Pragma RHI Pty Limited
Last updated & Effective from 22 July 2016
how we are strongly committed to protecting your privacy when you interact with us, our content, products and services.
We are committed to ensuring the privacy of your information and to complying with the Australian Privacy Principles (APPs), which are contained in the Privacy Act 1988 (“Privacy Act”).
Information”) when you use our Table Pay Product.It also covers any information we collect or receive when you use any of Pragma
services (“Services”). These Services include products sold under subsidiary Entities wholly owned by Pragma.
This policy is limited to the procedures and systems that Pragma owns and/or controls and to the activities of its officers and employees.
This policy does not cover the practices of any third party outside the employ or control of Pragma.
The primary purpose Pragma collects Personal Information is so we can supply our customers and their patrons with the products and services provided by us and our subsidiary companies. We also require your information so we can issue you with digital receipts.
Please note that, although we seek to minimise the Personal Information we collect, if you do not provide us with that information, we may not be able to provide you with the services, products or support you seek.
We collect information for secondary purposes to allow us to:
1. identify you in communications;
2. manage your account/s;
3. assist in the provision of product or service information;
4. assess your product or service request;
5. enable a product or service to be provided to you;
6. inform you about other products or services available to you;
7. assist loyalty partners or other partner organisations to promote or provide a product or service;
8. perform administrative and operational tasks (including, but not limited to, staff training, risk management, systems testing and development, debt collection and market research or customer satisfaction research);
9. consider your concerns or complaints;
10. manage any legal action in which Pragma is involved;
11. identify, prevent or investigate any actual or suspected fraudulent, unlawful or non-bona fide transactions;
12. provide you with information about promotions, as well as the products and services of Pragma affiliated companies;
13. enable you to redeem rewards such as cash bonuses and product rewards;
14. enhance your service experience when using Pragma’s product and services by providing aggregated anonymous performance feedback to Merchants.
Pragma may collect Personal Information when:
- you are automatically registered as a user of Pragma’s services if you use a credit, debit or virtual EFT card in any Pragma designed POS interface;
- a page of the Pragma website is visited (including online feedback forms);
- any page related to the content contained within the Pragma website is visited.
We endeavour to collect Personal Information directly from you. That information may be collected from you when you use a Pragma designed interface, fill in an application form for registration, deal with us over the telephone, send us a letter, send us an email or use our website.
However, if this is not practicable, Personal Information may be collected from third parties, including from publicly available sources. In those circumstances, we will take reasonable steps to ensure the individuals concerned are made aware that the information has been collected.
Pragma will not collect Sensitive Information except with your consent and only if the collection of such information is necessary for an activity or function.
Registration information will primarily be used to provide a link to a merchant customer list to allow contact for specials, promotions and product offers. The registration information we collect may include information such as your first and last name and email address, but in certain circumstances your mailing address or other information such as a phone contact will be required in order to assist Pragma
to contact you or to provide goods or services to you.
If you register, agree to the terms and conditions and subsequently sign in to use Pragma’s Services, all such use will no longer be anonymous and Pragma will collect information about your transactions with Pragma and your use of Pragma’s Services.
Pragma may automatically receive and record information from your browser (such as your IP address, device, browser settings, and pages requested) on our server logs.
Pragma collects this information through:
- automatic logging files to record IP origin address, browser defaults, pages visited and device type
- and registration information to record: user account ID, user name, user email address, access time and date, changes made, changes to account and other requests for support or modification to account status
The information is collected so we can enhance the way we provide our products and services to you. Other information we request is optional.
Pragma may also collect personally identifiable information which you divulge about other people, in the process of making referrals or gift purchases or in sending money to them.
COLLECTING INFORMATION REQUIRED BY LAW
Information may also be collected from you because we are required or authorised by an Australian law or a court or tribunal order to collect that information.
If collection is required or authorised by law, we can provide details of the relevant law, court or tribunal order.
We may collect identification information that is required under the Anti-Money Laundering and Counter-Terrorism Financing legislation. If you are using our financial services, we may need to request identification information such as your date of birth, place of birth, passport number, driver’s license details, Medicare number or credit card number, where applicable, information regarding the beneficial or legal ownership of certain property.
It may, in certain circumstances, also be necessary to collect information from you regarding other people. For example, the collection of such information may be required in order to provide a product such as a gift certificate.
Pragma uses information to:
- fulfil your product and service requests;
- provide you with product and service information, email announcements, special deals, newsletters or advertisements, but you will have the option to not receive these types of communications;
- create customer profiles based on purchasing history or to supplement information collected at Pragma with data from other sources such as credit history to authorise purchases;
- improve Pragma’s Services; and/or
- contact you, conduct research, and provide anonymous reporting for internal and external clients
- collate and relay aggregated anonymous performance feedback to relevant internal customers from your interaction with Pragma interfaces
Pragma will not use Sensitive Information for Direct Marketing purposes. In some circumstances Pragma may use non-sensitive Personal Information to enable Direct Marketing to individuals on the basis that:
- you will be asked for implicit consent to allow contact for Direct Marketing when providing your electronic contact details directly (“Opt in”)
- you will be clearly notified of your right to expressly request an exclusion from any further Direct Marketing (“Opt Out”);
- you will be given the option to Opt Out from any further Direct Marketing;
- if you Opt Out of all Direct Marketing your decision will be respected by Pragma and all its Related Body Corporate.
INFORMATION SHARING AND DISCLOSURE
Pragma may disclose Personal Information to a Related Body Corporate or an unrelated third party if your consent has been obtained and this may include disclosures made under the credit reporting requirements of the Privacy Act.
Pragma does not rent, sell, or share Personal Information about you with other people or non-affiliated companies, except to provide products or services you've requested. Such disclosure will be limited to when we have your permission or when such disclosure is within your reasonable expectations.
The other exceptions will be when Personal Information is disclosed:
- to a trusted partner who works on behalf of or with Pragma under confidentiality agreements (“Service Partner”) or to billing, customer
relations management, credit card, order fulfilment or shipping companies in order to provide goods or services to you;
- to a Service Partner who requires access to your Personal Information to help Pragma communicate with you (but a Service Partner will not have an independent right to share Personal Information or to contact you regarding any matter not related to Pragma);
- as required under a subpoena, court order, or legal process, or in order to establish, exercise or defend Pragma’s legal rights;
Pragma may automatically gather information that helps us monitor the use of our services; this includes information on the number of users and the frequency that they use our services.
This information helps us learn what services are most popular or useful so we can improve our services. This information also helps us identify problems that need to be fixed.
Credit/Debit card information is never stored in a cookie.
aggregate results that help us evaluate and improve our services. Some of the data automatically logged includes your device and operating system, Internet Protocol (IP) address, access times, browser type, pages visited and services used.
Placing a cookie on your device also allows us to serve promotional information that may be of more interest or more relevant to you. Such promotional information may appear on our services or on third party digital services. This data also enables us to control the number of times certain promotional information is shown to you and helps us measure campaign effectiveness.
Cookie Control and Deletion
Popular browsers usually have settings that allow you a level of control over cookies.
Your settings can be adjusted to accept or reject all, or certain, cookies. Or, to
prompt you each time a cookie is offered.
Most cookies are easily deleted and further information should be available in your browser’s ‘Help’ section. However some digital services may not load or function properly if you block cookies. It is your decision how you balance convenience and privacy.
Pragma may use the following types of cookies: Session Browser Cookies: allow you to navigate page to page without repeatedly
signing in. Shopping cart data is one example and how such cookies are used. Such cookies are stored in the browser and are deleted when the browser is shut down. Persistent Cookies: help us monitor user behaviour and measure the performance of our services. These browser cookies are only readable by the company that places them on the device. Persistent cookies are saved to the hard drive until they expire, and they are not deleted when the browser is shut down.
Cookies or Local Shared Objects: track activity in Applications run in an Adobe Flash Player. They are designed to retain your custom settings that are applied each time you use those Applications.
Web Beacons: are combined with cookies to track activity. Blocking cookies will also prevent web beacon tracking activity.
Third Party Cookies
A number of suppliers to Pragma also set cookies on our services on our behalf so
they can deliver their services or help us provide our services.
Content sharing is an example of where third party cookies may be used. Pragma
does not control or block cookies set by third parties in those ways.
Most of the data we collect is aggregated, and this information is effectively anonymous to us.
In some cases we may collect data that can be linked to you individually. For example, when you log in to a Pragma digital service as a registered user, we may store records of information such as the comments you make, the pages you viewed or links you click on. Similarly, if you use our email newsletters we may collect data about the mailings you open and the links you click on from that newsletter.
As well as helping to improve our services, we may use this data to provide recommendations that you might find helpful based on your activity. In some cases, a digital profile may be formed based on your activity. We do this in order to improve your experience (for instance, because some services may allow you to build a profile which earns different privileges); or to improve our ability to provide a
service (for instance, because our decisions about moderation of content may need to have regard to your profile).
Though surveys usually collect aggregate data, we will make it clear to you if any survey information is being collected in a way that could personally identify you.
CHANGING INFORMATION AND PREFERENCES
You are entitled to access, in accordance with the Privacy Act, any Pragma recordsthat contain your Personal Information.
Pragma will at your request in accordance with the Privacy Act, correct as soon as reasonably possible any Pragma records that contain your Personal Information. Although Pragma may charge a fee for a complex or resource intensive change, there will normally be no fee charged for processing an access or correction request.
You can lodge a request to access and/or correct Personal Information, edit your account information at any time or cancel your membership by contacting support email@example.com
Your use of Pragma’s products and services is conditional on your acceptance that:
- any material you may have contributed to Pragma may remain in some form on the site even after you cease to be a member;
- receiving certain communications from Pragma (such as service announcements and administrative messages) is a condition of Pragma
CONFIDENTIALITY AND SECURITY
Access by Pragma’s employees to your Personal Information will be restricted to circumstances where we reasonably believe such access is needed in order to provide products or services to you or for operational purposes. Pragma will implement physical, electronic, and procedural safeguards in line with standard best practice in order to protect your Personal Information.
You are responsible for protecting your Pragma access logon and password and the content of your account information.
All data transfer transactions are encrypted by a 128bit SSL certificate.
OVERSEAS INFORMATION TRANSFER
Reasonable steps will be taken to limit the amount of Personal Information Pragma sends to organisations located overseas.
If there are sound business reasons for Personal Information being sent overseas, Pragma will require the overseas service provider to sign a service contract that obliges that entity to handle that information in accordance with the National Privacy Principles.
Pragma reserves the right to change this policy from time to time and such changes will take effect once placed on a tablepay.com.au website that I slinked to Pragma RHI website. Registered account holders shall be notified by email of updates to this policy.
Please contact us firstname.lastname@example.org if you have questions or suggestions.
Direct Marketing means the marketing through written, verbal or electronic means of goods or services that may be those of Pragma or a Related Body Corporate or those of an independent third party.
Pragma means all companies in the Pragma group. Related Body Corporate means a body corporate that is or is deemed to be related
- a holding company of another body corporate;
- a subsidiary of another body corporate; or
- a subsidiary of a holding company of another body corporate,
Sensitive Information means health information or information or an opinion about an individual's:
- racial or ethnic origin; or
- political opinions; or
- membership of a political association; or
- religious beliefs or affiliations; or
- philosophical beliefs; or
- membership of a professional or trade association; or
- membership of a trade union; or
- sexual preferences or practices; or
- criminal record.