Privacy Policy

Updated 13 July, 2018

1.             Overview

In this Privacy Policy, 'us', 'we' or 'our' means Funlocka Pty Ltd (ACN 616 476 656) and our related bodies corporate.

Your privacy is important to us and we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) (Privacy Act), which includes the Australian Privacy Principles and any related privacy codes.

This Policy applies to all personal information collected via our mobile application known as "Funlocka", our social media outlets and our website ( (together referred to as the Online Services) and does not apply to employee records of our current or former employees, which are exempt from the Privacy Act.

Please read this Policy carefully and contact us using the details below if you have any questions.

2.             Consent


You may refuse to give us your consent, and you may withdraw your consent, to some or all of the purposes in this Policy. However, if you do so:

(a)  we may not be able to provide our Online Services to you; and

(b)  you may need to stop using our Online Services.


3.            The types of information we collect

3.1          Personal information

Personal information is information or an opinion about you or from which you can be reasonably identified.

We may collect the following types of personal information about you:

(a)  your name, gender, delivery address, email address, phone number, age or date of birth;

(b)  information about your working practices, such as your employment details and job title;

(c)  your device ID, device type and information, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, Internet Protocol (IP) address and standard web log information;

(d)  details of products or services which we have provided to you or about which you have enquired;

(e)    information contained in any communications between you and us;

(f)  photos and images that you provide through our Online Services; and

(g)  any information about you that you provide through our Online Services, including information you provide if you participate in a survey, promotion or competition.

3.2          Sensitive information

Sensitive information is a form of personal information and is information or an opinion of a sensitive nature.

We may collect the following types of sensitive information:

(a)  ethnicity;

(b)  religion;

(c)  political affiliation;

(d)  sexual orientation;

(e)  health information;

(f)   genetic information; and

(g)  criminal history.

We will only collect, use or disclose your sensitive information if it is reasonably necessary to carry out our functions or activities and we have your consent.

4.             Why we collect and use your personal information

We collect and use your personal information through lawful and fair means so we can perform our business activities and functions.

Your personal information is collected and used for the following purposes:

(a)  to provide you with our products and services, including accepting and processing your orders, delivering orders and providing refunds or discounts;

(b)  to give you information about our products and services;

(c)  to interact with you;

(d)  to create your account;

(e)  to allow you to share your experiences of our products and services;

(f)    to administer surveys;

(g)  to connect you with our business partners;

(h)  to send you promotional and marketing information, including information sent by our business partners;

(i)    to administer rewards or other promotional activities sponsored or managed by us or our business partners;

(j)    to conduct product and market research;

(k)  to develop consumer insights so we can better understand your preferences and interests, personalise your experience and enhance the products and services you receive;

(l)    to send you service, support and administrative messages, reminders, technical notices, updates, security alerts and information requested by you;

(m) to perform administrative and operational functions;

(n)  to comply with any legal requirements;

(o)  for any related purpose for which we are entitled to use your personal information; and

(p)  for any other purpose for which you give your consent.

5.             How we collect your personal information

5.1          You give it to us

We collect personal information directly from you when you:

(a)  use our Online Services;

(b)  set up an account with us;

(c)  share personal information with us via our Online Services;

(d)  communicate with us;

(e)  participate in one of our surveys, promotions or competitions;

(f)    interact with our Online Services and advertising; and

(g)  purchase one of our products or services.

5.2          We collect it

We also use cookies to collect personal information when you use our Site. We explain our use of cookies below.

(a)  Cookies are small data files transferred onto computers or devices by websites.

(b)  When you use or access our Site, we may collect information by sending and storing cookies from our Site to your device.

(c)  Cookies tell us when you visit our Site, which pages you visit and the information you download. They also remember your details and preferences so you can easily continue your browsing session when you return to our Site.

(d)  If you do not want to activate cookies, you can opt-out of receiving them by amending the settings of your internet browser, however, you may find that some parts of our Site will have limited functionality and personalisation if you do so.

5.3          We collect it from third parties

We may also collect your personal information from third parties including:

(a)  service providers;

(b)  credit reporting bodies;

(c)  marketing companies;

(d)  referrals who may have referred you to us; and

(e)  organisations with whom we have an agreement to share information for marketing purposes.

6.             Dealing with us anonymously

You may choose to deal with us anonymously or using a pseudonym in certain circumstances, such as when you contact us to make a general enquiry.

However, we may need, at a minimum, your name and contact details to allow us to handle your enquiry or request. 

7.             Disclosing your personal information and who might have access

7.1          Within Australia

We may disclose your personal information to the following third parties for the purposes described in this Policy:

(a)  our employees, related entities and employees of those entities;

(b)  our business partners, including the owners or operators of any app or platform you have subscribed for through us or in connection with us;

(c)  our professional advisers, dealers and agents;

(d)  third parties and contractors who provide services to us, including customer enquiries and support services, debt-recovery functions, information technology service providers, marketing, advertising and door-knocking services;

(e)  payment systems operators;

(f)    our sponsors or promoters of any competition that we conduct;

(g)  any third parties authorised by you to receive information held by us; and

(h)  government, regulatory and law enforcement agencies as required, authorised or permitted by law.

7.2          Outside Australia

(a)  We may disclose your personal information to our third party service providers who assist us with our business functions. These entities may have servers in and operate out of locations outside Australia. As some of these entities are of a global nature, we cannot say with certainty where their servers are located or the countries out of which they operate. Further, these locations may be subject to change without notice to us.

(b)  By providing us with your personal information, you consent to us disclosing your personal information to overseas third parties and acknowledge that we will take reasonable steps to ensure that overseas third parties deal with your personal information in a way that complies with the Privacy Act and the APP.

8.             Security

8.1          How we store and protect your personal information

We hold your personal information in hardcopy and/or electronic forms, in secure databases that are owned and operated by our third-party service providers.

We protect the personal information we hold through encryption, firewalls and login password protocols, and auditing.

While we take reasonable steps to ensure your personal information is protected from loss, misuse and unauthorised access, modification or disclosure, security measures over the internet can never be guaranteed. This means we cannot guarantee the security of your personal information. In the event of a data breach, we will comply with the required data breach reporting laws. 

9.             Links to third party websites/platforms

Our Online Services may contain links to websites, other apps and social media platforms operated by third parties.

Those links are provided for convenience and may not remain current or be maintained. Unless stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites.

The privacy policies that apply to third parties' websites may differ substantially from this Policy, so we encourage you to read those privacy policies before using those websites.

10.          Accessing or correcting your personal information

10.1      Accessing your personal information

If you would like to access your personal information, please contact us using the details below.

While we try to give you access to your personal information free of charge, we may charge you a reasonable fee to cover costs associated with:

(a)  searching for, locating and retrieving your personal information; and

(b)  reproducing and sending you your personal information.

In certain circumstances, we may not be able to give you access to your personal information. In these circumstances, we will write to you to explain why we cannot comply with your request.

We will try to respond to your request for access within 14 days of receiving your request. 

10.2      Correcting your personal information

We try to ensure any personal information we hold about you is accurate, up-to-date, complete and relevant.

If you believe the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or incorrect, please contact us using the details below and we will take reasonable steps to ensure it is corrected.

We will try to respond to your request for correction within 14 days of receiving your request.

11.          Destroying or de-identifying personal information

We destroy personal information when we no longer need it, unless we are otherwise required or authorised by law to retain the information.

12.          Making a complaint

(a)  If you believe your privacy has been breached or you have a complaint about our handling of your personal information, please contact us using the details below.

(b)  We take privacy complaints seriously. If you make a complaint, we will respond within a reasonable time to advise you of the person responsible for managing your complaint. We will try to resolve your complaint within 30 days. When this is not reasonably possible, we will contact you within that time to let you know how long we will take to resolve your complaint.

(c)  We will investigate your complaint and, where necessary, consult with third parties about your complaint. We will decide how to address your complaint and write to you to explain our decision.

(d)  If you are not satisfied with our decision, you can refer your complaint to the Office of the Australian Privacy Commissioner and/or other state bodies. Details about how to file a complaint can be found at

13.          Changes

We may, from time to time, amend this Policy, in whole or part, in our sole discretion.

Any changes to this Policy will be effective immediately upon the posting of the revised Policy on our Site.

Depending on the nature of the change, we may announce the change on our Site home page or by email (if we have your email address). However, in any event, by continuing to use the Online Services following any changes, you will be deemed to have agreed to such changes.

14.          Contact us

All questions or queries about this Policy and complaints should be directed to:

Privacy Officer


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