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Privacy Policy

  1. Mumli Pty Ltd (ACN 601 987 491) (“Mumli”, “we” or “us”) and its services (including the Mumli

    mobile app and website), collectively the “Service”, respects user’s (“you” or “your”) privacy.

  2. The Privacy Policy provides:

    2.1. an overview of our collection of data and information in relation to you; 2.2. how we may use such data and information;
    2.3. who we may share such data and information with; and
    2.4. your rights in relation to such data and information.

  3. By downloading, accessing or using the Service:

    1. 3.1.  you acknowledge that you have read and understood the Privacy Policy and you accept the practices and terms detailed in the Privacy Policy; and

    2. 3.2.  you provide authorisation and consent for us to obtain, gather, analyse, append additional, and retain, use, process, disclose or transfer, data and information in accordance with such Privacy Policy.

  4. References to the “Privacy Policy” are to the Privacy Policy as updated from time to time on the Service.

An overview of our collection of data and information in relation to you

  1. We may collect data and information that can or could identify you (“identifiable personal information”). In addition to data and information that does not or may not identify you (“non- identifiable information”).

  2. The Privacy Policy applies to all information we collect, use or process about you and may include some information about your physical or mental health or condition, political opinions, religious or similar beliefs, commission or allegations of an offence and other sensitive personal information. References to identifiable personal information in the Privacy Policy include such sensitive personal information.

  3. Data and information may be collected through:

    1. 7.1.  a website or websites;

    2. 7.2.  a mobile application or multiple mobile applications;

    3. 7.3.  publicly available identifiable personal information and non-identifiable information through social media data; or

    4. 7.4.  private identifiable personal information and non-identifiable information accessible through social media data where you give permission either by using social log in capability or by giving permission electronically.

  4. In order to gain access to the Service you will be required to create an account (“Account”) and login with a valid and active mobile phone number, email address or other alternate login option that we may make available.

  5. You may also be asked to allow Mumli to collect your location information from your mobile, computer or other device (“Device”) when you download or use the Service.

  6. We may collect and store any identifiable personal information you provide while using the Service. This may include (but is not limited to) personal-identifiable information, such as your name, address, email address and telephone number, information associated with managing requests, queries and complaints and, if you transact business with or through us, financial details and information.

  7. You will have the option to provide us a personal description and information about your gender and preferences for recommendations.

Protecting your privacy

  1. We may also collect information about you from other users of the Service or from third parties in connection with the provision and operation of the Service, public sources, information service providers, providers of products or services, anyone authorised to act on your behalf.

  2. We may collect information from or in relation to your Device when you visit the Service. The information we collect may also include (but is not limited to) your Device type and operating system, IP address, Device ID, browser type and language, geographic location when the Service is running, access times, and usage information.

  3. When you visit the Service, we may assign to your Device one or more cookies to facilitate access to and use of the Service. A cookie is a piece of information that allows the server to identify and interact more effectively with your Device. The cookie assists us in maintaining the continuity of your use of the Service and remembering your details and preferences for you.

  4. Through the use of a cookie or multiple cookies, we also may automatically collect information about your activity, such as (but not limited to) the pages you visit, the time and date of your visits and the links you click.

  5. Other technologies that may be used with the Service include web beacons (which may operate in conjunction with cookies), Flash local stored objects and JavaScript.

  6. Our systems record a variety of information in relation to your interactions, including (without limitation) information about software versions used, Device identifiers (like IP address), location data (where available and not disabled by the user), dates, times, file metadata, referring website, data entered and user activity.

  7. We may monitor and record your communications with us (including email and telephone) for security, dispute resolution, and training purposes.

How we use data and information

19. We may use information that we collect about you to:

  1. 19.1.  verify your identity;

  2. 19.2.  provide or administer the Service and its functions;

  3. 19.3.  design, improve or personalise products and services;

  4. 19.4.  manage, administer or run our business;

  5. 19.5.  process payments;

  6. 19.6.  deliver orders, manage promotions, provide refunds and discounts;

  7. 19.7.  maintain and update our records;

  8. 19.8.  communicate with you;

  9. 19.9.  manage your Account and provide you with customer support;

  10. 19.10.  conduct product and market research and analysis about your use of, or interests in, products, services or content or others interests in you or products, services, or content;

  11. 19.11.  communicate with you (other than using your name) by email, telephone, mobile devices, digital services or other means about products or services that may be of interest to you either from us or other third parties;

  12. 19.12.  develop, display, and track content and advertising tailored to your interests on the Service and other sites or applications or mediums, including (without limitation) providing our advertisements to you when you visit other sites (not addressed to you by name);

  13. 19.13.  compile or use website or mobile application analytics or statistics, survey information, behavioural advertising information and campaign management information;

  14. 19.14.  carry out any investigation or in relation to any demand, court order, request, rights, property, safety claim, proceeding, insurance, law, actual or suspected illegal activity, fraud or other wrongdoing or transaction;

  15. 19.15.  verify your eligibility and deliver prizes in connection with contests and sweepstakes;

  1. 19.16.  enforce or exercise any rights in our Terms of Use;

  2. 19.17.  work with our service providers and other Mumli related companies;

  3. 19.18.  comply with law or regulation;

  4. 19.19.  protect our lawful interests;

  5. 19.20.  facilitate purchases and potential purchases of our businesses; or

  6. 19.21.  perform functions or services as otherwise described to you at the time of collection.

  1. We may use the information collected to provide advertising on the Service or on other sites, applications or mediums (but not addressed to you by name), either ourselves or through a third party.

  2. We may implement analytical services into the Service and its advertising to track effectiveness, as defined by us or a third party. The information we obtain in this manner enables us to customise the services we offer users, to deliver targeted advertisements (not addressed to you by name) and to measure the overall effectiveness of our online or digital advertising, content, programming or other activities.

  3. We may allow service providers, advertising companies and ad networks, and other third parties to display advertisements on the Service. These companies may use tracking technologies, such as cookies or web beacons, to collect information about users who view or interact with their advertisements but we do not provide any non-anonymized identifiable personal information to such third parties.

  4. We will not use or provide your identifiable personal information for use in direct marketing addressed to you by name unless we receive your consent or have another lawful basis.

  5. If at any time you provide information or data of a third party to us, you warrant and represent that (i) you have already given written notice to the third party of the intention to use the information or data for the purposes and in the manner set out in the Privacy Policy from time to time, (ii) you have obtained the written consent of the third party to such use or provision of their information or data and (iii) the intended use of such information or data in accordance with such Privacy Policy is consistent with and covered by the consent of the third party.

Who we may share data and information with

  1. If you access the Service from a third-party social platform, such as Facebook, Instagram, Google+ or LinkedIn, we may share non-identifiable information with that platform to the extent permitted by your agreement with that platform and its privacy settings.

  2. When using the Service, we cannot control who reads your postings or what other users may do with information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your identifiable personal information.

  3. We may perform the functions referred to above directly or use a group company or third party to perform any of these functions on our behalf in accordance with the Privacy Policy.

  4. We hold data and information electronically and with the assistance of our service providers.

  5. We may share information, including (without limitation) identifiable personal information and financial information, with third parties that perform certain services on our behalf. These services may include (without limitation):

    1. 29.1.  fulfilling orders;

    2. 29.2.  providing customer service and marketing assistance;

    3. 29.3.  performing business and sales analysis;

    4. 29.4.  data processing;

    5. 29.5.  ad or data tracking and analytics;

    6. 29.6.  member screenings;

    7. 29.7.  information broking;

    8. 29.8.  online computing;

  1. 29.9.  printing;

  2. 29.10.  contact management;

  3. 29.11.  legal, accounting, financial services, business consulting, insurance or associations;

  4. 29.12.  marketing or research;

  5. 29.13.  auditing;

  6. 29.14.  benchmarking;

  7. 29.15.  archival;

  8. 29.16.  delivery;

  9. 29.17.  security;

  10. 29.18.  investigation;

  11. 29.19.  mailing;

  12. 29.20.  the provision of products and services;

  13. 29.21.  supporting other functionality with respect to the Service; or

  14. 29.22.  supporting contests, sweepstakes, surveys and other features offered through the Service.

  1. Service providers may have access to identifiable personal information needed to perform their functions but are not permitted to share or use such information received from us for any other purposes. We take steps to ensure that our service providers are obliged to protect the privacy and security of your personal information and use it only for the purpose for which it is disclosed.

  2. We may disclose your information, including (without limitation) identifiable personal information:

    1. 31.1.  when we respond to any investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims or proceedings; in connection with insurance or as otherwise required by law. In such cases, we may at our option raise or waive any legal objection or right available to us;

    2. 31.2.  when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Mumli, our users, our employees, or others; to comply with applicable law or regulation or cooperate with authorities, regulators or law enforcement; or to enforce our Terms of Use or other agreements or policies; and

    3. 31.3.  in connection with any corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the event of bankruptcy.

  3. We do not share your identifiable personal information with others except as indicated in the Privacy Policy or where we have any other lawful basis to share the information.

  4. We may use and share non-identifiable information we collect in any of the circumstances set out in the Privacy Policy. We may also share it with third parties to develop and deliver targeted advertising on the Service or applications of third parties, and to analyse and report on advertising you see.

  5. We may combine non-identifiable information we collect with additional non-identifiable information collected from other sources. We also may share aggregated, non-identifiable information, or identifiable personal information in hashed, non-human readable form, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other business purposes.

Your rights in relation to data and information

  1. If you have an Account, you have the ability to review and update your identifiable personal information within the Service by logging into your Account and going to settings.

  2. If you close your Account, we reserve the right to retain all information associated with your account for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of the Service or our users, or take other actions otherwise permitted by law.

  3. If certain information has already been provided to third parties as described in the Privacy Policy, retention of that information will be subject to those third parties’ policies or practices.

  4. You can control information collected by cookies. You can delete or decline cookies by changing your browser settings. Click “help” in the toolbar of most browsers for instructions. You can configure your web browser to reject and delete cookies and block JavaScript.

  5. We may deliver notifications to your Device. You can disable these notifications by deleting the Service or by changing the settings in either the Service or on your Device.

  6. You can choose not to provide us with certain information or allow cookies, location based information or technology, but that may result in you being unable to use the Service or certain features of the Service because such information may be required in order for you to register as a user, purchase products or services, participate in a contest, promotion, survey, or sweepstake, ask a question or initiate other transactions or use other services .

  7. We have security measures in place to help safeguard your identifiable personal information from unauthorized access or disclosure. However, no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise, nor should you expect, that your identifiable personal information, chats, or other communications will always remain secure.

  8. We take measures in respect of destroying or de-identifying personal information that is no longer needed for any lawful purpose.

  9. Our liability to you in respect of any security breach or accidental loss or disclosure of your information or data is hereby excluded to the maximum extent permitted by applicable law.

  10. Your information or data may be collected, used, disclosed, transferred or otherwise processed in or outside the country in which it was collected, including (without limitation) Australia. Laws in other countries regarding processing of information and data may be less or more stringent than the laws in the country in which you were located or the country in which the information or data was collected.

  11. The Privacy Policy does not create rights enforceable by third parties or require disclosure of any information relating to users of the Service.

Updates to the Privacy Policy

46. We will occasionally update the Privacy Policy. When we post changes to this Privacy Policy, we will revise the “last updated” date at the top of the Privacy Policy. We recommend that you check the Service from time to time to inform yourself of any changes in the Privacy Policy or any of our other policies. Any data or information will be governed by the most current version of the Privacy Policy.

How to contact us

  1. If you have any questions or complaints in relation to the Privacy Policy or our practices, or wish to request access, correction or deletion of your data or information (which you have the right to request and which we will do in accordance with applicable law) or to not receive any marketing, please contact us at hello@mumli.com.

  2. We may be required to provide reasons if we refuse any request. You may ask us to make a note of your request. We may charge a fee for your request in accordance with applicable law.

  3. For information about privacy generally, or if your concerns are not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au.