Privacy Policy

Privacy Policy


1      GENERAL

1.1   Purpose Of This Document

We take your privacy seriously. This Policy describes what we do, and what we don't do, with the personal information that we collect via our applications and online properties.

1.2   What This Document Does Not Cover

Our applications and online properties may include links, banners, widgets and advertisements that lead to other websites. When you click on these links, you become subject to their terms of use and privacy policies. We are not responsible in any way for the privacy practices of other websites.

1.3   Your Consent

You accept the terms of this Policy (and the uses of the technologies and procedures explained in it) by using any of the applications or online properties. Another way of signifying your consent is by choosing to submit personal information manually to us.

1.4   Defined Terms ETC

Italicised words in this Policy and the rules for interpreting this Policy are set out in the definitions and interpretation section at the end of this web page.

1.5   Changes To This Policy

We have the right to update this Policy from time to time by posting a new version on the website. Please check this web page periodically in order to ensure that you are familiar with any changes. This Policy was last updated on 20 June 2018.

1.6   Contacting Us

If you have any questions about this Policy, please contact us using the following information:


The Privacy Officer

GHES International Pty Ltd

PO Box 2363




In the course of our interactions with our users and partners, we may collect personal information that relates to you. The types of personal information that we collect vary according to the type of activity as follows:

2.1   Browsing By You

We capture data about your browsing activities on the website and other websites using tracking technologies. We do this in our own right and in conjunction with third party providers such as analytics companies such as Google analytics and third party ad servers and networks. The technologies that we and our partners use include cookies, clear GIFs pixel tags and ETags. You have the ability to opt out of the use of some of these tracking technologies as discussed in Section 5 below.

Using these tracking technologies, we capture ‘clickstream data’. This is data pertaining to your browsing activities based on the links that you choose to click. Clickstream data includes:

-        details of the referring page that brought you to the website (which may be another website or a search engine);

-        the pages that you visit on the website;

-        search terms that you enter on the website or a referring site;

-        the pages, content or ads that you see or click during your visit;

-        the items that you download;

-        the time that you visited the website and the duration of your stay; and

-        the site that you visit after you leave the website as well as the type of device, operating system and web browser that you use.

If your device is equipped with the ability to determine its precise geographic location, and if it has been configured to do so, your device will transmit its location to our servers in real time at any time that the website is open. This will occur even if you are not actively using the website, or if it is minimised on your device, and will occur until you configure your device so that it doesn’t do so.

2.2  Registering By You

Registration is required to:

-        use any of our applications; and

-        take advantage of some of the features and functions offered on our online properties.

For example, registration is required if you wish to post content or make purchases using our online properties. If you decide to register, you will need to provide personal information to us. There are different ways to register with us. You may choose to register by providing us with the details of a social media account (such as a Facebook or Google+ account) that is owned or controlled by you.

When registering, the information that you will be asked to provide includes:

  • your name;
  • your email address;
  • your username for a social media site;
  • a photograph or other image of you;
  • your mobile number;
  • your physical address or alternatively, your postcode;
  • date of birth;
  • gender;
  • phone number;
  • email address; and
  • optionally, the name and date of birth of any children for whom you are responsible.

When registering, you have the options to:

  • identify yourself, or the children for whom you are responsible, by a pseudonym; and
  • enter a fictitious date of birth for the children for whom you are responsible.

However, if you choose to do this, you may find it difficult to make bookings through us with our Providers.

2.3  Using Our Applications

We may capture personal information about you if you download and use any of our applications. This data may include:

-        the pages, content or ads that you see or click during your visit;

-        search terms that you enter in the application;

-        the items that you download;

-        your location (if you allow the application to access this data);

-        the time that you visited the website and the duration of your stay; and

-        the site that you visit after you leave the website as well as the type of device, operating system and web browser that you use.

2.4  Nomination of Your Details By Others

Our applications enable users to enter the details of children for whom they are responsible. This enables those users to identify suitable Providers and activities more readily than they otherwise would be able to do. If you are a child, this may involve your personal information (including your name and email address or other contact details) being provided to us by persons known to you rather than by you directly.

We offer a ‘Refer a Business’ function which enables users to nominate the details of businesses which may be suitable to become Providers. If a third party nominates you using this function, this may involve them providing us with your personal information.

2.5  Enquiries And Information From You

You will need to provide personal information to us if you choose to send a request to us via our ‘contact us’ form. The information that you will need to provide will include a name, and one or more means to contact you (whether by telephone, email address, instant messaging, or skype or other media).

2.6  Reviews

We offer users the ability to post ratings and reviews of the Providers they choose, and activities in which they participate. If you choose to post such reviews, the reviews you provide may include personal information.

2.7  Conducting Transactions

We collect further personal information if you conduct transactions on our online properties, including credit card and other payment information, transaction history, and information about your actual and proposed performances.

2.8  Partnering

We have established partnerships with service providers such as ad network providers, web analytics companies, and social media sites. We may also sponsor content which is hosted by other parties. These organisations may hold your personal information, and they may pass this information on to us.

2.9  Other

We may collect information for purposes not listed above in the following circumstances: (i) where the use is related to one of the primary purposes listed above and where it could reasonably be expected; (ii) where it is necessary for us to comply with the law or the lawful direction of a governmental authority or court; or (iii) where it is in the interests of public health and safety.


We will only store and use your personal information for the purposes set out in this Clause, and not for any other purpose.

3.1   Responding To Your Actions And Requests

We may use your personal information to respond to specific actions and requests by you, including administering your account with us, answering queries that you submit to us, processing your transactions and fulfilling your orders.

3.2  Providing You With Information And Offers

We may use contact information provided by you to provide offers and promotional information from the Providers, the products and services they offer, as well as companies and events sponsored by us and others that we think may interest you.

3.3  Coordinating With Providers Chosen By You

If you choose to participate in the events or activities that are offered by the Providers, then we may disclose personal information to those Providers in order to assist in the coordination of your participation with those Providers.

3.4  Announcements And Direct Communications

We may also use information to send announcements, including service-related notifications, and messages received from the Providers.

You have the right to opt-out of such information as detailed in Section 5 below.

3.5  Displaying Or Delivering Your Content To Others

If you submit personal information to us which is part of the content that is intended to be displayed on our applications or online properties, then we will display that content. We may also disclose your personal information to other people nominated by you if you decide to utilise our ‘Email-A-Friend’ functionality.

3.6  Sending Messages To You At The Request Of Others

If someone known to you utilises our ‘Email-A-Friend’ functionality to send a message to you, then this will involve us collecting your personal information from someone other than you.

3.7  Displaying Advertisements To You

Except to the extent that you exercise your right to ‘opt out’ as discussed in Section 5 below, we may use your personal information and the usage information from our online properties to help us display advertisements that are customised to your interests. We may use third party ad servers and networks to administer this functionality. This may involve us showing advertisements of third parties when you are visiting our online properties, and advertisements of our business being shown to you when you visit third party websites.

3.8  Providing Localised Content To You

We may use any location information that we capture from your devices to present you with information based on your location, including maps for events and activities that are taking place near you.

3.9  Helping Us To Understanding You And Our Other Users

We use your information to generate a holistic picture of our individual users and also of our user base as a whole. For example, we may use information that we collect to assess your level of interest in, and use of, our applications, the online properties, our emails and our other messaging campaigns, both on an individual basis and in aggregate.

In doing so, we may combine personal information collected from third parties as well as information gathered directly by us. This information allows us to analyse trends and demographics which helps us to improve upon and add to the services, features and functions that we provide, to provide you with a more personalised service, including personalised offers.

3.10 Managing Our Day-To-Day Business Operations

As with nearly all businesses, we keep business records including keeping details of transactions for operational purposes including enabling us to comply with tax and audit requirements and assisting with quality control. We also use non-personally identified information (which may be linked with personal information) to help to diagnose problems with our servers.

3.11 Securing And Protecting Our Rights And Systems

We may use your personal information to protect our systems and rights (including intellectual property rights), to exercise or defend a legal or equitable right (including recovering debts), prevent fraud. If we believe that the security of your account password or your information in general has been compromised, then (subject to your right to opt-out of such communications) we may notify you of this by email.

3.12 Co-Operating With Third Party Partners

We use third party partners such as third party ad networks, payment processors, web analytics companies, and social media and networking platforms, and as part of their service, we allow some of these partners to collect information about your online activities over time and across our online properties, including the website.

3.13 Transferring Our Business Assets

At some point in the future, we may decide to transfer or sell the assets of our organisation. This may be as a result of an acquisition, merger, sale or liquidation, or the re-organisation or consolidation of our corporate group. Our user database would be included in this sale or transfer. The new owners would also be bound by the terms of this Policy unless you reach a separate agreement with them. We would not sell our customer or user database separately from our other assets.

3.14 Other

We may also disclose your personal information where required or necessary under the provisions of the Privacy Act 1988 (Cth) (e.g. if it is necessary to prevent a serious threat to public safety, or if it is required by a court order etc).


During the course of our business, we may disclose your personal information to third parties as set out in this Section 4.

4.1   Providers

We may provide your details to Providers of activities or events where this is necessary to coordinate the participation of your child or children in those activities or events.

4.2  Sub-Contractors

Third party companies and individuals may be engaged from time to time to perform specific business services for us, including operating the applications or the website. These services include software and web developers, server hosts, data management companies, address list hosting companies, e-mail service providers, third party ad servers and network providers; analytics companies, distribution companies, fulfillment companies and payment processors. We may need to provide some of your details to these services providers in order for them to perform their functions.

4.3  Related Companies

We have close business relationships with our related companies. We may share your personal information to enable us to combine our operations and build a picture of our global user base. The website is administered by one of our related companies.

4.4  Co-Sponsors

If we obtain your information in connection with a contest, trade promotion lottery, sweepstake, or other promotional activity that is jointly offered by us and another party (i.e. a ‘co-sponsor’), then we will disclose your personal information to our co-sponsor unless you instruct us not to do so by opting out in accordance with Section 5 below.

4.5  Third Party Marketers

With your consent, we may provide you with offers from third parties who offer products and services that might be of interest to you, and we will do so by sharing your personal information (usually your name and contact details) with such third parties. If you opt in to accept such communications, but then change your mind, you may opt out at any time as discussed in Section 5 below.

4.6  Credit Agencies

We may provide your information to credit agencies in connection with late payments, missed payments, or other defaults on your account.

4.7  Court Orders

We may disclose your personal information to comply with court orders including orders for discovery and subpoenas.

4.8  Law Enforcement Authorities ETC

We will pass on information relating to suspected fraudulent or other illegal activity to the appropriate law enforcement authorities including the police. If we deem it necessary to protect our own legal or proprietary interests, we may also disclose your personal information to other companies and agencies including our lawyers and investigators.

4.9  Transfer Of Assets

As detailed above, we might decide to transfer our user database as part of a going concern to a new owner. We would ensure that this owner would also be bound by this Policy unless you reach a separate agreement with them.

4.10 The World At Large

If you choose to post information (including reviews) on any of the applications or the online properties this information may be posted on our online properties for all other users to see. If the information includes personal information (e.g. your name) then this will become personal information.


5.1   Precise Location Information

You may opt-out from further allowing us to have access to the precise location information provided by your device by configuring that device so as not to share its location with us. If you choose to do this, you will need to enter your location of interest manually when conducting searches for events or activities using the applications or the website, and certain other features and functions of our online properties may not work properly. Even if you do this, then we may still capture rough location information based on the IP address used by your device.

5.2  Usage Data

You may opt-out from allowing certain clickstream data from being included in our Google analytics reports by following the instructions at: You may also opt-out from allowing us to use cookies by following the information available at:

Some web browsers may transmit ‘do-not-track’ or ‘DNT’ signals to us. There are differences in how web browsers incorporate and activate this feature, so it is not always clear whether users intend for these signals to be transmitted. Further, there are no industry standards concerning what websites should do when they receive such signals. Accordingly, we do not currently change our tracking practices in response to DNT settings in your web browsers, and we do not require third party partners to do so. We will review this position if and when a final standard is established and accepted.

5.3  Internet-Based Advertising

You may opt to prevent us from using personal information to display interest-based advertising. To do this, follow the instructions made available by:

•    Network Advertising Initiative (; or

•    Digital Advertising Alliance (

You must do this on each of your browsing applications separately. Even if you complete the above steps, we may still suggest offerings to you based on the history of your usage of the website.

5.4  Promotional Emails From Us

If you have opted to receive email communications from us, you may change your mind by clicking on any ‘unsubscribe’ link within any email that you receive.

If you opt out of receiving promotional emails from us, we may still contact you in connection with your relationship, activities, transactions and communications with us, and may still provide promotional messages to you through the messaging system on any of our applications or online properties.

5.5  Third Party Promotional Emails

If you want us not to share (or stop sharing) your personal information with third parties for their direct marketing use, please send us an email at: If you do request to have us stop sharing your personal information with other entities for their direct marketing purposes, please note that we are not responsible for any communications that you may receive from entities that received your personal information prior to the date of your request. In these cases, please contact that entity directly.

5.6  Other Emails

If you do not wish to receive emails from us for other purposes, including purposes associated with the administering or securing of your account, then please contact us at


The disclosures of information listed in Section 4 above may involve transmitting, storing or processing information across national borders for a number of reasons and purposes. When we do so, we will take reasonable steps to ensure that the overseas recipient handles the information in accordance with your rights under Australian law.

We have the right to host personal information on servers located in the United States or another country outside of Australia.

We have the right to provide personal information to third party service providers pursuant to our contracts with those suppliers as detailed above, and some of these are located outside of Australia.

We have the right to provide personal information to overseas recipients where necessary to perform contracts with you.

The sharing of personal information with the related companies may also involve the transmission of that data overseas.

The provision of personal information to third party purchasers of our business.

You consent to the transmission of data for all of these purposes.


If you voluntarily provide us with unsolicited personal information (for example, if you send us an unsolicited resume), then we will assess whether the holding of the personal information could have been collected by us if it had been solicited by us. This requires us to consider whether collecting the information would be ‘reasonably necessary’ for one of our functions or activities. 

If the information could have been collected by us, then we will deal with it in accordance with this Policy.

If the information could not have been collected by us, then we will destroy or de-identify the information as soon as practicable providing it is lawful and reasonable for us to do so.


8.1   General Obligation

We will take reasonable steps to ensure that the personal information that we hold about you is accurate, complete and up-to-date.

8.2  Viewing

Subject to the exceptions allowed by law, you have a right to view, change and remove the personal information that we store about you.

8.3  Updating Information Yourself

You may review, update or modify certain of the information that is associated with any account that you create or maintain on the website by logging into the ‘My Account’ or similar area of the website

8.4  Requests For Us To Change Or Update

If you are able to establish that your personal information is not accurate, complete or up-to-date, then we will take reasonable steps to update that information. If we disagree about the accuracy, completeness or currency of this information, then we will include a statement to this effect if you request us to do so.

Requests for us to assist you to view, change or remove your personal information, should be made in writing to We have the right to ask you to verify your identity and to provide us with any details necessary to enable us to comply with your request, including your name and the capacity in which you believe we are storing your personal information (i.e. as a customer, newsletter subscriber etc).

8.5  Intermediaries

If we deny your right to access to the information directly, we will consider the option of using mutually agreed intermediaries to allow sufficient access to meet both your needs and our needs.

8.6  Administrative Charges

If you ask us to attend to your request, we have the right to request a small fee before we can assist you. This is a fee for answering your request, and not for making the request. Before we act on requests of this nature, we will tell you how much this service will cost, and we undertake that this charge will not be excessive. We will respond to your request within 10 business days.

8.7  Right To Receive Reasons

If we refuse to give access, or correct personal information, then we will provide you with our written reasons for doing so (unless this would be unreasonable) and the mechanisms available to complain about the refusal.

8.8  Limit On Right To Delete

Your right to delete your information is subject to our obligations under law to keep records for other purposes, including tax purposes.

8.9  Sources of Information

Finally, in addition to the above, you may also request details of the source of the personal information that we hold about you. We have the right not to disclose the source of information if it is impracticable or unreasonable for us to have to do so, but if we do provide that information to you, then there will be no charge.


We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information, and to prevent unauthorised access, modification or disclosure of your personal information.

We will take reasonable steps to ensure that the personal information is deleted or de-identified if it is no longer required for any purpose for which it may be used or disclosed, and if we are not under legal obligations to retain it.

Due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information will be absolutely safe during transmission through the Internet, while stored on our systems or while otherwise in our care.

If you contact us via email, via a messaging feature or through a ‘contact us’ or similar on our website you should be aware that your transmission might not be secure. A third party could view information you send by these methods in transit. We have no liability for disclosure of your information due to errors or unauthorised acts of third parties during or after transmission.


The website is intended solely for users who are thirteen years of age or older. We do not knowingly collect personal information from users who are under 13 years of age without prior parental consent. If you are under the age of 13 years, please do not provide personal information of any kind whatsoever. If we learn that we have received personal information from a child under the age of 13, then we will take steps to delete such information or to obtain verifiable parental consent.


If you are a registered member, please sign out once you have finished using our website and close your browser (e.g. Internet Explorer, Mozilla Firefox or Apple Safari). This ensures that no one else can access your personal information after you.

You are responsible for the security of, and access to, your computing device. There are particular risks when you use a public computer (such as at an Internet cafe), or unsecured wireless connection (such as in a restaurant or shopping centre).

You are responsible for maintaining the secrecy of your username, password and any account information.

Further privacy information can be obtained on the website of the Australian Privacy Commissioner, which can be found at:


If you wish to make a complaint about how we handle your personal information, then you must make it in writing to us using the contact details in Section 1 above. You must provide us with sufficient information about the nature and basis of your complaint to enable us to understand it, and the details of the resolution or action sought by you. We will investigate your complaint and respond to you within 30 days.

If you are not satisfied with the response to your complaint, or if (for whatever reason) we have not responded to you within 30 days, then please inform us of this fact. You may have the right to lodge a complaint with the Office of the Australian Information Commissioner (OAIC).


13.1 Definitions

In this Policy, the following words have the following meanings:

Application’ means any software application designed to advertise events and activities suitable for kids, which is commercialised by us under any trade mark, regardless of whether it is distributed through a third-party service (such as the App StoreTM, or Google Play StoreTM), or directly by us.

Content’ means all text, graphics, images, video, sound and other data displayed on, or made available from, any application or the website.

Online properties’ means the website and any other websites and social networking platforms which we use to promote or administer any application.

Personal information’ means information that identifies you or could be used to identify you.

Provider’ means any business that presents activities or events designed to entertain or educate children, and which is featured on any application or any of the online properties.

Related companies’ means any company which would be regarded as a ‘related body corporate’ under section 50 of the Corporations Act 2001 or the Privacy Act 1988.

Trade mark’ means any mark, whether registered or unregistered mark, which features or includes the words ‘NRichKids’, including the domain name

Website’ means the website located at the domain ‘’ and on all sub-domains, folders and sub-folders of that domain.

14    Interpretation

This Policy is governed by the following rules of interpretation:

A reference to ‘we’, ‘us’ or ‘our’ is a reference to GHES International Pty Ltd 84 619 589 927.

A reference to ‘you’, or ‘your’ is a reference to you as an end user of any of our online properties and any application.

A term defined in the singular has the corresponding meaning when used in the plural, and vice versa.

A reference to a person includes a reference to a group of persons or an incorporated body.

A reference to ‘this Policy’ is a reference to this document, and any document incorporated by reference.