Ripplebox Privacy Policy

  1. Introduction
  2. This website www.ripplebox.com.au (the Ripplebox Platform), the mobile application (the Ripplebox App) and the Services made available through the Ripplebox Platform and Ripplebox App is created and controlled by Genejeanie Pty Ltd trading as Ripplebox (ACN 666 618 757) (we, us or our).
  3. We are committed to ensuring your Personal Information is protected. We manage your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act)
  4. The Ripplebox Platform is an online management system or conduit through which a Business can create, administer and amend Referral Programs and grant Rewards to Customers on, or via, the Ripplebox Platform. The Ripplebox App is a mobile application used by Customers to earn Rewards by referring customers and clients to a Business.
  5. This Privacy Policy outlines how we collect, store, use and disclose your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.
  6. For the purposes of this Privacy Policy:
  7. Customer means a person or entity that uses the Ripplebox App to refer customers or clients to the Business through the Ripplebox App for the purpose of qualifying to earn a Reward in accordance with the Business’ Referral Program;
  8. Business means a business that uses the Ripplebox Platform to create, administer and amend Referral Programs and to grant Rewards to Customers who refer clients and customers to the Business in accordance with the terms and conditions of the Referral Program;
  9. Referral means a third party who receives a Referral Code from a Customer and gives the Referral Code to the Business.
  10. Referral Code means the unique referral code given by Ripplebox to a Customer for the purpose of making referrals to a Business.
  11. Referral Programs means the referral program created, administered and used by a Business on, or via, the Ripplebox Platform to grant Rewards to Customers who refer third parties to the Business via the Ripplebox App;
  12. Reward means the discounts, coupons, goods, services, or other items earned by Customers from a Business though the Ripplebox App, by referring third parties to the Business in accordance with the terms and conditions of the Business’ Referral Programs; and
  13. Services means the services made available by Ripplebox through the: (A) Ripplebox Platform under which a Business can create, manage and amend Referral Programs (including tracking and managing Rewards earned by Customers); and (B) Ripplebox App under which Customers can earn Rewards by referring customer and clients to the Business. 
  14. The information we collect about you
  15. Personal information
  16. Personal information has the same meaning that it has under Privacy Laws, namely, information 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 recorded in a material form or not.
  17. We collect and use Personal Information and Non-Personal Information from Businesses, Customers and Referrals who access and use the Ripplebox Platform, the Ripplebox App, the Services, and our other products and services and any other individual who interacts with us.
  18. We will only collect and hold Personal Information about Businesses, Customers and Referrals that are reasonably necessary to undertake our business activities and functions, to make the Ripplebox Platform, the Ripplebox App, the Services and our other products and services available to Businesses and Customers, or as otherwise permitted by law.
  19. Businesses
  20. We collect and hold Personal Information as well as information or data that does not contain Personal Information about Businesses who access and use the Ripplebox Platform. For example, the type of Personal Information and non-Personal Information that we collect includes:
  21. account registration details (for example, business owner’s name and mobile number);
  22. account credentials (for example, any username created by you as the account holder on behalf of the Business);
  23. Business profile (such as business name, ACN, ABN or other business identifiers, phone number, website address, description of the products and services provided by the Business and photos provided).
  24. any other content, information and other data that the Business post or submit on, or via the Ripplebox Platform;
  25. information relating to your dealings, or enquiries you have made, with us, including information about the Ripplebox Platform, Services, our other products and services or complaints Business have raised with us about a Customer; and
  26. other information that you provide to us or that we may collect in the course of our relationship with you.
  27. Customers
  28. We collect and hold Personal Information as well as information or data that does not contain Personal Information about Customers that access and use the Ripplebox App. For example, the type of Personal Information and non-Personal Information that we collect includes
  29. Customer account details (for example, full name and mobile number);
  30. account credentials (for example, any username created by the Customer and Referral Code given to the Customer by us);
  31. information about the Referral Programs you have joined or you are interesting in joining, the referrals you have made to a Business and the Rewards you have earned and redeemed from a Business under a Referral Program on, or via, the Ripplebox App;
  32. information relating to your dealings, or enquiries you have made, with us in relation to the Ripplebox App, the Services, our other products and services or complaints you have raised with us about Referral Programs, Rewards and a Business; and
  33. other information that you provide to us or that we may collect in the course of our relationship with you.
  34. Referrals
  35. We collect and hold Personal Information as well as information or data that does not contain Personal Information about Referrals made by Customers to Businesses. For example, the type of Personal Information and non-Personal Information that we collect includes:
  36. contact details of a Referral (such as the Referral’s full name and mobile number);
  37. information about the products and services that a Referral may interested in acquiring or purchasing from a Business, and the contact details and Referral Code of the Customer who referred the Referral to the Business the Rewards you have earned and redeemed from a Business under a Referral Program on, or via, the Ripplebox App; and
  38. other information that you provide to us or that we may collect in the course of our relationship with you.
  39. Other information
  40. We may also collect some information that is not Personal Information because it does not identify you or anyone else. Information that we may collect includes (but is not limited to):
  41. anonymous answers to surveys or aggregated information about how Businesses and Customers use the Ripplebox Platform, Ripplebox App and Services; or
  42. information regarding your access and use of the Ripplebox Platform, including location information, your computer’s internet protocol (IP) address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on the Ripplebox Platform, dates and times of visits to the Ripplebox Platform and other usage statistics.
  43. If you are a candidate seeking employment with us, we may use your Personal Information to process your application and assess your suitability for any role. We may retain your information for future reference.
  44. Sensitive Information
  45. We do not collect your Sensitive Information (as defined by the Privacy Act). However, some of our services are automated and we may not recognise that you have accidentally provided us with Sensitive Information.
  46. If you have accidentally sent us Sensitive Information, please contact us using the contact details set out in section 11 below.
  47. How we collect Personal Information
  48. Direct collection from you
  49. We will collect Personal Information and Non-Personal Information about you in a number of different ways. We may collect Personal Information and Non-Personal Information directly from you or in the course of our dealings with you. For example:
  50. in the case of Businesses, when you:
  51. access and use the Ripplebox Platform (including when you open an account or create or update your account or Business profile on, or, via, the Ripplebox Platform);
  52. upload, publish or display information about your Referral Programs or otherwise submit information or data on, or via, the Ripplebox Platform; or
  53. contact, interact or communicate with Customers on, or, via, the Ripplebox Platform (including when you grant Rewards to Customers).
  54. in the case of Customers, when you:
  55. download, access and use the Ripplebox App (including when you open an account or create or update your account on, or, via, the Ripplebox App);
  56. use the Ripplebox App to refer a Referral to a Business; and
  57. contact, interact or communicate with a Business on, or, via, the Ripplebox App (including when you earn and redeem Rewards).
  58. in the case of Referrals, when you add your contact details to a Business  via, the Ripplebox App.
  59. when you contact or correspond with us via email or telephone or when you submit query or question through Ripplebox Platform and/or Ripplebox App about the Ripplebox Platform, Ripplebox App, Services and/or our other products and services or when you enter or participate in competitions, promotions, events, sweepstakes, surveys and questionnaires; and
  60. when you otherwise contact, interact or communicate with us (such as by telephone, email or in person) with a query or request or make a comment on our social media sites or lodge a complaint; and
  61. when we are otherwise legally authorised or required to do so.
  62. When we collect Personal Information directly from you, we will take reasonable steps to notify you (using a collection notice) at, before, or as soon as practicable after, the time of collection.
  63. By providing your Personal Information to us, you acknowledge that you are authorised to provide such information to us.
  64. Collection from third parties
  65. We may also collect Personal Information and Non-Personal Information about you from publicly available sources and third parties, including:
  66. when you provide your Personal Information to our Authorised Affiliates or other third parties;
  67. from Businesses and Customers;
  68. if you use:
  69. our social media sites or applications, pages or plugins;
  70. third party products or services that interact with Ripplebox Platform and Ripplebox App, the Services or our other products or service; or
  71. our third party payment processors.
  72. When we collect your Personal Information from third parties, we shall take reasonable steps to make sure you are aware of the collection.
  73. If you provide us with Personal Information about another individual (as their authorised representative), we rely on you to:
  74. inform them that you are providing their Personal Information to us; and
  75. advise them that they can contact us for further information.
  76. You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy, including that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual's right to access that information, and who we are and how to contact us.
  77. Upon our request, you must also assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.
  78. Third party payment processor
  79. We use a third party payment processor to process payments made to us. In connection with the processing of such payments, we do not collect, process, use, share, store or disclose any payment information (such as credit card and bank account details). Rather, all such information is provided directly to our third party processor, Stripe, whose use of your Personal Information and payment information is governed by their privacy policy, which may be viewed at www.stripe.com/au/privacy.
  80. How we use your Personal Information
  81. Purposes of use and disclosure
  82. We only use, process and disclose your Personal Information for the purposes for which it is collected. 
  83. In particular, we use, process and disclose your Personal Information and Non-Personal Information to:
  84. provide or deliver the Ripplebox Platform, Ripplebox App, Services and/or our other products and services to you, including, without limitation, to provide the means through which to provide Businesses with the ability to create, amend and manage Referral Programs and Customers with the means through which to earn and redeem Rewards;
  85. inform you about the Ripplebox Platform, Ripplebox App, Services, our other products and services or about offers, competitions, promotions, events, sweepstakes, surveys, questionnaires about us, the Ripplebox Platform, Ripplebox App, the Services, our other products and services or other matters which we believe are of interest to you (such as recruitment or job opportunities);
  86. manage, administer, improve, test, develop and upgrade the Ripplebox Platform, Ripplebox App, Services and our other products and services, informing you about scheduled maintenance or outages and managing our relationship with you or to otherwise investigate complaints about the Ripplebox Platform, Ripplebox App, the Services, our other products and services, Businesses and Customers;
  87. share with our Authorised Affiliates;
  88. charge and bill Businesses to access and use the Ripplebox Platform and Services;
  89. verifying your identity;
  90. for internal record keeping;
  91. for direct marketing purposes (see below); 
  92. complying with our legal and regulatory obligations;
  93. for any purpose to which you have consented; and
  94. for any other purpose notified to you at the time of collection.
  95. In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your Personal Information as part of the transaction, without your consent or notice to you. 
  96. Disclosure to Authorised Affiliates
  97. In order to provide or deliver the Ripplebox Platform, Ripplebox App, Services and/or our other products and services to you, we may disclose your Personal Information and Non-Personal Information to:
  98. our related bodies corporate, business partners, service providers, third party contractors, agents or suppliers; 
  99. authorised external service providers who perform functions on our behalf, such internet and technology services providers, app and website software developers, hosting and data storage companies, marketing, advertising and security service providers, third party payment processors, fulfilment companies, credit reporting agents, debt collection agents, market research and recruitment service providers; and
  100. external business advisors, such as auditors, lawyers, insurers and financiers,(collectively, Authorised Affiliates).
  101. We may also disclose your Personal Information and Non-Personal Information:
  102. to any other party with your consent and direction; 
  103. to law enforcement bodies or regulatory authorities to assist with their functions, or as otherwise required or authorised by law; or
  104. where we consider necessary to comply with any applicable law, regulation, legal process, governmental request or industry code or standad. 
  105. When we disclose your Personal Information or Non-Personal Information to any of our Authorised Affiliates, we will ensure that they undertake to protect your privacy. These Authorised Affiliates are not permitted to use the information for any purpose other than the purpose for which they have been given access. 
  106. Our Authorised Affiliates may also provide us with Personal Information and Non-Personal Information collected from you. If you disclose Personal Information to an Authorised Affiliates, we rely on you to provide the Authorised Affiliates with consent for us to collect, storage, use, process, alter and disclose your Personal Information.
  107. Overseas disclosure
  108. In the course of providing you with access to, and use of, the Ripplebox Platform, Ripplebox App, Services and our other products and services, it may become necessary or desirable to disclose Personal Information to Authorised Affiliates located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we commonly disclose Personal Information to:
  109. our third party payment processors located in the United States and elsewhere outside of Australia; and
  110. our website and app developers located in Australia, Malaysia and the Philippines.
  111. The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas we will take reasonable steps to ensure that your Personal Information is treated securely and the means of transfer provides adequate safeguards.
  112. If you have any questions in relation to the transfer of your Personal Information please contact us using the contact details set out in section 11 below.
  113. Disclaimer
  114. We will not disclose your Personal Information to any third party (other than our Authorised Affiliates) without your written consent, unless: 
  115. we are otherwise required by the relevant Privacy Laws; 
  116. we are permitted to under this Privacy Policy; or 
  117. such disclosure is, in our opinion, reasonably necessary to protect our rights or property, avoid injury to any person or ensure the proper functioning of the Ripplebox Platform and Ripplebox App.
  118. This Privacy Policy only covers the use and disclosure of information we collect from you. The use of your Personal Information by any third party is governed by their privacy policies and is not within our control. 
  119. Notifiable Data Breaches 
  120. In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, we will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with notifiable data breach laws as set out in the Privacy Act.
  121. Marketing communications
  122. Direct marketing
  123. We may use and disclose your Personal Information to send you information about the Ripplebox Platform, the Ripplebox App, the Services or information about the other products and services we may offer from time to time, as well as other information that may be of interest to you.
  124. These communications may continue, even after you stop using the Ripplebox Platform and/or the Ripplebox App
  125. Communication channels
  126. We may send this information to you via the communication channels specified at the time you provide your consent. 
  127. These communication channels may include mail, email, SMS telephone, social media or by customising online content and displaying notices on the Ripplebox Platform and the Ripplebox App.
  128. Opting-out
  129. You can opt out of receiving these communications by:  
  130. contacting us using the details below; or
  131. using the unsubscribe function in the email or SMS.
  132. Storage and security 
  133. Protecting your Personal Information
  134. We take reasonable steps in the circumstances to keep your Personal Information and Non-Personal Information safe. We use a combination of technical, administrative, and physical controls to protect and maintain the security of your Personal Information and Non-Personal Information.
  135. Our officers, employees, agents and third-party contractors are expected to observe the confidentiality of your Personal Information and Non-Personal Information.
  136. Wherever possible, we procure that Authorised Affiliates who have access to your Personal Information and Non-Personal Information take reasonable steps to:
  137. protect and maintain the security of your Personal Information and Non-Personal Information; and 
  138. comply with the Australian Privacy Principles when accessing and using your Personal Information. 
  139. No guarantee
  140. The transmission of information via the internet is not completely secure. While we do our best to protect your Personal Information and Non-Personal Information, we cannot guarantee the security of any Personal Information and Non-Personal Information transmitted through the Ripplebox Platform or the Ripplebox App.
  141. You provide your Personal Information and Non-Personal Information to us at your own risk and we are not responsible for any unauthorised access to, and disclosure of, your Personal Information and Non-Personal Information.
  142. Destruction of Personal Information
  143. We will destroy or de-identify Personal Information in circumstances where it is no longer required, unless we are required or authorised by law to retain the information. 
  144. Accessing and correcting your Personal Information
  145. We shall use our reasonable endeavours to keep your Personal Information accurate, up-to-date and complete. You have the right to access any Personal Information we hold about you, subject to some exceptions under the Privacy Act. 
  146. You can access, or request that we correct, your Personal Information by writing to us using the details below. We may require proof of identity. If we do not allow you to access any part of your Personal Information, we will tell you why in writing. 
  147. We will not charge you for requesting access to your Personal Information but may charge you for our reasonable costs in supplying you with access to this information.
  148. We will endeavour to respond to your request for access or correction within 30  days from your request.
  149. Cookies Policy
  150. Cookies
  151. The Ripplebox Platform uses small text files placed on your computer called ‘cookies’ to collect standard log and visitor behaviour information in an anonymous form. We use this information to analyse how visitors use the Ripplebox Platform      and to compile statistical reports on website activity. You can set your computer to reject cookies, but this may affect your ability to use certain parts of the Ripplebox Platform     .
  152. We may also log your IP address. Your IP address is your computer’s electronic Internet address. We may collect your IP address to see trends, run the website, track user movements, and gather broad demographic information.
  153. Google Analytics
  154. Services that the Ripplebox Platform and the Ripplebox App may use from time to time include Google Analytics, which transmits website traffic data to Google servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand traffic and usage on our website. By using the Ripplebox Platform and the Ripplebox App, you consent to Google processing your data in the manner described in Google’s Privacy Policy (www.policies.google.com/privacy) and for the purposes set out in this Privacy Policy.
  155. Google may pass on cookies to its partners and other third parties to achieve its purposes. For more information on how Google uses the information collected from cookies, and how you can opt out of this feature please see Google’s Privacy Policy. You can also view Google Analytics’ currently available opt-out (see https://tools.google.com/dlpage/gaoptout).
  156. Privacy complaints
  157. If you have any issues about this Privacy Policy or the way we handle your Personal Information, please contact us using the details below and provide full details of your complaint and any supporting documentation.
  158. At all times, privacy complaints:
  159. will be treated seriously;
  160. will be dealt with promptly;
  161. will be dealt with in a confidential manner; and
  162. will not affect your existing obligations or your commercial arrangements with us.
  163. Our Privacy Officer will endeavour to:
  164. respond to you within 10 business days; and
  165. investigate and attempt to resolve your concerns within 30 business days or any longer period necessary and notified to you by our Privacy Officer.
  166. If you are dissatisfied with the outcome of your complaint, you may refer the complaint to Office of the Australian Information Commissioner
  167. How to contact us
  168. If you have any complaints or issues you wish to raise with us regarding the way we have handled your Personal Information, or would like to discuss any issues about our Privacy Policy, please contact us directly by:
  169. email at info@ripplebox.com.au; or
  170. calling us on +61 45798743. 
  171. Changes to this Privacy Policy
  172. From time to time, it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on the Ripplebox Platform and/or the Ripplebox App.
  173. We encourage you to check the Ripplebox Platform and the Ripplebox App from time to time to ensure you are familiar with our latest Privacy Policy.