Privacy Policy

Introduction

By registering a personal account, you’ll be asked to provide some personal and sensitive information, as detailed here and in our Terms of Service.

Our Privacy Policy is based on the following provisions:

• You can request to update or change profile information at any time
• You can opt-out of LiveTribe and close your account at any time
• We only store profile information you choose to provide. We use the latest technologies and best practises to protect all personal information from unauthorised physical and electronic access and interference
• We don’t permit businesses to access your personal information, unless you decide to make this information available, or if you provide a recorded video response (in which case the video, including your image and voice, may be provided to businesses)
• We don’t forward or transfer your information to any third parties, other than the organisations detailed in this document, which are required to operate LiveTribe. This disclosure is necessary in your LiveTribe use and these organisations are required to respect and maintain our commitments to your privacy and security

We are absolutely committed to these policies. If you have any concerns or questions relating to this document or our Terms of Service, please feel free to contact us.

What information do we collect?

We collect three broad types of information:

• Information you directly provide us;
• Information about your use and interaction with LiveTribe; and
• Information collected through the platform, applications, third parties or other websites

1. Information you directly provide us can include:
   • the email address and password you provide when registering an account;
   • profile information;
   • any responses you submit during activities, which may include your image and voice if you submit your response in a recorded video;
   • the content of any customer service correspondence;
   • your login details for other associated apps you’ve registered with;
   • any banking details you provide when requesting a redemption; or
   • any other information you directly provide on LiveTribe
2. Information about your use and interaction with LiveTribe can include:
   • your IP address, geolocation and data stored in LiveTribe cookies;
   • your activities on LiveTribe, such as when you accept or skip an invitation, your participation in activities and your progression through a particular activity;
   • your other account activity, such as when you login to your account, when you send us customer service correspondence and when you opt-in to an application;
   • information about the device you’re using to access LiveTribe; or
   • your transaction history, including your account balance, the payments you receive from participating in activities and any rewards you have requested
3. Information collected through the platform, applications, third parties or other websites can include:
   • details about yourself, which are stored on other websites;
   • the names, email addresses and other details of contacts or friends you have stored on other websites; and
   • any other data that may be stored on other websites or held by third parties

How do we use the information we collect?

LiveTribe's use of information

We use the information you provide us to publish and deliver insights and relevant activities to you through LiveTribe. This can include:

• Sending you emails or notifications to alert you of activities for which you may qualify (if you have opted in to receiving such notifications);
• Sending you emails or notifications for marketing purposes such as promotions, competitions and upcoming events;
• Using responses from an activity, which has been provided to a business in a de-identified way, for further analysis or use, including publication of the de-identified results;
• Using responses from a video/audio based activity, which has been provided to a business, for further analysis or use, including publication of the identified results. The video will be securely stored and may be viewed by our researchers to understand reactions better. By participating, you consent to the collection, storage, analysis, and potential publication of your identifiable video responses as part of this study;
• Help detect and prevent fraudulent activity;
• Maintain the data quality of activity responses;
• Improve and personalise your LiveTribe experience;
• Maintain, operate and improve LiveTribe; and
• Promote our services on affiliated third party websites using banner ads or other materials

Businesses’ use of information

There are times when businesses may require access to profile information such as:

• Profile information to help determine the target audience for an activity; or
• The responses you submit during an activity

All information provided to businesses will be presented in an aggregated and de-identified format, unless you grant us express permission to do otherwise.

Businesses are also allowed to ask you to provide your name, email address and other contact information during an activity. You should know that:

• you are providing this information directly to the business and not LiveTribe;
• your information will be dealt with in accordance with the relevant business’
• Privacy Policy and not LiveTribe's Privacy Policy; and
you are always free to decline providing contact details to a business

Targeted advertising

We may use the information we collect (for example, email address and LiveTribe cookies) to send you targeted advertising on third party sites. The purpose of this retargeted advertising could be to provide you with a relevant experience through a third party site or to encourage you to login to your account.

Information you can use

Information collected through the platform, applications, third parties and other websites may be used by you to allow you to:

Create a relationship between your account and other online accounts you’ve registered for;

• invite your friends to join LiveTribe;
• communicate with your friends and contacts about LiveTribe;
• view and access your online accounts through the site;
• complete some of your profile information using information stored on another website;
• help detect and prevent fraudulent activity;
• improve the accessibility of the site; and
• participate in retargeting activities

Accessing and controlling your information

If you:

• want to obtain access to any personal information that we hold about you;
• object to profiling, including profiling for marketing purposes;
• believe any of your personal information that we hold is inaccurate, incomplete or it is not necessary to hold it; or
• want to delete your personal information from our records, you can contact us using one of the channels listed in the ‘Contact Us’ section. We will use reasonable efforts to resolve your request within 30 days.

We will provide you with our reasons if we refuse your request and, if you disagree, you are entitled to ask us to make a note of the request with your information.

You may also request that your personal information be restricted from processing where one of the following applies:

• we are verifying the accuracy of personal information, which you believe to be inaccurate;
• the processing is unlawful and you oppose the erasure of personal information;
• we no longer require the personal information but you require it for the establishment, exercise or defence of legal claims; and
• you have objected to processing and we are verifying whether there are legitimate grounds to refuse the objection

Disclosure to third parties

We will not sell, trade, give or rent any information to a third party unless:

• you have expressly consented;
• such disclosure is permitted by the Terms of Service or this Privacy Policy; or
• required to do so by law

When we provide information to third parties, profile information and activity responses are only disclosed to businesses in an aggregate and de-identified format, with the exception of recorded video responses which include your image and/or voice, for which we will specifically seek your prior written consent before providing to a third party. We never provide any personally identifiable Information about you to a business, unless you expressly grant us permission to do so. This permission will (unless otherwise indicated) generally be required on a case-by-case basis.

Banking details

We only disclose your banking details to our bank for the purpose of actioning your reward requests. This disclosure occurs in an extremely secure and protected online facility.

Overseas staff handling your data

The response data for some activities may be stored and/or analysed and aggregated by staff residing in the United States, United Kingdom, Australia, Greece, The Philippines and India. Our staff, including contractors, are required to maintain the same privacy and data protection standards as required under the General Data Protection Regulation.

Overseas third parties

Some activities may originate from businesses based outside of your country of residence and accordingly, you agree to allow your activity response data to be provided to these businesses. When this happens, we may need to use third party hosting facilities located outside of your country of residence to ensure your information is constantly accessible and backed up in secure data storage facilities. We will ensure all third party hosting providers used are not permitted access to your information.

Data matching

We may share your information with third parties to determine if these parties already hold information about you. We do this for the following purposes:

• to seek your consent to add the information held by third parties to your LiveTribe account; and
• to determine if you qualify for an activity (for example for businesses who want to deploy a survey to individuals already on their database)

If the third party does not hold information about you, we ensure that the information we shared with them is destroyed.

Linking to other websites

If you associate your account with another website or online account through a LiveTribe product, we may save any data retrieved via this association into our system. In this case, the nature of the data being transferred will be outlined to you and require your express consent. Read the terms of any application carefully before accepting and using an application.

As required by law: We may be required to disclose your personal information by law, for example, to comply with a court order or legal investigation. In these cases we will do the following:

• Review the legality of the request
• Challenge the request if it is considered unlawful
• Disclose the minimum amount of information necessary
• Document these requests, including our response to the requests and the legal reasoning and actors involved.

Information security

We are committed to providing a secure online environment to use LiveTribe and have invested considerable resources to protect your information from loss, misuse, corruption and unauthorised access. More precisely, we have invested in:

• A secure server software (SSL) technology to encrypt the transfer of all personally identifiable information
• Firewalls that protect against unauthorised access of all of the data we collect and store

Due to the nature of the internet, it’s possible that information stored on our servers and data transmitted online can sometimes be accessed by unauthorised third parties. While we make significant investments to ensure that this risk is minimised, we cannot guarantee the information you provided us will never be compromised. By accepting this Privacy Policy, you acknowledge and accept these risks.

Closing your LiveTribe account

Using LiveTribe and maintaining an account is completely opt-in and you may close your LiveTribe account at any time. You’re always able to dissociate your account from any application or website you’ve previously linked to your personal account. Upon dissociating your account, we’ll provide you the option of having all associated data deleted from our records.

How to contact us

If you have any enquiries or complaints about either our Privacy Policies or procedures, including requesting access to or correcting personal information that LiveTribe holds, please get in touch via the Contact Us section of our site, with the subject heading “Attention: Privacy Officer”.

Policy changes

We may make changes to the Privacy Policy from time to time and you’ll be notified of any changes.