Flybuys card or number or associated identifiers such as payment cards;
  • make a purchase in store;
  • place an order online;
  • make a non-cash payment;
  • participate in a promotion, competition, or survey; 
  • register for services; including services provided by Participants; or
  • use Online Channels.

We may monitor and record your communications with us (including email and telephone) for security, dispute resolution, and training purposes. 

 

3.2 Collection of Personal Information from third parties

We may also collect personal information from third parties including:

  • 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, and for data integrity purposes);
  • providers who administer Coles-branded products and services such as payment cards and insurance;
  • anyone authorised to act on your behalf; 
  • Participants, Coles and Wesfarmers group companies; 
  • service providers who help us to administer the Flybuys program; and
  • Flybuys media and advertising partners, to enable us to provide them with aggregated and de-identified data and services for targeted advertising purposes (as further described in the “Targeted Advertising” section below).

 

3.3 Collection of data via Cookies and other technologies

We may use “cookies” on Online Channels to collect data. 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. 
We may also use other tracking or data collection technologies across Online Channels including web beacons (which may operate in conjunction with cookies), Flash local stored objects, and JavaScript.

4.Storage and security of Personal Information

We hold personal information electronically and in hard copy form, both at our own premises and with the assistance of our service providers. We implement a range of measures to protect the security of that personal information. Examples of these measures include:

  • access to Personal information is controlled through identity and access management systems;
  • staff members are bound by internal information security policies and are 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; and
  • we also take measures to destroy or de-identify Personal Information that is no longer needed for any lawful purpose.

5.Purposes for handling Personal Information

5.1 Registration and use of the Flybuys loyalty program

We handle your Personal Information in connection with providing, administering, improving and personalising the Flybuys program, Flybuys products and services, and those provided by Participants, Coles, and Wesfarmers group companies. This can include:

  • to register and service your membership account, including keeping your information up-to-date, and verifying your identity;
  • to communicate with you about our and our Participants’ products, services and promotions (including via direct marketing as described below);
  • to help us and our Participants improve our products and services, including conducting product and market research;
  • to improve our understanding of your interests and behaviour in relation to products, services, and offers;
  • to improve our operational processes to enhance your customer experience;
  • to respond to your feedback, queries or concerns; or
  • investigative, fraud and loss prevention activities.

 

5.2 Offers and marketing communications

We may provide offers, marketing communications and targeted advertising to you on an ongoing basis by telephone, electronic messages (e.g. email), websites, social media and other Online Channels, and by other means. These communications may relate to the products and services we, Participants, Coles, and Wesfarmers group companies provide, and other products which we think may be of interest to you.

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

You can call us on 13 11 16 or login to your Flybuys account at flybuys.com.au at any time to opt out of electronic and telephone direct marketing communications from us. You can also use the unsubscribe facility provided in Flybuys electronic marketing communications. 

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.

To opt-out of any marketing communications received from Participants, you can use the unsubscribe facility provided in the Participant’s electronic marketing communication.  

 

5.3 When you interact with us online

You may interact with us, Participants, Coles or Wesfarmers group companies, our service providers or our other business partners through a range of digital and online channels, including:

  • websites (e.g. flybuys.com.au or the websites of Participants);
  • apps;
  • email;
  • online advertisements;
  • IPTV; and
  • social media profiles,

(“Online Channels”).

We may collect and handle your Personal Information and other data collected via these Online Channels for a range of purposes, including to provide a consistent experience, personalise your use of each of those Online Channels and to provide targeted marketing.

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