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PRIVACY POLICY

LAST REVIEWED: APRIL 2022

COMMITMENT TO PRIVACY

E-COM (Aus) Pty Ltd, ABN 60 150 104 715, its subsidiaries and affiliates in
Australia (collectively referred to as “MyDeal”) are committed to managing
personal information in accordance with the Australian Privacy Principles under
the Privacy Act 1988 (Cth) (“Privacy Act”) and in accordance with other
applicable privacy laws.

MyDeal provides services which allow you to sell or purchase goods and services
(including on behalf of third party merchants) via our website
(www.mydeal.com.au) or app (collectively, the “Sites”) (collectively, the
“Services”).

This document explains how we collect, use, disclose and protect your personal
information (“Your Information”) and is referred to as our Privacy Policy.

In this Privacy Policy, “we”, “our” and “us” refers to MyDeal and “you” or
“your” refers to any individual about whom we collect personal information.

This Privacy Policy applies to all personal information collected by us,
including personal information collected or submitted through our Sites.

We take privacy very seriously and are committed to the protection of your
privacy. By providing Your Information to us, you understand we will handle and
treat Your Information in accordance with the practices described in this
Privacy Policy. If you do not agree with any of the terms of this Privacy
Policy, please do not submit any personal information to us.

Other terms may also apply to you and the personal information we hold about you
(for example where we provide you with a specific privacy collection notice).

WHAT INFORMATION DO WE COLLECT ABOUT YOU?

The type of personal information we collect will vary depending on the nature of
your dealings with us. We have outlined this in more detail below:

CUSTOMER AND PROSPECTIVE CUSTOMERS

When you enquire about our Services or when you become a customer of MyDeal, a
record is made which includes Your Information. The type of personal information
that we collect will vary depending on the circumstances of collection and the
kind of service that you request from us, but will typically include:


 * your name;
 * contact details including your phone number, email address and
   mailing/delivery address;
 * your date of birth;
 * your professional details (such as your job title);
 * information about your employer or an organisation you represent (i.e. the
   relevant supplier/merchant whom you are associated with);
 * any other information you provide to us through our Services; and
 * any additional information relating to you that you provide to us directly or
   indirectly through the use of our Sites or online presence.



To provide some of our Services, you may provide us with personal information
which relates to another person (for example, name and business contact details
of a person who is the contact in a company or government agency with whom we
deal). If you provide us with information about any other person, you must
obtain that person’s permission to give us the information and inform them of
our privacy policy.

PROSPECTIVE EMPLOYEES/APPLICANTS

We collect personal information when recruiting personnel, such as your name,
contact details, qualifications and work history (including references and other
information included in a CV or cover letter as part of the application
process). Generally, we will collect this information directly from you.

Before offering you a position, we may collect additional details such as your
tax file number and superannuation information and other information necessary
to conduct background checks to determine your suitability for certain
positions.

SHAREHOLDERS

We (or a share registry provider we may engage) may also collect information to
maintain shareholder information in accordance with Australian Securities
Exchange (“ASX”) requirements, such as:


 * the name of the individual shareholder and any trustee (if applicable);
 * personal details relating to any Power of Attorney (e.g. the attorney’s name,
   address, occupation, date of birth and phone number);
 * bank account details; and
 * your Securityholder Reference Number or Holder Identification Number.



When we collect personal information from shareholders, we may also use and
disclose it for other reasons related to your shareholding, such as identity
verification, providing shareholder services, sending you correspondence and
documents and responding to complaints or inquiries. We may also use Your
Information to market our products and services, such as exclusive shareholder
offers, to you.

VISITORS TO OUR SITES

The way in which we handle the personal information of visitors to our Sites is
discussed below.

WHAT HAPPENS IF YOU DON’T PROVIDE YOUR INFORMATION?

You can always decline to give MyDeal any of Your Information we request, but
that may mean we cannot provide you with some or all of the Services you have
requested, and may not be able to do business with you effectively or meet the
expectations of customers or shareholders. If you have concerns about the
personal information we have requested, please let us know.

HOW DOES MYDEAL COLLECT YOUR INFORMATION?

Generally, we collect Your Information directly from you where possible. We may
collect and update Your Information over the phone, by email, or over the
internet or social media such as when you provide Your Information to us by:


 * accessing our Sites;
 * using our Services;
 * completing any forms on the Sites; or
 * making any requests or transactions through the Sites.



We may also collect Your Information from other sources, for example:

 * our affiliated and related companies;
 * third party suppliers and contractors who assist us to operate our business;
   and
 * third party resellers or affiliates, or other third party intermediaries who
   introduce you to us and our Services; in respect of prospective employees /
   job applicants, from recruitment agencies or referees you have nominated.



Where personal information is collected from a third party, MyDeal will treat
Your Information in accordance with the practices described in this Privacy
Policy. MyDeal cannot guarantee the accuracy of personal information provided by
a third party.

HOW DO WE INTERACT WITH YOU VIA THE INTERNET?

WEBSITE AND COOKIES

You may visit our Sites without identifying yourself. If you identify yourself
(for example, by logging in as member or registering for membership), Your
Information you provide to MyDeal will be managed in accordance with this
Privacy Policy.

If you visit our Sites, we may collect certain information, such as the type of
device or browser you’re using, IP address, your device ID (a numeric identifier
for your mobile device, if you access our Sites using a mobile device), the time
of your visit, the duration and the pages you accessed on our Sites. We may also
collect information on how you navigate our Sites and generally use our Sites.
This is to, amongst other things, help us to provide a positive user experience
on our Sites, including optimising our marketing activities to help us ensure
that advertisements on the Sites are most directly relevant to your interests
and to personalise your browsing experience (for example, by remembering your
preferences and recognising you as a repeat visitor to our Sites).

To do so, we use cookies to help us collect information about visitors to our
Sites. Cookies are small data files sent by a website or application that are
stored by the web browser on your device that enable our system to recognise a
returning visitor to our Sites. You are not identifiable from such information.

We may from time to time, use other technical methods of identifying your
interaction with our Sites, which has similar functionality to cookies to
provide our Services to you. Most browsers can be set to detect cookies and you
can control how your browser deals with cookies by changing your browser
settings (for example by rejecting cookies). However, in doing so, you may not
be able to use certain content on our Sites and may not have the same user
experience.

THIRD PARTY LINKS AND PRODUCTS

Our Sites may contain links to third party websites, platforms or applications.
We are not responsible for content or the privacy practices of those websites,
platforms, or applications that are linked to our Sites.

Our Sites may also offer you the opportunity to receive offers of goods and
services from third parties (“Third Party Offers”). Third Party Offers will be
presented to you via a third party intermediary, whose functionality we have
incorporated into our Sites.

You must opt in to receive a Third Party Offer. Where you do opt in, we will
then provide your information to the intermediary who will then organise for the
Third Party Offer to be made to you. We are not however responsible for the
conduct of the third party who is making the Third Party Offer, or their supply
of any goods and services to you.

If you transact with any intermediaries in relation to Third Party Offers, these
transactions are subject to the privacy and other policies, terms and conditions
of the intermediaries and their affiliate partners, which are not connected to
MyDeal. We recommend that you read the privacy policy and terms and conditions
of any third party website, platform or application that you intend to use or
procure goods or services from.

WHY DOES MYDEAL COLLECT AND USE YOUR INFORMATION?

In summary, MyDeal only collects Your Information where it is reasonably
necessary for us to carry out our business functions or activities, including to
assess and manage our customer’s needs and provide Services to our customers. We
may also collect information to fulfil administrative functions associated with
the Services, for example, billing and managing customer and other business
relationships. We also collect information to improve our Services and how you
and other customers interact with them.

We also collect personal information to administer and manage relationships with
our shareholders. MyDeal may allow shareholders and other visitors to our
website to sign up for alerts and otherwise communicate with us.

The purposes for which we collect and use Your Information depends on the nature
of your interaction with us, but may include:


 * enabling you to access and use the Services;
 * researching, developing, expanding and improving our products and the
   Services;
 * administering your account with us;
 * providing you with our Services;
 * analysing your interactions and use of our Sites to understand and improve
   the effectiveness of our marketing initiatives;
 * keeping and updating records and databases to ensure the smooth operation of
   our business and Services;
 * communicating with you about changes or developments to our Services and
   business or in the normal course of business dealings, including via email to
   SMS;
 * to send you communications and notices in connection with your account on our
   Sites;
 * responding to your enquiries or requests for information, including about our
   Services;
 * maintaining and improving our customer service by monitoring our Services for
   quality and training purposes;
 * managing our relationship with you, for example if you are a supplier,
   business partner or shareholder; and
 * managing, planning, advertising and administering programs and events which
   may be of interest to you.



HOW DO WE USE OR DISCLOSE YOUR INFORMATION?

FOR CUSTOMERS AND BUSINESS PARTNERS

The purposes for which we may use and disclose Your Information will depend on
the Services we are providing to you. For example, if you have engaged us to
provide our Services to you, we may disclose Your Information as follows:


 * to our third party service partners to permit them to provide products and
   services on our behalf, including fraud prevention;
 * to our third party merchants to either: (i) deliver/provide goods or services
   ordered; or (ii) redeem vouchers you have purchased; and
 * to intermediaries where you accept or indicate you wish to receive a Third
   Party Offer; to ensure the protection of Your rights, property or personal
   safety, any member of the public, or to protect our interests.



MyDeal will also use and disclose Your Information for a range of
administrative, management and operational purposes. This includes:


 * planning, managing, monitoring and evaluating our Services;
 * quality improvement activities;
 * statistical analysis and reporting;
 * training staff, contractors and other workers;
 * risk management and management of legal liabilities and claims (for example,
   liaising with insurers and legal representatives);
 * responding to enquiries and complaints regarding our Services;
 * obtaining advice from consultants and other professional advisers; and
 * responding to subpoenas and other legal orders and obligations.



DISCLOSURE TO CONTRACTORS AND OTHER SERVICE PROVIDERS

We may disclose Your Information to third parties we engage in order to assist
us in providing our Services to you or to administer our relationships with
shareholders, including suppliers, merchants, distributors and service providers
such as those providing the payment gateway, website engagement, marketing,
fraud prevention, data processing, data analysis, customer satisfaction surveys,
information technology services and support, website maintenance/development,
intermediaries who provide you or facilitate Third Party Offers, and market
research.

FOR PROSPECTIVE EMPLOYEES / JOB APPLICANTS

To assist us with our recruitment process, we may disclose Your Information to
those employees who it is necessary for Your Information to be disclosed to as
part of the recruitment process as well as recruitment agents and other advisers
who assist with recruitment.

OTHER USES AND DISCLOSURES

Personal information may also be shared between related or affiliated companies
of MyDeal, where necessary.

We may use and disclose Your Information for other purposes explained at the
time of collection (such as in a specific privacy collection statement or
notice) or otherwise as set out in this Privacy Policy.

Third parties to whom we have disclosed Your Information may contact you
directly to let you know they have collected Your Information and to give you
information about their privacy policies.
You may receive push notifications through the mobile app device (currently only
available for android devices) or your browser where you have consented to being
sent such notifications.

We may share certain non-personally identifiable information such as activity on
the Site, purchase history, survey responses and other information with third
parties to assist with their own marketing programs. We may also obtain similar
data from third parties for the same reasons, namely to improve the Services and
offering we provide.

DOES MYDEAL DISCLOSE YOUR INFORMATION OVERSEAS?

MyDeal may use third party contractors or service providers who are based
overseas or perform services provided outside of Australia. Further, MyDeal or
its third party providers may store Your Information in the cloud or other types
of network systems, where it can be accessed from and transferred between
various countries over the internet.

Unless we have your consent, or an exception under the Australian Privacy
Principles applies, we will only disclose Your Information to overseas
recipients where we have taken reasonable steps to ensure that the overseas
recipient does not breach the Australian Privacy Principles in relation to Your
Information.

In circumstances where your information is disclosed to overseas recipients,
those recipients may (amongst others) be located in the United States of
America.

CAN YOU DEAL WITH US ANONYMOUSLY OR USE A PSEUDONYM?

We will, if practicable and lawful, provide you with opportunities to use a
pseudonym or to remain anonymous in your dealings with us.

Generally, it is not practicable for us to deal with individuals anonymously or
pseudonymously on an ongoing basis. If we do not collect Your Information, you
may be unable to utilise our Services or we may not be able to provide you with
the relevant service, product or information.

DOES MYDEAL USE OR DISCLOSE YOUR INFORMATION FOR DIRECT MARKETING?

MyDeal may use or disclose Your Information for the purpose of informing you
about our services, upcoming promotions and events, or other opportunities that
may interest you, or as otherwise permitted under applicable privacy laws.

If you do not want to receive direct marketing communications, you can opt-out
at any time by contacting us using the contact details below or using the
opt-out functionality contained in the electronic message.

If you opt-out of receiving marketing material from us, MyDeal may still contact
you in relation to its ongoing relationship with you.

HOW DOES MYDEAL HOLD YOUR INFORMATION SECURELY?

We will take all reasonable steps to keep Your Information secure and to ensure
it is protected against misuse, interference, loss, unauthorised access,
modification or inappropriate disclosure. We require our staff to maintain the
confidentiality of Your Information. We may hold Your Information in electronic
form and will store it in secure systems accessible only to authorised personnel
who have logins and passwords to gain access.

We host Your Information that we collect in secure server environments that are
protected by firewalls and other industry-standard technology in an effort to
prevent interference or access from unauthorised persons.

ONLINE TRANSACTIONS

If you purchase Product(s) or Voucher(s) (as defined in our terms and conditions
available at https://www.mydeal.com.au/info/tnc) through our Sites, we process
your credit card details securely over the internet using a third party
provider’s tier-one PCI-DSS compliant payment gateway. Our sites are also
protected by a 256 Bit SSL Certificate to ensure that your credit card and
anonymity are protected when you purchase online. If you opt-in to save your
credit card details, our third party provider will retain your credit card
details on its servers for future purchases on our Sites. We do not store your
credit card details on our servers.

While we take reasonable steps to protect Your Information, no website, internet
connection or transmission, computer system or wireless connection is completely
secure and we cannot guarantee or provide assurances regarding the security of
transmission of information you communicate to us online or the integrity of
transmission over the internet. Any information which you transmit to us online
is at your own risk.

RETENTION PERIOD AND DISPOSAL OF PERSONAL INFORMATION

We will only retain Your Information for the period necessary to fulfil the
purposes outlined in this Privacy Policy unless a longer retention period is
required or permitted by law.

If we no longer need Your Information, we will take reasonable steps to securely
destroy or permanently de-identify Your Information.

CHANGES TO OUR PRIVACY POLICY

We may amend this privacy policy from time to time, with or without notice to
you. The changes will be effective immediately upon being made public on our
Sites. We also try to let you know about major changes to our Privacy Policy
(for example by putting up a notice on our Sites). We recommend that you visit
our Sites regularly to keep up to date with any changes.

HOW TO ACCESS OR SEEK CORRECTION OF YOUR INFORMATION

ACCESS TO YOUR INFORMATION

You may request to access Your Information we hold about you at any time by
contacting us (see below for details), including by asking us to provide you
with a summary of Your Information that we hold.

For your protection, we may require you to confirm your identity before access
to Your Information is granted.

You will not be charged for making a request to access Your Information,
however, in some circumstances, you may be charged for the reasonable time and
expense incurred in compiling information in response to your request.

CORRECTION OF PERSONAL INFORMATION

We will take reasonable steps to ensure that Your Information we collect, use or
disclose is accurate, complete and up-to-date. However, the accuracy of that
information largely depends on the information you provide. We recommend that
you:


 * let us know if there are any errors in Your Information; and
 * keep us up to date with changes to Your Information such as your name,
   address and telephone number.



If you believe that any of Your Information we hold about you is inaccurate,
out-of-date, incomplete, irrelevant or misleading you are entitled to request
correction of the information. After receiving a request from you, we will take
reasonable steps to correct your information.

We may decline your request to access or correct Your Information in certain
circumstances in accordance with the Australian Privacy Principles. If we do
refuse your request, we will provide you with a reason for our decision and, in
the case of a request for correction, we will include a statement with Your
Information about the requested correction.

DELETION OF YOUR INFORMATION

In some instances, you may request that we delete some or all of Your
Information. Please note, however, that we may need to retain certain
information for record keeping purposes, to complete transactions or to comply
with our legal obligations. If you ask to delete information which we are
permitted by law or have compelling legitimate interests to keep, we may not be
able to fully meet your request.

DELETION OF YOUR ACCOUNT

If you access our Services through an app, then you can delete your account
through the My Account section of the app and clicking ‘Delete Account’.

If you access our Services through our website and wish to delete your account,
this can be done by making the request through the enquiry page.

When an account is deleted, all customer level data is deleted. This includes
shipping/billing address, stored payment information, linked social accounts and
email and SMS subscriptions. However, while the account is deactivated and
deleted, we do retain your email address and any order history so we have
records of the transactions.

QUERIES AND COMPLAINTS

If you have a question or want to make a complaint about how we handle Your
Information, please contact us at any time using the details below and provide
details of the incident so we can investigate it.

Where we receive a question or complaint regarding MyDeal’s use of Your
Information, we will first review any question or complaint you may have to
determine whether there are simple or immediate steps which can be taken to
resolve the question or complaint. We will generally respond to your complaint
within a week.

If your question or complaint requires more detailed consideration or
investigation, we will acknowledge receipt of your complaint or query within a
week and endeavour to complete our investigation into your complaint promptly.
We may require further information from you in order to resolve your complaint
or question and the outcome you are seeking. We will then typically gather
relevant facts, locate and review relevant documents and speak with the
individuals involved.

We will, where reasonably possible, take steps to investigate and resolve
complaints within 30 days of receipt of the complaint. If the matter is more
complex or our investigation may take longer, we will notify you.

If you are not satisfied with the outcome or you consider that MyDeal may have
breached the Australian Privacy Principles or the Privacy Act, a complaint may
be made to the Office of the Australian Information Commissioner (“OAIC”)
directly. The OAIC can be contacted by telephone on 1300 363 992 or by using the
contact details on the website www.oaic.gov.au.

CONTACT DETAILS

We can be contacted via:


Email:  Submit an email enquiry via
https://help.mydeal.com.au/hc/en-us/requests/new .
Mail:   MyDeal.com.au,
Attention: Privacy Officer
Level 1, 446 Collins Street
MELBOURNE, VIC 3000.





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