Privacy

Introduction

By registering a Octopus Group account ("Account") you will be asked to provide certain personal and sensitive information ("Information") as detailed in this document and our Terms of Service.

Our Privacy Policy is based on the following principles of our provision of Octopus Group to you:

  • You can access, update or change profile information at any time.
  • You can opt out/unsubscribe at any time.
  • You can request to have your account deleted.
  • We only store profile information you choose to provide. We use the latest technologies and best practices to protect all Information from both unauthorised physical and electronic access and interference.
  • We do not permit third party business or businesses ("Business" or “Businesses”) to access your Information unless you decide to make this information available.
  • We do not forward or transfer your information to any third parties, other than the organisations detailed in this document, which are required to operate Octopus Group.
    • This disclosure is necessary to enable us to provide Octopus Group to you, these organisations are also required to respect and maintain our commitments to your privacy and security.

We are absolutely committed to these policies. This document forms part of our Terms of Service. We recommend that you read it carefully to ensure that you are entirely comfortable with the content. If you have any concerns or questions relating to this document then please send your enquiry to privacy@octopusgroup.com.au.

Information we collect

  1. We collect two broad types of information:
    1. Information that you directly provide Octopus Group; and
    2. Information about your use of, and interaction with, Octopus Group and the members portal ("Site");
  2. Information which you directly provide Octopus Group can include:
    1. the mobile phone number, email address and password you provide when registering a Octopus Group Account;
    2. Profile information;
    3. any responses you submit during survey/s or poll/s ("Activity" or "Activities");
    4. the content of any customer service correspondence you send Octopus Group;
    5. any banking or other details you provide Octopus Group when requesting a redemption; or
    6. any other information you directly provide Octopus Group through the public website or Site.
  3. Information that we collect relating to your use of, and interaction with, Octopus Group can include:
    1. your IP address and data stored in your authentication cookie;
    2. your activities, such as when you accept or skip an invitation, your participation in Activities and your progression through a particular Activity;
    3. your activity on the Site, such as when you log in to your Account, when you send customer service correspondence to Octopus Group and when you opt-in to an application;
    4. information about the device you are using to access Octopus Group (eg whether you are using a computer, mobile phone, tablet etc); or
    5. your transaction history, including your Account balance, the rewards you receive from participating in Activities and any redemptions you have requested.

How do we use the information we collect?

  1. We use profile information to publish and deliver Activities to you.
  2. We use profile information in conjunction with information obtained from sources such as your IP address and address (via Geo-Location software) to match and deliver relevant Activities to you through Octopus Group. This can include sending you emails or other online notifications to alert you of Activities for which you may qualify (if you have opted in to receiving such notifications).
  3. At times, Businesses may require access to profile information to determine the target audience for a Activity. We only provide profile information to Businesses in an aggregate and de-identified format. The responses you submit during a Activity are provided to Businesses in a de-identified format. We never provide Businesses your Account details, email address or any other personally identifiable Information unless you provide express permission to do so.
  4. As mentioned above, the responses that you submit during a Activity are provided to Businesses in a de-identified format. Octopus Group, or the Businesses, may subject these de-identified results for further analysis or use, including publication of the de-identified results.
  5. During a Activity you may be asked to provide your name, email address and other contact information. In relation to these Activities, you should note that:
    1. you are providing this Information directly to the Business and not Octopus Group;
    2. your Information will be dealt with in accordance with the relevant Business’ privacy policy and not this Privacy Policy; and
    3. you are always free to decline providing contact details to a Business.
  6. We use information relating to your activity and interaction with Octopus Group to:
    1. help detect and prevent fraudulent activity;
    2. maintain the data quality of Activity responses;
    3. improve and personalise your Octopus Group experience;
    4. maintain, operate and improve Octopus Group, the Site and associated platforms.
  7. We only ever access the authentication cookie which we place on your computer and never access or attempt to access any other cookies stored on your machine.
  8. We use all information we collect to help manage and provide Octopus Group to you, as well as maintain and constantly improve the Site, associated platforms, applications and your Octopus Group experience.

Accessing your information

  1. You can access and update or amend profile information at any time by accessing your Account via the Site.
  2. You agree to update and maintain the accuracy of any personally identifying information you provide Octopus Group, whether stored in your profile or elsewhere on the Site.
  3. You can update and change the email address with which you registered and your Account password by accessing the relevant section of the Site.
  4. A history of your activities and the rewards you have earned can be accessed in the transaction history section of the Site.
  5. For any questions relating to accessing your information or account please go to the FAQ section of the public website (www.octopusgroup.com.au), or send us the details of your inquiry to privacy@octopusgroup.com.au

Disclosure to Third Parties

  1. We will not sell, trade, give or rent any Information to a third party unless:
    1. you have expressly consented to such disclosure;
    2. such disclosure is permitted by the Terms of Service or this Privacy Policy; or
    3. required to do so by law.
  2. As mentioned above, Activity information is only disclosed to Businesses in an aggregate and de-identified format and Activity responses are provided Businesses in a de-identified format. We never provide any Information about you to a Business unless you expressly grant permission to do so. This permission will (unless otherwise indicated) generally be required on a case-by-case basis.
  3. We only disclose your banking details to our bank to action your redemption requests. This disclosure occurs in an extremely secure and protected online facility.
  4. The response data for Activities may be analysed and aggregated by Octopus Group employees in our offices located in Australia. You agree to allow your Activity response data to be processed in Australia. All Octopus Group employees are required to maintain the same privacy standards as required in Australia.
  5. Additionally, some Activities may originate from Businesses which are based outside of Australia and accordingly you agree to allow your Activity response data to be provided to Businesses which operate or are based outside of Australia.
  6. As part of our commitment to adopting best practices and procedures we have recognised the need to use third party hosting facilities which may be located outside of Australia. This arrangement aims to ensure that your information is constantly accessible and backed up in secure data storage facilities. We will ensure that any third party hosting providers used are not permitted access to your Information.

Security

  1. We are committed to providing a secure online environment to host Octopus Group infrastracture and have invested considerable resources to protecting your Information from loss, misuse, corruption and unauthorised access.
  2. All of the information collected and stored by Octopus Group is protected by firewalls against unauthorised access.
  3. Due to the nature of the internet, it is possible that information stored on our servers and data transmitted online can sometimes be accessed by unauthorised third parties. While we have made significant investments in hardware and software to ensure that this risk is minimised, we cannot guarantee that information you provide to Octopus Group will never be compromised. By accepting this Privacy Policy you indicate that you acknowledge and accept these risks.

Closing your Account

You are always able to request closure of your Account. Upon closure of your account we will provide you the option of having all data obtained through the Site deleted from Octopus Group records with the exception of information required for taxation and auditing purposes.

General

  1. Defined terms used in this Privacy Policy have the same meaning as those used in the Terms of Service. Please refer to the Terms of Service as appropriate
  2. Using Octopus Group and maintaining a Account is completely opt-in and you may request closure of your Account at any time.
  3. By registering a Account you agree that you understand and accept this Privacy Policy.
  4. In the event that you should have any complaints to make about either our privacy policies or procedures, please send them via email to privacy@octopusgroup.com.au with the subject heading “Attention: Privacy Officer”.
  5. We may change the Privacy Policy from time to time; The public website will be updated in the event of any changes.

Effective Date: 01/10/2016