DEAL-IT PRIVACY POLICY

Deal-It Pty Ltd (ACN 691141625)

Effective date: 9 August 2026

1. About this policy

• 1.1. This privacy policy explains how Deal-It Pty Ltd (ACN 691141625) (Deal-It, we, us or our) collects, holds, uses and discloses personal information in connection with the Deal-It mobile application (App) and the related web-based portal used by Venues (Portal).
• 1.2. This policy applies to individual Users of the App, and to individuals associated with a Venue (such as an owner, manager, or nominated contact) whose personal information we collect in connection with a Venue Account.
• 1.3. We are committed to handling personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles.
• 1.4. This policy should be read together with our User Terms and Conditions and our Business Account Terms and Conditions, as applicable to you.
• 1.5. Capitalised terms used but not defined in this policy have the meaning given to them in our User Terms and Conditions or our Business Account Terms and Conditions, as applicable, including Redemption Zone, Alcohol Promotion, Deal, User Account, Venue Account and Portal.

2. What personal information we collect

• 2.1. From Users, we collect:
  • (a) identity and contact information, including your name and email address, obtained through your Apple ID or Google account when you create a User Account;
  • (b) your self-declared date of birth, which we use to confirm you are 18 years or older before you can create a User Account or access the App;
  • (c) location information from your device, which we use to operate the Redemption Zone (see clause 5) and to send you push notifications;
  • (d) your activity on the App, including Deals you view, “like”, and Redeem; and
  • (e) any information you provide to us directly, including in a support request or a report made under our User Terms and Conditions.
• 2.2. From Venues, we collect:
  • (a) business information, including your legal business name, ABN, trading address, and business structure;
  • (b) contact information for the individuals associated with your Venue Account, including names, phone numbers and email addresses;
  • (c) payment and billing information, collected and processed on our behalf by our payment processor;
  • (d) where you publish an Alcohol Promotion, your liquor licence type, licence number, a copy of your current liquor licence, your trading hours, and whether you hold a post-1am trading authority; and
  • (e) Deal content you submit, and analytics relating to the performance of your Deals.
• 2.3. We do not require Users to provide payment information, as the App is currently free to download and use.

3. How we collect personal information

• 3.1. We collect personal information directly from you, including when you create a User Account or Venue Account, use the App or Portal, contact our support team, or, for Venues, are onboarded by our team.
• 3.2. We collect location information automatically from your device while you have the App open and location services enabled.
• 3.3. We may collect personal information from a third party, including your Apple ID or Google account provider (to facilitate sign-in), or our payment processor (in connection with a Venue's subscription).

4. How we use your personal information

• 4.1. We use personal information to:
  • (a) provide, operate and improve the App and Portal;
  • (b) create and manage your User Account or Venue Account;
  • (c) confirm your age and apply the age-based access restriction on Alcohol Promotions;
  • (d) operate the Redemption Zone and process a Redemption;
  • (e) process a Venue's subscription and Boost payments;
  • (f) provide customer support and respond to your enquiries or reports;
  • (g) screen Deal content for compliance with our Business Account Terms and Conditions; and
  • (h) comply with our legal obligations, and manage any legal claim or dispute.

5. Location information and the Redemption Zone

• 5.1. If you are a User, the App uses your device's location to operate the Redemption Zone - a proximity and dwell-time based mechanism that automatically records a Deal as redeemed once you are within a distance of, and remain near, a Venue for a period of time, each as determined by us.
• 5.2. We also use your location to send you push notifications, including about Venues you have favourited.
• 5.3. You can control the App's access to your device's location through your device settings. If you disable location services, some features of the App, including the Redemption Zone, may not function correctly.

6. Automated decision-making

• 6.1. The App uses automated processes to make decisions that may affect you, including:
  • (a) automatically confirming a Redemption once you meet the Redemption Zone's proximity and dwell-time conditions, based on your device's location;
  • (b) automatically restricting your access to Alcohol Promotions unless you are logged in to a User Account and have confirmed you are 18 years or older; and
  • (c) automatically screening Deal content submitted by Venues, including using artificial intelligence, against a restricted list of words, phrases and images, to determine whether it can be published.
• 6.2. These processes rely on information you or a Venue provide (such as your self-declared date of birth, or your device's location), and do not involve an independently verified check.
• 6.3. If you believe an automated decision has affected you incorrectly - for example, if a Deal you believe you were entitled to redeem was not recorded as redeemed - you can contact us using the details in clause 14, and we will review it.

7. Cookies, analytics and push notifications

• 7.1. We may use analytics tools within the App to understand how it is used, which may involve the collection of technical and usage information from your device.
• 7.2. We may send you push notifications, including about Deals from Venues you have favourited, based on your location and App activity. You can manage or disable push notifications through your device settings.
• 7.3. We provide Venues with access to analytics relating to the performance of their own Deals, such as redemption volumes over time. This does not include the personal information of individual Users.

8. Disclosure of personal information

• 8.1. We disclose personal information to our payment processor, which we currently use solely to process a Venue's subscription and Boost payments. We do not disclose User personal information to our payment processor, as the App does not currently charge Users any fee.
• 8.2. We do not disclose personal information to any other third party, except:
  • (a) as required or authorised by law;
  • (b) to a professional adviser, to the extent reasonably necessary; or
  • (c) in connection with a sale, merger or restructure of our business.
• 8.3. We do not sell personal information to any third party.

9. Overseas disclosure

• 9.1. Our payment processor may store or process information outside Australia. Where this occurs, we take reasonable steps to ensure that any overseas recipient handles personal information consistently with the Australian Privacy Principles, to the extent required by law.

10. Direct marketing

• 10.1. We may send you information about Deal-It, the App, or Deals we consider may interest you, including by push notification.
• 10.2. You can opt out of receiving marketing communications at any time by adjusting your notification settings on your device, or by contacting us using the details in clause 14.

11. Data security

• 11.1. We take reasonable steps to protect the personal information we hold from misuse, interference, loss, and unauthorised access, modification or disclosure, including through the security measures used by our hosting and payment processing providers.
• 11.2. No method of electronic storage or transmission is completely secure. While we take reasonable steps to protect your personal information, we cannot guarantee its absolute security.

12. Data retention and deletion

• 12.1. We retain personal information for as long as your User Account or Venue Account remains active, and as reasonably necessary to provide the App and Portal.
• 12.2. If you cancel your User Account or Venue Account, we retain your account and usage data for 30 days, after which it is deleted from our systems, except to the extent we are required to retain it by law, or need to retain it to resolve a dispute or enforce our agreements.

13. Access and correction

• 13.1. You may request access to, or correction of, the personal information we hold about you by contacting us using the details in clause 14.
• 13.2. We will respond to your request within a reasonable time. We may need to verify your identity before providing access to, or correcting, your personal information, and there may be circumstances in which we are permitted by law to refuse a request.

14. Complaints and contact us

• 14.1. If you have a question or complaint about how we handle personal information, please contact us at support@deal-it.com.au.
• 14.2. We will investigate your complaint and aim to respond within a reasonable time. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

15. Minimum age

• 15.1. You must be at least 18 years old to create a User Account or use the App, as set out in our User Terms and Conditions. The App is not intended for use by children, and we do not knowingly collect personal information from anyone under 18.

16. Personal information you provide to us about others

• 16.1. If you are a Venue, and you provide us with personal information about an individual associated with your business (such as a manager, staff member, or the licensee named on your liquor licence), you must ensure that individual is aware of this policy, and that you are otherwise entitled to provide us with their personal information.

17. Changes to this policy

• 17.1. We may update this policy from time to time. We will publish the updated policy within the App or Portal, and it takes effect from the date it is published unless we say otherwise.

18. Contact us

• 18.1. If you have any questions about this policy or how we handle personal information, please contact us at support@deal-it.com.au or through the App or Portal.