1 Privacy policy

1. (a) Fronterly.com is operated by Fronterly Pty Ltd (ACN 659 014 749) who is referred to in this privacy policy as "we", "us", "our" and similar grammatical forms.
2. (b) This privacy policy describes how we collect, hold, use and disclose personal information, and how you can access and correct the personal information we hold about you or make a privacy complaint.
3. (c) We appreciate that your privacy is important to you. We manage personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
4. (d) We will take all reasonable steps to ensure that all personal information we collect, use or disclose is accurate, complete, up to date and stored in a secure environment.
5. (e) We handle personal information in two distinct capacities:
   1. as the operator of the Fronterly website and platform, where we collect personal information from our subscribers, clients and website visitors for our own purposes; and
   2. as a technology service provider to brands, agencies and promoters (Promoters) who run consumer promotions, competitions and rewards programs using our platform. In that capacity, we collect and process the personal information of promotion entrants (Entrant Data) on behalf of, and at the direction of, the relevant Promoter. Section 1.5 explains how we handle Entrant Data.

1.1 When do we collect information?

1. We do not automatically collect personal information from you, such as your name, address, phone number, email address or other personally identifiable information about you (personal information). We collect three categories of information when you use our Website or our Services:
   1. the personal information you voluntarily provide to us;
   2. technical and usage information about how you use our Website and our Services, some of which may constitute personal information under the Privacy Act (for example, IP addresses and online identifiers); and
   3. "cookie" based information that makes your use of our Website easier by recording your preferences so that when you return to our Website the "cookie" re loads that information into your web browser.
2. For example, we will collect personal information from you when you register on our Websites, place an order, subscribe to our newsletter, respond to a promotional offer, competition or survey or fill out a form related to any customer service feature operating on our Websites.
3. When you become a subscriber to Fronterly.com, you will need to provide certain details so that we can establish and manage your customer account.
4. When you log into our Website using our secure log in (or use any other log in connected to any other social media platform) you are allowing that social media platform to share your personal information with us (that is, your personal information related to your log in with that social media platform, which may include your email address and other personal information).
5. When you enter a promotion, competition or rewards program operated on our platform, we collect the information you submit through the relevant entry form on behalf of the Promoter of that promotion.

1.2 Why do we need to collect personal information?

1. We collect personal information from our subscribers and clients in order to provide the services requested, such as setting up and managing your subscription to one of our Plans or processing any purchases you may make.
2. We collect Entrant Data in order to operate promotions on behalf of Promoters, including to record and validate entries, verify eligibility, conduct draws and instant win mechanics, detect fraudulent or duplicate entries, deliver prizes, rewards, gift cards and wallet passes, send promotion related SMS and email communications, and report to the Promoter and, where required, regulatory or permit authorities.

1.3 What information do we collect?

1. The type of information we collect from you will depend on what services you use. From our subscribers and clients, the personal information we may collect includes your name, postal address, email address, telephone numbers, contact details and information for identification purposes. If you make online purchases from us or pay your subscription by credit card, debit card or direct debit from your bank account, payment is processed by our payment service providers and we do not store your full card details on our systems.
2. From promotion entrants, and depending on the requirements of the particular promotion, we may collect on behalf of the Promoter: name, email address, telephone number, postal address, state, date of birth, proof of purchase (including uploaded receipt images, which may incidentally contain other purchase information), entry details, prize acceptance details, and responses to promotion questions.
3. General information about visits to our Websites or our other Services is collected by our computer servers, with small files ("cookies") that our Websites transfer to your computer's hard drive through your web browser (if you allow the delivery of cookies). Cookies are used to follow the pattern of movements of users by letting us know which pages on our Websites or Services are visited, in what order and how often and the previous website visited, and also to process the items you select if you are making purchases from us.

1.4 Why do we use "cookies" and other web use tracking technologies?

1. When you access our Website, a small file containing a unique identification (ID) number may be downloaded by your web browser and stored in the cache of your computer. The purpose of sending these files with a unique ID number is so that our Website can recognise your computer when you next visit our Website or use our Services. While cookies do not directly reveal your name or contact details, unique identifiers and IP addresses may constitute personal information under the Privacy Act, and we treat them accordingly.
2. We also log the internet protocol address (IP address) of visitors to our Website or our Services for security, fraud prevention and geographic analysis purposes.
3. We collect information using cookies and other tracking technologies for the following reasons:
   1. to help us monitor the performance of our Website and our Services so that we can improve the operation of the Website and the services we offer;
   2. to provide personalised services to each user of our Website and our Services to make their navigation through our Website and our Services easier and more rewarding to the user;
   3. to support the security and integrity of promotions operated on our platform, including the detection of fraudulent or duplicate entries; and
   4. when we have permission from the user, to market the services we provide by sending emails that are personalised to what we understand are the interests of the user.
4. Even if you have given us permission to send you emails, you can, at any time, decide not to receive further emails and will be able to unsubscribe from that service.
5. If you are unhappy about having a cookie sent to you, you can set your browser to refuse cookies or choose to have your computer warn you each time a cookie is being sent. However, if you turn your cookies off, some of our services may not function properly.

1.5 Promotion entrants and Entrant Data

1. Where we operate a promotion, competition or rewards program on behalf of a Promoter, the Promoter determines the purposes for which Entrant Data is collected and used. The Promoter's own privacy policy and the terms and conditions of the relevant promotion apply to that collection, and should be read together with this privacy policy.
2. We use Entrant Data only to operate, secure and report on the relevant promotion and as directed by the Promoter. We do not use Entrant Data for our own direct marketing, and we do not sell Entrant Data to any third party.
3. Entrant Data for each promotion is held in logically separated environments on a per client basis.
4. Any market or industry insights we publish (for example, aggregate promotion trends and benchmarks) are compiled from publicly available promotion details and aggregated, de-identified statistics, and do not identify individual entrants.
5. If you have a question or request relating to personal information you submitted when entering a promotion, you may contact us using the details in section 1.10 or contact the Promoter directly. Where the Promoter controls the relevant information, we will refer your request to the Promoter and assist them to respond.

1.6 Disclosure to third parties and overseas recipients

1. We disclose personal information to third parties only where necessary to deliver our Services, and only to the extent required for the relevant service. The categories of third parties to whom personal information may be disclosed are:
   1. the Promoter of a promotion you have entered, and its authorised agencies;
   2. gift card and reward issuers, for the purpose of issuing prizes and rewards you have won or redeemed;
   3. prize fulfilment, draw and instant win service providers engaged for a particular promotion;
   4. receipt validation and OCR service providers, for the purpose of verifying proof of purchase (receipt images are processed for data extraction and are not retained by the provider);
   5. SMS, email and wallet pass delivery providers, for the purpose of sending promotion and service communications;
   6. hosting, content delivery, security and infrastructure providers;
   7. payment service providers, for subscription and purchase transactions; and
   8. professional advisers, regulators, permit authorities and law enforcement, where release is required or authorised by law, or appropriate to enforce our agreements or protect our rights, property or safety or those of others.
2. Our website, platform and databases are hosted in data centers located in Australia. However, some of our service providers (for example, content delivery, security, mobile wallet and message delivery providers) may process limited personal information on infrastructure located overseas, including in the United States. Where personal information is disclosed to an overseas recipient, we take reasonable steps, consistent with APP 8, to ensure the recipient handles that information in a manner consistent with the APPs, including through contractual safeguards.

1.7 How long do we keep personal information?

1. We retain personal information only for as long as it is reasonably needed for the purposes for which it was collected, or as required by law, permit conditions or audit requirements.
2. Entrant Data is retained for a period of six months following the close of the relevant promotion, or for such other period as is directed by the Promoter or required by applicable permit conditions, in case of audit, prize claim disputes or regulatory enquiry. At the end of the applicable retention period, Entrant Data is securely destroyed or de-identified.
3. Subscriber and client account information is retained for the duration of the account relationship and thereafter for the period required to satisfy our legal, accounting and reporting obligations.

1.8 How do we store and protect your information?

1. We use different technologies and procedures to help protect personal information from unauthorised access, loss, alteration, disclosure or use, including technical and organisational measures consistent with APP 11. Some of the safeguards we use are physical access controls, information firewalls and access authorisation controls to where your personal information is held in data centers. We also use data encryption when personal information is transferred to and from our service providers. Our commitment to data security means:
   1. we have procedures to limit access to personal information within our organisation;
   2. we use security measures and technologies within our organisation to protect your personal information, including encryption of data in transit and logical separation of client data; and
   3. we use service providers that can establish that they have secure controls relating to software security, access security and network security, including where payment information is being transferred.

   Our website and server are hosted in Australia. See security page link below for more information titled "Our Data Centers" (bottom of page): https://fronterly.com/security

2. In the event of a data breach involving personal information that is likely to result in serious harm, we will act in accordance with the Notifiable Data Breaches scheme under the Privacy Act, including notifying affected individuals and the Office of the Australian Information Commissioner where required.

1.9 Automated processes, draws and fraud detection

1. Some functions of our platform operate using computer programs without human intervention. These include the random selection of winners in electronic draws and instant win mechanics, the validation of entries and unique codes, and automated systems that score entries for indicators of fraudulent, duplicate or ineligible activity.
2. These automated processes use the personal information submitted with an entry, together with technical information such as IP addresses and device signals, and may substantially and directly affect outcomes for entrants, such as whether an entry is accepted, flagged for review or declared a winner.
3. Entries flagged by our automated fraud detection systems are subject to review, and final decisions on disqualification are made in accordance with the terms and conditions of the relevant promotion. If you believe an entry has been incorrectly flagged or rejected, you may contact us or the Promoter using the details in section 1.10.

1.10 How can I access the personal information that you collect?

1. We are happy to provide you with details of personal information held about you. APP 12 allows you to get access to, and correct, the personal information we hold about you.
2. To access this information, you need to email or write to us using the contact details below. Please also include your name and email if you are a subscriber to Fronterly.com, or the name of the promotion and the details you entered if your request relates to a promotion.
3. APP 13 allows you to ask us to take reasonable steps to correct any personal information that is inaccurate, out of date, incomplete, irrelevant or misleading.
4. If you believe that your personal information has been misused, you can inform us of your complaint by writing to our address and we will attempt to resolve the matter within a reasonable period.

   Fronterly Pty Ltd
   Address:
   Level 5, 447 Collins St
   Melbourne VIC 3000
   Email:
   [email protected]
   

5. If you are not satisfied with the outcome of your complaint, you may refer the matter to the Office of the Australian Information Commissioner (OAIC). Telephone: 1300 363 992.

   [email protected]
   OAIC complaints page: http://www.oaic.gov.au/privacy/privacy-complaints

1.11 Direct marketing

We may send our subscribers and clients information and updates about products, services and special offers we provide. Every commercial electronic message we send includes a functional unsubscribe facility, and you may opt out of receiving direct marketing from us at any time. We do not use Entrant Data for our own direct marketing.

1.12 Third party links

Our Websites and Services may include links to websites operated by third parties. We have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our Websites and Services and welcome any comment about linked websites.

1.13 Terms and conditions

Please also visit our Terms of Access to our Website and our Terms of Use regarding uploading material or information to our Website here which sets out the conditions of use and limitations of liability governing the use of our Website.

1.14 Changes to our privacy policy

1. If we decide to change this privacy policy, we will post those changes on this page, and update the privacy policy modification date below. Where a change is significant, we will take reasonable steps to bring it to your attention.
2. This privacy policy was last modified on 8 July 2026.