Privacy Policy

When we say “we”, “us” or “our”, we mean Fronk Enterprises PTY LTD and our related bodies corporate (if any), operating the Rewardom.com platform.

The type of information we collect depends on how you interact with us (creating an account, purchasing a membership/product, entering a promotion, contacting support, etc.). It typically includes:

• Identity and contact details, such as your name, date of birth, email address, phone number and address;
• Account and membership details, such as your username, membership status, preferences, and support history;
• Transaction information, such as purchase and refund records, payment references, and information needed to administer entries/benefits or manage disputes. We do not aim to store full payment card details unless there is a clear need and appropriate security controls are in place;
• Technical and usage data, such as IP address, device and browser information, pages viewed, timestamps, referral URLs, cookie identifiers and log data;
• Marketing and communications data, such as your subscription status, communication preferences and interactions with our campaigns;
• Location data, where you choose to enable it or where it is reasonably inferred (for example, approximate location from IP address).

We generally do not seek to collect sensitive information (as defined by the Privacy Act). If we ever need to collect it, we will only do so where permitted by law and, where required, with your consent.

We collect personal information in three main ways:

From you directly, when you register, purchase, enter a promotion, complete forms, take part in surveys, contact support, or otherwise interact with our services.

Automatically, when you use our website/app, through cookies and similar technologies. This helps us keep the platform working properly, understand usage, and improve performance.

From third parties, where appropriate and lawful. This may include payment providers, fraud and security vendors, identity/age verification providers, analytics and marketing partners, and publicly available sources.

Where we collect information from a third party, we take reasonable steps to ensure you are aware of this, either at the time of collection or as soon as practicable afterwards.

We collect, use and disclose personal information for the purpose of running our business and providing our services. This typically includes:

• Providing and managing your account and membership. For example, setting up and administering your account, providing customer support, verifying your identity where necessary, and communicating with you about your service.
• Processing transactions and administering promotions. For example, processing purchases and refunds, confirming eligibility, allocating entries/benefits, contacting winners, delivering prizes and maintaining audit trails.
• Protecting the platform and our users. For example, monitoring for fraud, chargebacks, suspicious activity, abuse, security incidents and policy breaches.
• Complying with legal obligations. For example, responding to lawful requests, maintaining records required for tax, accounting, disputes and complaints, and meeting regulatory requirements.
• Marketing and service communications. We may send service-related messages (like important account notices). We may also send marketing communications where permitted and aligned with your preferences, and you can opt out at any time.
• Improving our services. For example, analytics, debugging, testing, product development and reporting.

We do not “sell” personal information in the ordinary commercial sense (that is, disclosing it to third parties for their unrelated marketing purposes).

We share personal information only where it is necessary for the purposes described above. Common categories of recipients include:

• Service providers that help us operate the platform (for example hosting, IT support, email/SMS delivery, analytics, CRM/ticketing, identity verification, fraud prevention, payment processing, fulfilment and prize delivery);
• Professional advisers such as lawyers, auditors and insurers;
• Partners or sponsors of a specific promotion, where disclosure is needed to run the promotion or deliver prizes. If this applies, we will usually identify the relevant partner in the promotion terms or at the point of collection;
• Government agencies, regulators and law enforcement where disclosure is required or authorised by law, or where reasonably necessary to protect rights, safety and security, or to investigate suspected unlawful activity.

When we use service providers, we take reasonable steps to ensure they handle personal information appropriately, including through due diligence and contractual terms.

Some of our service providers may be located overseas or may store/process information outside Australia. This commonly happens with cloud hosting, communications tools, customer support platforms, analytics services, and certain security vendors.

Where overseas handling is likely, the countries in which recipients may be located include: Hong Kong.

We take reasonable steps to ensure that overseas recipients handle personal information in a manner consistent with the APPs, such as contractual protections and vendor oversight.

In limited cases, we may rely on a permitted exception (including informed consent) for certain overseas disclosures. If we do, we will aim to explain the practical consequences to you at the time so your consent is properly informed.

We may use your personal information to send you marketing communications about our services, offers and promotions where permitted by law and consistent with your preferences.

You can opt out at any time by using the unsubscribe link in an email, following the opt-out instructions updating your account preferences (if available), or contacting us.

Even if you opt out of marketing, we may still contact you with important service messages (for example, security notices or material changes to your account).

We use cookies and similar technologies to make our services work, remember preferences, understand traffic and usage, and measure campaign performance. You can manage cookies through your browser settings and, where available, our cookie preference tools. If you disable some cookies, certain functions may not work as intended.

You may request access to the personal information we hold about you, and you may request correction if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading.

To make a request, contact our Privacy Officer (details below). We may need to verify your identity before we provide access or make changes. If we refuse a request, we will explain why (where permitted) and tell you how you can make a complaint.

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorized access, modification or disclosure. The measures we use depend on the type of information and how it is stored, but typically include access controls, encryption where appropriate, monitoring, staff confidentiality obligations, and security procedures for our vendors.

No system is perfect. You should keep your login details secure and contact us immediately if you believe your account has been compromised.

We keep personal information only for as long as needed for the purposes set out in this policy, including to meet legal, accounting, audit, dispute and fraud-prevention requirements.

When information is no longer required, we take reasonable steps to delete it or de-identify it, unless we are required by law to retain it.

As a practical guide, we usually retain:

• account and transaction records for e.g., 7 years or as required by law, and
• customer support and operational records for e.g., 2 years, depending on the nature of the issue.

We also keep opt-out records (suppression lists) for as long as needed to respect your marketing preferences.

Our website/app may link to third-party websites or services. We do not control those third parties and are not responsible for their privacy practices. If you choose to interact with them, you should review their privacy policies.

If we become aware of a suspected or actual data breach, we will assess it and respond in line with our legal obligations. Where required, we will notify affected individuals and relevant authorities.

We may update this Privacy Policy from time to time. The latest version will be available on our website with the updated effective date. If changes are material, we may take additional steps to notify you.

If you have questions, concerns, or want to make a request to access or correct your information, please contact our Privacy Officer:

Privacy Officer:

Fronk Enterprises PTY LTD, ACN: 669 088 779, ABN: 24 669 088 779, with its registered address at North Adelaide SA 5006

Email: [email protected]

If you believe we have breached the Privacy Act or the APPs, you can lodge a complaint using the details above. Please include your name, contact details and a description of what happened.

We will acknowledge your complaint within [5 business days] and aim to provide a written outcome within 30 days (or let you know if we need more time and why). If you are not satisfied with our response, you may escalate your complaint to the Office of the Australian Information Commissioner (OAIC).