Alby Privacy Policy

 

Our Privacy Commitment
This Privacy Policy governs the way we, Aspire Live Pty Ltd (ABN 99 662 218 135), trading as Alby (“Alby”), collect and use your personal information. In this Policy, “we”, “our”, “us” means Alby or its subsidiaries and affiliates (“Related Entities”).

 

Alby is committed to protecting the privacy of your personal information. This policy explains how we manage, use, and protect the personal data collected across all websites, applications, and services comprising Alby platforms and services, including Alby Place, Alby Market, Alby Travel, and Alby Plus (together, our “Services”).

 

Alby is bound by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) and any applicable State and Territory privacy legislation. These principles regulate how we may collect, use, disclose, and store personal information, and how individuals may access and correct it.

In this privacy policy, if we refer to “Platform” we are referring to any platform of ours that references or links to this Policy and if we refer to “Services” we are referring to our platforms, and other related services, including any sales, marketing, or events.

 

Alby may provide separate privacy notices and additional information at the time we collect your personal information. This may include additional country specific information in accordance with the applicable laws of the country where such information is being collected.

 

Please read this Policy carefully to understand what our privacy practices are and the choices you can make about your privacy. If there are any terms in this Policy that you do not agree with, please discontinue the use of our Services immediately.

 

 

1. Types of information we collect

1.1 Personal Information: We collect personal information about an individual from:
(a) Our Customers and potential customers- The types of personal information we collect depend on your interaction with our services and may include:

  • Full name, date of birth, contact details, current and previous addresses, email, country of citizenship, country of residence and signature.
  • government issued identification numbers (to the extent permitted under the applicable law), such as passports, social security number, driver’s licence, or other national cards issued for identification purposes.
  • other identity information required for credit checks, fraud prevention and risk assessment from third parties including independent identification verification providers, banks, financial institutions, government registries and credit reporting agencies for credit bureau.
  • Information about individuals’ connection with a legal entity, such as an individual’s role, and whether he or she is a beneficial owner or authorised signatory.
  • financial account information including bank account and credit card/ debit card numbers, bank statements and utility account statements.
  • Profile information including marketing information with respect to preferences for receiving promotional communications for our product and services.
  • Travel, booking, and itinerary details (for Alby Travel);
  • Purchase, delivery, and order details (for Alby Market);
  • Membership or loyalty program information (for Alby Plus);
  • Business or listing details (for Alby Place partners);
  • Sensitive information such as health or travel conditions, only when required for relevant services (e.g., insurance or travel cover) and only with your consent.

 

If you choose not to provide the necessary information, we may be unable to offer certain products or services to you.

 

(b) Suppliers including potential suppliers and service providers – we collect information to complete due diligence of suppliers and service providers, to communicate with them, for organizing the provision of goods and/or services, and to assess their business. The types of information we may collect includes business contact information such as full name, role, mobile number, business address, and details of their key personnel.

 

(c) Past, present, and prospective employees – this is information that we may collect directly from the job applicant or from a recruiter as part of our recruitment process. The types of information we may collect and hold about you includes:

  • details to verify your identity including your full name, date of birth, gender, contact details, current addresses, country of citizenship/residency, date of birth and signature.
  • occupation and employment details including employment status and any previous work experience.
  • information in connection with your employment with us (which may include health information, bank account details and your tax file number among other things).  
  • information from or in connection with your resume or job application if you apply for a position with us (including information from referees and to verify your qualifications, work, and academic history).

 

(d) Private and publicly available resources – we or our third-party verification providers may collect information about individuals from publicly available resources (such as accessible government lists) and private or commercially available resources (such as reports or information from credit reporting agencies or fraud prevention agencies) to the extent permitted under applicable law.

 

(e) Online surveys, feedback, and contests – we may conduct online surveys, solicit your feedback, or hold contests to better understand your needs, to provide you with enhanced services, to improve our services, and to help you use our Services more effectively. If you participate in our online surveys or provide feedback, we may collect information such as your full name, email address, and demographic information. Participation in our surveys or contests, or providing feedback, is completely voluntary and you therefore have a choice whether to disclose this information. We will not share the personal information you provide with other third parties unless we give you prior notice and choice. We may display your feedback or personal testimonial on our Website, subject to obtaining your consent.

 

1.2 Information other than personal information (“non-personal information”)

When you visit our Website or use services provided by us, we and our service providers may automatically collect information about your visit, such information is not personal information as it does not reveal your identity. We use this information to help us improve our Services and for promotional and marketing purposes. We may aggregate this information for our own statistical purposes provided that it remains anonymous, we may disclose the aggregated information to third parties, commercialise or publish it for promotional, marketing or research purposes.

 

(a) Site visit information – when you visit our Website, we may record your server address, the date, time and duration of your visit, the search terms you used, the pages you viewed, any documents you downloaded, the type of device, browser, and operating system you used, the manufacturer and model device identifier, and general location information.

We use Internet Protocol (also known as “IP”) addresses to analyse trends, execute the websites, track our users’ activities, and gather broad demographic information for aggregate use. We may combine this automatically collected log information with other information we collect about you. We do this to improve Services we offer you, to improve marketing, analytics, or Website functionality.

 

(b) Cookies – a cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users. We use cookies to hold anonymous site visit information. This information is used to personalise your current visit to the Website. It may also be used as a basis for targeting online advertising. Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies or to notify you when they are being used. Rejecting cookies can, however, limit the functionality of our Websites. For more information about our use of cookies, please refer to clause5 of this Policy.

 

 

2. How we collect and hold your personal information

We collect personal information by lawful and fair means and primarily from you directly, including when you:

  • Register an account, make a purchase, or submit an inquiry on any Alby platform (Alby Place, Alby Market, Alby Travel, or Alby Plus);
  • Request a quote, book travel, or purchase a product or service through us or our partners;
  • Communicate with us by phone, email, chat, or social media;
  • Subscribe to newsletters, promotions, or loyalty programs;
  • Participate in surveys, competitions, or feedback campaigns.
  • We may also collect information indirectly from:
  • Partner companies, service providers, or affiliate programs that refer you to us;
  • Marketing and analytics tools that help us understand user activity;
  • Publicly available sources or third-party databases where legally permitted.

If you provide personal information about another person (for example, a family member or colleague), you must ensure that they are aware of this policy and consent to their information being shared.

 

3. How we use your personal information
We collect, hold, and use your personal information to:

  • Provide and manage our products, services, and marketplace listings;
  • Facilitate transactions, bookings, and service connections with partners;
  • Process payments, invoices, and receipts;
  • Verify your identity and respond to inquiries or complaints;
  • Send updates, notifications, or promotional materials;
  • Conduct market research, data analytics, and improve user experience
  • Operate loyalty, rewards, and membership programs (Alby Plus);
  • Maintain compliance with laws, regulations, and partner agreements;
  • To protect our services from example for fraud monitoring and prevention;
  • To enforce our terms, conditions and policies
  • To develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

 

We may also use your information for any purpose you have consented to or where required by law.
Your privacy is important to us. To protect your privacy, we present this clause  explaining our practices with regard to your personal information and the choices you can make about the way your information is collected and used. Please read this clause carefully to understand what we do and the choices you can make.

 

To facilitate our operations, we may transfer, store and process your personal information in Australia and other jurisdictions. Any overseas transfer of personal information will be conducted in accordance with the requirements of the Australian Privacy Principles, particularly APP 8 regarding cross-border disclosure of personal information.

 

Alby handles all personal information in accordance with the Australian Privacy Principles under the Privacy Act 1988 (Cth). For more information about your privacy rights under Australian law, you can visit the Office of the Australian Information Commissioner’s website at www.oaic.gov.au.

Alby processes your personal information in accordance with the Australian Privacy Principles. When we disclose your personal information to third parties, we take reasonable steps to ensure they handle your information in accordance with the Privacy Act 1988 (Cth) and our privacy obligations.

Alby is subject to the regulatory enforcement powers of the Office of the Australian Information Commissioner under the Privacy Act 1988 (Cth). In certain situations, we may be required to disclose personal information in response to lawful requests by Australian public authorities, including to meet national security or law enforcement requirements under Australian law.

 

We will use your personal information only in accordance with the terms of this clause. We will not sell or rent your personal information or provide a list of our customers to third parties. However, there are limited circumstances in which some of your information will be shared with third parties under strict restrictions, so it is important for you to review the details of this clause.

 

4. When we share your personal information
To provide you with our services, we may share your personal information with trusted third parties such as:

  • Related entities, Partner vendors, travel operators, and insurance providers;
  • Payment processors and financial service partners;
  • Third party service providers such as Marketing, communication, and customer support providers;
  • Agencies that assist with credit checks, identify verification and fraud protection – as part of the onboarding of our customers (merchants and partners),
  • Regulatory bodies or government agencies (when required by law).
  • Professional advisors such as lawyers, bankers, auditors where necessary in the course of the professional services that they render to us.
  • Business transfer in case of a future merger or partnership with another entity.
  • Any other person or entity with your consent
  • Following categories of third parties-

– Data Analytics Service Providers
– Data Storage Service Providers
– Cloud Computing Service Providers
– Communication & Collaboration Tools
– Performance Monitoring Tools
– Product Engineering & Design Tools
– Social Networks
– Sales & Marketing Tools
– Testing Tools
– Website Hosting Service Providers

Some partners or service providers may be located overseas. Where this applies, Alby takes reasonable steps to ensure that your personal information is handled in accordance with the Australian Privacy Principles.

 

5. Use of cookies and similar technologies
Alby uses cookies and similar technologies when you interact with our platforms. Information collected via cookies is used for several purposes and depends on the product and Services accessed by you. Cookies are widely used to make platforms work, or work in a better, more efficient way. Cookies and automated technologies can be set up by us or our third parties who assist us with our delivery of services.

 

5.1 Types of cookies we may use

The types of cookies that we may use include:

(a) Storing your Preferences and Settings – Settings that enable our website to operate correctly or that maintain your preferences over time may be stored on your device. For example, we save preferences, such as language or browser and multimedia player settings, so that your preferences do not have to be reset each time you return to our Website. If you opt-out of interest-based advertising, we store you opt-out preference in a cookie on your device.


(b) Sign-in and Authentication – When you sign into our platforms using your personal account, we store a unique identification number and the time you signed in, in an encrypted cookie on your device. This cookie allows you to move from page to page within the site without having to sign in again on each page. You can also save your sign-in information on your device so that you do not have to sign in each time you return to the site.
(c) Security – We use cookies to detect fraud and abuse of our Websites and Services.


(d) Social Media – Some of our Websites include code snippets provided by social media companies that can sense if you are already logged into a given social media account. This allows you to easily share Aspire’ content with other social media users via your social media account. These code snippets read cookies set previously by the social media company’s web content while you are logged in and browsing such content on the social media site.


(e) Interest-Based Advertising – Aspire uses cookies to collect data about your online activity and identify your interests so that we can provide advertising that is most relevant to you. You can opt out of receiving interest-based advertising by changing the privacy and security settings on the device and/or the platform used to browse the Website which will allow you to limit our use of information.


(f) Analytics – To provide our products and Services, and improve your user experience on our Website, we use cookies and other identifiers to gather usage and performance data. For example, we use cookies to count the number of unique visitors to our Website and to develop other statistics about the operations of our products and Services. This includes cookies from Aspire and from third-party analytics providers.

 

(g) Performance – Aspire uses cookies for load balancing to ensure that Websites remain up and running.

 

5.2 How to control cookies

Most web browsers automatically accept cookies and provide controls that allow you to block or delete them. For example, in most modern browsers, you can block or delete cookies by clicking Settings > Privacy > Cookies. Instructions for blocking or deleting cookies in other browsers may be available in each browser’s privacy or help documentation.

 

Certain features of our products depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and your preferences that are dependent on cookies may be lost.


If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, will be deleted and may need to be recreated.

 

6. Links to third-party websites
Our platforms may include links to third-party websites, including travel agencies, suppliers, and insurance providers. Please note that Alby does not control or endorse the content, security, or privacy practices of these external sites.
We recommend reviewing the privacy policies and terms of use of any third-party website before sharing your personal information. Once you leave the Alby Marketplace and visit another site, any data you provide is governed solely by that third party’s policies, and Alby is not responsible for how that information is managed or used.

 

7. Direct marketing and communication
Alby may use your information to inform you about products, services, promotions, or partner offers that may be relevant to you. We may contact you by email, phone, SMS, or social media
You can opt out of receiving marketing materials at any time by following the “unsubscribe” instructions in our messages or by contacting us directly.

 

8. Data quality and security
The quality and security of your personal information is important to us and to the products and Services that we offer to you. We take commercially reasonable precautions consistent with applicable regulatory requirements to ensure that any personal information we hold is kept secure and protected against any loss or unauthorised access. While we strive to use commercially reasonable means to protect your personal information no method of transmission over the internet is 100% secure and we cannot guarantee absolute security. Transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment. You are responsible for your username and password and should keep them safe.

 

We employ contractual, administrative and security measures to protect against any unauthorised access or disclosure, with procedures and mechanisms put in place to monitor and deal with any suspected data breach.

We limit access to personal information to only such employees, contractors and service providers who have a business need to know and for purposes as set out in this Policy

 

We will retain your information for as long as needed to provide you with our products and Services, for as long as necessary to comply with our legal and/or regulatory obligations, to resolve disputes, and administer our agreements.


If you would like to cancel your account or request that we no longer use your information to provide you with any products or Services, please let us know by emailing us (See below Section 11: Contact Us).

 

You may request that we delete your personal information. If we no longer need your information and are not required by or under a law or court/tribunal order or any other regulatory authority to retain your information, we will take necessary steps to destroy the information. Where deletion is not possible, we will ensure that the information is de-identified.

 

9. Complaints
If you have concerns or complaints about how Alby has handled your personal information, please contact us using the details below. We will investigate and respond within 30 days.
If you are unsatisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) via www.oaic.gov.au or call 1300 363 992.

 

10. Children’s personal information

We recognize the importance of children’s safety and privacy on the internet. For this reason and to comply with certain laws, we do not intentionally collect personal, individually identifiable information from children under the age of 13, nor do we offer content targeted to children under 13.


11. Contact us
If you wish to:

  • Ask a question about this Privacy Policy,
  • Access or correct your personal data, or
  • Make a privacy complaint,

please contact our Privacy Officer
Email: [email protected] 
Postal Address:
Aspire Live Pty Ltd
70 Stirling Terrace
Albany, WA 6330
Australia