Privacy notice
Blue Light Card respects your privacy and is committed to protecting your personal information.
This privacy notice aims to give you information on how we collect, use and disclose your personal information when you use our Australian websites or mobile applications (together, the sites), use our services or otherwise correspond or deal with us.
Our sites are not intended for children and we do not knowingly collect data or personal information relating to children.
It is important that you read this privacy notice, together with any other notice that we may provide to you on specific occasions when we are collecting, using or disclosing personal information about you, so that you are fully aware of how and why we are collecting and using your personal information. This notice supplements other notices but is not intended to override them.
Your personal information will be processed either by our Australian trading entity, Blue Light Card Pty Ltd ACN 658 375 725, or our UK trading entity, Blue Light Card Ltd CRN 06581540. The type of processing being undertaken will determine which Blue Light Card entity is responsible for your personal information. References in this privacy notice to Blue Light Card, we, our, us will refer to the applicable Blue Light Card entity undertaking the processing.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO:
You have the right to make a complaint at any time to the Office of the Australian Information Commissioner (OAIC), the Australian privacy regulator (www.oaic.gov.au). We would, however, appreciate the chance to deal with your concerns before you approach the OAIC, so please contact us in the first instance.
We keep our privacy notice under regular review. This notice was last updated on 5 July 2024.
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us, through the ‘Contact’ page of our website.
Our sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies or their compliance with any privacy laws and regulations. When you leave our sites, we encourage you to read the privacy policies of every website you visit.
Information we collect
‘Personal information’ (as that term is defined under the Privacy Act 1988 (Cth)) is any information or an opinion which identifies you or could reasonably identify you, whether true or not and whether recorded in a material form or not. It does not include information that is de-identified (anonymous information).
We will collect, use and disclose your personal information in accordance with the requirements of the Privacy Act 1988 (Cth) as well as the Australian Privacy Principles made under that Act (together, the Australian Privacy Laws).
We may collect and use the following types of personal information about you:
- full name, email address, position, staff number/service number, employer;
- gender;
- financial data including your bank account and payment card details;
- email address and mobile number;
- residential address;
- copy of ID/service documents or other proof of employment;
- date of birth;
- transaction data including details of payments to and from you and other details of products and services you have purchased from any other third parties using discounts and offers from us;
- technical data including your IP address, internet service provider, geographical location, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, screen resolution and platform, and other technology on the devices you use to access our sites;
- your username and password for your account with us;
- member card numbers and member ID;
- voucher codes and QR codes allocated to you;
- preferences (including marketing preferences and details of your interests, company ‘follows’ and company ‘hides’);
- survey or feedback responses;
- usage data about how you use our sites, products and services;
- personalised redemption data relating to sales and savings;
- information, dates and times you have used our sites to login, request passwords, register on our sites; and
- information relating to offers you view and click including time/date, company, offer, newsletter offer used.
By providing your personal information to us, you consent to us handling your personal information in accordance with this privacy notice.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal information but is not considered personal information in law as this data will not directly or indirectly identify you. If we combine or connect aggregated data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this privacy notice.
Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We use different methods to collect personal information from and about you, including through:
- direct interactions, when you sign up to our service, create an account, enter a competition, promotion or survey, give us feedback, fill in forms, enter into a contract with us or correspond with us by post, phone, email or otherwise;
- your use of our sites. When you use our sites we will automatically collect personal information about your equipment, browsing actions and patterns. We collect this personal information using cookies, server logs and other similar technologies. Please see our Cookies Policy for details; and
- various third parties and public sources including third party sites, retailers featured on our site, third party platform providers, analytics providers, advertising networks and search information providers.
You may choose to sign in to our app, following initial sign in, or using a fingerprint or facial recognition. That information is collected and used at a device level and Blue Light Card will not receive or use that personal information.
Third party sites
We work with a number of third party sites to provide our service to you. We may be a joint controller with those third party sites under the applicable privacy and data protection legislation in order to track any commission payable by advertisers to us. In respect of the use and disclosure of personal information for which Blue Light Card and the relevant third party site operator are jointly responsible, you may exercise your rights against Blue Light Card, as set out below, or the relevant third party site operator, as set out in the privacy notices for those networks linked to below:
Specific uses of information you provide to us
Under the Australian Privacy Laws, we may use and disclose your personal information for the ‘primary purpose’ for which that personal information was collected. We may collect, use and disclose your personal information for the purposes of:
- registering you as a member;
- providing our services to you;
- verifying your identity, age and eligibility to use our services;
- processing and delivering any of your orders physical Blue Light Card and any items won by you in one of our competitions, along with the management of payments, fees and charges;
- managing and administering our relationship with you;
- communicating with you;
- personalising the way in which our services are delivered to you including to deliver relevant sites content, marketing communications and advertisements to you;
- measuring or understanding the effectiveness of the marketing communications and advertising we send to you, including placement of pay-per-click advertising;
- using data analytics to improve our sites, products/services, marketing, customer relationships and experiences;
- making suggestions and recommendations to you about goods or services that may be of interest to you;
- preventing fraud;
- communicating with third parties in respect of goods or services ordered by you and managing and calculating payments and commission;
- dealing with complaints and requests;
- sending marketing communications to you via email, SMS, push notification and in-account notifications;
- integrating with social media applications and websites;
- managing our relationships with our partners;
- complying with our legal obligations, including under the Australian Privacy Laws; and
- ordering our sites and/or services.
We will not use or disclose your personal information for any purpose other than the ‘primary purpose’, unless you have consented to its use for another secondary purpose, or unless we are permitted or required to do so by law.
Marketing
We aim to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.
We may use your personal information to form a view on what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us (emails and SMS messages) if you have consented to do so.
We will, in each marketing communication we send you, provide you with an option to ‘opt-out’ of that communication. You can also ask us to stop sending you marketing messages at any time by logging into your account on our sites and checking or unchecking relevant boxes to adjust your marketing preferences, or by contacting us at any time using the ‘Contact’ page on our website.
Cookies
Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.
Our sites use cookies. For more information about the cookies we use, please see our cookies policy.
Social Media
Our sites use Facebook to build audiences for retargeting and lookalike advertising campaigns on Facebook. You can also ‘like’ our sites and our service on Facebook via a button on our site.
Disclosure and sharing of your information
We may share your information with service providers, including providers of the following services:
- IT hosting or support
- CRM and systems
- Payment processing (Stripe)
- customer surveys
- live chat
- analytics and tracking services (including to track use of our codes, sales made and commission payable)
- fraud prevention
- email verification tools
- marketing activities, including segmentation and personalised marketing communications
- servicing communications and
- market research services.
We may share information with our professional advisors (including our lawyers, third party auditors and insurers).
We may disclose personal information to social media companies (such as Facebook) for the purposes for providing you with relevant advertisements and enabling you to use the ‘like’ buttons on our website.
Other payment methods are available on our site including PayPal, Apple Pay and Google Pay. Those payment providers will use your personal information in accordance with their own privacy policies available on their sites.
We may also share your personal information with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy notice.
We will disclose information if we have a legal obligation to do so.
Data processing outside of Australia
By providing your personal information to us we may disclosure your personal information to recipients outside Australia. We will only disclose such personal information overseas in connection with the purposes for which that information was collected (as set out in this privacy notice).
Personal information collected and held by us may be accessed from, disclosed to, and held outside of Australia (including but not limited to Canada, European Union, Indonesia, Japan, Singapore, the United Kingdom and the United States of America), including by other Blue Light Card entities, our third party service providers and their affiliates. Similarly, your personal information may be accessed by staff or other third parties operating outside of Australia who work with or for us, our related bodies corporate, or our other suppliers, advisors, agents or partners.
You may not have the same rights in relation to the handling of your personal information by overseas recipients as you would under the Australian privacy laws, but when we disclose information to overseas recipients, we take reasonable steps to ensure that your personal information will be held, used or disclosed in a way which is consistent with Australian law.
Data retention
We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we use and disclose your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Your rights
You have rights under the Australian Privacy Laws in relation to your personal information. If you wish to exercise any of the rights set out above, please contact us at [email protected] or by submitting a support ticket via our website or mobile apps or, as a non-logged in user, via the contact form on our main homepage.
If you wish to exercise your right to access your personal data, we have also provided a button on the My Account section on our website to enable you to easily request your personal data.
When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.
Access to your personal data
At any time you may request a copy of your personal information that we hold about you and check that we are using and disclosing it lawfully, or request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Erasure of your personal data
You have the right to ask us to delete or remove personal information where there is no good reason for us continuing to hold it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to us holding it (see below), where we may have used or disclosed your information unlawfully or where we are required to erase your personal information to comply with the Australian Privacy Laws. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Objection to use and/or disclosure
You have the right to ask us not to use or disclose your personal information for marketing purposes. We will inform you (before collecting your personal information) if we intend to use your personal information for such purposes.
Request restriction of use and/or disclosure of your personal information
You have the right to ask us to suspend the use or disclosure of your personal information if you want us to establish the accuracy of that personal information, where our use of that personal information is unlawful but you do not want us to erase it, where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims, or you have objected to our use of your personal information, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party
You have the right to ask us provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time
Where we are relying on consent to use and disclose your personal information you may withdraw that consent at any time. However, this will not affect the lawfulness of any use or disclosure carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Use of our site and services by children
We do not sell products or provide services for purchase by children, nor do we market to children. You are required to be 16 years or older in order to use our website and apps. You are required to provide a date of birth to ensure the products and services we are advertising are suitable.
Encryption of data sent between us
We use Secure Sockets Layer (SSL) certificates to verify our identity to your browser and to encrypt any data you give us. Whenever information is transferred between us, you can check that it is done so using SSL by looking for a closed padlock symbol or other trust mark in your browser’s URL bar or toolbar.