The must-read 2025 Spriggy Economy Report is here 💸
Read more
Last updated 5 August 2024
If you have any questions, then
get in touch by emailing hello@spriggy.com.au
All references to "Spriggy", "we", "us" or "our" in this privacy
policy are references to Rivva Pty. Ltd. ABN 86 603 542 918
trading as Spriggy and the Spriggy group entities (Spriggy Schools
Pty Ltd ABN 48 650 445 819, Spriggy Invest Pty Ltd ABN 21 639 671
926 and Rivva Mobile Pty Ltd ABN 35 674 423 333). Spriggy is
committed to protecting your privacy and to compliance with the
Privacy Act 1988 (Cth). If you have any questions relating to this
privacy policy or your privacy rights, please contact us.This
privacy policy sets out the policy of Spriggy for handling and
protecting your personal information when you visit our websites,
download and use our apps, apply for and use Spriggy products, or
otherwise interact and engage with us in relation to our products,
features, and services. It applies to the personal information of
both parents and/or guardians and their children who may use our
products and services. If you do not provide the information
requested, we may be unable to provide you with our products
and/or services.
PERSONAL INFORMATION
Personal information is information or an opinion about an
individual who is identifiable or reasonably identifiable, from
the information or opinion. Spriggy may collect personal
information about you, which may include:
• your contact
details, including your name, postal address, email address and
phone numbers;
• payment details;
• information
collected using cookies, such as when you visit our website(s) and
interact with our content (please see section on cookies below for
more information), and technical information about your device;
• information about your activity on our website and mobile
applications;
• any identity information (such as your date
of birth, driver's licence details, passport details, residential
address or Medicare number) necessary for the purposes of
complying with applicable laws such as the Anti-Money Laundering
and Counter-Terrorism Financing Act 2006.
COLLECTION OF PERSONAL INFORMATION
Spriggy may collect personal information as follows:
•
directly from individuals (generally sought or collected through
our sign-up forms, and if you use a Spriggy card to make a
purchase in store or on-line or make a non-cash payment (if
applicable) or otherwise use our applications);
• through
our website, apps, social media and other digital services;
•
third parties, such as from another Spriggy group entity, our
service providers or partners;
• public sources; and
•
any party authorised to act on your behalf.
We may
monitor and record your communications with us (including email
and telephone for security, dispute resolution and training
purposes).
We may receive information about you when you
link a third-party service with our services. For example, you may
authorise our services (including via our apps) to access,
collect, display and store files including images from your
device. We only use images where they are uploaded by you to our
app or website for the purpose of using an image as a profile
photo or goal photo (as applicable). You or your child (where you
have activated SPRK mode in the Spriggy pocket money app) may
authorise our services (including via our apps) to sync a contact
list, address book or individual contact. This information is only
used so that your connections are available to you through our
services or so you can invite others to collaborate with you on
our services. Where persons in your contact list are existing SPRK
users, we may also store a unique identifier number for them for
analytical purposes and to better understand interactions between
existing SPRK users. We will not publish or disclose your contacts
without your prior authorisation.
We may use Stripe
Payment Australia Pty Ltd (ACN 160 180 343) ("Stripe") for
payment, analytics, and other business services. Stripe may
collect personal information including via cookies and similar
technologies. The personal information Stripe collects may include
transactional data and identifying information about devices that
connect to its services. Stripe uses this information to operate
and improve the services it provides to us, including for fraud
detection, loss prevention, authentication, and analytics related
to the performance of its services. To provide these services to
Spriggy, Stripe shares personal information (including your
payment method information e.g. the last 4 digits of your card
number and expiration date) with Spriggy. Stripe may update your
payment method information (and share this updated information
with Spriggy) if your information has changed or been updated to
ensure your transactions go through smoothly, including by working
with your card issuer. You can learn more about Stripe and its
processing activities via its privacy policy at https://stripe.com/privacy.
OUR WEBSITES, APPS, COOKIES AND EVENT TRACKING
We provide information and services through a range of
digital and online services including websites (e.g.
spriggy.com.au), apps, email, online advertisements, IPTV and
social media profiles. These services may be operated by us to
provide a consistent experience, personalise your use of each of
those services and provide targeted marketing. Our website(s) and
app(s) may also use a variety of analytics and tracking tools
designed to help us understand usage, fix bugs and improve the
effectiveness of our marketing activities. This includes
"cookies", tracking pixels and app or website based event data.
These tools help us with marketing analytics, provide information
on how users interact with our website and determine the most
relevant audience for our ads. To amend your ad preferences for a
specific social media network, please review the relevant privacy
policy for that provider. 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 browsing session and remembering your details and
preferences when you return. Other technologies that may be used
with Spriggy include web beacons (which may operate in conjunction
with cookies), Flash local stored objects and JavaScript. You can
configure your web browser to reject and delete cookies and block
JavaScript but you may find some parts of Spriggy services then
have limited functionality. You can control your preferences
regarding Flash local stored objects via this site.
Our
systems record a variety of information in relation to
interactions with our online services. This can include
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 such as links clicked. In some cases,
third parties may use cookies and other technologies such as those
described above as part of the Spriggy services. These
technologies may be used in connection with activities like
surveys, online behavioural advertising, website analytics and
email campaign management.
USE AND DISCLOSURE OF PERSONAL INFORMATION
We may use your personal information to:
• provide you
with our services (this includes providing you with access to our
mobile application(s) and, where applicable, enabling our service
providers or partners to provide their products/services to you);
• provide our card/ payment services (this includes processing
payments, delivering orders, managing promotions, providing
refunds and discounts, and verifying your identity);
•
conduct product/market research and user analytical activities;
• communicate with you and respond to any specific requests you
may make of us;
• notify you of any products, services or
special offers that may be of interest to you;
• audit and
monitor the services we provide to you;
• tailor, personalise
and improve our products and services;
• provide you with
information and marketing about our products;
• conduct risk
assessments;
• update your personal files and manage our
relationship with you;
• enable us to meet our legal
obligations under law (eg AML/CTF, tax laws); and
• protect
our legal rights and resolve disputes or complaints.
Spriggy may disclose your personal information within the
Spriggy group and to our agents, contractors, partners or third
party service providers to enable them to provide administrative
and other support services to us and, where applicable, to provide
their products/services to you. We may also use third party
service providers to maintain some of our data systems and provide
auxiliary services. We require any party that has access to
personal information to maintain comparable privacy policies and
procedures and be subject to comparable privacy regulation in
their jurisdiction, if located outside Australia.
When you
use our services, we may share certain information about you with
other service users. For example, we may display images you
authorise us to access from your device with connections you
invite to collaborate with you on our services.
We will also
disclose your personal information where the disclosure is
required by law, for example to government agencies and regulatory
bodies as part of our statutory obligations, or for law
enforcement purposes.
Spriggy is not responsible for the
privacy practices of third parties. Where we provide links to
third party websites or services you should review any privacy
policies of those third parties for further information on their
privacy practices.
DIRECT MARKETING
We may utilise your personal information to provide you with
targeted marketing and advertising initiatives via telephone,
email or other media such as social media, regarding products,
services or special offers we think may be of interest to you. You
may notify us that you do not wish to receive such communications
by clicking on the opt-out link provided or otherwise opting out
by contacting us at any time, for example by emailing us at hello@spriggy.com.au.
Often the law requires us to advise you of certain
changes to products/services or regulations. You will continue to
receive this information from us even if you choose not to receive
direct marketing information from us. We will only disclose your
information to an outside party for the purpose of allowing them
to directly market to you, where you have consented to such
disclosure.
CROSS BORDER DISCLOSURE
Spriggy transfers personal information overseas for the purpose
of operating the services we provide to you including providing
you with customer support and communications to jurisdictions with
a comparable privacy regime in place. At the current time these
overseas jurisdictions are primarily the United States, Europe and
the United Kingdom.
ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
You may request access to or correction of the personal
information which Spriggy holds about you by contacting our
Privacy/Data Protection Officer on the details set out below. We
will not charge you a fee for your access request but may charge
you the reasonable cost of processing your request.
Privacy/Data Protection Officer
hello@spriggy.com.au
We will seek to provide such information within a
reasonable period of time, and in the manner so requested (where
reasonable to do so). If you change your contact details (such as
your phone number, street address or email address) or if any of
your details need to be corrected or updated please let us know as
soon as possible.
Spriggy may not always be able to give you
access to all the personal information we hold about you. If this
is the case, we will provide a written explanation of the reasons
for our refusal, together with details of our complaints process
for if you wish to challenge the decision.
SECURITY OF PERSONAL INFORMATION
We take reasonable steps and precautions to keep personal
information secure from loss, misuse, and interference, and from
unauthorised access, modification or disclosure.
If you use
the Internet to communicate with us, you should be aware that
there are inherent risks in transmitting information over the
Internet. While Spriggy utilises SSL security protocols we do not
have control over information while in transit over the Internet
and we cannot guarantee its security.
Where information is no
longer required to be held or retained by Spriggy for any purpose
or legal obligation, we will take all reasonable steps to destroy
or de-identify the information accordingly. If at any time you
wish to have your personal information that we hold destroyed or
de-identified please contact us at hello@spriggy.com.au and we will take reasonable steps to attend to this request, unless
there is a requirement for the information to be held or retained by
Spriggy to comply with our legal obligations or as may be permitted
by law.
The Spriggy website(s) and app(s) may contain links
to the websites of third parties. If you access those third party
websites, they may collect information about you. You will need to
contact them or review their privacy policies to ascertain their
privacy standards.
YOUR CONSENT AND CHANGES TO THE PRIVACY POLICY
Upon using our website(s), any Spriggy mobile application and our
services, you consent to our use and handling of your information
as set out in this policy. If at any time our information
practices change in the future, we will amend our policy and will
provide the updated version on our website. You should check our
website periodically to ensure you are up to date with our current
policy. We may provide you with notice where we make material
changes to our policy.
PRIVACY COMPLAINTS
If you have a complaint relating to our compliance with
privacy laws or our treatment of your personal information, please
contact our Privacy/Data Protection Officer via email to hello@spriggy.com.au.
We will investigate your complaint and endeavour to
resolve the issue to your satisfaction. If you are not satisfied
with the outcome of your complaint, you have the right to lodge a
complaint with the Office of the Australian Information
Commissioner by telephoning 1300 363 992 or visiting their website
at www.oaic.gov.au.
