Although our Services may be available via Affiliate (defined below) or other third-party WiFi networks, we do not operate or own these networks.
What personal information do we collect?
The types of personal information we collect about you may include:
How do we collect personal information?
We may collect your personal information relating to our Services including when you:
We may also collect personal information from third-parties including:
GFS is committed to protecting the online privacy of children. We do not knowingly collect personal information from children under 13 or allow them to create an account.
How do we hold and protect your personal information?
We maintain personal information in a combination of our secure online systems, paper-based files and other records, both at our own premises and with the assistance of service providers located in Australia and/or the United States.
In doing so, we take reasonable steps to protect your personal information from misuse, interference and loss, and unauthorized access, modification or disclosure. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information as it is transmitted to us.
Consequences if you do not provide us with your personal information
You are not required to provide any personal information to us, however, if you do not provide your personal information, we may not be able to provide products, services or benefits in connection with the Rewards Program. For example, if you have not provided your name and email address, we will not be able to create a member account and you will not be able to participate in the Rewards Program.
Why do we collect, hold, use and disclose your personal information?
We handle your personal information for the purposes of providing, administering, improving and personalizing the Rewards Program, our products and services, and the products and services of other Redemption Partners. This can include registering you to participate in the Rewards Program; enabling you to access the Rewards Program platform; providing Rewards Program benefits; procuring ads and online content matching your interests and voting feedback; verifying your identity, communicating with you (including through direct marketing, where we are permitted to do so); understanding your interests and preferences to help us tailor our communications and offers to your needs; handling your queries and complaints; assessing the performance of the Rewards Program website and platforms and improving their operation; analyzing data; conducting surveys, market and product research; producing analytics to improve their advertising and marketing services; otherwise providing goods, services and benefits you have requested or are eligible to receive in connection with the Rewards Program; working with our service providers; and any other purposes which we have notified to you at the time of collection of the information, or to which you have provided consent.
We may also handle your personal information:
Legal basis for processing your personal information
This section only applies if you are located within the UK/EU.
We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:
Direct marketing choices
Where we have your consent or are otherwise permitted by law to do so, we may also use and disclose your personal information to provide you with marketing communications and targeted advertising on an ongoing basis by sending electronic messages (such as SMS or email), through our Services and by other means.
These communications may relate to the products and services we, other Rewards Program participants (such as our Redemption Partners) and other group companies provide, promotions run by us or for which there is automatic entry for Rewards Program members, and other products or developments which may be of interest to you.
You may opt-out of receiving future electronic and telephone direct marketing communications through the unsubscribe function that will be made available to you with each direct marketing communication. Please Contact Us to understand the consequences of unsubscribing from email communications.
To whom do we disclose your personal information?
ADFREEWAY may disclose your personal information to:
Social Media Login
Device Data and other technologies
We may use digital technologies such as cookies, location services, web server logs and web beacons, ad optimization technology, machine learning and user profile algorithms in connection with the Rewards Program website, platform, social pages and other digital portals. A cookie is a small data file that a website may write to your hard drive when you visit it. A cookie file can contain information, such as a session ID which the website uses to track the pages you have visited. Other technologies we use include web beacons. We allow cookies and other digital technologies to be used:
Generally, the cookies we use fall into the following categories:
Our ad optimization technology relies upon information we collect (including your preferences and Device Data) to curate the ads you receive to improve your online experience. Our platform may block, re-prioritise or substitute ads that you would have otherwise received based on your Voting Activity, Device Data, online activity, and other information we have collected about you.
The Rewards Program website may use cookie data to track user traffic patterns and to provide better service when you revisit our website.
Whenever a URL or ad is accessed via the Rewards Program platform, information is recorded such as the time, date, URL hash, ad and Voting Activity.
Third Party Technologies:
By using our Services, you (where not located in the UK/EU) consent to:
If you are located in the UK/EU, we will collect the relevant consents for cookie use separately. For other activities, we may not require your consent all the time, and we may rely on other legal basis to process your personal data – see “Legal basis for processing your personal information” above, for further details.
If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies or otherwise withdraw your consent in relation to cookies, you may not be able to access all of the functions of the site.
Please note that if you have accepted third-party cookies and subsequently wish to remove them, you must do so from your own browser (as per the instructions above).
Additional Disclosures for Australian Users
As applicable, this Policy is subject to and does not limit the rights and/or exceptions available to ADFREEWAY under the Australian Privacy Principles of the Privacy Act 1988 (Cth) (the Privacy Act).
ADFREEWAY discloses personal information, for some of the purposes described above, to organizations located in Australia and in other countries, including New Zealand, the United States, United Kingdom, Israel and South Africa. We or our service providers may also make personal information held in Australia or the other countries listed above remotely available for processing by service provider personnel located in other countries, such as New Zealand, United States, United Kingdom, Israel and South Africa. We take reasonable steps to ensure that overseas recipients of your personal information do not breach the privacy obligations relating to your personal information, and only use it for the purpose for which it was disclosed.
At your request, ADFREEWAY will provide a copy of any personal information we hold about you, unless an exception under the Privacy Act applies. We may charge reasonable fees for retrieving this information, in which case we will obtain your prior consent.
When your personal information is no longer required, we take reasonable steps to destroy or permanently de-identify the information.
We will promptly acknowledge and investigate any complaint about the way we manage personal information.
We will take reasonable steps to remedy any issues resulting from our failure to comply with privacy obligations. If our response to you does not satisfactorily address your concerns, you may have the right to make a complaint to a competent regulator (e.g. Office of the Australian Information Commissioner at oaic.gov.au).
California Do-Not-Track Disclosures
GFS respects your privacy, but we do not alter the information we collect or change our services upon receiving “do-not-track” signals, as the term appears in Cal. Bus. & Prof. Code §§ 22575(b)(5). For more information about DNT signals, visit http://allaboutdnt.com.
How you can access and correct your personal information
We will take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can ensure certain personal details (i.e., name, address, email, phone, etc) are updated in your account settings on ADFREEWAY.com or Contact Us.
If you are located in the UK/EU, you have certain rights in relation to your personal information. These include: the right to object to the processing of your information for certain purposes, the right to access your personal information, and the ability to erase, restrict or receive a machine-readable copy of your personal information. We will handle any request to exercise your rights in accordance with applicable law and any relevant legal exemptions. If you wish to exercise any of these rights please contact us using the contact details below. You may also have the right to complain to a data protection authority if you think we have processed your personal information in a manner which is unlawful or breaches your rights. If you have such concerns we request that you initially contact us (using the contact details below) so that we can investigate, and hopefully resolve, your concerns.
How to contact us