Privacy Policy

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.

1. What this policy covers

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.

2. The personal information we collect

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.

3. How we collect personal information

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.

4. Why we collect, use, and hold personal information

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.

5. Customer privacy boundaries

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.

6. Disclosure of personal information

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.

7. Overseas disclosure

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.

8. Cookies and analytics

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.

9. Data quality, security, and retention

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.

10. Access and correction

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.

11. Marketing and communications

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.

12. Complaints

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.

13. Changes to this policy

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.

14. Contact

For privacy questions, access or correction requests, or complaints, contact [email protected].