Privacy Policy

Athenee Solutions Pty Ltd, referred as the "Gifted Service Provider", is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information within the scope of the installation of the Gifted mobile application (referred to as the "App").

We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act). The NPPs govern the way in which we collect, use, disclose, store, secure and dispose of your Personal Information. A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at https://www.oaic.gov.au/.

What is Personal Information and why do we collect it?

We collect and/or disclose Personal Information in order to:

• provide and improve the products and services you have requested;
• notify you about changes to the products and services you have requested;
• provide customer support;
• detect, prevent and address technical or other issues;
• preserve IT security;
• generally carry out our business;
• comply with laws or regulations; and
• promote and market products, services and special offers that may be of interest to you.

When we collect Personal Information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. In connection with the installation and usage of the App, we collect, process and use the data described below to find out which companies, products or other topics you might be interested in and which information and offers from our partner companies are relevant for you to be able to use the functions of our App on this basis as needed and to provide you with the most relevant information and offers from our partner companies in the App.

If you use the App, we collect, process and use the following data for the previously listed purposes : name, email address, location as part of records of your communication and interaction with us; information from enquiries you have made via email, history of your preference, interests and behaviour relating to transactions, products, and services on the App or the website.

• Gift Cards data: In order to use the functions of the app, you have to provide details about the card merchant, the card number, the barcode number, the pin number, the value amount and expiry date. The Gift Card data are used within the scope of the App as well as to protect against abuse and - if additionally agreed upon - the provision of other services. To note that we do not process or share the card number, the barcode number or pin number of your Gift Cards.
• Usage data: If you use the App, we collect and save how and when you use the card (for example, when you record a new transaction for the card).
• Location data: If you allow the App to access the location function on your mobile device, the Gifted Service Provider is entitled to use the corresponding location data (so-called location-based data) to design the App as needed, to deliver location-related information and for advertising. The App only accesses this data in an anonymous form. There is no further usage or sharing of this location-based data from the respective user. For the location-based data, the App uses the GPS module from the mobile device, the IP address or cellular network data (cell ID) from the respective user.

Additionally, we use the previously listed data in an anonymised form for market research and to create anonymised statistics in order to improve the App.

We also collect Information which does not allow us to identify you specifically, including:

• your device's IP address
• your device type;
• the browser type;
• details of the site from where you accessed the app-gifted.com site;
• the pages you visit on app-gifted.com website; and
• the time spent on those pages, items, and information searched, access times, dates and other statistics.

We don't guarantee any of the website links or policy of authorised third parties.

Third Parties

We use the following third-party services:

• Vercel: we use Vercel to operate the app-gited.com site - a service offered by Vercel Inc. 440 N Barranca Avenue #4133, Covina, CA 91723, United States. Vercel is a frontend cloud for deploying and scaling frontend applications. You can find more information about Vercel at https://vercel.com/legal/privacy-policy.
• Mixpanel: we use Mixpanel in our App - a service offered by Mixpanel Inc. (Mixpanel), 405 Howard Street, Floor 2, San Francisco, CA 94105, USA to collect technical data from our App and website in a pseudo-anonymous manner so that we can better understand how users interact with our app. Mixpanel is used to be able to better understand and track activities within the app as well as to inform you based directly on your activities. You can find more information about Mixpanel at https://mixpanel.com/terms. You can opt out of this data processing at any time through https://mixpanel.com/optout.

Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

• Third parties where you consent to the use or disclosure; and
• Where required or authorised by law.

Other than the processing listed above, your personal data will only be shared with your consent. We may disclose your Personal Information to third parties (including banks, payment gateways, credit card schemes and processors, suppliers, couriers, mailing houses and Government Authorities) in order to fulfil our services to you. While such third parties may be overseas, we require them to apply standards that are no less rigorous than those required by Australian legislation.

We do not sell Personal Information to third parties.

With the express consent to this data protection declaration, You give us the consent to share your data with the respective gift card provider or the respective partner company.

Security of Personal Information

Your Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure. But remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. We use commercially acceptable means to protect your Personal Information but we cannot guarantee its absolute security.

We process and save your personal data as long as it is required to fulfil our contractual and legal obligations.

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years.

Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

You have the right to request access to any of your Personal Information which we are holding. We may charge you a reasonable fee for such access.

In order to protect your Personal Information we may require identification from you before releasing the requested information.

Policy Updates

We are constantly developing and enhancing our use of online technologies and make reasonable efforts to ensure we keep this privacy statement and related documents up to date in this regard. This Policy may change from time to time and is available on our website and app.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy please contact us at: legal@app-gifted.com