Privacy Policy

Introduction

This Privacy Policy explains in general terms how Accumulate Loyalty Services Pty Ltd ('Accumulate', 'we', 'our' or 'us') handles your personal information.

Accumulate is an Australian company affiliated with O.C. Tanner Company located in the United States of America and its related bodies corporate located world-wide (together, 'O.C. Tanner').

We may amend this Privacy Policy as our business requirements change or there are changes to the law or how we handle personal information. Any changes to this Privacy Policy will be updated on this website. We may also issue specific privacy collection notices from time to time relating to particular products or services.

This Privacy Policy does not apply to Accumulate's employee records.

Our Business

This Privacy Policy applies to all products and services that comprise Accumulate's business. These are:

  1. programs and services that we operate on behalf of corporate clients, such as:
    • retail loyalty programs (such as store or credit card loyalty programs);
    • employee and member reward, recognition and incentive programs;
    • employee and member benefits programs; and
    • sales incentive programs;
  2. on-line retail for goods, services, and gift cards ordered or purchased by our customers.

Where we refer to programs and services that we operate on behalf of corporate clients (listed in point 1. above), we will use the term 'Programs'.

Where we refer to any or all of the products and services that comprise our business listed above we will use the term 'Products and Services'.

Information We Collect

The types of personal information that we collect about you will depend on our relationship with you and the circumstances of collection. The personal information may include:

If you are an employee of a corporate client who participates in a Program we may also collect information about your role with that client, your employment type, your employee number and your start date with that client.

When we collect your personal information to administer and operate a Program, we do so under specific instructions from corporate clients.

How We Collect Information

Directly: We may collect personal information about you when you place an order for or purchase goods or services from us, create an account to use our Products and Services, otherwise register to be part of and participate in one of the Programs, register to receive our communications (including subscribing to our blogs or other communication tools), visit our websites, complete one of our surveys or otherwise interact with us.

Indirectly: There may be occasions when we collect information about you from others, including:

Purpose for Using Your Personal Information

We may use your personal information for the following purposes:

If you are located in the European Economic Area ("EEA"), we use your personal information on the grounds of:

as required in providing our Products and Services and operating and administering the Programs.

Disclosure of Personal Information

We may disclose your personal information to other O.C. Tanner entities, our suppliers and third parties that perform services for us and for corporate clients in connection with the Products and Services, including those who:

We may disclose your personal information to corporate clients for whom we operate Programs (that you are member of) to allow them to administer and manage their Programs, support their Program members, and review and report on the use of their Programs. In some circumstances, this may also require us to disclose your information to related bodies corporate of the corporate clients and third-parties that provide services to the corporate clients in connection with the administration and management of the Programs.

We may disclose your personal information to comply with our legal obligations, including to:

How We Use Cookies and Tracking Images

Cookies are small pieces of data stored on the web browser on your computer or mobile device. Our website and associated websites (including those you reach by clicking on any advertising) may store cookies on your web browser.

The main reasons we store cookies are to:

If you are logged into your online account the information we collect via cookies may be linked with your personal information.

You can set up most web browsers so you are notified of when a cookie is received, so you can then either accept or reject it. You can also check the cookies stored by your web browser and remove any that you do not want.

If you disable the use of cookies on your web browser or remove or reject specific cookies from the websites or linked sites, then you may not be able to gain access to all the content and facilities of our website or linked sites.

Tracking images are small pieces of data that are down loaded when a recipient opens an email. We use tracking images to inform us when an email is opened, the Internet Protocol address and geo-location at the time of opening.

The main reasons we use tracking images are to:

You can set up your web browser to block tracking images. If you do so, then we may not be able to provide you with full customer support associated with the delivery of digital goods and services that are emailed.

How We Hold Information and Keep it Secure

We hold your personal information in a combination of hard copy and electronic files. We use third party information system providers who may store or may have access to your personal information.

We may combine personal information we receive about you in connection with one of our Products or Services with other information we hold about you in connection with that particular Product or Service. This includes information received from corporate clients in respect of a Program we operate on their behalf. However, we do not combine personal information we receive about you in connection with one of our Products or Services with other information we hold about you in connection with a different Product or Service.

We employ industry standard security measures designed to protect the security of Personal Information. When you make a purchase, order or booking, or access your online account, a secure server is used. Secure Sockets Layer (SSL) encrypts the information you send through this website.

We cannot be responsible for the acts of those who gain unauthorized access and we make no warranty we will prevent unauthorized access to your Personal Information. Additionally, the security of information transmitted through the Internet can never be guaranteed, including use of websites, emails and any mobile application.

We receive Personal Information transmitted to us through the Internet in encrypted format, when supported by our clients.

We are not responsible for any interception or interruption of any communications through the Internet or for changes to or losses of data resulting from Internet transmission.

We retain your Personal Information only as long as it is necessary and relevant to offer the Products and Services or operate or administer the Program, to comply with applicable law, prevent fraud and resolve disputes.

Disclosure of Information Overseas

In the course of providing our Products and Services, we may disclose your personal information to the following parties located overseas:

We use tools that are delivered as software as a service that requires data to be disclosed overseas, this includes:

Access & Correction of Information About You

If you would like to request access to, or correction of, your personal information we hold about you, please contact us using the contact details in the section titled 'Our Contact Details'.

We will provide you with access to the personal information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception that applies under the Australian Privacy Principles.

We may recover from you our reasonable costs of supplying you with access to this information. However, we will not charge you for the making of the request or to correct or update your personal information.

Your request to provide access to this information will be dealt with within a reasonable time.

If we refuse to provide you with access to, or correct, the information, we will notify you of our reasons for refusal to the extent required and how you may complain about the refusal.

Where you have one, you can also update your information via your online account.

In addition to the above, under certain conditions you may have the right under European Union data protection law to ask us to:

Privacy Complaints and Further Information

If you have a concern about your privacy or a query on how your personal information is collected or used, please contact us using the details below.

We will respond to your query or complaint within a reasonable time.

If you are not satisfied with our response, you may also contact the Office of the Australian Information Commissioner.

Our Contact Details

You can contact us by email at: contracts@accumulate.com.au

or by writing to us at:

Contracts and Compliance
Accumulate Loyalty Services Pty Ltd
PO Box 555
Port Melbourne Victoria 3207
AUSTRALIA


If your query relates to European Union data protection laws, you may contact our European Data Protection Officer by email at: privacy@octanner.com

or by writing to us at:

Data Protection Officer
O.C. Tanner
1930 South State Street
Salt Lake City, Utah, 84115
UNITED STATES OF AMERICA
Phone: +1 (888) 708-7080


Version Date: 26 October 2018