At Purkle* the security of personal information that we collect is of utmost importance to us.
Privacy Officer for a copy.
What kinds of personal information does Purkle collect and hold?
The kinds of personal information that we collect will vary depending upon our interaction with you but may include:
- your name, address and other contact details (like your telephone number);
- your email address;
- your date of birth;
- your gender;
- geographic location;
- any preferences or profiling information that you tell us about; and
- any other personal information which may be required in order to facilitate your dealings with us.
With your consent, Purkle may also collect sensitive information from you. In referring to 'sensitive information' Purkle means information relating to a person's racial or ethnic origin, membership of political bodies, religions, trade unions or other professional or trade association, sexual preferences, criminal record and health information. By way of example, some of Purkle’s profile or survey questions relate to health information. If you decide to provide Purkle with sensitive information, it is Purkle’s policy that this information will be used and disclosed only for the purpose for which it was provided (which will be advised at the time of collection) or a directly related secondary purpose, unless you agree otherwise or where the use or disclosure of this information is permitted by law.
How does Purkle collect personal information?
Generally, we collect personal information when you:
- become a Purkle member;
- complete or update your Purkle profile;
- redeem your Purkle Dollars;
- participate in a Purkle survey, competition, promotion or other marketing campaign;
- indicate that you wish to receive news, offers or other marketing material from Purkle;
- make an inquiry or a complaint;
- have other dealings with us, for example, via social media or in person, over the phone or when you write to us.
Sometimes we collect personal information about you from other sources, for example:
- our related companies which include Ticketek Pty Ltd, TEG Live Pty Ltd, Eventopia Pty Ltd and other TEG Pty Limited businesses;
- our redemption partners (Merchants);
- our business clients and their third party suppliers and contractors; and
- third party suppliers and contractors who assist us to operate our business.
Also, Purkle collects personal information about individuals who are not customers. This is usually where we collect the name and business contact details of a person who is the contact in a government agency or company with whom we deal. Purkle's policy is to only use personal information collected from non-customers for the main business purpose for which it was collected.
How does Purkle hold personal information?
Purkle may hold your personal information in electronic or hard copy format or a combination of both. This personal information may be combined or linked with other information held about you, including information that we receive from third parties. We have taken a number of physical, electronic and procedural steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
Purkle protects the personal information it collects in a secure database stored by our third party data storage provider.
Data collected online is stored in a Microsoft SQL database; a protected, secure data centre that is unreachable by the internet. Purkle also employs firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems.
Purkle employees are required, as a condition of their employment, to treat personal information held by Purkle as confidential, and to maintain the confidentiality of that personal information. They are also required to use a login and password when accessing Purkle systems and to undertake training about how to manage personal information.
What are the purposes for which Purkle may collect, hold, use and disclose personal information?
Generally, Purkle only uses personal information for the primary purpose for which we have collected it, or for another closely related secondary purpose. Our potential uses of personal information which Purkle collects (and for which you consent to us using your personal information for) may include:
- managing your dealings with us as a Purkle member;
- receiving information on opportunities to participate in Offers;
- redemption of your Purkle Dollars for Rewards;
- so that we can promote our products and services to you;
- so that the third parties we deal with can promote their products and services to you (including through direct mail – see below under the heading ‘Third Party Direct Mail’);
- to allow our related companies from the TEG Pty Limited (TEG) group to promote their products and services to you and those of their partners;
- to assist in identifying ways in which we can provide you with a better service, or enhance your experience of our website or other services;
- for business research and development of new products and services;
- to facilitate the competitions, special offers and promotions that we or our partners run;
- displaying content and advertising that are customised to your interests, preferences and experiences;
- verifying your identity;
- so that we can respond to inquiries and complaint handling; and
- to comply with our legal and regulatory obligations and enforce our legal rights.
From time to time, there may be other purposes for which we collect, hold, use and disclose your personal information. we will tell you about these at the point of collection.
Redeeming Purkle Dollars
Also, with your consent, Purkle may pass your personal information on to Merchants from whom you have received a Reward, so that the Merchant can keep you informed of future events/offers they may be providing. If you are required to make a booking with a Merchant in order to redeem your voucher, you may be asked at the time of that booking if you would like to receive this information. You may change your preference at any time by dealing directly with the Merchant which has collected your personal information. If you do not have the Merchant’s contact details you may contact our
Privacy Officer directly.
Third Party Direct Mail
Purkle has relationships with direct marketing agencies who can arrange for you to receive from their clients, direct mail marketing and promotional materials for products and services you may be interested in. Purkle will provide your name and postal address details to these direct mail companies for the limited purpose of sending you third party direct mail offers and marketing and promotional materials by post.
Where Purkle provides your postal address details to these direct mail companies, Purkle ensures that they are contractually bound to comply with applicable privacy laws in the use of your postal address details. While Purkle approves the types of marketing campaigns, it has no control over the content of the direct mail. If you do not wish to receive third party directly mail, please contact the Purkle Privacy Officer whose details are below. In your email/letter, please specify that you would like to be opted out of third party direct mail.
Sometimes Purkle extracts information from our collected records to produce aggregated data. This aggregated data does not identify individuals. Purkle uses the aggregated data for research purposes and may share the data with third parties.
Who might Purkle disclose my personal information to?
Purkle may disclose personal information it collects about you for a variety of purposes in connection with Purkle providing its products and service and Offers to you (including to our agents, contractors, to a related company of Purkle or direct marketing agencies). Purkle may provide your personal information to:
- organisations who are involved with or participating in an Offer (for example, our client who is making the Offer available via Purkle) or providing a Reward (including Merchants);
- other companies or individuals Purkle engages to perform functions on behalf of Purkle such as for production functions, mailing of information or Rewards or other gifts/ offers/ prizes, printing functions, data analysis, data washing, telemarketing, research, and advertising;
- direct mail companies, as set out above under ‘Third Party Direct Mail’;
- to other TEG Group companies and their contractors (such as data management providers). TEG group companies include the TEG Live Pty Ltd, Ticketek and any entities that may in future become part of the TEG group of companies or in which TEG may have an interest. Purkle may disclose your personal information to these entities for the purposes of, for example, ensuring that information collected is accurate, complete and up-to-date, producing anonymised and aggregated information for the benefit of other TEG group companies, and enabling us and other TEG group companies to better understand and meet your needs and interests.
Otherwise, Purkle will only disclose your personal information:
- where we are required to do so by law;
- if the disclosure is permitted under the Privacy Act 1988 (Cth); or
- if you have consented to the disclosure.
Does Purkle disclose personal information to overseas recipients?
Some of the recipients to whom we disclose personal information may be located overseas, most likely in the United States of America, Japan and New Zealand. For example, from time to time we disclose personal information to our related company, Ticketek New Zealand Ltd.
What happens if Purkle does not collect my personal information?
Purkle will not make it mandatory for you to provide personal information to us unless such personal information is necessary in order for Purkle to provide a product/service or otherwise achieve the desired outcome. Purkle may however request that you provide personal information voluntarily to Purkle (for example, as part of a competition or questionnaire).
Purkle will allow you to deal with it anonymously or using a pseudonym wherever that is reasonable and practicable.
Cookies, Tracking and Advertising
To try and identify Offers that may be of interest to you, Purkle has relationships with other companies that we allow to place advertisements on our web pages. If you visit our website, advertisement server companies may collect information such as your domain type, your IP address and clickstream information.
To the extent that the Purkle website contains links to sites operated by third parties and not related to Purkle products, services or events (Linked Websites), the Linked Websites are not controlled by Purkle. We may collect personal information from the Purkle website and Linked Websites in our role as website portal. However, we are not responsible for the privacy practices of those companies. Before disclosing your personal information to Linked Websites, we advise you to examine their privacy policies.
Access and Correction
Under the Australian Privacy Principles, you have a right to request access to the personal information that Purkle holds about you and seek its correction. If you are a Purkle Member, you are able to access or correct some of your personal information by logging onto your Purkle account (www.purkle.com.au). If you are not a Purkle member, so that your request reaches the right person, please send it our Privacy Officer. Please include your contact details such as email address and telephone number and enclose a copy of a form of identification such as a current driver's licence or passport. We will not charge you for making such a request but will let you know if there is a cost for supplying you with access to or correcting the personal information. We aim to respond to requests for access or correction within 30 days. There are certain situations under the Australian Privacy Principles where we may refuse to provide you with access to or correct your personal information but we will always let you know in writing if this is the case.
Complaints and how to contact our Privacy Officer
Our Privacy Officer can be contacted by:
e-mail at firstname.lastname@example.org
facsimile on (02) 9266 4244
letter to GPO Box 1610, Sydney NSW 2001
We will always endeavour to investigate your complaint and respond to you as soon as practicable after receipt, generally within 30 days. If you are not satisfied with our response, you may refer the matter to the Office of the Australian Information Commissioner.
Last updated 19 August 2015
*Purkle means TEG Rewards Pty Ltd, ABN 78 128 328 469 (formerly Nine Rewards Pty Ltd)
The terms ‘Offer’, ‘Member’, ‘Merchant’, ‘Dollars’ and ‘Reward’ are defined in the Terms and Conditions of Membership