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Last updated: 31 March 2026
This Privacy Policy explains how Maslin Enterprises Pty Ltd ABN 87 118 426 190 handles personal information for Smally Loyalty. In this policy, we, us, and our mean Maslin Enterprises Pty Ltd.
This policy applies to personal information we collect through the Smally Loyalty website, business dashboard, customer account area, scanner tools, wallet pass features, support interactions, and related products and services.
Depending on how you use Smally Loyalty, we may collect personal information such as your name, business name, contact details, billing details, loyalty profile details, date-of-birth fields, account credentials or login tokens, device and browser information, usage data, support history, and records of scans, rewards, offers, redemptions, campaigns, or customer-business interactions processed through the platform.
We collect personal information when you provide it directly, when a business sets up or administers a Smally Loyalty account, when a customer creates or uses a Smally Loyalty identity, when you contact support, and when you use or interact with the platform. We may also collect technical information automatically through cookies, logs, analytics tools, and similar technologies.
We collect, use, and hold personal information to provide and operate Smally Loyalty, authenticate users, maintain customer accounts, support loyalty and rewards functions, deliver communications, process billing, prevent fraud and misuse, improve platform performance, respond to support requests, comply with legal obligations, and protect our rights and the rights of users and third parties.
Smally Loyalty is designed so that participating businesses do not automatically receive a customer's private contact details through the standard loyalty experience where Smally Loyalty has decided those details should remain platform-controlled. We may still use customer contact information ourselves to operate accounts, handle support, deliver platform-level messages, or provide services the customer has requested or consented to receive.
We may disclose personal information to our related service providers, contractors, professional advisers, payment processors, hosting and infrastructure providers, analytics providers, telecommunications and messaging providers, wallet and app platform operators, and other suppliers who help us run Smally Loyalty. We may also disclose personal information where required or authorised by law, to protect safety, rights, or property, or in connection with a sale, merger, restructure, or transfer of all or part of our business.
Some of our service providers may store or process personal information outside Australia. This may include providers located in countries where our cloud, messaging, analytics, or support tools operate. While we take reasonable steps to work with reputable providers, overseas recipients may be subject to different privacy laws from those in Australia.
We may use cookies and similar technologies to keep you signed in, remember preferences, understand usage patterns, improve site performance, and support security and diagnostics. You can usually control cookies through your browser settings, but some features may not work properly if cookies are disabled.
We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure. No system is completely secure, so we cannot guarantee absolute security. We keep personal information for as long as reasonably needed for the purposes described in this policy, to comply with legal obligations, resolve disputes, enforce agreements, and maintain appropriate business and security records.
You may request access to personal information we hold about you, and you may ask us to correct inaccurate, out-of-date, incomplete, irrelevant, or misleading information. We may need to verify your identity before acting on a request. In some circumstances, the law may allow or require us to refuse a request, in which case we will explain why where we are permitted to do so.
We may send service, account, security, billing, and operational messages where needed to run Smally Loyalty. We may also send marketing or promotional communications where permitted by law. You can opt out of non-essential marketing communications using the unsubscribe or preference options provided, but you may still receive essential service-related messages.
If you have a privacy concern or complaint, please contact us first so we can investigate and respond. We will aim to respond within a reasonable time. If you are not satisfied with our response, you may be able to contact the Office of the Australian Information Commissioner.
We may update this Privacy Policy from time to time. The latest version published through Smally Loyalty will apply from the date it takes effect.
For privacy questions, access or correction requests, or complaints, contact [email protected].
Last updated: 8 April 2026
These Terms of Service govern your access to and use of Smally Loyalty, a digital loyalty and customer engagement platform operated by Maslin Enterprises Pty Ltd ABN 87 118 426 190. In these terms, we, us, and our mean Maslin Enterprises Pty Ltd, and you means the person or business using Smally Loyalty.
By accessing Smally Loyalty, creating an account, or using any Smally Loyalty website, dashboard, app, scanner, wallet pass, or related service, you agree to these terms and our Privacy Policy. If you use Smally Loyalty on behalf of a business or other entity, you confirm that you have authority to bind that entity to these terms.
Smally Loyalty provides software and related services for loyalty programs, customer identity, rewards, offers, messaging, reporting, staff scanning flows, and related business tools. We may improve, change, suspend, or discontinue any part of the service from time to time.
You must provide accurate, current, and complete information when creating or updating an account. You are responsible for maintaining the confidentiality of your passwords, tokens, and devices, and for all activity carried out using your account. You must notify us promptly if you suspect unauthorised access or a security issue.
You must not misuse Smally Loyalty. This includes, without limitation, attempting to gain unauthorised access, interfering with platform performance, introducing malicious code, scraping or copying data without permission, impersonating another person, sending unlawful or misleading communications, or using Smally Loyalty in a way that breaches any law, regulation, code, or third-party right.
If you use Smally Loyalty for a business, you are responsible for the loyalty settings, rewards, promotional offers, campaign content, staff access, customer-facing representations, and any legal obligations that apply to your business. You must ensure your offers, rewards, promotions, and communications are lawful, accurate, and honoured as presented to customers. You are solely responsible for the wording, conditions, exclusions, redemption outcomes, and fulfilment of your offers and rewards.
We provide platform tools only. We do not review, approve, certify, or guarantee that a business offer is lawful, accurate, enforceable, or suitable for your circumstances.
Smally Loyalty may operate a shared customer identity across participating businesses. Platform rules, privacy settings, communication controls, delivery safeguards, and plan entitlements may limit what data is visible to a business and what actions a business can take. You must not attempt to work around those controls.
Some parts of Smally Loyalty may be free and others may require payment. If you subscribe to a paid plan or paid feature, you agree to pay the fees and charges we specify at the time of purchase. Unless we state otherwise, fees are in Australian dollars and are non-refundable except as required by law, including the Australian Consumer Law. We may change pricing or plan inclusions prospectively by giving reasonable notice.
Smally Loyalty may rely on or integrate with third-party services such as hosting providers, analytics tools, payment processors, wallet providers, telecommunications services, email delivery tools, or app platforms. We are not responsible for third-party services, and your use of them may also be subject to separate terms and policies.
We or our licensors own all rights, title, and interest in Smally Loyalty, including software, branding, content, workflows, designs, documentation, and underlying technology, except for content you lawfully submit. Subject to these terms, we grant you a limited, non-exclusive, non-transferable, revocable right to use Smally Loyalty for your internal business or personal use as applicable.
You retain ownership of content and data you submit to Smally Loyalty, but you grant us a licence to host, store, reproduce, adapt, transmit, and otherwise use that content and data to operate, secure, support, improve, and provide Smally Loyalty. You confirm that you have all rights needed to provide that content and data to us.
We handle personal information in accordance with our Privacy Policy. You must also comply with applicable privacy and marketing laws when using Smally Loyalty, including any obligations that apply to your collection or use of customer information outside the platform.
We aim to provide a reliable service, but Smally Loyalty is provided on an as is and as available basis. We do not promise uninterrupted availability, error-free operation, or that every feature will always be available. Maintenance, upgrades, outages, security events, third-party issues, or internet failures may affect access to the service.
To the maximum extent permitted by law, we exclude all warranties, representations, and guarantees not expressly stated in these terms. Nothing in these terms excludes, restricts, or modifies any consumer guarantee, statutory right, or other non-excludable right under the Australian Consumer Law or other applicable law.
To the maximum extent permitted by law, we are not liable for any indirect, incidental, special, punitive, or consequential loss, or any loss of profits, revenue, goodwill, data, or business opportunity arising from or connected with Smally Loyalty. To the maximum extent permitted by law, our total aggregate liability for any claim arising out of or in connection with Smally Loyalty is limited to the amount you paid us for the relevant service in the 12 months before the event giving rise to the claim, or if no amount was paid, AUD $100.
You indemnify us, our directors, officers, employees, and contractors against loss, damage, liability, cost, and expense arising from your misuse of Smally Loyalty, your breach of these terms, your content or data, your offers/rewards/promotions, or your breach of any law or third-party right, except to the extent the loss is caused by our own wrongful act or omission.
We may suspend, restrict, remove, or terminate access to Smally Loyalty immediately if we reasonably believe this is necessary to protect the service, comply with law, respond to a security risk, prevent misuse, address a breach of these terms, or address an offer, reward, promotion, or communication that appears unlawful, misleading, inaccurate, or likely to cause customer harm. This includes pausing or removing specific loyalty rules, rewards, campaigns, or related account actions.
You may stop using Smally Loyalty at any time. Clauses that by their nature should survive termination continue to apply after termination.
We may update these terms from time to time. The updated version will apply from the time it is published, or from any later date we specify. Continued use of Smally Loyalty after an update takes effect means you accept the updated terms.
These terms are governed by the laws of New South Wales, Australia. You submit to the exclusive jurisdiction of the courts of New South Wales and any courts entitled to hear appeals from those courts.
If you have questions about these terms, contact us at [email protected].
Last updated: 14 April 2026
These Universal Rules and Terms of Use (Terms) govern the operation and use of the Smally Loyalty network (the Network), a platform provided by Smally Digital (Smally, we, us).
The Network enables participating businesses (Merchants) to offer loyalty programs (Programs) to customers (Customers) subject to a standardized set of rules governing program operation.
By participating in or using any Program, both Merchants and Customers agree to be bound by these Terms.
These Terms establish the universal operating framework for all Programs available through Smally Loyalty.
2.1 These Terms establish the uniform operational rules applicable to all Programs made available through the Network (Network Rules).
2.2 Each Program is created and administered by an individual Merchant and may include additional terms specific to that Program (Merchant-Specific Terms).
2.3 Merchant-Specific Terms apply only to the relevant Program and must not conflict with these Terms.
2.4 In the event of any inconsistency between Merchant-Specific Terms and these Terms, these Terms prevail.
For the purposes of these Terms:
Program means a loyalty offer created by a Merchant and made available via the Network.
Progress means a Customer's accumulated participation toward earning a Reward under a Program.
Reward means the benefit issued to a Customer upon completion of the applicable Program conditions.
Legacy Program means a Program that has been replaced or superseded but remains available for limited completion purposes.
Effective Date means the date on which a new or amended Program becomes active.
The following provisions apply to all Programs without exception.
4.1 Reward Expiry
4.1.1 All Rewards issued through the Network expire sixty (60) days from the date of issuance.
4.1.2 Expiry occurs automatically and may not be extended, modified, or overridden by the Merchant.
4.2 Program Changes
4.2.1 Merchants may amend, replace, or discontinue a Program at their discretion.
4.2.2 Any such change is subject to a minimum notice period of thirty (30) days prior to the Effective Date.
4.3 Legacy Progress
4.3.1 Following a Program change, Customers are permitted to continue accruing and completing Progress under the Legacy Program.
4.3.2 Legacy Programs remain available solely for the purpose of allowing Customers to complete previously accrued Progress.
4.4 Legacy Expiry
4.4.1 All Progress under a Legacy Program expires ninety (90) days after the applicable Effective Date of the Program change.
4.4.2 Upon expiry, any incomplete Progress is automatically forfeited without compensation.
4.5 Automatic Transition
4.5.1 Upon either:
(a) completion of a Reward under a Legacy Program; or
(b) expiry of Legacy Progress,
the Customer automatically transitions to the current active Program.
4.6 Single Active Program State
4.6.1 At any given time, a Customer may accumulate Progress in only one of the following:
(a) a current active Program; or
(b) a Legacy Program pending completion.
4.6.2 Progress must not be accumulated concurrently across multiple Programs.
4.7 No Conversion or Transfer
4.7.1 Progress accumulated under one Program must not be converted into monetary value, transferred, or applied toward any other Program.
4.8 Flash Offer Dispatch Finality
4.8.1 A Flash Offer may be edited or cancelled only before dispatch begins.
4.8.2 Once dispatch has started, the Flash Offer must not be cancelled or materially changed.
4.8.3 Merchants must honour dispatched Flash Offers as presented to Customers until the stated expiry time.
4.8.4 Flash Offer delivery is best-effort only and is subject to platform controls, including cooldown, contact-frequency limits, channel eligibility, and expiry-window constraints.
4.8.5 Smally does not guarantee delivery of a Flash Offer to every recipient in a selected segment where those controls suppress or defer delivery.
5.1 Merchants are solely responsible for defining Program economics (including thresholds and Reward value), accurately describing Programs and Rewards, honouring fulfilled Rewards, and ensuring legal and regulatory compliance.
5.2 Smally does not determine or guarantee Reward value, provide or fulfil Rewards, or act as seller/supplier of goods or services offered by a Merchant.
6.1 Customers are entitled to accrue Progress and redeem Rewards in accordance with these Terms, receive clear Program information, and complete eligible Progress within applicable timeframes.
6.2 Customers acknowledge that Rewards expire in accordance with clause 4.1, Progress may be forfeited under clause 4.4, and Rewards are provided by the Merchant, not Smally.
7.1 Each Program must include Merchant-Specific Terms defining Program structure, eligibility requirements (if any), reward scope, and any additional Merchant conditions.
7.2 Merchant-Specific Terms must be clear, not misleading, and consistent with these Terms.
8.1 Smally provides the technical infrastructure supporting the Network and the standardized rules governing Program operation.
8.2 Smally does not act as a party to Merchant-Customer transactions, guarantee goods/services availability or quality, or assume liability for Reward fulfilment.
9.1 Smally reserves the right to suspend or remove any Program that breaches these Terms, creates operational/system inconsistencies, or violates applicable law.
9.2 Smally may take such action without prior notice where reasonably necessary.
10.1 Smally may amend these Terms from time to time.
10.2 Continued use of the Network constitutes acceptance of the amended Terms.
Merchant: Cafe Roma
Program Name: Coffee Rewards
Program Description: Customers receive one (1) stamp per eligible coffee purchase. Upon collecting nine (9) stamps, the Customer is entitled to one (1) Reward.
Reward: One (1) standard coffee, as defined by the Merchant. No cash alternative is available.
Conditions: Valid for in-store purchases only; not transferable; subject to availability.