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Privacy Policy

Fligno ("we","our", "us”,”Fligno”) and are collectively committed to respecting the privacy of your personal information.

This Privacy Policy explains our policy for dealing with personal information that we collect through the following channels (here and after, the Collection Channels):

  • our online properties (here and after, each a "Website"), including:
    • any Fligno website;
    • any of our related websites, social media pages, internal websites; and
    • any Fligno mobile or tablet applications;
  • any other means through which an individual provides personal information to Fligno, including either physically or electronically; and

any other means through which we lawfully collect personal information about you. You may contact us with any queries you may have in respect of this Privacy Policy or your personal information by contacting Flignos’ privacy officer via email: 

Personal information is important to us

  • We are committed to safeguarding your personal privacy. We recognise that you have a right to control how your personal information is collected and used. Providing personal information is an act of trust and it is taken seriously. Unless given consent to do otherwise, we will only collect and use personal information as set out below.
  • Throughout this Privacy Policy, we refer to your 'personal information', which means information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Your full name, gender, date of birth, home address, home telephone number, mobile telephone number, email address and workplace contact details are examples of information which may constitute personal information. Personal information may also include information we may collect about your individual preferences. Fligno also business information from sole proprietorships that apply for membership and for program participation, some of which could constitute personal information, as well as personal information from individuals acting solely in their business capacity.
  • Fligno has developed and implemented its Privacy Policy with respect to personal information to reflect world best practice on privacy policies. These principles meet and exceed the requirements of the Privacy Act 1988 (Cth) (as amended) and the 13 Australian Privacy Principles (“APP”).
  • In order to keep up with changing legislation and best practice, we may revise this Privacy Policy at any time without notice. We will post any changes to this Privacy Policy on our Websites, so we encourage you to check this Privacy Policy from time to time.
  • In addition to the provisions of this Privacy Policy, there may also be specific and additional privacy and consent provisions that apply to certain Collection Channels. Because those specific and additional provisions also relate to your privacy protection, we recommend that you review them wherever they appear. In the event of any inconsistency between the provisions of this Privacy Policy and those other specific and additional provisions, the specific and additional provisions will prevail.

Anonymity and pseudonymity

  • Where practicable, we will allow you to deal with us on an anonymous or pseudonymous basis. If this is practicable, our Collection Channels will only seek information in this way. However, where it is not practicable for the purposes for which information is collected, we will seek the information identified below. It will not be practicable to deal with you on an anonymous or pseudonymous basis when we wish to send you direct marketing materials or need to provide you with goods or services requested by you.

Kinds of Personal Information Fligno Collects and Holds

  • Personal information that may be requested includes, but is not limited to:
    • contact information such as your full name, telephone number, mobile telephone number, current and valid email address, business address, drop off addresses, billing address and postcode;
    • more detailed contact preferences;
    • your gender;
    • your Apple AppStore and/or Google Play Store ID and your unique device identifier (UDID);
    • location information;
    • financial details including your bank account, PayPal or other electronic payment details;
    • transaction data including the details of any products or services you have purchased from our partners through the Website;
    • your online behaviour and interests based on your online browsing activity;
    • demographic information such as age group, preferences and interests;
    • information about your preferences, interests, and experiences with our products or services. This information is collected in order to tailor our communications to you and continuously improve our products and services;
    • information about your experience with our products or services or third party products or services listed on a Website;
    • the contact details of third parties. If you are asked to provide details about other people, please ensure that these individuals are happy for their details to be given to Fligno and used for the purposes set out in this policy (which may include using their details for marketing purposes); and
    • any other personal information which you provide directly to us. Where you provide us with unsolicited personal information, we will retain this information where it falls within our primary purposes for collection of personal information (as stated in this privacy policy).
  • When you use a Website, we may also collect personal information about you in the following general categories:
    • usage and preference information: we collect information about how you interact with a Website, including the pages you visit, your preferences and settings that you choose. We may do this through the use of cookies and other similar technologies that uniquely identify you;
    • device information: we may collect information about your mobile device such as the hardware model, operating system, preferred language, unique device identifier and mobile network; and
    • other information: we may also collect and log information such as your IP address, access dates and times, browser type and pages visited when you interact with a Website.

Sensitive Information

  • We will only collect sensitive information with your consent and where you provide it to us directly. Where you provide us with any sensitive information (including, but not limited to, your signature, information about your sexual orientation, medical and/or criminal history), we will only use this information for the purposes stated at the time of collection will share this information with our trusted third parties in the manner stated on the Website or in this Privacy Policy.

How Fligno Collects and Holds Personal Information

  • We will only collect or monitor any personal information about you with your consent including as provided in this Privacy Policy or if it is otherwise lawful to do so. The only personal information collected by us is what has been provided to or collected by us in accordance with this Privacy Policy or has been provided to us lawfully by third parties.

Active Information Collection

  • Personal information may be collected (and combined) via our Collection Channels if you:
    • have previously provided us with personal information prior to this Privacy Policy coming into effect, either directly from you personally or via a third party;
    • sign-up and/or register to become a member of any Collection Channel;
    • download and use a mobile and/or tablet application including Fligno App;
    • submit any content to or participate in any way via a Collection Channel, including engaging with other users or taking part in campaigns or offers;
    • subscribe to any newsletters, updates, alerts or news and media releases, or request launch or event information or information about our products or services or other information services as well as third party products or services;
    • complete and submit any forms or applications to us;
    • contact us directly in person or via any medium including mail, telephone, social media and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Message Service), IM (Instant Messaging) and email) including via the contact details listed on a Website;
    • participate in any offers, promotions, competitions, games, rewards or marketing activities or other activities offered by Fligno from time to time;
    • interact with a Website for a specific purpose;
    • interact with or browse a Website generally; or
  • Personal information is requested in order to allow you to participate in a Collection Channel, to facilitate the services undertaken by Fligno in connection with but not limited to the carriage, transport and/or the storage of goods, marketing materials (including direct marketing materials), newsletters, electronic newsletters (e-newsletters), news and media releases / launch information, and also to advise you of other Fligno or third party opportunities and products, services, offers, competitions or promotions which may be of interest. No one is obligated to provide personal information. However, failure to do so may result in you being unable to participate in a Collection Channel and Fligno being unable facilitate or provide you with certain content, products or services, products or services information, upcoming opportunities and promotion, competition, game, offer or event information or accept competition entries or other content from you (where applicable).
  • We may also obtain your personal information from legitimate third party sources and platforms including social media channels, marketing companies, targeting companies, list brokers and other data providers or organisations that share data in circumstances where it is lawful and/or you have given permission for them to do so. For example:
    • we may use services from other companies that enable us to derive a general geographic area based on your IP address in order to customise certain services to your geographic area.
    • if you connect your third-party social networking or other platform service profile (such as but not limited to Facebook, LinkedIn, Twitter, Google, Apple or Windows Live) to your Fligno registration, we may access and use your username, profile image, location information, interests, activities, ‘likes’, connection list and age for those services; and
    • we may obtain third party information relating to your advertisement interaction and viewing data, such as ad click-through rates and information about how many times you viewed a particular advertisement.
  • To customise your user experience on our Websites we provide you with the opportunity to connect, access and/or interact with third-party social networking services, such as but not limited to Facebook and Twitter. When you connect through these third-party social networking services, you are authorising Fligno to access and use certain information from your social network profile. Of course, you can cancel this service at any time by deleting the application from your social network account.

Children

  • The collection of personal information is neither intended for, nor directed to, persons who are under the age of sixteen (16) years old. Personal information will not be collected by any person who is known by Fligno to be under the age of sixteen (16) without the consent of a parent or legal guardian. Persons under age sixteen (16) may only use our Websites with the involvement and consent of a parent or legal guardian.

Passive Information Collection

  • As with many commercial websites and mobile and tablet applications, we may also collect information which tells us about visitors to our Websites. For example, we may collect information about the date, time and duration of visits and which pages of a Website are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website is accessed via links in an email we have sent or where we are able to uniquely identify the device or user accessing a Website. By accessing a Website via links in an email we have sent and/or by accessing a Website generally including when you are logged into an account, you consent to the collection of such information where it is personal information. When you receive newsletters or promotional emails from Fligno, we may use web beacons (described below), customised links or similar technologies to determine whether the email has been opened and which links you click in order to provide you with more focused email communications or other information.
  • As you navigate through our Websites, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies, such as Unique Device Identifiers (UDI), cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). In certain circumstances, this information may be considered anonymous information or personal information under the Privacy Act 1988 (Cth). This is dependent on the device used and the method by which you connect to the Internet and the Website. Your Internet browser automatically transmits some of this anonymous information or personal information to the Website, such as the URL of the website you just came from, the Internet Protocol (IP) address, the UDI (if applicable) and the browser version your device is currently using. Our Websites may also collect anonymous information or personal information from your device through cookies and Internet tags or web beacons. You may set your browser to notify you when a cookie is sent or to refuse cookies altogether, but certain features of a Website might not work without cookies and this may limit the services provided by a Website. Cookies and other technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf.
  • Our Websites may use and combine such passively collected anonymous information or personal information and/or information from various third party sources, including as described above, and may combine this anonymous information or personal information with other personal information collected from you to provide better service to Website visitors and users, customise a Website based on your preferences, compile and analyse statistics and trends, provide you with relevant advertising when you visit a Website or a third party website, and otherwise administer and improve a Website for your use. We may combine your visitor session information or other information collected through tracking technologies with personally identifiable information from time to time in order to understand and measure your online experiences and to determine what products, promotions and services are likely to be of interest to you. By accessing a Website, you consent to information about you being collected, compiled and used in this way.
  • For more information about cookies and how you can opt out, you can visit http://www.youronlinechoices.com.au/.

Platform permissions

  • Mobile platforms such as iOS and Android generally define certain types of information or data that applications cannot access without your consent. Each platform has its own permissions system for obtaining your consent. For example, the iOS platform generally alerts you the first time a Fligno app wants permission to access certain types of data, such as location services, and will let you choose whether or not to consent to that request. Android devices will generally notify you of the permissions that an app seeks before you first use the app, and your use of the app constitutes your consent. You can generally manage your platform level permissions via the Settings section on your device. For more information, please contact our Privacy Officer at the details set out in this policy.

Purposes for which Fligno collects, holds, uses and discloses personal information

  • Personal information collected will be used for the following primary purposes:
    • To facilitate the services undertaken by Fligno in connection with but not limited to the carriage, transport and/or the storage of goods.
    • For the purposes stated in a privacy collection statement on a particular Collection Channel.
    • To maintain the functionality of a Website, including the provision of information to you relating to the content available on the Website and e-commerce transactions conducted via the Website.
    • To send you any technical, administrative or legal notices important to our Websites.
    • To allow you to create an account, sign in and use the functionality of a Fligno Website.
    • To allow you to respond to and participate in offers and competitions.
    • To conduct competitions or promotions and communicate offers either for us or third parties.
    • For internal record keeping including site usage and administration of our products and services.
    • To provide you with information about your transactions, content, services and products.
    • To provide direct marketing materials, events, offers, competitions, games and promotions in person and via any medium including mail, telephone and commercial electronic messages (SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, push notifications) or any other form of electronic, emerging, digital or conventional communications channel.
    • To render services related to our company (such as after sales services and enquiries).
    • To provide you with newsletters via mail and electronic newsletters (e-newsletters) via commercial electronic messages.
    • To respond to customer enquiries, complaints and complaints handling.
    • To improve Website and system administration.
    • To obtain opinions or comments about products and/or services and to conduct other research and development.
    • To verify your identity.
    • To investigate complaints made by you or if we have reason to believe that you are in breach of our Terms or otherwise engaged in unlawful activity.
    • To record statistical data for marketing analysis and to conduct market research.
    • To share personal information with any sub-Contractor or Agent of Fligno, or any agent or sub-Contractor of a sub-Contractor of Fligno for the legitimate purposes of fulfilling the undertaking by Fligno in connection with but not limited to the carriage, transport and/or the storage of goods.
    • Any other purpose as may be deemed reasonably necessary by Fligno in the circumstances.
  • For the purposes described above, personal information may be shared within Fligno, any servant or agent or sub-contractor of Fligno or any servant or agent of any sub-contractor or by any other person and any such arrangement required to fulfill the undertaking by Fligno in connection with but not limited to the carriage, transport and/or the storage.
  • Failure to provide personal information may result in Fligno being unable to fulfil any undertaking requested of them.
  • In order to operate a Website or deliver a service (including for example, processing of credit card payments), personal information may also be shared with selected service providers and their related bodies corporate, and/or other trusted third parties either in Australia or overseas countries. Fligno selected service providers and/or other trusted third parties may be engaged by Fligno to perform a variety of functions, such as email systems providers, legal and accounting services, data storage, fulfilling orders, conducting market research, processing credit card payments, assisting with promotions or offers and providing technical services for our Websites. These companies may have access to personal information if needed to perform such functions.
  • We recognise the trust with which you provide personal information, and except as stated in this Privacy Policy or as is otherwise lawful, such information will not be used or disclosed for any other purposes without consent. However, Fligno reserves the right to use or disclose any information, including personal information, as needed to satisfy any law, regulation or legal request, to protect the rights or property of Fligno, any member of Fligno, or any member of the public, to protect the integrity of a Website, to fulfil your requests, or to cooperate in any law enforcement investigation or an investigation on a matter of public safety.

Email Offers from Fligno

  • Fligno provides a service that delivers great offers direct to your inbox. Any promotional offers and direct marketing messages from us will be sent via the email address you have provided.
  • Opt-In - At the point you register with Fligno you subscribe to our mailing list. By subscribing to our mailing list you are opting-in to us using your personal information as set out in this Privacy Policy. You may also be asked to opt-in to receive further information or communications from our advertisers and partners.
  • Opt-Out - When you opt-out of our email services, your mailing subscription with the specific Fligno company will be cancelled and you will no longer receive marketing communications from that company. The above steps will ensure your personal information is de-identified or permanently deleted from our records, where we no longer need it for the purposes of adhering to the APP.
  • If you receive communications purporting to be connected with us or our services that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any law, please contact our Privacy Officer (contact details set out below).

Contact by Fligno

  • Fligno of companies, any servant or agent or sub-contractor of Fligno or any servant or agent of any sub-contractor or by any other person and other selected service providers either in Australia or overseas, may contact you via telephone, SMS (Short Message Service), MMS (Multimedia Messaging Service), IM (Instant Messaging), email, post, push notification or any other form of electronic, emerging, digital or conventional communications channel using the information provided in order to contact you in respect of the primary purposes for collection of personal information as stated above.
  • Fligno does not send advertising or marketing information without obtaining prior consent, for example the consent contained within this Privacy Policy, or as is otherwise lawful. If you receive communications from Fligno which you do not wish to receive, you may unsubscribe, opt out, or request to remove your name from the database in the manner indicated in the communication, including by utilising the functional unsubscribe/opt-out facility (if the communication is via commercial electronic message) or by contacting Fligno at the contact details in this Privacy Policy. Please allow 5 working days for this request to be processed.
  • Despite removing your name from the database from receiving future advertising and marketing information, Fligno may send you non-commercial “Administrative Emails”. Administrative Emails relate to a Fligno user account and may include administrative and transaction confirmations, requests and inquiries or information about a particular Fligno user account. If you do not wish to receive such communications from Fligno, you may remove your name from the database by utilising the functional unsubscribe facility.

Ability of others to view information

  • Fligno may provide areas on a Website where you can upload user-generated content, post or provide information about yourself, communicate with other users, utilise functionalities that allow you to post content to your own social media channels, or interact with particular content. This information may be shared with others and may be publicly posted on our Websites, including without limitation, other social media platforms and other public forums in which you choose to participate. This information may become publicly available and may be read, collected and used by others either on our Websites or outside of our Websites. Fligno is not responsible for the conduct of others who may read, collect and use this information.

Changing and deleting the information we have about you

  • Information contained on the database may be amended, or your preferences for contact from us changed, by contacting Fligno’s privacy officer at the contact details contained in this Privacy Policy. Please allow 30 days for this request to be processed.
  • We are not responsible for removing your personal information from the lists of any third party who has previously been provided your information in accordance with this policy.

Storage and security of personal information

  • Fligno will endeavour to take all reasonable steps to keep secure any personal information recorded and to keep this information accurate, up to date, complete and relevant. We ensure only those necessary have access to your personal information. Personal information is stored on secure servers that are protected in controlled facilities. This service may be performed on our behalf and data may be hosted by our selected data storage providers. In some cases these facilities may be overseas.

Related Fligno Websites

  • All Websites operated by Fligno will adhere to this Privacy Policy. The policies on the Websites of some members of Fligno may vary, however, because of local customs, practices or laws.

Sale of the Company

  • If Fligno merges with, or is acquired by, another company, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

Problems or queries

Please allow 30 days for this request to be processed. If you do not receive a satisfactory response from Fligno to your query, problem or complaint within 30 days, you may refer your query, problem or complaint to the Office of the Australian Information Commissioner via the contact details listed at http://www.oaic.gov.au/about-us/contact-us.

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