1. Introduction

This Privacy Policy outlines how RedeemX (“we”, “us”, “our”) manages and protects personal information in alignment with our commitment to privacy and in accordance with relevant privacy regulations, including the Privacy Act 1988 and the Identity Verification Services Act 2023.

2. Definition of Personal Data

We collect the personal data of our clients’ members either directly or through our clients for the following purposes:

2.1 Personal data for Identity Verification

Personal data encompasses information about an identifiable individual (such as members, guests, visitors, or employees of RedeemX’s customers), including but not limited to:

• Full name
• Residential address
• Date of birth
• Geometrical representation of the face (Faceprint)
• Information found on identification documents
• Any other information from which an individual’s identity can be reasonably deduced

Note: We do not store actual copies of ID documents, nor do we collect or store credit/debit card details.

2.2 Membership Data

Membership data includes a member’s:

• Full Name
• Email address
• Phone number
• Mailing address
• Date of birth
• Membership details
• Photo to be printed on the membership card where applicable.
• Other relevant information required by a Business/Club/Pub to comply with service obligations.

3. Use of Personal Information

3.1 Our Use of Personal Information

We will use members’ personal information for the purpose of identity verification through the Australian Government’s Document Verification Service (DVS), in accordance with Know Your Customer (KYC) requirements.

This includes information collected directly for identity verification and compliance purposes.

3.2 Our Use of Clients’ Membership Data

Our use of our clients’ members’ data is strictly limited to the following purposes:

• Providing and enhancing services to members on behalf of our clients
• Communicating with members, including responding to queries or concerns and support.
• Complying with legal and regulatory obligations
• Improving the effectiveness, functionality, and user experience of our products and services

3.3 Consent Statement for Personal Information Collection and ID Verification:

The following Consent statement will be used at the time of Member sign-up or while collecting member information for ID verification purposes and it will be complied with the relevant Acts.

Consent Statement:

By continuing, you expressly consent to the collection, use, and disclosure of your personal information for identity verification through the Australian Government’s Identity Verification Services. Your information will only be used to confirm your identity and it will be handled in accordance with the Privacy Act 1988 (Cth) and the Identity Verification Services Act 2023 (Cth).

If you do not give this consent, we will be unable to verify your identity and you may be unable to access the relevant product or service.

By providing your personal details, you confirm that you have read and understood this consent and agree to proceed with identity verification using the DVS.

4. Storage and Security

4.1 Secure Storage

We store all personal information in secure digital formats and take robust measures to protect it from unauthorised access, misuse, or disclosure. Data is encrypted during the transmit and rest.

4.2 Security Measures

Our security measures include:

• Storing all personal information in data centres located in Australia, with robust cloud infrastructure such as Microsoft Azure, the service provider that employs over 3,500 cybersecurity professionals.
• Utilising a cloud-based system enhanced protections (e.g. against DDoS attacks)
• Enforcing internal security training for employees
• Implementing multi-factor authentication for accessing cloud services
  
• Conducting regular reviews, audits, and monitoring of our security practices

5. Disclosure of Personal Information

5.1 Third Party Disclosure

We do not disclose our clients’ members’ data to any third parties, except:

• When legally required by Government authorities or for verification purposes
  

5.2 Client Access

Our clients have access to their respective members’ data solely to provide membership services that the members have previously opted into.

6. Overseas Disclosure

Since RedeemX stores all personal information in Australian data centres, Australian privacy laws apply. We do not reasonably expect to be subject to overseas disclosure laws.

In rare circumstances where personal information of an overseas members may need to be disclosed to overseas entities for identity verification purposes, we will ensure such disclosure complies with applicable laws and with the consent of the overseas member and our client.

7. Support Services

To provide effective support for our products and services, our support team may access membership data. This data remains stored in Australian data centres.
Support staff have limited access and may only view personal information strictly necessary to deliver support services for the products and services you use.

8. Marketing Use

• RedeemX does not use personal or membership data for RedeemX’s marketing purposes.
  
• RedeemX does not send marketing or promotional materials to the members of its clients.
• RedeemX will never sell any personal or membership data to any third party or individual.

9. Access and Correction

9.1 Right to Access

You have the right to request access to your personal information held by us.

9.2 Right to Correction

You may request corrections to ensure the accuracy and currency of your personal data.

9.3 Fees and Response Time

We do not charge a fee for access requests, but we may request reimbursement of reasonable costs (e.g. for photocopying or collation).We will respond within a reasonable timeframe and take all reasonable steps to keep your information accurate and up to date.

10. Complaints

If you have any concerns about how we handle your personal information, please contact us.
We take such concerns seriously and will investigate promptly. You will be notified once a conclusion has been reached.

11. Contact Us

For questions, concerns, or requests related to this Privacy Policy or your personal information, please contact us: 

Email: support@redeemx.com

12. Policy Updates

We may update this Privacy Policy periodically. The latest version will always be available on our website.