PRIVACY POLICY

This Privacy Policy sets out how Flying Turtle Australia Pty Ltd and its related bodies corporate (together referred to as “Flying Turtle”, “we”, “us” or “our”) collect, hold, use and disclose personal information, including through the Flying Turtle mobile application, our websites, and our automated beverage and retail machines.

We are committed to protecting your privacy and comply with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth).

This Privacy Policy does not apply to third-party websites, applications or services that may be linked to or accessed through our platforms, and we are not responsible for the privacy practices of those third parties.

This Privacy Policy applies to personal information collected and used by Flying Turtle in relation to:

• customers and app users
• loyalty program members
• venue partners and clients
• suppliers and prospective suppliers
• contractors, job applicants and employees

WHAT IS PERSONAL INFORMATION?

“Personal Information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether it is recorded in a material form.

WHEN DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

• download, register for, or use the Flying Turtle app
• purchase a drink or product from a Flying Turtle machine
• create or use a Flying Turtle account or loyalty program
• participate in promotions, competitions or surveys
• contact us with enquiries, complaints or feedback
• interact with Flying Turtle on social media
• visit our websites or use digital services linked to Flying Turtle

WHAT PERSONAL INFORMATION DO WE COLLECT?

Customers & App Users

• name
• email address
• mobile number
• date of birth or age group
• gender
• location data (such as postcode or machine location)
• order history and drink preferences
• loyalty points and rewards usage
• app usage data and interactions
• payment information (processed securely by third-party payment providers)
• customer service communications and feedback

From time to time, photos or videos may be taken at Flying Turtle locations or events and used for operational, training or marketing purposes. Where individuals are identifiable, reasonable steps will be taken to obtain consent where required.

DO YOU HAVE TO PROVIDE PERSONAL INFORMATION?

• provide services through the Flying Turtle app
• process payments or loyalty rewards
• respond to enquiries or complaints
• offer certain products, promotions or employment opportunities

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

• Flying Turtle app and website
• Flying Turtle machines and payment systems
• customer support channels
• promotions, surveys and competitions
• social media interactions
• third-party service providers (such as payment processors, analytics platforms, recruitment partners)
• publicly available sources
• internal operational records

We may use cookies, analytics tools and similar technologies on our websites and app to improve performance, security and user experience.

HOW DO WE USE YOUR PERSONAL INFORMATION?

• provide and operate the Flying Turtle app and services
• process transactions and deliver products
• manage loyalty programs and promotions
• communicate with you about your account, orders or support requests
• improve product quality, machine performance and user experience
• conduct analytics, research and service optimisation
• send marketing communications (where permitted)
• comply with legal and regulatory obligations

HOW DO WE DISCLOSE PERSONAL INFORMATION?

• related Flying Turtle entities
• technology, payment and cloud service providers
• logistics, maintenance and operations partners
• marketing and analytics providers
• professional advisers (legal, accounting, insurance)
• government or regulatory authorities where required by law
• venue partners, where necessary to operate services

Where Personal Information is shared with third parties, we take reasonable steps to ensure it is handled securely and only used for authorised purposes.

SOCIAL MEDIA & PUBLIC PLATFORMS

By interacting with Flying Turtle on social media, you acknowledge that content you post may be publicly visible and subject to the privacy policies of those platforms. Flying Turtle is not responsible for third-party platform practices.

CROSS-BORDER DISCLOSURE

Some Personal Information may be stored or processed outside Australia, including in cloud infrastructure or systems located overseas. Where this occurs, we take reasonable steps to ensure compliance with Australian privacy obligations.

SECURITY

• secure IT systems and access controls
• encryption and secure payment processing
• internal policies and staff training
• restricted access to sensitive data

However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.

DIRECT MARKETING & OPT-OUT

• using the unsubscribe link in communications
• adjusting app notification settings
• contacting us using the details below

ACCESSING OR CORRECTING YOUR INFORMATION

You may request access to or correction of your Personal Information by contacting us. We may charge a reasonable fee where permitted by law.

HOW LONG DO WE KEEP YOUR INFORMATION?

We retain Personal Information only for as long as necessary to fulfil the purposes for which it was collected, including to meet legal, accounting, tax or reporting obligations.

Account and loyalty program information (including date of birth) is retained for as long as your account remains active, and for a reasonable period afterwards to allow you to resume use of your account or to meet our legal obligations. Where information is no longer required, we take reasonable steps to destroy or de-identify it.

Where an account is deleted, we retain a limited record linked to your mobile number (not your full account) to prevent a Birthday Reward being claimed more than once per year across re-registered accounts. This record does not include your date of birth or other account details.

You may request deletion of your account and associated Personal Information at any time by contacting us, subject to information we are required to retain by law.

CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. The latest version will always be available on our website and within the Flying Turtle app.

COMPLAINTS

If you believe we have breached your privacy rights, please contact us. We aim to acknowledge complaints within 5 business days and resolve them within 30 days.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC).