PointsPanel Privacy Policy- Australia

Effective:  June 16th 2015

This privacy policy (“Policy”) describes the commitment that PointsPanel Ltd (“we”, “us”, “our”) makes to protecting your privacy. This Policy applies to all Australian participants in our research study (“Study”) that download and install a small data collection software application (the “Application”) to their mobile device.

If you have any additional questions regarding this Policy, the Study or the Application, you may contact us using the details noted at the end of this Policy.

Personal Information
Throughout your participation in the Study, we may collect both non-personally identifiable information and personally identifiable information from you as described below. Any information or opinion that identifies you or that enables your identity to be ascertained is considered to be “personal information” for the purpose of this Policy. We collect and use personal information only to the extent permitted by law, particularly the Privacy Act 1988 (Cth) (the “Act”) and the Australian Privacy Principles.

As part of the registration process prior to installation of the Application or in connection with your participation in the Study, we may collect personal information such as information regarding your:

  • name;
  • telephone number;
  • email address;
  • birth year;
  • household information (including address);
  • income;
  • gender;
  • racial or ethnic origin;
  • political opinions (including participation and membership of a trade union) and religious or similar beliefs;
  • physical or mental health status;
  • sexual activity;
  • criminal history (g. whether you have, or are alleged to have, committed an offence and any proceedings – including the outcome of such proceedings – in relation to that offence);

directly from you. This information is part of your consumer profile and used as described below. At the registration stage, you are entirely free to decide whether or not to supply your name and telephone number, but the Application will not continue past registration without you providing your email address. However, if you wish to remain anonymous, you may choose to provide us with email addresses that do not include your name or any other information through which you might reasonably be identified. Further, we collect the following types of information, including personal information, through the installation of the Application on your mobile device:

  1. Answers to diary and survey questions (“Questions”), which may include:
  • Your location (such as your home or workplace)
  • If traveling, your reasons and mode of transport
  • Who you were with (such as your spouse or co-workers)
  • What general communication media were you using (such as TV, radio, the Internet or print publications)
  • What types of programming or content were you using (such as TV networks for sports, news radio, or fashion magazines)
  • What you were doing on the Internet (such as email, search, or watching video clips)
  • How you were communicating (such as talking face-to-face, texting, email, or phone)
  • How you felt (such as in a good mood or relaxed)
  1. Online browsing information, including the sites you visit and apps you use, including news sites/apps or social networks, and your interactions with them.
  2. Information regarding your online activities, which may include personal information, including:
  • Search terms and results
  • Videos you view
  • Products you shop for online
  • Information you enter into forms
  • Materials you download or upload
  • Advertisements you see
  • Information and content on sites or apps that you visit or use and with which you interact.
  1. System information, including information about the device (e.g. IP address and phone number), the browser that you are running, other applications installed or running.
  2. Mobile usage information regarding your use of the mobile device on which the Application is installed, which may include:
  • Information about your internet browsing habits – how much time you spend browsing the internet on your mobile device, the sites you visit or apps you use, and the terms of any search you carry out.
  • Information about your usage of other apps and features (such as the camera, though we do not collect any photos) on your mobile device, including the identity of the apps and features, when you downloaded them, how often you use them and for how long.
  • Your location (see below)
  • Information about the time and duration of calls you make or receive on your mobile device. We do not collect or record the content of your calls.
  • Information about when you send or receive text messages, SMS or MMS. We do not collect or record the content of SMS text or MMS messages sent and received through your phone’s native OS.
  • Information about the time emails are sent and received on your mobile device.
  • Information about the type of mobile device you own, when and for how long you charge it, its battery status, whether it is switched on, off or in a stand-by or ‘Airplane’ mode.
  • Information about which mobile network you use, which wi-fi networks you connect to, and at what times.
  • Information about the volume of data downloaded to your mobile device, the times that you download that data and the method of connection you use (wi-fi or mobile network).
  • Information we can deduce from combining the above information, for example, what apps you were using just before you searched for particular information using your mobile device’s internet browser, or how often you call, email or text a particular contact, or the geographic location in which you are most likely to charge your device, make a telephone call, or download an app.

Please note that we ‘scramble’ the numbers and email addresses of the third parties that you call, email, SMS or MMS, so that those telephone numbers and email addresses cannot be identified. However, we can tell whether the person you have contacted is already saved in your ‘Contacts’ in your mobile device.

  1. Location information, meaning data revealing the geographic location of you and your mobile device. Please note, when you first download the Application, you will be asked if you agree to your location information being disclosed to us. If you consent, we may collect this information on a semi-continuous and passive basis, which does not require any further activation on your part. You will not be notified each time we collect this information. If you wish at any stage to turn off this passive location tracking, you will need to uninstall the Application, by following all of the defined steps from the instructions set out here. The Application will not function if you choose not to allow us to access your location information.
  2. Other information you provide in response to a specific request by us (e.g. video, audio or image content). That content may include personal information, for example in the form of an identifiable image of you. You are entirely free to decide whether or not to supply this information and choosing not to provide this information will not affect the operation of the Application.

By using the Application, you will collect “points” which you are able redeem in the form of cash. In order to redeem the points you will need to create an account on our website, which requires you to provide us with an active email address. You will also need to provide us with the email address linked to your PayPal account. If you wish to remain anonymous, you may choose to provide us with email addresses that do not include your name or any other information through which you might reasonably be identified.

The above list contains examples of the type of data collected, and is not a comprehensive list of every single data element.

Collection of information
We will only collect certain personal and sensitive information, such as your email address and information regarding your ethnic or racial origin, directly from you.

We collect further information of the types noted above from you, through your use of the Application. This information can be collected by the Application:

  • prompting you to answer Questions or send us other information or data;
  • as “clickstream data”, which is information generated by you and your device while surfing the Internet and interacting with various sites, services and device functions. Mobile usage information, as described above, is collected and transmitted to us by the Application ‘in the background’. It does not require any further activation on your part. We call this ‘passive tracking’.

The Application will either install the “Meter” (a piece of software on your device to collect the data described above) and/or will establish the “VPN” (a profile on your device to direct all internet data generated by and for your device through the Application to enable us to collect the data). Regardless of whether data is collected via the Meter or the VPN, we will only use the data as described in this Policy.

Protecting Personal & Sensitive Information
As noted above, we endeavour to only collect sensitive information directly from you. With this in mind, we have established certain procedural and technical protocols designed to avoid the collection of sensitive information such as credit card and social security numbers by the Application. As part of our security program, we conduct regular checks to update and refresh these procedures and technical protocols. Despite our efforts, certain personal or sensitive information might get through the privacy rules and procedures. However, we do not knowingly use any inadvertently retained personally identifiable or sensitive information in our services. Any inadvertently collected data that we do not reasonably require for one or more of our functions will be destroyed or de-identified.

You should note that the personal information, including sensitive information, collected about you by the Application is sent to us via the public Internet. When this occurs, your personal information is encrypted on your device and transmitted to our servers via a Secure File Transfer Protocol, where it is subject to further encryption.

We may collect certain information in part through the use of a technology called a “cookie.” A cookie is a small text file that is saved to your device using your browser, which allows sites to recognize you and store preferences and other information if you return to the site using the same device and browser.
We use temporary session cookies during the download, registration process and use of our website to correctly identify the research panel that you have joined, enable the creation of a unique, anonymous identifier and to trigger the download process.
We may use cookies apart from the Application and link that data to other data in your profile, including data that is collected through your use of the Application.
You may remove cookies and/or control their operation by adjusting your browser settings. Please visit the ‘help’ section of your browser for more information.

Information Use and Sharing
We may use your personal information collected directly from you or through the Application for the following purposes:

  • to provide to, or process on behalf of, our parent company, Reality Mine Ltd (“RM”), for its use in the services it provides to its customers, as noted below;
  • to process and provide the services noted below in respect of RM on our own behalf;
  • to provide you with further information regarding maintenance and upgrades of the Application;
  • to establish an account on our website through which you are able to redeem the points you accrue through your use of the Application;
  • to pay you a cash amount, on redemption of your points, into your PayPal account;
  • to notify you of other matters related to your use of the Application or participation in the Study, including information related to Application maintenance and upgrades and other service related communications;
  • to notify you of any changes to this Policy.

We may use personal information supplied by those who make a specific request for the purpose of responding to that request.

As noted above, we disclose the personal information you provide to our parent company RM, which is located in the United Kingdom. RM may use your personal information in one of the following ways.

Typically, RM will combine participants’ data into consumer segments, which are pools of users who have common interests or characteristics, for example, “women between the ages of 28-34 interested in travel websites.” Once aggregated, the results and consumer segments are shared with RM’s clients and other parties as described in this Policy. On some occasions, RM may share non-aggregated results for limited purposes. The following are examples of the kinds of services RM provides, and how your data is used in these services:

Advertising Research – Your data is combined with data from other users into a pool that is then analysed for exposure to certain advertising. Information about the combined pool, which does not identify any particular user and so is not personal information, is shared with clients so they can understand if and how their advertising spending impacts the consumer journey and consumer decisions. For example, by comparing the behaviours of a group of users who saw a particular online advertisement with another group of users who did not see that advertisement, RM can help advertisers understand the effectiveness of their ads. The service may also modify or replace content or ads that you see as part of a market research study.

Media Use Analysis – Your data is combined with data from other users to form consumer segments that are shared with clients without identifying any particular user. These segments are typically analysed by RM on behalf of clients to understand where consumers go online and how consumers interact with digital media, which includes website content, apps and advertising that they see. For example, RM helps companies understand the effectiveness of their websites or apps by comparing how users are interacting with their websites or apps versus how users are interacting with their competitors’ websites or apps.

Profile Building – RM may use the personal information you provide to us outside of the Application or an anonymous identifier associated with you (such as an IP address or similar identifier) to get additional information about you from other public and private data sources. These third party data sources may provide RM with information on your purchases (both online and off-line), your household and lifestyle information, and broader demographic and personal history details. RM may combine this information with other information to create and enhance profiles that are shared as described in this Policy. For example, by looking at both web browsing activity and in-store purchases, RM’s research may identify a consumer segment whose members visit certain websites when they are in the process of researching a product (like a television, computer, or automobile) but are likely to make the actual purchase in a physical store. This data can help the manufacturer or seller of that product better understand where to find customers who may be interested in their products.

Targeted Surveys – we may send you invitations to participate in surveys on the basis of your online behaviours collected by the Application. For example, if you visit sites that suggest you enjoy travel, we may send you a survey regarding travel services. We may provide RM with some or all of the responses to these surveys, and RM may provide this information to its clients without directly identifying any particular user, including specific answers and quotes from individual respondents.

RM also may use your information for the purpose of database or Application services (such as customer support, email, or surveys) or, in a de-identified form, for purposes of maintaining the configuration and proper functioning of the Application.

Additional Disclosure of your Information
In the event that we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your information may be among the assets transferred.

We also reserve the right to disclose your information as required by law, court order, or legal process served on us, when we believe that disclosure is necessary to protect our rights, or to combat suspected fraudulent activities.

Application Removal
You can remove the Application from your device at any time. Please note that the Application may still continue to operate and collect and send data to us even if you use the “private browsing” or similar setting on your browser. To completely stop the operation of the Application and the collection of data from your device, you must remove the Application.
For instructions on how to do so, please read and follow all defined steps of the Application Removal Instructions, available here .
If you are not able to quickly and easily opt-out from data collection, we can and will help you if you ask. If you have any questions regarding removal or opting-out, please contact us using the contact details noted below.

Data Security
We have put in place reasonable administrative, technical, and physical safeguards to protect against unauthorized access to the information we collect. However, no security measures are 100% impenetrable and we cannot guarantee against all potential security breaches. Moreover, the transmission of information over the Internet is not inherently secure, so we cannot give an absolute assurance that the information you provide to us will be secure at all times. We will not be held responsible for unauthorised access to your personal information where we have taken reasonable steps to protect and secure that information.

Please note that we and RM store your personal information on servers in the Republic of Ireland and the United Kingdom. If you provide personal information to us, either directly or through your use of the Application, you also consent to the transfer by us of your information to those servers. However, this does not change any of our commitments to safeguard your privacy to the standard required by the Australian Privacy Principles.

Data Access Rights
You are entitled to request access to your personal information held by us and to correct that information if you believe it to be out of date or incorrect. If you would like to access or correct the personal information we hold about you, you should contact us with your specific request using the contact details in the Contact Us section below.

Data Retention
We will retain the information described above for as long as the information has value to us or RM, or as long as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, whichever is longer. If you opt out of the Study by following the directions to remove the Application as described above in the Application Removal section, we will stop collecting data from you, but we will retain and continue to use the data, including personal information, collected prior to your removal of the Application.

Children’s Privacy
We do not seek to collect personal information from users under the age of 15 for use in connection with our online research panels.

Privacy Policy Changes
We reserve the right to amend this Policy at any time.
If we are going to use your personal information in a manner materially different from that stated in this Policy at the time of collection, you will be notified via email or via the Application by us. You will have a choice as to whether or not we use your information in this different manner and instructions for how to make that choice will be included in the notification.
If we make any non-material changes to our privacy practices that do not affect information already stored in our database or for future collection, we will post a prominent notice on our website notifying you that there has been a change and pointing you to the revised privacy policy.

Making a complaint
If you have any concerns about how your personal information has been collected, used or disclosed, and you wish to make a complaint about a possible breach of this Policy, the Act, Australian Privacy Principles, or other privacy laws, you can contact the Complaints Manager via complaints@pointspanel.com.

The Complaints Manager will investigate your concerns and take any necessary steps to resolve your complaint. We may need to contact you if we need further information to investigate your complaint and will advise you of the outcome of the investigation as soon as it is completed.

If you are not satisfied with the outcome of the investigation, you can contact us again to discuss your concerns, or you may complain to the Australian Privacy Commissioner via www.oaic.gov.au.

Contact Us
If you have any queries relating to this Policy, or a problem or complaint that you would like to discuss with us, please contact our Complaints Manager by emailing complaints@pointspanel.com or sending a letter to Points Panel Ltd, Warren Bruce Court, Warren Bruce Road, Manchester M17 1LB UNITED KINGDOM.