There is no obligation for you to sign up to Offers, at all. If you sign up to any Offers, we may share your Personal Information, where applicable, with the party identified in the Offer, so that any Offers they have offered may be fulfilled by them, and so they may provide further information associated with such Offers, as further detailed below under ‘Use and Disclosure of your Personal Information’. Importantly, there are no negative consequences if you do not sign up to an Offer, nor are you prevented from accessing the services in future from that company – simply no further action will be taken in respect of that Offer.
RPBA takes your privacy very seriously and is committed to protecting it, as well as securing the data entrusted to us by Partners, Advertisers and you. We understand that you will only use our service if you can trust us to protect your Personal Information and use it appropriately. For more information on the steps we take to secure your data, see ‘Information security safeguards’ below.
“Personal Information” or “Personal Data” is information about you which (i) can be used to identify, contact or locate you; (ii) can be combined with other information that is linked to you; or (iii) is defined as “Personal Data” or “Personal Information” by applicable laws or regulations relating to the collection, use, storage or disclosure of information about you. Personal Information includes contact information (e.g. email address, telephone number), online information (e.g. IP addresses, device identifiers), and other data which can be used individually or in combination with other data to identify an individual (such as gender, marital status, age, or postcode).
We collect and process a number of categories of Personal Information, on the basis of the legitimate interests of RPBA and its Partners and Advertisers:
In some circumstances where we process your Personal Information on the basis of our legitimate interests and those of our Partners and Advertisers, separate consent may be required by law for us to operate our technology (for example, in the case of cookies or other tracking technology that we use to access end user devices or technology that identifies your general location or geographic position). Your consent may be obtained by us or on our behalf by our Partners and Advertisers.
The legitimate business interests referred to above, which have been balanced against the rights and freedoms of data subjects and their reasonable expectations, include:
Note that, depending on local data protection laws where you are located, you may have a right to object to processing on the above basis – see below under ‘Your rights in relation to your Personal Information’.
Note in order to offer you a more consistent and personalised experience in your interactions with RPBA, information collected through one RPBA service may also be combined with information obtained through other RPBA services.
RPBA’s technology allows us to display Offers from Partners and Advertisers on RPBA Sites, and allows you to sign up to receive communications with respect to such Offers. The following subsections detail how your Personal Information is used by RPBA (i.e. for what purpose), as well as the basis on which we disclose information to our Partners and Advertisers and other third-party processors.
(i) Use of Personal Information by RPBA
We use your Personal Information for purposes including:
We may state a more specific additional purpose when we collect your Personal Information.
(ii) Disclosure of your Personal Information to Advertisers or Partners
(iii) Further disclosure of your Personal Information
We may additionally disclose your Personal Information as follows:
RPBA processes Personal Information in multiple countries, on high-security servers, possibly located outside the country where you live, with our primary servers located in Australia. Before we disclose your Personal Information to an overseas recipient, we take steps as are necessary and reasonable in the circumstances to help ensure that the overseas recipient does not breach privacy laws in relation to your Personal Information.
Where we disclose your Personal Information to Advertisers and other third-party processors, it is likely (although not assured) the Advertisers or third-party processor will be located in one of the markets in which we operate or have a presence – Australia and any other countries in which we operate as disclosed on our site.
RPBA discloses Personal Information of individuals located in Australia with: (i) suppliers; (ii) other members of the RPBA Group; and (iii) RPBA’s Advertisers and Partners located outside of the Australian Economic Area. Such transfers may be made: (a) to a third country or territory that is assessed by the Australian Commission as ensuring an adequate level of protection; (b) to recipients who have in place appropriate safeguards, such as standard contractual clauses that are approved by the Australian Commission or binding corporate rules that have been approved by a competent supervisory authority; or (c) where a transfer to a third country is occasional and necessary in relation to a contract between us or in your interest or for the establishment, exercise or defense of legal claims.
The security of your Personal Information is a priority for us, especially when your personal information is transferred ‘overseas’.
We take appropriate technical and organisational measures (including physical and electronic security) designed to safeguard Personal Information from loss, misuse, unauthorised access, modification or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information. However, no method of online transmission or storage of information is 100% secure, and we cannot guarantee that your Personal Information will always be safe no matter what measures we put in place. Specific measures that we use include:
determining how long to retain the Personal Information about you supplied to us by them, subject to you exercising your lawful data subject rights, and further subject to any requirement for us to hold data for such period as may be required to establish, exercise or defend legal rights or ongoing legitimate business interests (e.g. to prove that you signed up to a particular Offer or electronic communication). These periods vary by market in accordance with local laws. Please refer to the ‘Your rights in relation to your Personal Information’ section below for more information about how you can exercise your rights.
In respect of other categories of Personal Information and Personal Information collected on RPBA Owned Sites, if RPBA has no ongoing legitimate business need to process your Personal Information, we will take all reasonable steps to destroy the information and/or ensure that the information is de-identified or anonymized or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
We rely on the following criteria to help determine the appropriate retention periods: (i) the necessity of the Personal Information to provide our services to Partners and Advertisers; (ii) the types and sensitivity of Personal Information being processed; (iii) regulatory requirements that we are subject to, including laws and regulations related to tax, employment, accounting, and securities; and (iv) whether a legal claim might be brought against us, for which the Personal Information would be relevant.
RPBA is not responsible for how long Partners and Advertisers may retain your Personal Information. You should consult the privacy notices provided by Partners and Advertisers with whom you interact in order to determine how long they may retain your Personal Information.
Like many companies, when we display online Offers to you, we may use one or more persistent “Tracking Technologies” (such as cookies, entity tags (eTags), pixels, web beacons/ GIFs, local storage, or other identifiers on your device and browser settings) in order to recognise you and your device each time we display Offers to you. We also apply statistical probabilities to data sets, which attempt to recognise or make assumptions about users and devices (e.g., that a user of multiple devices is the same user). Tracking Technologies may set or alter settings or configurations on your device. We use both session and persistent Tracking Technologies.
We use these technologies for a number of purposes to enhance your online experience, such as for preference setting, Offer selection, analytics, conversion attribution and fraud reduction. By rejecting Tracking Technologies, this does not mean that you will no longer see ads when you visit RPBA Sites.
Further information on our use of Tracking Technologies, and how you can exercise your rights not to accept the use of Tracking Technologies, is set out in our ‘Cookies’ Policy.
This policy does not apply to the practices of organisations that RPBA does not own or control, or to people that RPBA does not employ or oversee even if Offers, coupons or links to their websites appear within our technology.
As a marketing technology provider, RPBA does not endorse any specific Partner or Advertisers, nor does it take any responsibility for concluding or finalising Offers on their behalf. RPBA gives you the opportunity to elect to receive information about Offers that you determine are of interest to you – without taking any of your specific personal circumstances into account.
Where provided for by applicable law where you are located, you may have a number of rights regarding the processing of your Personal Information, including some or all of the following rights:
Non-discrimination and applicability of these rights
Other users may have similar rights granted to them under local laws. In such case we will act in accordance with those laws. You will not be discriminated against for exercising your privacy rights. We may deny certain requests, or fulfil a request only in part, based on our legal rights and obligations. As noted earlier, if you are an employee or contractor, or if you are a job applicant, your rights with respect to your Personal Information collected in those contexts will be described in a separate privacy notice that we provide to you where and when appropriate.
How to exercise your privacy rights (including through an authorized agent)
If you are not satisfied with the outcome of your request and would like to request further review, you may send an email to [email protected] with “Personal Information Requests Appeal” in the subject line.
Verification and security
We will take reasonable steps to verify your identity prior to responding to your requests. The verification steps will vary depending on the sensitivity of the Personal Information and the nature of your request. Note as a security measure, to ensure that we properly identify you, such requests will only be actioned in respect of, and confirmed by way of reply email to, the specific email address from which the request was made. Note we will refuse requests made in respect of email addresses which a user cannot access. User requests will be answered as soon as possible but not later than one month after they are made or such other time that may be required under applicable privacy laws.
Withdrawing consent from RPBA for direct marketing communications / unsubscribing
Where you have given your consent for specific purposes, such as sending direct marketing by electronic mail, RPBA provides a facility for you to withdraw such consent for RPBA to process the Personal Information for that purpose. Note there are no adverse consequences for withdrawing your consent.
To unsubscribe from:
Note: if you withdraw consent, we will keep a copy of your email address on file to record that you have withdrawn your consent, and we will retain any information not provided on the basis of consent, and any information to the extent necessary to establish, exercise or defend legal rights. Even if you opt-out, we will still send you non-marketing emails, such as emails about recent transactions or updates to our legal terms.
Withdrawing consent from RPBA’s Advertisers and Partners for direct marketing communications / unsubscribing
In order to withdraw consent from our Advertiser and Partners, to exercise your data subject rights or to otherwise access, update or delete any of your Personal Information retained by them, you should contact them directly.
Where RPBA Advertisers and Partners have integrated with the RPBA unsubscribe mirroring service, where you request to unsubscribe from any further email correspondence from RPBA, you will be presented with the option to also unsubscribe from the applicable RPBA Partner or Advertiser’s communications at the same time. This may only be done by following the unsubscribe link contained in the emails we send you, and will be confirmed at the time of making the unsubscribe.
Is unsubscribing the same as opting out?
No. Unsubscribing/ withdrawing consent means we won’t send future electronic communications to you unless you sign up again to subsequent Offers. However, if you want to avoid in the future seeing any third-party Advertiser Offers on RPBA Sites, you should ‘opt out’. The next section deals with Opting Out.
Opting out from Advertiser Offers
RPBA provides a facility for you to opt out of seeing all future third-party Advertiser Offers on RPBA Sites (thereby avoiding any targeted third-party Offers in the future).
To request this please send an email to [email protected] with the subject “Opt Out”. Note we will keep a copy of your email address on file to retain a record that you have opted out. If you use another email with a RPBA Partner, then you may need to opt out from multiple email addresses in order to ensure you don’t see any targeted third-party Offers in future.
Even if you opt out you will still need to unsubscribe directly from any of our Partners’ or Advertisers’ mailing lists if you want to stop receiving electronic communications from them.
Opting out from Partner Offers
Even if you opt out you will still see offers from Partners which are native to the Partner’s site. You cannot opt out from seeing first party Partner Offers.
RPBA does not allow advertisements to be targeted at individuals under the age of 18.
RPBA does not knowingly collect Personal Information from or about children under the age of 18. If we learn that we have collected Personal Information of a child under the age of 18, we will delete that data from our systems.
RPBA encourages parents and guardians to monitor their children’s activities online.
RPBA’s Data Protection Officer can be contacted via [email protected].
Version: August 2023