Privacy Policy (Full Terms)

This version: 23-1

Last version: 21-1

Last updated: 9 November 2023

This privacy policy may be updated from time to time to reflect current business practices and ensure compliance with applicable laws. You can always find the most up-to-date version on our website. Any specific terminology used throughout this policy is capitalised and defined in Appendix 1 below for your reference.

Slyp Pty Ltd ("Slyp", "we", "our" or "us") has developed this policy for you, an individual or organisation with whom we interact, whether you are a partner (such as a Merchant, point-of sale provider or Bank), a partner’s customer accessing our services directly or through a partner, a visitor to our Site, or any combination of the above. In other words, this policy is not limited to current and direct customers. It applies to all individuals who deal with us for any business purpose.

We have developed this policy to describe how we collect and use data, including Personal Information, and clarify how we comply with the Australian Privacy Act 1988 (Cth) (“Privacy Act”), the Australian Privacy Principles (“APPs”) and the Spam Act 2003 (Cth) (“Spam Act”).

About Slyp

1.1 Who we are

At Slyp, we are committed to delivering innovative and elegant solutions that solve real problems for real people. Our vision is to power the world’s most convenient transaction by ensuring every person in Australia has easy access to the Smart Receipt experience. Our purpose is to reduce the impact that paper receipts have on the environment while also helping consumers and businesses transact in a more digitally friendly way.

1.2 What we do

We have created the Slyp Smart Receipt. Our solution revolutionises paper receipts with a smarter, feature-rich, digital transaction record that may be delivered in a Bank partner’s mobile application, Merchant partner’s mobile application, Slyp mobile application or via SMS. Smart Receipts offer new ways for consumers and Merchants to digitally connect.

Your privacy is very important to us

2.1 Our privacy stance

At Slyp, the protection of your data is of critical importance. This policy is laid out in an easy to understand way so that you can readily understand our position on data privacy and our commitment to protecting the data and Personal Information we collect.

2.2 Your agreement to this policy

By using this Site and/or our services, you agree to the terms and conditions of this policy.

Information we may collect, use or disclose

The type of data we may collect, how it is used and who it may be disclosed to vary based on the services you use. This section details the type of data we may collect for the services we offer, how we collect it and how we handle it.

3.1 Smart Receipts delivered in Bank partners’ mobile application

3.1.1 Service description

We provide Smart Receipts to customers of partnering Banks directly to their mobile banking application (subject to this feature being activated). We do not collect Personal Information to deliver Smart Receipts in Bank partners’ mobile applications, in other words, the data we collect is not identifiable to you. The feature works by linking your anonymised Bank transaction details with your anonymised Merchant transaction details to render your Smart Receipts inside your mobile banking application. Bank partners and Slyp exchange information using a randomly generated customer identifier meaning that Bank partners do not share your identity with Slyp.

3.1.2 Type of data collected

As part of this service, Slyp may collect the data outlined below:

Type of data	Data description	How data is collected
Bank transaction details (anonymised)	Anonymised information about transactions you made with your registered Bank cards enabling us to match those with your corresponding Merchant receipts, including: anonymised account details payment authentication details transaction time, amount and currency other transaction metadata	Supplied by Bank partners
Merchant receipt details (anonymised)	Anonymised information typically available on your tax receipts enabling us to surface such information inside your Smart Receipts and to match your corresponding Bank transactions, including: your matching transaction details: details of Merchant you purchased from details of items you purchased your loyalty and membership number where relevant* your Australian business number (ABN) where relevant* * To protect your privacy, your loyalty or membership number and ABN are stored in encrypted form.	Supplied by Merchant partners
Customer demographics (anonymised)	Your anonymised demographic details: age range; gender; and approximate area of residence (SA2)	Supplied by Bank partners
Usage data (anonymised)	Information about how you access and use our services, including: the time when you access Smart Receipts your device type and operation system (iOS, Android) your feature use (including receipt exports, receipt searches and interactive links)	Supplied by Bank partners

At each stage, data is collected (either from Bank partners or Merchant partners) electronically using RESTful Application Programming Interface (API) technology.

3.1.3 How we use information collected to provide Smart Receipts in Bank partners mobile application

We will only use the information collected where we have a legitimate business purpose to do so and in accordance with the contractual terms agreed with our relevant Bank and Merchant partners. Below is an outline of the purposes for which we may use the information we collect:

to generate Smart Receipts and display those in Bank partners mobile application
to perform internal analysis, helping us improve and develop our services
to provide Merchant and Bank partners with analytics products and insights using anonymised data
to conduct general administration of the business (including preparing partners’ invoices, accounting, finance, answering enquiries from partners and their customers)
to monitor and conduct activities related to the security of our informatic systems and services
to comply with our legal and regulatory obligations and exercise our legal rights
to provide any additional services you have consented to (including additional Smart Receipt integrations with third-party services such as expense and financial management tools).

3.1.4 Who we may disclose your information to

We may disclose the information we collect to the following:

Bank partners for the purpose of surfacing the Smart Receipts inside their mobile application
third-parties you have consented to share information with (including third-parties who provide services integrated with Smart Receipts such as expense and finance management tools)
Merchants that you shop with to access Smart Receipts issued on their behalf and de-identified demographic information about customers who transacted with them
accountants, auditors, lawyers and other professional advisors we engage who require access to information
government agencies, regulatory bodies and law enforcement agencies, or other similar entities, where required under or authorised by law
third-party service providers to whom we may outsource certain organisational functions
third-party acquirer(s) in the event that we sell or transfer all or any relevant portion of our business or assets.

3.2 Smart Receipts delivered via SMS or Merchant mobile applications

3.2.1 Service description

We provide Merchants with the ability to deliver Smart Receipts to their customers via SMS or mobile applications owned, operated or controlled by a Merchant.

3.2.2 Type of data collected

When providing this service, Slyp may collect the information outlined below:

Type of data	Data description	How data is collected
Contact details	Mobile number enabling us to send Smart Receipts via SMS	Supplied by Merchant partners
Merchant receipt details (anonymised)	Anonymised information typically available on a tax receipt enabling us to surface such information inside the Smart Receipts, including: Your anonymised transaction details details of Merchant you purchased from details of items you purchased your loyalty and membership number where relevant* your Australian business number (ABN) where relevant* * To protect your privacy, your loyalty or membership number and ABN are stored in encrypted form.	Supplied by Merchant partners
Usage data and cookies (Anonymised)	Anonymised information about how you access and use our services, including: the time when you access Smart Receipts the IP address used to access our web hosted receipt any cookies.	Collected via Sites

Where information is collected from Merchant partners, this information is collected electronically using RESTful API technology.

3.2.3 How we use information collected to provide Smart Receipts in Merchant partners’ mobile applications or via SMS

We will only use the information collected where we have a legitimate business purpose to do so and in accordance with our Merchants’ services agreements. Below outlines the purposes we may use the information we collect:

to generate Slyp Smart Receipts and deliver those via SMS or to Merchant to make available via their mobile application (Smart Receipts are hosted on our Site and Slyp provides a unique link to access them)
to perform internal analysis helping us improve and develop our services
to provide Merchants with analytics products and insights using anonymised data
to conduct general administration of the business (including partners’ invoice, accounting, finance, answering partners and their customers’ enquiries)
to monitor and conduct activities related to the security of our systems and services
to comply with our legal and regulatory obligations and exercise our legal rights.

3.2.4 Who we may disclose your information to

We may disclose the information we collect to the following:

Merchants that you shop with to access Smart Receipts issued on their behalf
accountants, auditors, lawyers and other professional advisors we engage who require access to information
government agencies, regulatory bodies and law enforcement agencies, or other similar entities, where required under or authorised by law
third-party service providers to whom we may outsource certain organisational functions
third-party acquirer(s) in the event that we sell or transfer all or any relevant portion of our business or assets.

3.2 Smart Receipts delivered via Slyp App

3.2.1 Service description

We provide Merchants with the ability to deliver Smart Receipts to their customers via the Slyp App.

3.2.2 Type of data collected

When providing this service, Slyp may collect the information outlined below:

Type of data	Data description	How data is collected
Contact details	Name Email Phone number	Supplied by you upon signing up to the Slyp App
Merchant receipt details	Information typically available on a tax receipt enabling us to surface such information inside the Smart Receipts, including: Your transaction details details of Merchant you purchased from details of items you purchased your loyalty and/or membership number where relevant	Supplied by Merchant partners
Usage data and cookies (Anonymised)	Information about how you access and use our services, including: information you provide in free text fields, such as surveys, search terms or chat functions the time when you access Smart Receipts the IP address used to access our web hosted receipt and general location information information from any enabled cookies information from third parties you enable or connect to Slyp other information stored on your phone that you grant us access to, such as scanned or online receipts	Collected via Sites and/or Slyp partners you interact with

Where information is collected from Merchant partners, this information is collected electronically through APIs.

3.2.3 How we use information collected to provide Smart Receipts in the Slyp App, Merchant partners’ application or via SMS

We will only use the information collected where we have a legitimate business purpose to do so. Below outlines the purposes we may use the information we collect:

to generate Slyp Smart Receipts and deliver those via SMS, the Slyp App, or via any Merchants' application
to perform internal analysis helping us improve and develop our services
to provide Merchants with analytics products and insights using anonymised data
to conduct general administration of the business (including accounting, finance, answering enquiries)
to monitor and conduct activities related to the security of our systems and services
to comply with our legal and regulatory obligations and exercise our legal rights.

3.2.4 Who we may disclose your information to

We may disclose the information we collect to the following:

Merchants that you shop with to access Smart Receipts issued on their behalf
accountants, auditors, lawyers and other professional advisors we engage who require access to information
government agencies, regulatory bodies and law enforcement agencies, or other similar entities, where required under or authorised by law
third-party service providers to whom we may outsource certain services or functions
third-party service providers who you connect or enable with Slyp
third-party acquirer(s) in the event that we sell or transfer all or any relevant portion of our business or assets.

3.4 Users interacting with our website or merchant portal (“My Slyp”)

3.4.1 Service description

We provide a range of services on our website and our merchant portal which are accessible by a range of different users. For example, Merchants can create an account with Slyp, manage their account details and access their Smart Receipts. Users (whether they are retailers, Smart Receipts recipients or any other individual visiting our website) can provide feedback or seek to get in touch with us. We also conduct business activities such as marketing, recruitment and corporate communications operations via our website.

3.4.2 Category of information
As part of these services, Slyp may collect the information outlined below:

Type of data	Data description	How data is collected
Contact details	Contact details you provide when contacting us via our Sites, including your: name email address relationship with Slyp (i.e. customer, retailer, Bank or other).	Supplied by you when contacting us
Views, opinions, requests, etc.	Any information you share with us when contacting us.	Supplied by you when contacting us
Merchant account details	Information to set up a Merchant account with Slyp, to enable Smart Receipts to be offered to your customers including: your business details (including ABN, phone number and trading name) your store details (including name, address, phone number, ABN, opening hours) your branding details (including logo, brand colour palette, social links, website)	Supplied by Merchants when using our Sites and managing their accounts
Usage data and Cookies	Information about how you access and use our services.	Collected via your interactions with our Sites

3.4.3 How we use information collected when you use our SitesWe will only use the information collected where we have a legitimate business purpose to do so. Below outlines the purposes we may use the information we collect:

to answer enquiries and feedback submitted via our Sites
to perform internal analysis, helping us improve and develop our Sites and services
to monitor and conduct activities related to the security of our systems and services
to conduct general administration of the business (including management of Merchants' accounts, partners’ invoice, accounting and finance)
to comply with our legal and regulatory obligations and exercise our legal rights
to communicate with you about maintaining and updating your contact information where appropriate.
to communicate with you on subject which may be of interest including:

service updates and news about our services;
news items and other information in which you may be interested;
maintaining and updating your contact information where appropriate;
conducting surveys.

3.4.4 Who we may disclose your information to

We may disclose the information we collect to the following:

accountants, auditors, lawyers and other professional advisors we engage who require access to information
government agencies, regulatory bodies and law enforcement agencies, or other similar entities, where required under or authorised by law
third-party service providers to whom we may outsource certain organisational functions (including direct marketing)
third-party acquirer(s) in the event that we sell or transfer all or any relevant portion of our business or assets.

3.5 General business operations

3.5.1 Service description

Slyp may collect information from any person who interacts with us in the course of conducting business, including employees, job applicants, clients (current and prospective) and other third-parties.

3.5.2 Category of information

Slyp may collect the information outlined below:

Type of data

Data description

How data is collected

Employee and job application details

We may collect information from employees and job applicants to carry out relevant operations:

your contact details (name, email, mobile number and address)
your payment details (bank details, superannuation details and tax file number)
your health information where relevant (including allergies and disability affecting your work)
your resume, background checks and performance and disciplinary records
records of your access to our systems and devices.

Information is normally supplied by you, referees or third-parties (such as University or professional bodies)

Some information may also be directly collected by our systems

Clients, prospective clients and third-parties we conduct business with details

We may collect the below information from clients, prospective clients and third parties we conduct business to carry out relevant operations:

your contact details (name, email, mobile number and work address)
the company your represent and your role
records of your previous interactions with Slyp for customer relationship management purposes

Information may be supplied by you directly, a colleague of yours or one of our partners.

3.5.3 How we use information collected from employees, job applicants, clients and third-parties we engage with

We will only use the information collected where we have a legitimate business purpose to do so. Below outlines the purposes we may use the information we collect:

to consider the suitability of employment for prospective job applicants
to conduct general administration of the business (employee payroll, organising networking events and managing employee performance)
to perform internal analysis helping us improve and develop our services
to monitor and conduct activities related to the security of our systems and services
to comply with our legal and regulatory obligations and exercise our legal rights
to communicate with you on subject which may be of interest including:

Service updates and news about our services
News items and other information in which you may be interested
Open roles
Maintaining and updating your contact information where appropriate
Conducting surveys.

3.5.4 Who we may disclose your information to

We may disclose the information we collect to the following:

accountants, auditors, lawyers and other professional advisors we engage who require access to information
government agencies, regulatory bodies and law enforcement agencies, or other similar entities, where required under or authorised by law
third-party service providers to whom we may outsource certain organizational functions (including direct marketing)
third-party acquirer(s) in the event that we sell or transfer all or any relevant portion of our business or assets.

Direct marketing

We may, with your consent, use the information we have collected about you to contact you from time to time by email to tell you about new products or services that we believe may be of interest to you, to send you promotions, newsletters and to conduct surveys.

You can withdraw your consent to receiving direct marketing communications from us at any time by unsubscribing from the mailing list by clicking on the link in the marketing communication or contacting us using the details set out below.

Smart Receipts that are delivered by SMS to you may also include Merchants' offers or promotions. These promotions are those of our Merchant partners, and do not relate to Slyp's products or services. However, you can unsubscribe from receiving future promotions via Smart Receipts by clicking on the link at the bottom of the Smart Receipt.

Keeping your data secure and maintaining accuracy of your data

Protecting your privacy and maintaining the accuracy of the data we use to serve you is vitally important to us. This section details the measures we take to achieve this.

5.1 Securing Data

We have implemented appropriate technical and organisational security measures designed to protect your Personal Information against unauthorised or unlawful destruction, loss, alteration, disclosure, and other unlawful or unauthorised forms of Processing. A selection of these measures are listed below:

Staff education: we train and remind our staff of their obligations with regards to your Personal Information
System security: when you transact with us on the internet via our Sites or via our partners’ APIs, we encrypt data sent to our systems
Building security: we have protection in our buildings against unauthorised access such as cameras and access key controls
Disposal of data which is no longer required: we have defined policies to ensure that we only keep Personal Information for as long as required (for example, to meet user needs, legal requirements or our internal needs). If we no longer need to hold your Personal Information for any reason or we are no longer required by law to keep it, we will take reasonable steps to de-identify or destroy that information. These steps may vary depending on the nature of the information, the way it was collected and how it was stored.

5.2 Maintaining Data Accuracy

On an ongoing basis, we take every reasonable step to ensure that:

your Personal Information is accurate and has been kept up to date (where necessary)
any of your Personal Information that we process that is inaccurate (having regard to the purposes for which it is processed) is erased or rectified if we become aware of the inaccuracy.

From time to time we may ask you to confirm the accuracy of your Personal Information.

Cookies and similar technologies

In some cases, we use cookies or other similar technologies to provide our services to you.

6.1 How we use cookies

When you visit our Sites, we may use ‘cookies’ or other similar tracking technologies that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. While we do not use browsing information to identify you personally, we may record certain information about your use of our Sites, such as which pages you visit, the time and date of your visit, search engine referrals and the internet protocol address assigned to your device.

6.2 How you can stop cookies

You can change your cookie settings at any time and can disable cookies through your internet browser. How you do so depends on your browser and the type of cookie. Certain browsers can be set to reject all browser cookies. If you configure your device to block all cookies, you may disrupt certain features and limit the functionality we can provide when you visit or use our Sites. If you use our Sites without changing your settings, you are consenting to our use of cookies.

6.3 Web beacons

Our direct marketing communications may contain electronic images, known as web beacons. These electronic images enable us to know if a recipient has opened our communications or visited certain click through links (such as our website). Web beacons are a tool we use to analyse the engagement with our communications and help us improve your experience.

Dealing with us anonymously or using a pseudonym

Where possible and lawful, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general question, you are not required to give us your name unless we need it to adequately handle your question. Generally, we do not collect the names of customers from Merchants’ partners who receive Smart Receipts from us. However, for some of our functions and activities, we may need your name, contact information and other details to enable us to provide our services or products to you.

Accessing, updating and correcting your Personal Information

We will endeavour to ensure that the Personal Information collected from you is up to date, accurate and complete.

You may request access to, or correction of, the Personal Information we hold about you at any time by contacting us using the details provided below. We will need to verify your identity before responding to your request. Subject to any applicable exceptions or requirements, we will provide you with access to the Personal Information you request within a reasonable time and usually within 30 days. If we decide to refuse your request, we will tell you why in writing and how to complain if you are not satisfied by our response.

Contact us or find out more

9.1 Contacting us

If you have any questions regarding this Privacy Policy, our treatment of your Personal Information, complaints, or would like to access or amend your Personal Information, please contact us at info@slyp.com.au.

9.2 Complaints

If you contact us to raise a complaint, we will consider your complaint promptly and contact you to seek to resolve the matter. If we’re unable to provide a final response within 45 days, we will contact you to explain why and discuss a timeframe to resolve the complaint.

Under the Privacy Act, if you are not satisfied with our response, you are also entitled to make a complaint to the Australian Privacy Commissioner. For more information about the Australian Privacy Principles, or if we are unable to satisfactorily resolve your concerns about our handling of your Personal Information, you can contact the Office of the Australian Information Commissioner via the OAIC website, www.oaic.gov.au, or by using the details provided below:

GPO Box 5218, Sydney NSW 2001
Email: enquiries@oaic.gov.au
Tel: 1300 363 992

Appendix 1: Definitions

Term	Definition
*Bank*	Bank means a financial institution that issues credit cards or debit cards, or an entity providing other payment method, to customers and has entered into, and remains a party to, a services agreement with Slyp to provide Smart Receipts to its customers.
*Merchant*	Merchant means a person who has entered into, and remains a party to, a services agreement with Slyp under which Slyp is to create and issue Smart Receipts for its customers.
*Personal Information*	Personal Information means any information or opinion about an identified individual, or an individual who is reasonably identifiable: whether the information or opinion is true or not; or whether the information or opinion is recorded in a material form or not.
*POS*	POS means point of sales software providers that partner with Slyp; enabling retailers who use their software to offer Smart Receipts.
*Process, Processing or Processed*	Process means anything that is done with any data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
*SA2*	SA2 means Statistical Area Level 2 in the main structure under the Australian Statistical Geography Standard released by the Australian Bureau of Statistics.
*Site*	Any related web pages located under the domain name slyp.com.au.
*Slyp App*	Mobile application owned, controlled or operated in partnership with Slyp for the purpose of making Smart Receipts and other services available to Merchant customers.
*Smart Receipt*	Smart Receipt means the dynamic digital representation of a proof of purchase invoice issued on behalf of a Merchant by Slyp.

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