Privacy

Honeycomb Media Pty Ltd ACN 166 152 405



GENERAL

This Privacy Policy sets out:

  1. our practices, including your choices, regarding the collection, use, and disclosure of certain information, including your personal information, by Brauz; and
  2. our commitment to protecting the privacy of your personal information that we collect through (the Site), through the Brauz IQ application (Brauz IQ App), the Brauz personal application (Brauz Consumer App), through our Third Party Retailer Plugin or directly from you, being the person, organisation or entity that uses our Site, Brauz IQ App, Brauz Consumer App and/or the Third Party Retailer Plugin (referred to as you or your).

Your consent to our terms is the legal basis upon which we collect, use and process your data. By actively confirming you’re acceptance of our terms via the Consent Mechanism and providing us with your personal information, you confirm that you have had sufficient opportunity to access and review this Privacy Policy and that you have read and consented to it. If you do not wish to provide personal information to us, then you do not have to do so. However, please be aware this may affect your use of our Site, Brauz IQ App, Brauz Consumer App and/or the Third Party Retailer Plugin as well as any products and services offered on it.

SECURITY OF DATA

At Brauz, your privacy is important to us. We ensure that all personal information is handled carefully and securely in accordance with the Australian Privacy Principles (Privacy Principles) contained in the Privacy Act 1988 (Cth) (Privacy Act).

CONTACTING US

If you have general queries about our services or your account, please contact us by email at privacy@brauz.com. For questions specifically in relation to this Privacy Policy, or our use of your personal information or data (including cookies or similar technologies), please contact our Data Protection Officer by email at rajesh@brauz.com. If you contact us, for your protection (and ours) we may need to authenticate your identity before responding to any queries.

COLLECTION OF INFORMATION

The below section sets out how we receive and store information about you. This includes, information you provide to us (Information You Provide), information we collect automatically (Information we Collect) and information from other sources (together, Personal Information).

INFORMATION

If you download and use the Brauz IQ App or the Brauz consumer App, use our Site and/or use a Third Party Retailer Plugin we may collect information such as your name, iPhone or android smartphone device identification details (Device IDs) and locational data sent by your device, your email address, date of birth, information about products or services you are interested in and other information required to provide the Brauz IQ App or our Site and to personalise the content you receive through the Brauz IQ App to your particular shopping interests.

PERSONAL INFORMATION

Pursuant to the below, the types of Personal Information we expect to collect from you includes but is not limited to any of the following:

  1. name;
  2. images;
  3. contact details including email address, address and telephone number;
  4. marital status and anniversary;
  5. date of birth;
  6. demographic information such as postcode and gender;
  7. preferences and opinions; and
  8. any other information requested on our Site, Brauz IQ App, Brauz Consumer App and/or Third Party Retailer Plugin or otherwise requested by us or provided by you.

INFORMATION YOU PROVIDE

We collect Information You Provide to us which includes:

  1. your name;
  2. email address;
  3. address or postal code;
  4. payment method(s); and
  5. telephone number.

We collect this information in a number of ways, including when you enter it while using our Services, interact with our Services or personnel, or participate in surveys or marketing promotions.

We may also collect information when you choose to provide reviews or ratings, preferences, account settings, or otherwise provide information to us through our Services or elsewhere.

INFORMATION WE COLLECT

Brauz will also collect information about you and your use of our Service, your interactions with us (including our personnel) and our advertising, as well as certain information regarding your Devices used to access our Service.

This information includes:

  1. your activity on our Service (such as items viewed, history, search queries and purchases);
  2. your interactions with our system (including any email, push notification and text messaging);
  3. details of your interactions with our personnel (such as the date, time and reason for contacting us);
  4. Device IDs or other identifiers;
  5. Cookies and internet advertising and any information collected via the use of cookies, web beacons and other technologies; and
  6. Device and software characteristics (such as type and configuration), connection information, statistics on page views, referring source (for example, referral URLs), IP address (which may tell us your general location), browser and standard web server log information.

YOUR USE OF OUR SERVICES

As with most online businesses, we may log information about your access and use of our Services, including through the use of Internet cookies, your communications with the Brauz IQ App or the Brauz Consumer App, use our Site and/or use a Third Party Retailer Plugin, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.

Your opinion and feedback: We may contact you to voluntarily respond to questionnaires, surveys or market research to seek your opinion and feedback. Providing this information is optional to you.

INFORMATION FROM OTHER SOURCES

Brauz may also collect information from other sources including directly from Third Party Retailers. Brauz protects this information in accordance with this Privacy Policy.

The sources from which we collect data may include:

  1. Third Party Retailers;
  2. select entities or individuals that make our Service available on their device or with which we offer co-branded services or engage in joint marketing activities;
  3. payment service providers who provide us with updated payment method information based on their relationship with you; and
  4. publicly available sources.

RETAILER INFORMATION

If you are a Third Party Retailer who has subscribed to use of the Third Party Retailer Plugin and/or Brauz IQ App, we will collect information such as your name, phone number and email address and the name, phone number and email address of any users who will have access to the software and credit card details for payment of your subscription fees.

COLLECTION AND USE OF PERSONAL INFORMATION

SERVICES

Through our Services, we collect and use the information for purposes including:

  • to contact and communicate with you (including by email, text message and/or push notification);
  • for internal record keeping;
  • for market research and business development including website development;
  • with your consent, for marketing including direct marketing;
  • to run competitions or offer additional benefits to you;
  • to send you promotional information about third parties that we think may be of interest to you;
  • for data analytics purposes;
  • assisting us to improve our products and services and making them more relevant to you;
  • assisting us to improve our website;
  • optimise content selection, recommendation algorithms and delivery;
  • processing and assessing employment applications for current and future positions;
  • otherwise managing our internal business operations and processes; and
  • with your consent which can be rescinded at any time by email in accordance with the contact provisions of this policy, for automated decision making in processing your personal information for some of the services or products we provide (you can at any time request a manual review of the accuracy of an automated decision).

BRAUZ CONSUMER APP

If you use the Brauz Consumer App, we collect and use the information for purposes including:

  • providing access to promotions, sales events, offers, discounts and products offered through the Brauz Consumer App;
  • providing notifications of discounts and offers on products purchased, collected or interacted with;
  • providing notifications of special offers and discounts at followed Brauz businesses; and
  • recommending stores and products based on browsing history.

MEANS OF COLLECTION

We will only collect Personal Information through lawful and fair means and not in an unreasonably intrusive way. Brauz collects your Personal Information when you deal with us directly, including via the Brauz IQ App, the Brauz Consumer App, our Site and or our Third Party Retailer Plugin as well as via forms or correspondence (i.e. by mail or email) or over the phone.

SENSITIVE INFORMATION

Brauz does not generally collect sensitive information as defined under the Privacy Act, such as racial or ethnicity information, political opinions or associations, criminal records or health information. However, subject to obtaining your prior consent, Brauz may collect sensitive information from you where we consider it necessary to do so, such as in the course of considering an application for employment.

UNSOLICITED INFORMATION

Where unsolicited information is received by Brauz, we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information. If it would not be permitted for Brauz to collect the information, we will destroy the information or ensure it is de-identified as soon as practicable. Otherwise, Brauz may retain the information in accordance with the terms of this policy.

ANONYMOUS INFORMATION

Brauz collects anonymous information to:

  • provide aggregated and anonymised reports to businesses who have a Brauz business subscription;
  • monitor the use of our Site and/or the Brauz IQ App;
  • help us make improvements to the Site and/or the Brauz IQ App; and
  • offer relevant information and services to as many users as possible.

USE OF DATA BY STORES AND OR RETAILERS

By using our Services, you consent to us providing your Personal Information to Third Party Retailers (and their stores and staff) for the purposes of allowing the Third Party Retailer (and their stores and staff) to identify you and allow you to collect items you have reserved.

USE OF DATA FOR MARKETING

We will only send you direct marketing materials (including exclusive offers and information about our Services or other services, where you have indicated consent by way of a Consent Mechanism.

Transfer of Information to Third Party Retailer

By using our Services you consent to Us sharing, where required for the provision of our Services, any and all of your Personal Information with our Third Party Retailers.

To protect the Personal Information that we provide to any Third Party Retailers, we will enter into contracts with the Third Party Retailer to require the protection of your Personal Information.

Where you use our Service by way of a Third Party Retailer Plugin, we may provide you with the option to join the mailing and/or subscriber list of the relevant Third Party Retailer. If you take action to indicate your consent of such option, for example by ticking a consent box, we may provide a record of such consent to the relevant Third Party Retailer and direct them to add you to their mailing and/or subscriber list.

TRANSFER OF INFORMATION TO RIDESHARE PLATFORMS AND PAYMENT PLATFORMS

By using our Services, you consent to Us sharing your Personal Information with ridesharing platforms and payment platforms where such sharing is required to facilitate the use of the platform for the purposes of providing you with components of our Services.

To the greatest extent possible under the relevant laws, we are not responsible for or liable for the protection and privacy of any information which is provided to a ridesharing platform and/or payment platform.

GENERAL TRANSFER TO A THIRD PARTY

Brauz may transfer your personal information to a third party providers for the purposes of processing personal data on the behalf of Brauz or any Third Party Retailer including but not limited to, for the purposes of:

  • shipping;
  • hosting, managing and servicing our data;
  • distributing emails;
  • research and analysis;
  • advertising, analytics, manage brand and product promotions; and
  • administering certain services and features.

Brauz may also share your information if requested by law, to prevent any illegal activity and defend third party claims against Brauz.

To the greatest extent possible under the relevant laws, we are not responsible or liable for any linked websites or apps not owned or controlled by us including their content, use of apps, or their privacy practises.

TRANSFER OF INFORMATION OUTSIDE AUSTRALIA

Brauz may transfer your personal information to our related entities, Third Party Retailers and third party service providers based in Australia or overseas (including in the USA, UK, Europe, Asia or Australia).

We may also transfer your Personal Information to service providers who will hold your information on a cloud computing system which may hold your data on servers located outside of Australia. However, where your Personal Information is disclosed to an overseas recipient or held on a cloud computing system located overseas, we will take adequate measures to ensure that your Personal Information is handled in accordance with the Privacy Principles, the Privacy Act and our instructions in accordance with this Privacy Policy.

By providing Brauz with your personal information, you consent to your personal information being stored or sent overseas for the purposes set out in this Privacy Policy.

INFORMATION BRAUZ DOES NOT COLLECT

Brauz does not collect information from you in relation to:

  • your race or ethnic origin;
  • your political opinions;
  • your religious or philosophical beliefs;
  • your trade union memberships;
  • your genetic or biometric data;
  • your health or mortality; and
  • your sex life or sexual orientation.

STORAGE AND SECURITY

We take our obligations to protect your Personal Information very seriously. This includes ensuring that we meet the Office of the Australian Information Commissioner guidelines with respect to the appropriate level of information and software security, governance and associated procedures so as to adequately protect your Personal Information from unauthorised access, loss, misuse, disclosure or alteration.

Brauz will take reasonable steps to protect your personally identifiable information as you transmit your information from your computer or Device to our Services and to protect such information from loss, misuse, and unauthorised access, use, modification, disclosure, alteration, or destruction. However, you should keep in mind that the transmission of information over the Internet is never completely secure or error-free. In particular, email sent to or from our Services may not be secure, and you should therefore take special care in deciding what information you send to us via email.

We may need to maintain records for a significant period of time. However, we will take reasonable steps to destroy or de-identify personal information where we consider that the information is no longer needed or where you request deletion of such information.

COOKIES

Cookies are small text files placed on your hard-disk that allows the server to identify and interact more effectively with your computer or Device and are frequently used on many websites. We may use cookies to enable us to identify you and to personalise and enhance your experience and use of our Site. For example, a cookie may be used to pre-populate a registration form, or avoid details having to be entered more than once. You can choose if and how a cookie will be accepted by changing your preferences and options in your browser. Please note that declining cookies may impact your experience of our service or limit the use or functionality of our Site.

Once you choose to furnish the Site with personally identifiable information, this information may be linked to the data stored in the cookie. If requested by you, we will assist you to remove our cookies and or web beacons.

WEB BEACONS

Web beacons or clear.gifs are small pieces of code placed on a web page to monitor the visitors’ behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

We may use web beacons on our Site and Software from time to time.

FACEBOOK PIXELS, GOOGLE ANALYTICS AND OTHER SIMILAR CODE

A Facebook Pixels, Google analytics and other similar codes are used to analyse and track site visitors and to understand the actions site visitors take on websites.

We may use Facebook Pixels, Google analytics and other similar code on our Software from time to time, if you use a Facebook and/or Google account to sign up to any of our Software.

GEOTRACKING

In the course of providing Services to you, we may use geotracking or other geolocation technology, if you consent. We may use geotracking to personalise suggested items you may be interested in and to provide you with a better user experience and geotracking is intended so that our Services are useful at particular locations.

THIRD PARTY RETAILER PLUGINS

Third Party Retailers will include links to our Services on their respective websites or applications or make use of our Services through their existing websites or applications (including by way of the Third Party Retailer Plugin). Brauz will collect and use information obtained through Third Party Retailers in accordance with this Privacy Policy.

As noted in this Privacy Policy, Brauz will share the information it obtains via our Third Party Retailer Plugin with the Third Party Retailer subscribing for that plugin. To the greatest extent possible under the relevant laws, we are not responsible for or liable for the protection and privacy of any information which is provided to a Third Party Retailer.

LINKS TO OTHER SERVICES

Our Services may also contain links to other websites of interest. We do not have any control over those websites. To the greatest extent possible under the relevant laws, we are not responsible for or liable for the protection and privacy of any information which you provide whilst visiting such websites.

ACCESS

We endeavour to ensure that the personal information we hold is accurate and up-to-date. We realise that this information may change frequently with changes of address and other personal circumstances. If at any time you would like to access, correct or change any personal information provided to us by you, please contact our privacy officer by email at rajesh@brauz.com. Please note that where you require copies of your personal and/or sensitive information held by us, we may charge you a reasonable fee for the postage and administration involved in complying with any such request.

YOUR RIGHTS

Each Information Subject has the right to.

  • access the data we hold about you;
  • be informed (including being informed about what data is being processed and how and why it is being processed as well as being informed about anyone else the data may be passed to);
  • rectify your data (including the right to have your data modified or corrected)
  • erase your data (including the right to request the deletion of your data in certain circumstances such as where you withdraw your consent, deletion of data where your data is no longer required for the collection purpose or deletion of your data where it has been unlawfully processed).
  • Restrict processing of your data (including the right to ask for any temporary stop to procession);
  • take your data (including the right to ask Brauz to provide you with any of the data you supplied directly to the Data Controller in a useable form);
  • object (including the right to object to additional processing of your data which is inconsistent with the reason for which it was collected and including the right to object to profiling, automation, and direct marketing); and
  • right not to be subject to a decision based solely on automated processing.

CONTROLLING YOUR PERSONAL INFORMATION

Providing us with your Personal Information is optional to you.

You can choose not to provide Personal Information. When you provide us with your Personal Information, you consent to the terms in this Privacy Policy, and to us disclosing or receiving your personal information for purposes set out in this Privacy Policy.

If you provide us with third party Personal Information then you warrant to us that you have the third party’s consent to provide this.

You may choose to restrict the collection or use of your Personal Information.

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us at the email address listed in this Privacy Policy.

You may submit a Subject Access Request at any time to request details of Personal Information that we hold about you. If we receive a Subject Access Request from you we will within 30 days of your request, free of charge to you, provide you with disclosure of your Held Information.

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us at the email address listed in this Privacy Policy. We rely in part upon customers advising us when their Personal Information changes. We will respond to any request within a reasonable time. We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date.

To unsubscribe from our database, or opt out of communications, please contact us using the details below.

COMPLAINTS

If you believe that we have at any time failed to keep one of our commitments to you to handle your personal information in the manner required by this Privacy Policy or the Privacy Principles, then we ask that you contact us immediately using by email at legal@brauz.com.

We will respond and advise whether we agree with your complaint or not. If we do not agree, we will provide reasons. If we do agree, we will advise what (if any) action we consider it appropriate to take in response. If you are still not satisfied after having contacted us and given us a reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner.

UPDATES

Our Privacy Policy will be reviewed from time to time to take into account new laws and technologies, and changes to our operations and/or practices. Accordingly, we reserve the right to change, modify, add or remove portions of this Privacy Policy and will publish the revised version here on our Site. If we have collected your email information, we will notify you of such changes by way of email. By continuing to use, access or browse our Site following any changes to this Privacy Policy, you accept this Privacy Policy as it applies from time to time.

DEFINITIONS

For the purposes of this Privacy Policy, the words:

  • "Brauz", "we", "our" and "us" refers to Honeycomb Media Pty Ltd ACN 166 152 405 and its successors and assignees and appointed Data Controller.
  • "Brauz Button" refers to the clickable link or object on the Retailer’s website that connects the User to the Third Party Retailer Plugin.
  • "Consent Mechanism" means the functionality for a user to indicate their consent to either by way of a checkbox or other electronic mechanism.
  • "Data Controller" refers to Brauz.
  • "Data Protection Officer" refers to Rajesh Yeluri.
  • "Device" refers to any mobile phone, tablet or other device capable of running the Software.
  • "Held Information" means:
    • The personal information we hold in relation to you;
    • Why we process your personal information;
    • Who we provide access to in relation to your personal information;
    • How and if this personal information is being processed in automated decisions; and
    • The processes we use in relation to your information.
  • "Information Subject" means a person or persons whose personal information is collected by Brauz.
  • "Retailer Stores" refers to a store belonging to or associated with a Retailer.
  • "Retailer" refers to retailers with more than one physical store and/or online store which sell items or products belonging to a particular brand or items or products belonging to and sourced from more than one brand.
  • "Service" or "Services" refers to the functions, services, uses and content of the Software and the searchable directory between shoppers and retailers offering promotions.
  • "Software" refers to the Site, the Brauz IQ App, the Brauz Consumer App and the Third Party Retailer Plugin.
  • "Stores" refers to any store using the Software or Services other than a Retailer Store.
  • "Subject Access Request" means a user access request.
  • "Third Party Retailer Plugin" refers to the Software provided by Brauz which is integrated by the Retailer or Store (as applicable) in their Third Party Retailer Site. For the avoidance of doubt, the Third Party Retailer Plugin includes the Brauz Button or if the Third Party Retailer site does not utilise the Brauz Button, any of the features or functionality of the Brauz Button.
  • "Third Party Retailers" refers to Retailers, Retailer Stores and Stores.

CONTACT

If you have any questions, comments or concerns about this Privacy Policy or our data practices please contact us in writing by email at privacy@brauz.com.

FURTHER INFORMATION

More information about Australian privacy law is available from the Federal Privacy Commissioner’s website: www.privacy.gov.au



Last update – February 2019