This policy sets out how and why P4P (we, us, or our) collect, use, hold and disclose your personal information (which we call information). This policy does not apply to any information that is not ‘personal information’ as defined in The Privacy Act of 1974 (Cth) (Privacy Act), despite us using the term ‘information’ in this policy.
Why is your information important to us?
Your information is important to us as we may require it in order to conduct our business and provide our services to Members who sign up to our app/website as well as for Merchants and Causes that we facilitate donations to. Some of the Key Services we provide include (but are not limited to) the following:
- Making our app/website available to Members to facilitate donations from Merchants to Causes when the Member purchases products from the Merchant. In this regard, we will collect information from Members when they create accounts in our app/website, set their preferences in the app/website and provide us with other information via the app/website;
- Providing marketing services to Merchants who sign up with us. In this regard, we will collect information from Merchants when they sign up with us (whether via our website, by email or in-person and potentially via the app/website in the future), when Members purchase products at the Merchant and when the Merchant interacts with the app/website or contacts us to assist in marketing activities;
- Facilitating donations by Merchants when Members purchase products In this regard, we will collect information from Merchants to facilitate these payments and will pass on information relating to Members to the participating Causes so that they know who is donating money to them;
- Continually enhancing and improving our offering to our Merchants, Causes and Members and to contact them to let them know of any new product offerings or benefits we can provide to them. In this regard, we strive to continually improve our business and the services we offer and will collect information from Merchants and Members via the app/website, in person, over the phone and via email to achieve that goal;
- Complying with all applicable laws and regulations and our obligations to Merchants, Causes and Members; and
- Engaging with service providers or Merchants as needed, from time to time, to allow us to conduct our activities, including those referred to above.
- Our Key Services also include any functions or purposes that we may specify to you at the time of requesting the information, as well as any other functions or purposes for which you provide us the relevant information. We may also need information to perform functions that are incidental to, or are otherwise reasonably necessary for us to operate our business or provide our Key Services. In order to achieve the above, we rely on you to provide us with the most accurate information to enable us to provide you with continually improving services and support.
Collecting your information
The types of information we may collect, hold, use or disclose will depend on your dealings with us. Examples of the types of information we collect are set out below.
Information you provide to us directly: we may collect and hold information you provide to us directly. For example, such information may include:
- Contact information: names (such as a customer’s name who creates an account via our app/website), addresses (such as postal or email addresses), phone numbers and details of any social media or networking profiles;
- Demographic information: gender, dates of birth, ages, nationality, titles or languages.
Transaction Data Collection and Usage
Process Member payment card as well as display their associated transaction details.
Utilise transaction data such as transaction amount, transaction time and merchant location to confirm a Qualifying Purchase or return to match transactions to confirm whether a Member qualifies for rewards
- Share transaction data with the participating Merchants where a transaction occurred as needed for the Merchant to confirm a specific transaction occurred. For example, the date and amount of a Member’s purchase and the last 4 digits of their card number so the merchant can verify the purchase with its records if there is a missing or disputed transaction;
- Provide participating Merchants or Third-Party Service Providers aggregated and anonymized information relating specifically to registered card activity solely to allow participating Merchants and Third-Party Service Providers to assess the results of their campaign;
- Create a record of the transaction data and thereafter maintain and use data in connection with operating the to facilitate the calculation and application of the cashback amount to the members e-wallet and their selected Causes.]
- Provide information in order to respond to a request from a government authority or a payment organization involved in a transaction with the Member or a Merchant.
- If the Member specifically authorizes the sharing, exchange and use of transaction data described above and herein by and among Company and Company’s Third-Party Service Providers, applicable Payment Card Networks and applicable Merchants.
By registering a payment card in connection with transaction monitoring, the Member authorizes P4P to share their payment card information with Visa, Mastercard and AMEX (Payment Networks) to confirm enrollment. The Member authorizes Visa, Mastercard and AMEX to monitor transactions on their registered card(s) to identify qualifying purchases in order to determine whether the Member has qualified for or earned an offer linked to their payment card, and for Visa, Mastercard and AMEX (Payment Networks) to share such transaction details with P4P to enable the available cardlinked offer(s) and provide offers that may be of interest to the Member. The Member may opt-out of transaction monitoring on the payment card(s) registered by navigating to the settings menu to remove any or all linked card(s).
Sensitive information you provide
We will generally not collect ‘sensitive information’ (as defined in the Privacy Act) from you, unless you provide that information to us directly.
Information from third parties
We may collect information about you from third parties, such as when a customer purchases a product from a Merchant and our payment providers notify us that the Customer purchased a product from the Merchant as this is how we match Customer purchases to the relevant Merchants and their desired Causes.
Information we create using your information
We may develop information using your information. For example, where you make a complaint, we may develop a record relating to the complaint which may contain your information.
Information we collect automatically
We may collect information about you automatically when you visit our websites, such as your IP address and device type.
We may collect information from publicly available sources such as ASIC records, including information like American credit licence and/or credit representative numbers.
Information we request
Ordinarily, we may collect information from you through in person discussions (e.g. when we speak to a Merchant about marketing matters), email, telephone, web queries (e.g. when you interact with our website), via the app/website, online application forms, contracts, event registration platforms, and social media networking platforms (such as Instagram and Facebook). You have the option not to provide any information that we request. Depending upon what information you do not want to provide, we may not be able to deal with you further on a particular matter. If you make a complaint but refuse to provide your contact information, then we may not be able to process or escalate your complaint. Where you provide us with information on request, we do so on the understanding that you consent to our collection because you have this option to refuse to provide that information.
You may have the option not to identify yourself or identify yourself by a pseudonym. However, this is not generally practical for us as we need to know who you are in order to contact and liaise with you and to ensure that you are authorised to provide credit card information to us. For example, if you wish to use our app/website, we will need to know who you are so that we can allow you to access the app/website to its fullest extent, but we have designed the app/website so that you can include a nickname (which may be a pseudonym) where your name appears on donation leader boards or the like. However, we still need your legal name when you create an account with us, otherwise we may not know who to contact in the event of a dispute. Where we collect information about you from someone other than you, this is generally because it would be unreasonable or impracticable for us to do so.
Information we do not request
Sometimes you may voluntarily provide us with information that we have not requested. If this happens, we may use and disclose the information in order to determine whether we could have collected the information had we requested it. If we consider that we could not have collected the information, then we may either destroy or de-identify that information as soon as reasonably practical where required by law.
Holding your information
Your information may be stored in hard copy, electronically or both. We do not adopt or use any identifiers that a government agency may have assigned to you. Electronic information may be stored on our computer systems and networks and on our customer relationship management platform, our accounting platform and our email platform. Our digital systems are protected by mechanisms which may include firewalls, audit logs, scheduled password changes, internal access limitation processes and internal monitoring, depending on the relevant system.
Where we store your information, we take reasonable steps to ensure it is protected from misuse, interference, loss or unauthorised access, modification or disclosure. However, we cannot guarantee that this will never occur. If a serious data breach occurs, and we believe your information has been compromised, we will assess the breach as soon as we become aware of it and take all reasonable and necessary steps as prescribed under American privacy laws. We also take reasonable steps to destroy or permanently de-identify information that we no longer need for any purpose required by law.
Retention of information
The amount of time we may keep your information will depend on the circumstances and whether we have an ongoing business need to retain it. We will retain your information for as long as we have a relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, in accordance with our internal retention policies and practices. Following that period, we will make sure such information is deleted or anonymised where required by law.
Using your information
We may use your information to perform our Key Services (outlined above) or any activities that are related (or in the case of sensitive information, directly related) to the performance of our Key Services. We may do these things without your prior consent where the law allows us to do so, including where it is impracticable for us to obtain your consent.
We may provide your information to regulatory authorities where required from time to time. We may also provide your information to third parties such as our professional advisors where they are providing services to us and such information is necessary for them to provide those services.
We may use your information to directly market our services, Membership matters, events, publications, changes, notices or offers to you. This marketing material may be sent by email, electronic direct marketing via our app/website, SMS, phone or post. We may also use information collected about you from other individuals for these purposes where it is impracticable to obtain your consent in advance. You may ‘opt-out’ or raise any concerns you may have regarding these messages by contacting us through our Website.
Disclosing your information
We may disclose your information to perform our Key Services or any activities that are related (or in the case of sensitive information, directly related) to the performance of those Key Services. This may include disclosing information to third-party service providers that we engage such as those that provide our cloud-based computing systems. We may also disclose information to external contractors (e.g. IT Contractors), but only where those contractors are accessing our records generally to help us with any issues we are having.
If you are a Customer, we will disclose limited information about you to Causes that have received donations from your purchases with Merchants, such as the amount of the donation, your nickname in the app/website and your profile photo.
We will not otherwise disclose information unless we believe we have reasonable grounds to do so or that we reasonably believe you have provided your authorisation.
You should be aware however, that we may be required to disclose information without your consent in order to comply with any court orders, subpoenas or other legal process or investigation including by tax authorities, if such disclosure is required by law. Where possible and appropriate, we will attempt to notify you if we are required by law to disclose your information.
We do not intend to disclose information overseas, unless you have provided the information to us for that purpose or where required by law. However, there are some circumstances where we may disclose information overseas such as where we use secure cloud storage services that may have servers located overseas of when you communicate with us through a social network service (e.g. Facebook), the social network provider and its partners may collect and hold your information overseas.
How can you access and correct your information?
It is your responsibility to ensure that the information you provide to us is accurate, complete and up-to-date. We may periodically, review your information to ensure that it is accurate, up-to-date, complete and relevant. Where we have reason to believe that your information may not be accurate, up-to-date, complete or relevant then we may either attempt to contact you to correct the information or deidentify or destroy the information as required by law.
You may request access to the information we hold about you, or request that we update or correct any information we hold about you or ask us to restrict or cease processing your information or even delete your information, by setting out your request in writing and sending it by contacting us through our website.
Where you make a request to access your information, we will do our best to respond within a reasonable period. While we may allow access and provide the means by which you can access your information, we may refuse the request where we are entitled to do so under the Privacy Act or at law. In this event, we will tell you the grounds for this refusal as well as suggested steps which may allow you to access your information in the circumstances of our refusal. You may complain about this refusal by making a complaint as set out below.
If you have any concerns or are unhappy about how your information is handled, please contact us at:
Telephone: +1 (800) 677-3394
Post: 1209 Orange Street, Wilmington DE 19801 USA
Upon receipt of your concerns we will designate an individual within our team who will liaise with you regarding the complaint and how it can be resolved. We endeavour to provide a response to your complaint within 30 days of receipt.
Contacting the Office of the American Information Commissioner.
Changes to this policy
This policy will be routinely reviewed to ensure it is accurate, up-to-date and complies with any and all updates under American privacy law. The current policy is published on our website or can be obtained by contacting us using the information above.
This policy was last received and updated on 26 June, 2023.