CUDO and Privacy
CUDO is bound by the National Privacy Principles (“NPPs”) contained in the Privacy Act 1998 (Cth) (the “Privacy Act”).
What kind of personal information does CUDO collect and how does CUDO collect it?
The types of personal information we collect will vary depending on the nature of your dealings with CUDO (our agents, contractors and third parties).
CUDO collects most information directly from you. Generally we collect this information to provide you with a range of products and services and so you can receive information on opportunities to purchase Coupons and Coupons you have purchased, receive your purchased Coupon, receive other special offers, join loyalty clubs, advertise on our website, enquire about how you can become a CUDO Merchant , complete a survey or questionnaire, enter a competition or register to attend an event, seek employment, or communicate with CUDO by e-mail, telephone or in writing.
We may also collect personal information to assist in identifying ways in which CUDO can service you better, such as providing our products and services to you more effectively, and to assist our internal administration and operating including accounting, risk management, record keeping, archiving and staff training.
We may also collect personal information through:
• third parties such as our related companies;
• Merchants and other business partners who assist us provide CUDO’s products, offers and services;
• data washing organisations; and
• other websites that are maintained by CUDO but not owned by CUDO.
Sometimes CUDO may be provided with personal information about an individual from a third party, for example CUDO may obtain data from a 3rd party member club that we will use to provide a special offer or service to those members and/or CUDO may obtain personal information through social media forums/platforms that you sign up to and/or provide CUDO permission to obtain in relation to the respective social media forum guidelines and or conditions.
In general, the type of personal information CUDO collects and holds could include (but is not limited to) name, address (postal and email), contact details, geographic location, gender, transaction details relating to your use of CUDO’s products and services and any preferences you tell us about.
We may collect your personal information over the internet (including when you create an Account), over the phone, when you write to us or when you participate in a survey, questionnaire, competition or other marketing campaign.
How CUDO uses Personal Information
CUDO may use your personal information for a variety of purposes in connection with providing you with Coupons (and information on opportunities to purchase Coupons), CUDO’s products and services and special offers available to CUDO members.
In general, CUDO uses personal information for the following purposes:
• to provide offers to persons who register an Account to receive information on opportunities to purchase CUDO Coupons ;
• to provide other products or services which are requested from CUDO, including advertising services;
• to process and administer our dealings with you;
• to develop processes, products and services to better meet your needs;
• to help CUDO manage and enhance its products and services and the opportunities to purchase CUDO Coupons;
• unless requested not to, to communicate with you regarding opportunities to purchase Vouchers for products and services promoted by us via the Getaway Lounge website (www.getawaylounge,com.au);
• to communicate with online users of opportunities to purchase CUDO Coupons
• unless requested not to, to send you marketing materials which promote the goods or services of a third party (including by way of electronic direct marketing activities)
• to provide people with ongoing information and advertising about CUDO's products and services in which they may have an interest; and
• unless requested not to, CUDO may provide your personal information to third parties for marketing purposes.
In many cases where CUDO asks you to provide CUDO with personal information, if you do not provide CUDO with that personal information CUDO will not be able to provide you with the relevant product or service.
Secure Online Transactions
If you purchase a Coupon through our website, we process your credit card details securely over the Internet using eWAY’s bank-grade data centre (eWAY is an accredited Internet payment security system authorised as a third party processor for all major Australian banks). With the combination of transaction performed under 128 Bit SSL Certificate on our website and a secure browser at your end, we take all measures to ensure that your credit card and anonymity are protected when you purchase online.
Alternatively, you can purchase using PayPal. PayPal secures your information using 128 Bit SSL to encrypt your confidential information.
Links to Third Party Websites from CUDO Websites
CUDO operates one main website in relation to its products and services and general business. To the extent that CUDO contains links to sites operated by third parties and not related to CUDO products, services or events (“Linked Websites”), the Linked Websites are not controlled by CUDO. We may collect personal information from the CUDO Website and Linked Websites in our role as website portal. However, we are not responsible for the privacy practices of those companies. Before disclosing your personal information to Linked Websites, we advise you to examine their privacy policies.
Third Party Advertisements Online
To try and identify Coupons that may be of interest to you, CUDO has relationships with other companies that we allow to place advertisements on our web pages. If you visit our website, advertisement server companies may collect information such as your domain type, your IP address and clickstream information.
Redeeming Coupons with Merchants
Also, with your consent, CUDO may pass your personal information on to Merchants from whom you have received a Deal, so that the Merchant can keep you informed of future events/offers they may be providing. If you are required to make a booking with a Merchant in order to redeem your Coupon, you may be asked at the time of that booking if you would like to receive this information. You may change your preference at any time directly with the Merchant which has collected your personal information. If you do not have the Merchant’s contact details you may contact our Privacy Officer directly.
To whom might CUDO disclose Personal Information?
CUDO may disclose personal information it collects about you for a variety of purposes in connection with CUDO providing its products and service and special offers to you (including to our agents, contractors or to a related company). CUDO may provide your personal information to:
• organisations who are sponsoring, organising or otherwise involved with or participating in a Deal (including Merchants) and other promotion, competition or survey;
• other companies or individuals CUDO engages to perform functions on behalf of CUDO such as for production functions, processing credit card information, mailing of information or gifts/ offers/ prizes, printing functions, data analysis, data washing, telemarketing, research, and advertising; and
• anyone you authorise CUDO to disclose personal information to.
CUDO may decide to buy or sell assets which form part of or relate to its business. In any such transaction, personal information will usually be one of the transferred assets and will be disclosed to the purchaser.
Where we disclose personal information to third party contractors, agents or related companies, we take steps to ensure that those agents, contractors or related third parties:
• comply with the NPPs when they handle personal information about you (regardless of whether they are a small business and would otherwise be exempt from the NPPs); and
• are authorised only to use personal information in order to provide the services or to perform the functions we require.
Otherwise, we only disclose personal information if required or permitted to do so by law or if the disclosure is permitted under the Privacy Act.
How does CUDO treat Sensitive Information?
In referring to 'sensitive information' CUDO means information relating to a person's racial or ethnic origin, membership of political bodies, religions, trade unions or other professional or trade association, sexual preferences, criminal record and health information.
If you decide to provide CUDO with sensitive information, it is CUDO’ policy that this information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise or use or disclosure of this information is allowed by law.
Management and security of personal information
We take physical, electronic and managerial steps to ensure that the personal information we hold is secure from unauthorised access, destruction, use, modification or disclosure. We only permit your details to be accessed by authorised personnel and we educate our staff about their responsibilities under the NPPs. CUDO has also appointed a Privacy Officer to oversee CUDO’s management of personal information in accordance with this policy and the Commonwealth Privacy Act.
Additionally, we take reasonable steps to destroy or permanently de-identify personal information when we no longer need it. We also impose strict requirements of security and confidentially on all third parties as to how they store, handle and deal with personal information.
In striving to ensure that the security, integrity and privacy of personal information submitted to our site is maintained to the highest level, CUDO regularly reviews and updates its security measures in light of current technologies. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure and you need to be aware of this when using our website.
Where it is lawful and practicable to do so, customers may transact with CUDO without providing personal information. However, if we do not collect personal information about you at (without limitation) the point of a sale, transaction, registration of interest, registration for offer we will not be able to contact you in the case of an change in offer, event cancellation, venue change, cease of offer for example.
Sometimes, CUDO needs to collect personal information about individuals who are not Account holders or customers. This will usually arise where we collect the name and business contact details of a person who is the contact in a government agency or company with whom we deal. CUDO's policy is to only use personal information collected from non-customers for the main business purpose for which it was collected.
Transborder data flows
Updating Personal Information
CUDO endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. CUDO encourages you to contact it as soon as possible in order to update any personal information it holds about you. CUDO's contact details are set out below.
You have the right to check what Personal Information CUDO holds about you
Under the Privacy Act, you have the right to obtain access to any personal information which CUDO holds about you and to advise CUDO of any perceived inaccuracy. There are some limitations to this right set out in the Act, which mean that we can refuse to provide you access to that information in limited circumstances, including where granting you access might have an unreasonable impact on the privacy of other individuals, if the request is frivolous or vexatious; and if the information relates to anticipated legal proceedings.
To make a request to access any personal information CUDO holds about you, please contact CUDO in writing as set out below. CUDO will require you to verify your identity and specify what personal information you require. CUDO may charge a fee to cover the cost of verifying your application and locating, retrieving, reviewing and copying any material requested. If the personal information sought is extensive, CUDO will advise of the likely cost in advance and can help to refine your request if required.
CUDO takes its obligations under the Spam Act 2003 (Cth) very seriously and has a no tolerance policy when it comes to the sending of unsolicited emails.
As part of our policy, CUDO ensures that:
· new subscribers give their consent to receive emails from us, including emails about our daily deals;
· we send new subscribers a welcome email, and that email contains an unsubscribe option;
· every group email we send to our customer base also contains an unsubscribe option.
When we are notified by someone that they wish to unsubscribe, they are unsubscribed automatically and within 48 hours of the unsubscribe option being activated (if not sooner).
Customers can also unsubscribe by following these steps:
1. Login to your Cudo account
2. Click on your account
3. Under "Select your preferences" un-tick the box "Email my Cudo straight to my inbox"
If anyone has any difficulty in unsubscribing from our emails via the automatic unsubscribe facility, we ask that they contact CUDO via the details below, and we will investigate the reason for why the unsubscribe facility may not have worked, and arrange for the user to be unsubscribed as a matter of urgency.
How to contact CUDO
If you would like to make an access request or wish to provide feedback about this policy, please contact CUDO by writing to Privacy Officer, Cudo Pty Ltd, PO Box 40, Pyrmont NSW 2009, via e-mail to email@example.com.
The CUDO website www.cudo.com.au is an online service owned and operated by Cudo Pty Ltd (ACN 145 598 894) of PO Box 40, Pyrmont NSW 2009 (‘CUDO’)
The terms “Coupon”, “Merchant” and “Deal” are defined in the Terms & Conditions of Use.