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Privacy Policy
Our Commitment To You
At Local Offers, your privacy is a priority. Your privacy is at the core of the way we design and build our service, so that you can trust the service and focus on enjoying it.
We do not compromise with your privacy. We design all of our products and services with your privacy in mind.
We strive to be transparent in the way we process your data.
We work hard to keep your information secure. We have teams dedicated to keeping your data safe. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.
Privacy Policy
Welcome to Local Offers's Privacy Policy.
We appreciate that you trust us with your information. It is important to us that you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices while aiming to keep legal and technical jargon to a minimum.
This Privacy Policy applies beginning May 21, 2024.
EFFECTIVE DATE: May 21, 2024
Who We Are
The company that is responsible for your information under this Privacy Policy (the “data controller”) is:
Get Listings Pty Ltd
406/57 Upper Pitt StreetKirribilli, NSWAustralia, 2061
2. Where This Privacy Policy Applies This Privacy Policy applies to websites, apps, events and other services operated by Local Offers. For simplicity, we refer to all of these as our “services” in this Privacy Policy. To make it extra clear, we’ve added links to this Privacy Policy on all applicable services.
Some services may require their own unique privacy policy. If a particular service has its own privacy policy, then that policy -- not this Privacy Policy -- applies.
3. Information We Collect
Using Local Offers requires you to provide us with some information about you, such as basic profile details, information gathered during your profile creation, and the types of businesses you interact with. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional information, we go into more detail below.
4. Information You Give Us
You choose to give us certain information when using our services. This includes:
When you create an account, you provide us with at least your login credentials, as well as some basic details necessary for the service to work, such as your gender and date of birth. Depending on your gender, you will also be required to give certain follow up information in the onboarding. It is important that this is true and correct for everyone's experience on the app.
When you complete your profile, you can share with us content such as photos and videos. To add certain content, like pictures or videos, you may allow us to access your camera or photo album. Some of the information you choose to provide us may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation and religious beliefs.
By choosing to provide this information, you consent to our processing of that information.When you subscribe to a paid service or make a purchase directly from us (rather than through a platform such as iOS or Android), you provide us or our payment service provider with information, such as your debit or credit card number or other financial information.When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials.
When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.If you contact our customer care team, we collect the information you give us during the interaction. Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.If you ask us to communicate with or otherwise process information of other people (for example, if you ask us to send an email on your behalf to one of your friends), we collect the information about others that you give us in order to complete your request.Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.
Information we receive from others
In addition to the information you provide us directly, we receive information about you from others, including:
Other Users Other users may provide information about you as they use our services. For instance, we may collect information about you from other users if they contact us about you.
Social Media You may be able to use your social media login to create and log into your Local Offers account.
Other Partners We may receive info about you from our partners, for instance where Local Offers ads are published on a partner’s websites and platforms (in which case they may pass along details on a campaign’s success).
Information collected when you use our services
When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:
Usage Information
We collect information about your activity on our services, for instance how you use them (e.g., date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on) and how you interact with other users (e.g., users you connect and interact with, time and date of your exchanges, number of messages you send and receive).Device information We collect information from and about the device(s) you use to access our services, including:hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple's IDFA, both of which are randomly generated numbers that you can reset by going into your device’ settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g., IMEI/UDID and MAC address);information on your wireless and mobile network connection, like your service provider and signal strength;information on device sensors such as accelerometers, gyroscopes and compasses.Other information with your consent If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it. Similarly, if you consent, we may collect your photos and videos (for instance, if you want to publish a photo, video or streaming on the services).
5. Cookies and Other Similar Data Collection Technologies
We use and may allow others to use cookies and similar technologies (e.g., web beacons, pixels) to recognize you and/or your device(s). You may read our Cookie Policy for more information on why we use them (such as authenticating you, remembering your preferences and settings, analyzing site traffic and trends, delivering and measuring the effectiveness of advertising campaigns, allowing you to use social features) and how you can better control their use, through your browser settings and other tools.
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a “Do Not Track” (“DNT”) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Local Offers, do not currently respond to DNT signals.
6. How We Use Information
The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe and to provide you with advertising that may be of interest to you. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.
To administer your account and provide our services to youCreate and manage your accountProvide you with customer support and respond to your requestsComplete your transactionsCommunicate with you about our services, including order management and billing.
To help you connect with other usersAnalyse your profile, activity on the service, and preferences to recommend meaningful connections to you and recommend you to others; For more information on our profiling and automated decision-making, please see our FAQ Show users’ profiles to one another
To ensure a consistent experience across your devicesLink the various devices you use so that you can enjoy a consistent experience of our services on all of them. We do this by linking devices and browser data, such as when you log into your account on different devices or by using partial or full IP address, browser version and similar data about your devices to help identify and link them.
To provide new Local Offers services to youRegister you and display your profile on new Local Offers features and appsAdminister your account on these new features and apps
To serve you relevant offers and adsAdminister sweepstakes, contests, discounts, or other offersDevelop, display and track content and advertising tailored to your interests on our services and other sitesCommunicate with you by email, phone, social media, or mobile device about products or services that we think may interest you
To improve our services and develop new onesAdminister focus groups and surveysConduct research and analysis of users’ behaviour to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behaviour)Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).To prevent, detect, and fight fraud or other illegal or unauthorised activitiesAddress ongoing or alleged misbehaviour on and off-platformPerform data analysis to better understand and design countermeasures against these activitiesRetain data related to fraudulent activities to prevent against recurrences
To ensure legal complianceComply with legal requirementsAssist law enforcementEnforce or exercise our rights, for example our Terms
To process your information as described above, we rely on the following legal bases:
Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyse users’ behaviour on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection, and other legal purposes.Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.
6. How we Share Information
Since our goal is to help you make meaningful connections, the main sharing of users' information is, of course, with other users. We also share some users' information with service providers and partners who assist us in operating the services, with other Get Listings Group companies and, in some cases, legal authorities. Read on for more details about how your information is shared with others.
With other users
You share information with other users when you voluntarily disclose information on the service (including your public profile). Please be careful with your information and make sure that the content you share is stuff that you're comfortable being publicly viewable since neither you nor we can control what others do with your information once you share it.
If you choose to limit the audience for all or part of your profile or for certain content or information about you, then it will be visible according to your settings.
With our service providers and partners
We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing, and security operations.
We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.
With other Get Listings Group businessesLocal Offers is part of the Get Listings Group family of businesses which, as of the date of this Privacy Policy, includes websites and apps such as Get Listings, Propdeals & Digimatch.
We share your information with other Local Offers companies for them to assist us in processing your information, as service providers, upon our instructions and on our behalf. Assistance provided by other Local Offers companies may include technical processing operations, such as data hosting and maintenance, customer care, marketing and targeted advertising, finance and accounting assistance, better understanding how our service is used and users' behaviour to improve our service, securing our data and systems, and fighting against spam, abuse, fraud, infringement, and other wrongdoings.
We may also share information with other Local Offers companies for legitimate business purposes such as corporate audit, analysis and consolidated reporting as well as compliance with applicable laws. We may also share user information with other Local Offers companies to remove users who violate our terms of service or have been reported for criminal activity and/or bad behaviour. In some instances, we may remove that user from all platforms.
For corporate transactionsWe may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganisation, dissolution, bankruptcy, or other change of ownership or control.
When required by law: We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena, or search warrant, government/law enforcement investigation, or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
To enforce legal rights: We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and the legal rights of our users, business partners, or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing.
With your consent or at your requestWe may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
We may use and share non-personal information (meaning information that, by itself, does not identify who you are, such as device information, general demographics, general behavioural data, geolocation in de-identified form), as well as personal information in hashed, non-human readable form, under any of the above circumstances. We may also share this information with other Local Offers companies and third parties (notably advertisers) to develop and deliver targeted advertising on our services and on websites or applications of third parties and to analyse and report on advertising you see. We may combine this information with additional non-personal information or personal information in hashed, non-human readable form collected from other sources. More information on our use of cookies and similar technologies can be found in our Cookie Policy.
7. Cross-Border Data Transfers
Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (“EEA”), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguard to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.
Local Offers ensures that appropriate measures are in place to protect your personal information when it is transferred internationally. This includes using standard contract clauses approved by the European Commission or other suitable safeguards as required by applicable data protection laws. These safeguards ensure that your data is protected in accordance with the privacy regulations of the respective jurisdictions.
8. Your Rights
We want you to be in control of your information, so we have provided you with the following tools:
Access / Update tools in the service. Tools and account settings that help you to access, rectify, or delete information that you provided to us and that's associated with your account directly within the service. If you have any questions about those tools and settings, please contact our customer care team for help here.Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.Deletion. You can delete your account by using the corresponding functionality directly on the service.
We want you to be aware of your privacy rights. Here are a few key points to remember:
Reviewing your information.
Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called the right of access, right of portability, or variations of those terms). You can request a copy of your personal information by putting in such a request here.Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please contact us here.
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets, intellectual property, or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.
Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.
Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier with your previous transactions and activities.Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work, or where we are established.
9. Residents of California
If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request here. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.
If you have any questions or concerns about your privacy rights, including requests related to your personal information, please don't hesitate to contact us. We are committed to protecting your privacy and will do our best to address any inquiries or issues you may have.
10. How Long We Retain Your Information
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law. If you decide to stop using our services, you can close your account, and your profile will stop being visible to other members. After your account is closed, we will delete your personal information, as laid out below:
To protect the safety and security of our members, we implement a safety retention window of three months following account closure, or one year following an account ban. During this period, we keep your information in the event that it might be necessary to investigate unlawful or harmful conducts. The retention of information during this safety retention window is based on our legitimate interest as well as that of potential third-party victims.
Once the safety retention window elapses, we delete your data and only keep limited information for specified purposes, as laid out below:
a) We maintain limited data to comply with legal data retention obligations: in particular, we keep transaction data for 10 years to comply with tax and accounting legal requirements, credit card information for the duration the user may challenge the transaction, and "traffic data" / logs for one year to comply with legal data retention obligations. We also keep records of consents members give us for five years to evidence our compliance with applicable law.
b) We maintain limited information on the basis of our legitimate interest: we keep customer care records and supporting data as well as imprecise location of download/purchase for five years to support our customer care decisions, enforce our rights, and enable us to defend ourselves in the event of a claim, information on the existence of past accounts and subscriptions, which we delete three years after the closure of your last account to ensure proper and accurate financial forecasting and reporting, profile data for one year in anticipation of potential litigation, for the establishment, exercise, or defense of legal claims, and data necessary to prevent members who were banned from opening a new account, for as long as necessary to ensure the safety and vital interests of our members.
c) Finally, we maintain information on the basis of our legitimate interest where there is an outstanding or potential issue, claim, or dispute requiring us to keep information (in particular, if we receive a valid legal subpoena or request asking us to preserve data (in which case we would need to keep the data to comply with our legal obligations) or if data would otherwise be necessary as part of legal proceedings).
11. No Children Allowed
Our services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a member is under the age of 18, please use the reporting mechanism available on the service.
12. Job Candidates, Contractors and Vendor Representatives
We process the personal information of our job candidates, contractors, and vendor representatives, as part of our recruitment and talent management operations and our management of the services that contractors and vendors provide to us. If you are a job candidate, contractor, or vendor representative of ours, certain relevant terms of this Privacy Policy apply to our processing of your personal information, including the sections of this Privacy Policy that discuss the entity that is responsible for the processing of your personal information, transfers of personal information, rights you may have under applicable law, how to contact us, and California-specific information.
If you are a job applicant, the personal information we process about you may vary depending on the job you seek but typically includes what you provide to us as part of your job application as well as professional qualifications, background, and reference information that recruiters or other third parties share with us. We use this information to support the recruitment process, which may lead to an employment contract. For contractors and vendor representatives, we may process identification information and work-related information, as necessary to manage our relationship with you and your employer, which is necessary for the performance of the services agreement and to establish, exercise, or defend potential legal claims. We may share personal information with service providers that assist us with recruitment and technical data processing operations as well as with Local Offers companies (for instance, if you have a business relationship with employees of an affiliate). We keep your personal information only as long as necessary for those purposes.
13. Privacy Policy Changes
Because we’re always looking for new and innovative ways to help you build meaningful connections and strive to make sure explanations about our data practices remain up-to-date, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.