INTRODUCTION

1.This document sets out the privacy policy of Locali Pty Ltd ABN 24 692 125 018 (referred to in this privacy policy as ‘we’, ‘us’, or ‘our’).

2.We operate a digital advertising and loyalty platform (the Locali Platform) that displays advertisements to consumers via QR codes placed on coffee cup lids at participating cafes and venues. We also provide a self-service advertising portal for advertisers and an electronic loyalty and stamp system for participating venues.

3.We take our privacy obligations seriously and we have created this privacy policy to explain how we store, maintain, use and disclose personal information. We are committed to preventing serious invasions of privacy and ensuring the protection of your personal information.

4.By providing personal information to us, you consent to our storage, maintenance, use and disclosure of personal information in accordance with this privacy policy.

5.We may change this privacy policy from time to time by posting an updated copy on our website and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy.

TYPES OF PERSONAL INFORMATION WE COLLECT

6.The personal information we collect may include the following:

(a)name;

(b)mailing or street address;

(c)email address;

(d)telephone number and other contact details;

(e)business name, ABN and other business details (for advertisers and venue operators);

(f)credit card or other payment information;

(g)advertising campaign data, including advertisement content and scheduling preferences;

(h)your device identity and type, IP address, geo-location information, page view statistics, advertising data and standard web log information;

(i)information collected when you scan a QR code, including the time, date and location of the scan and the type of device used;

(j)loyalty program participation data, including purchase history and stamp redemption records;

(k)information in connection with surveys, questionnaires and promotions;

(l)social media information; and

(m)any other information provided by you to us via our website, the Locali Platform, or otherwise required by us or provided by you.

HOW WE COLLECT PERSONAL INFORMATION

7.We may collect personal information either directly from you, or from third parties, including where you:

(a)scan a QR code on a coffee cup lid at a participating venue;

(b)create an account on the Locali Platform as an advertiser;

(c)register as a participating venue;

(d)participate in a loyalty or stamp program at a participating venue;

(e)contact us through our website or the Locali Platform;

(f)submit any of our online sign-up forms;

(g)communicate with us via email, telephone, SMS, social applications or otherwise;

(h)interact with our website, social applications, services, content and advertising; and

(i)invest in our business or enquire as to a potential purchase in our business.

8.We may also collect personal information from you when you use or access our website, the Locali Platform or our social media pages. This may be done through use of web analytics tools, cookies or other similar tracking technologies that allow us to track and analyse your usage. Cookies are small files that store information on your computer, mobile phone or other device and enable and allow the creator of the cookie to identify when you visit different websites. If you do not wish information to be stored as a cookie, you can disable cookies in your web browser. For more information, please see our Cookies Policy.

9.We may use Google Analytics to collect and process data, including when you use third party websites or apps. To find out more see How Google uses data when you use our partners’ sites or apps at www.google.com/policies/privacy/partners/.

USE OF YOUR PERSONAL INFORMATION

10.We collect and use personal information for the following purposes:

(a)to provide, operate and improve the Locali Platform and our services;

(b)to display advertisements to users who scan QR codes at participating venues;

(c)to provide advertising campaign management, reporting and analytics to advertisers;

(d)to operate the loyalty and stamp system at participating venues;

(e)to process payments and manage advertiser and venue accounts;

(f)for record keeping and administrative purposes;

(g)to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing services to you;

(h)to improve and optimise our service offering and customer experience;

(i)to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;

(j)to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act 2003 (Cth)). You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);

(k)to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and

(l)to consider an application of employment from you.

11.We may disclose your personal information to cloud providers, contractors and other third parties located inside or outside of Australia. If we do so, we will take reasonable steps to ensure that any overseas recipient has similar legal safeguards and deals with such personal information in a manner consistent with how we deal with it.

PERSONAL INFORMATION OF MINORS

12.As the Locali Platform may be accessed by any person who scans a QR code, we recognise that personal information of individuals under the age of 18 may be collected. If we collect personal information from individuals under the age of 18, we will assess their capacity to consent on a case-by-case basis in accordance with the Australian Privacy Principles (APP) Guidelines. As a general principle, an individual under the age of 18 may have the capacity to consent if they demonstrate sufficient maturity to understand the nature and consequences of what is being proposed. Where it is determined that the individual does not have such capacity, we will seek verifiable consent from a parent or guardian.

13.If it is not practicable to assess capacity on a case-by-case basis, we will generally assume that individuals aged 15 and above have the capacity to provide consent, unless there are reasonable grounds to believe otherwise. Parents or guardians may contact us using the details set out in clause 20 to review, manage, or request deletion of their child’s personal information.

SECURITY

14.We take reasonable steps to ensure your personal information is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal information.

LINKS

15.Our website and the Locali Platform may contain links to other websites, including the websites of advertisers whose advertisements are displayed via the Locali Platform. Those links are provided for convenience and may not remain current or be maintained. We are not responsible for the privacy practices of those linked websites and we suggest you review the privacy policies of those websites before using them.

REQUESTING ACCESS OR CORRECTING YOUR PERSONAL INFORMATION

16.If you wish to request access to the personal information we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.

17.If you think that any personal information we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.

DELETION OF PERSONAL INFORMATION

18.You may request that we delete the personal information we hold about you by contacting us using the details set out below. We will take reasonable steps to delete your personal information unless we are required to retain it by law or for a legitimate business purpose (such as to comply with our legal obligations, resolve disputes or enforce our agreements). We will notify you if we are unable to delete your personal information and explain why.

COMPLAINTS

19.If you wish to complain about how we handle your personal information or believe your privacy has been seriously invaded, please contact us using the details provided below with your name and contact details. We will investigate your complaint promptly and respond within a reasonable timeframe.

CONTACT US

20.For further information about our privacy policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the details set out below:

Name: Privacy Officer

Email: support@reachlocali.com