What personal information do we collect?
We may collect the following types of personal information:
- Email address;
- Delivery address;
- Telephone number and other contact details;
- Date of birth;
- Your photograph;
- Records of your communications and interactions with us;
- Your history of preferences;
- Payment and transaction details/history (including information about payment cards linked to our loyalty programs and associated transactions); or
(b) Any additional information about you that you provide to us, including through your use of our services, our website, our online presence or through other accounts from which you permit us to collect information; or
(c) Any other personal information that may be required in order to facilitate your dealings with us.
(d) When you use our 3rd party platform where the proposal is made, we may also collect personal information about you in the following general categories:
- Location information: If you permit an app to access location services through the permission system in your mobile device, we may collect the precise location of your device when the app is running.
- Transaction information: We collect your transaction details when you make a payment via our app or website, including the services you have purchased, the date and time of your proposal acceptance and the amount charged.
- Device information: We may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network.
- Other information: We may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a website or our app.
In addition to the information listed above, in some cases, we may collect personal information about you from third parties, including:
- When you choose to create an account or register for our app using a social media platform, such as Facebook or Google;
- When a third party has your consent to disclose your personal information to us, such as when you enter a competition or promotion administered by a third party on our behalf; and
- When it is otherwise lawful for a third party to disclose your personal information to us.
How do we collect your personal information?
We may collect personal information either directly from you, or from third parties, including when you:
- Accept our proposal to engage our services;
- Interact with our website or social media pages;
- Interact with our online advertisements;
- You share information with us from other social applications, online services or websites or in person; or
- Interact with us and provide personal information by any other means, either physically or electronically.
Why do we collect, use and disclose personal information?
Our handling of your personal information will vary depending upon how you engage with us. Personal information collected may be used for a number of purposes connected with our business operations. We may collect, hold, use and disclose your personal information for the following purposes:
- To provide you with a product or service which you have requested from us, including processing payments and delivering the product;
- To maintain and improve the functionality of our services, including our app or website. This includes the compilation and analysis of statistics and trends, the provision of information to you relating to the content available and any transactions conducted via our app or website;
- To fulfil obligations in respect of any agreement between you and Clover;
- To manage and facilitate payment of such;
- To send you any technical, administrative or legal notices;
- To provide you with information about your transactions;
- To provide marketing materials and information about our products and services, events, special offers, competitions and promotions via any medium including mail, telephone and, where you have opted in, electronic messages or any other form of electronic, emerging, digital or conventional communications channel, or to request your feedback for promotional purposes, including information sent by, or on behalf of, our business partners;
- To maintain our relationship with you (including but not limited to, providing refunds, verifying your identity, maintaining and updating our records and communicating with you);
- To respond to enquiries, complaints and to provide other customer support services;
- To provide, maintain and improve our products and services;
- To facilitate our business operations, including fulfilment of all legal and regulatory requirements, to resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;
- Where the law requires or authorises us to do so (whether in Australia or overseas) and as directed by relevant federal, state and territory authorities;
- To share with trusted third parties including professional service providers, our related bodies corporate, our franchisees, our suppliers and our promotional partners and other trusted third parties (and their directors, servants and agents) and agencies;
- To connect with you via social media, which may include Facebook Custom Audiences and Facebook Lookalike Audiences;
- Facebook Custom Audiences: If you use Facebook, we may use your email address in an encrypted format to match with your Facebook profile so that we can provide you with personalised advertising on Facebook. This is subject to the privacy settings you have chosen on Facebook;
- Facebook Lookalike Audiences: If you use Facebook, we may use your email address in an encrypted format to enable Facebook to find other registered users of their services that share similar interests to you based on how you interact with us and what information Facebook has about you. This is subject to the privacy settings you have chosen on Facebook;
- To share with your social media communities, to the extent allowed by you; and We may monitor and record your communications with us (including email and telephone) for security, dispute resolution, and training purposes and we also operate video and audio surveillance devices in or around our premises.
We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information to enable it and us to develop anonymised consumer insights so that we can better understand your preferences
To whom do we disclose your personal information?
Clover may share personal information with:
- Our employees and related bodies corporate;
- Third party suppliers and service providers;
- Professional advisers, dealers and agents;
- Our existing or potential agents, business partners or partners;
- Specific third parties authorised by you to receive information held by us; and/or
- Other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.
Trusted third parties may be engaged by us to perform a variety of functions, such as fulfilling orders, conducting market research, processing credit card payments, assisting with promotions, data storage and providing technical services for our services. These companies may have access to personal information if needed to perform such functions. However, these companies may only use such personal information for the purpose of performing that function and may not use it for any other purpose.
Do we disclose your personal information overseas?
We are based in Australia, so your personal information will largely be processed and stored in Australia. We may exchange your personal information with service providers engaged to assist with services including data processing, data analysis, information broking, credit reporting, online computing, printing, contact management, legal, accounting, business consulting, marketing, research, auditing, archival, delivery, security, investigation and mailing services.
The 3rd parties to whom we disclose your personal information may be located in other countries.
Whilst we will take all reasonable care and steps to ensure that our overseas service providers handle your personal information securely, you acknowledge that by agreeing to the disclosure of your personal information to these overseas entities for the purposes stated in this policy, we will not be held accountable for any breaches of Australian privacy law by an overseas recipient.
Using our website and cookies
As you navigate and access our App and website, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as cookies, internet tags or web beacons, and navigational data collection (log files, server logs, and clickstream data). For example, we may collect information about matters including but not limited to the date, time and duration of visits when using our app. This information is generally not linked to the identity of visitors, except when the app is accessed via personalised links in an electronic message (such as an SMS or email) we have sent or where we are able to uniquely identify the device or user accessing our App via other means.
Our web servers gather your IP address to assist with the diagnosis of problems or support issues with our services. Information is gathered in aggregate only and cannot be traced to an individual user.
We may combine your anonymous or personal visitor session information or other information collected through tracking technologies with other personal information collected from you from time to time, to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing our app or website via links in an email we have sent and/or by accessing our app or website where you have identified yourself, you consent to the collection of such information where it is personal information.
We may use third party advertisements in our app or websites. All third party advertising, if paid for, is paid for by the relevant third party advertisers. Third party advertisements are not recommendations or endorsements by us or any of its affiliates. To the extent permitted by law, we are not responsible for the content (including representations) of any third party advertisements in our app or website. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign.
Mobile platforms such as iOS and Android generally define certain types of information or data that applications cannot access without your consent. Each platform has its own permissions system for obtaining your consent. For example, the iOS platform generally alerts you the first time Clover wants permission to access certain types of data, such as location services and will let you choose whether or not to consent to that request. Android devices will generally notify you of the permissions that an app seeks before you first use the app. Your use of the app constitutes your consent. You can generally manage your platform level permissions via the Settings section on your device. For more information, please contact your device provider or refer to the user manual for your device.
We do not intend to collect personal information from any person under the age of 18 years without the consent of a parent or legal guardian. We urge parents to regularly monitor and supervise their children’s online activities.
Security of personal information
We may hold your personal information in either electronic or hard copy form. 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 several physical, administrative, personnel and technical measures to protect your personal information. All information is passed through to a secure server using encryption technology and stored on secure servers that are protected in controlled facilities, which in some cases may be overseas. Our employees and data processors are obliged to respect the confidentiality of any personal information held by us. We will take appropriate measures to destroy or de-identify personal information that is no longer needed for any lawful purpose. These measures may vary depending on the type of information concerned, the way it is collected and how it is stored. There may be circumstances relating to employment or inappropriate or legal conduct that prevent us from permanently deleting your personal information. For example, in the case of fraud or where litigation has been threatened.
Please note however, we cannot guarantee the security of your personal information. The security of communications over the internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. We will not be held responsible for events arising from unauthorised access to personal information beyond our reasonable control. Please contact us if you become aware of, or suspect, any breach of security.
If we become aware of a data breach that is likely to result in serious harm (for example, your personal information was shared with unauthorised persons) we will notify you as soon as is practicable and the Office of the Australian Information Commissioner about that actual or possible breach (where appropriate to do so).
How can you access or correct your personal information?
You can access the personal information we hold about you by emailing to our Privacy Officer, details below. Sometimes, we may not be able to provide you with access to all your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information. If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.
How do you make a complaint?
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us by emailing our Privacy Officer, details below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you think that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
For more information about privacy issues in Australia and protecting your privacy or if you are not satisfied with how we deal with your complaint, you may refer it to the Office of the Australian Information Commissioner (“OAIC”).
You can contact OAIC by:
- Visiting www.oaic.gov.au, available here;
- Forwarding an email to firstname.lastname@example.org;
- Telephoning 1300 363 992; or
- Writing to OAIC at GPO Box 5218, Sydney NSW 2001.
Queries regarding privacy should be directed to the Privacy Officer:
Lvl 23 Collins Square Tower 5
727 Collins Street