1.1 Ewings LLC ("We", "Us", "Our"), an entity incorporated under the laws of the United Arab Emirates, with its principal place of business at U-Bora Tower, 24th Floor, Dubai, United Arab Emirates, is committed to protecting and respecting Your privacy.

We may make certain digital services available to users located in Australia via third-party application platforms, including Apple App Store and Google Play. Where We collect or process personal information relating to individuals in Australia, We will do so in accordance with applicable Australian Privacy Principles (APPs 1-13) under the Privacy Act 1988 (Cth), the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data ("UAE PDPL"), and, where applicable, the UK General Data Protection Regulation ("UK GDPR").

1.2 This privacy policy explains what personal information We collect from individuals ("You", "Your") who use Our services, products, applications, and Websites (Our "Services"). It also explains what information We collect automatically when You interact with Our Services, why We collect it, the purposes for which it is collected, and how it will be used and disclosed.

1.3 Ewings LLC is the entity and information handler responsible for Your personal information in accordance with the Privacy Act 1988 (Cth). You may contact Our Privacy Officer at privacy@ewings.com if You have any questions about this Privacy Policy or wish to exercise Your rights.

1.4 As an entertainment-led business, We prioritize the quality, confidentiality, integrity, and availability of the information We hold and are committed to meeting Our information protection obligations when processing personal information. We employ a variety of technical and organizational measures to help protect Your personal information from unauthorized access, use, disclosure or loss, including encryption, access controls, secure storage, and regular security assessments.

1.5 We update this privacy policy from time to time in response to changes in applicable laws and regulations, to Our processing practices, and to the products and services We offer. When We make material changes to this privacy policy, We will notify You via In-Game Notifications. Please review this privacy policy periodically to check for updates.

2.1 Personal information under the Privacy Act 1988 means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether recorded in a material form or not. Under the UAE PDPL, Personal Data means any data relating to an identified or identifiable natural person. Under the UK GDPR, Personal Data means any information relating to an identified or identifiable natural person. We collect personal information that You give Us, whether through interactions with Our Services, Our website, or by any other form of correspondence. Where it is reasonable and practicable to do so, We will collect personal information directly from You (APP 3.6). Where We collect personal information about You from third parties, We will take reasonable steps to notify You of that collection in accordance with APP 5, UAE PDPL requirements, and UK GDPR requirements.

2.2 Information You provide to Us

The categories of personal information We collect and hold include (but are not limited to):

Contact details (title, name, residential or business address, email address, phone number)

Date of Birth

Any information You share through Our social media channels (including posts, comments, messages, and profile information that You make publicly available or share with Us)

2.3 Registration via Google

2.3.1 You may register for and access the application using Your Google account. If You choose this option, We will receive certain information from Google necessary to create and manage Your account, such as Your name, email address, and profile picture (if applicable). This information is provided in accordance with Google's privacy policy. By choosing to register via Google, You consent to Our collection and use of this information for the purposes described in this privacy policy. We collect this information from Google (a third party) because it is reasonably necessary for Our functions and activities in providing the application to You. We do not receive or store Your Google account password.

2.3.2 By registering via Google, You authorize Us to use the information provided by Google for the purposes of account creation, authentication, and the provision of the application in accordance with this privacy policy. You may revoke this authorization at any time through Your Google account settings or by contacting Us directly using the contact details in clause 1.3; however, doing so may limit or prevent Your ability to access the application, as this information is reasonably necessary for Us to provide the Services to You.

2.3.3 By registering for Flier via Google:

2.3.3.1 You represent and warrant that all information provided through Your Google account is true, accurate, current, and complete, and You accept full responsibility for ensuring its accuracy and for promptly updating it where necessary;

2.3.3.2 You acknowledge that We are entitled to rely on the information provided through Your Google account without any obligation to verify its accuracy;

2.3.3.3 You agree that any loss, liability, or damage arising from the provision of false, inaccurate, or incomplete information shall be solely Your responsibility; and

2.3.3.4 You acknowledge that if You revoke Our access to Your Google account or if Your Google account is suspended or terminated, this may limit or prevent Your ability to access the application.

2.4 Information We collect about You when You use Our Services

When You use Our Services, We may collect:

Device details (including device identifiers, operating system information, and browser type)

Login information and credentials

Service usage data including interactions, preferences, and time spent using Our Services

Location data (approximate location based on IP address, or precise geolocation data only with Your express consent where We have explained why We need this information and how it will be used)

Information required for legal and regulatory compliance, including identity verification documents (such as driver's license or passport details) where required by law or reasonably necessary for Our functions and activities

2.5 We may use cookies and similar tracking technologies to personalize the user experience of Our Services, which may be disabled at any time using the privacy settings in Our Services or on Your device. Where cookies collect personal information, We will only use them where You have consented (which may be provided through Your browser settings) or where their use is reasonably necessary for Our functions and activities. You can withdraw consent at any time by adjusting Your privacy settings or browser settings, though this may affect Your ability to use certain features of Our Services.

2.4 Our Services are not directed to individuals under the age of eighteen (18). We do not knowingly collect personal information from individuals under 18 years of age. Where individuals aged less than 18 use the Services, personal information will be processed in accordance with applicable law. If it becomes apparent that personal information has been collected from a person under 18 without appropriate authority, reasonable steps will be taken to delete that information as soon as practicable.

3.1 We will only use and disclose Your personal information for the purposes for which it was collected (the primary purpose), or for a related secondary purpose that You would reasonably expect, or with Your consent, or as otherwise permitted or required by law (APP 6). The purposes for which We use and disclose Your personal information include:

To provide, maintain, and deliver Our Services to You in accordance with Our terms and conditions, including account creation, authentication, and service functionality (primary purpose of collection under APP 6.1)

Providing information on Your account, such as transaction history, rewards, and trends (primary purpose of collection)

Prevention and detection of crime, including money laundering, fraud, or other crimes (legal obligation and legitimate interests)

Compliance with sector-specific laws, regulations, and guidelines (legal obligation)

Providing you with updates about Our Services, additional features, and exclusive promotions (with Your consent, which may be withdrawn at any time). You may unsubscribe or opt out of receiving marketing communications from Us, including email and WhatsApp promotional material, at any time by following the "unsubscribe" or "opt-out" instructions provided in such communications or by adjusting Your preferences in the Application. Please note that opting out of marketing communications will not affect Our ability to send You non-marketing communications related to Your account, the application, or transactions You have initiated.

Improving Our Services and the overall user experience.

Ensuring maintenance of a secure connection between Our Services and Your device.

Initiating action against any User who acts outside any laws, regulations, or Our Terms and Conditions.

3.2 Where personal information is processed because it is necessary for the performance of a contract to which you are a party, We will be unable to provide Our Services without the required information. Where processing is based on consent, You have the right to withdraw consent at any time by contacting Us using the details provided below.

4.1 As a UAE-based entity, personal information collected from You in Australia will be transferred to and processed in the United Arab Emirates. Additionally, Your personal information will be transferred to and stored in the United Kingdom by Our third-party service providers who provide data storage and processing services on Our behalf. We may also share Your personal information with other recipients located in countries outside Australia, the UAE, and the UK. Before disclosing Your personal information to overseas recipients, We take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to Your personal information. Under the UAE PDPL, We ensure that cross-border transfers comply with applicable requirements, including adequacy assessments, binding contractual arrangements with appropriate safeguards, or Your explicit consent. Our UK-based service providers are subject to the UK General Data Protection Regulation (UK GDPR), which provides robust data protection standards. We ensure appropriate technical and organizational safeguards are in place through contractual arrangements with these recipients. By using Our Services, You acknowledge and consent to the transfer of Your personal information from Australia to the UAE, the UK, and You acknowledge that We remain accountable under Australian law for the handling of Your personal information by Our overseas recipients.

4.2 We may share Your information with service providers and suppliers, based in Australia, the United Arab Emirates, the United Kingdom, and other countries outside Australia, who process information on Our behalf, including but not limited to cloud service providers (including UK-based data storage providers), payment processors, analytics providers, and customer support services. In such cases, Our service providers and suppliers are information processors and may only use the information in line with Our instructions and not for any other purpose. We maintain appropriate contracts with these parties that require them to comply with the Australian Privacy Principles, UAE PDPL requirements, and applicable data protection laws in their jurisdictions (including UK GDPR for UK-based providers).

4.3 Our Services include links to Our social media pages, enabling You to view Our content through selected sites. These applications may collect Your IP address or device ID and may set a cookie on Your device. Please read the privacy policies provided by the particular social media Website You are sharing through before posting any personal information using these links, as We are not responsible for how these third parties collect or handle Your information.

5.1 Under the Privacy Act 1988 and the APPs, the UAE PDPL, and any other applicable data protection and privacy laws, You have certain rights in relation to Your personal information, including to:

Request access to personal information about You. We will respond to Your request within 30 days and provide the information in a clear and accessible format

Request rectification, correction, or updating to any of the personal information that We hold about You. We will respond to correction requests within thirty (30) days

Request personal information provided by You to be transferred in machine-readable format

Request erasure of personal information (subject to legal retention requirements and legitimate business needs)

Request the restriction of processing of Your personal information

Object to the processing of Your personal information in certain circumstances

5.2 If at any time You decide that You no longer wish to be contacted for marketing purposes, or if You would like to exercise any of Your rights as set out above, You can contact Us at privacy@ewings.com. To protect Your privacy, We may require verification of Your identity before responding to such requests. You will not have to pay a fee to access Your personal information (or to exercise any of Your other rights under the Privacy Act 1988 (Cth)). However, We may charge a reasonable fee if Your request for access is clearly unfounded or excessive.

5.3 In addition to the above, please note that You have the right to make a complaint at any time to the Office of the Australian Information Commissioner (OAIC) under section 36 of the Privacy Act 1988 (Cth) if You are concerned about the way in which We are handling Your personal information. The OAIC can be contacted at www.oaic.gov.au, by phone on 1300 363 992 (within Australia), or by email at enquiries@oaic.gov.au. You may also file a complaint with the UAE Data Office if You believe We have breached the UAE PDPL. We encourage You to contact Us first to resolve Your concern.

5.4 Where a User submits a request to unsubscribe from marketing communications, We will use Our best endeavours to process and record unsubscribe requests, as soon as possible, however you may continue to receive information for campaigns currently in process. While you may unsubscribe from Marketing communications, You will continue to receive necessary transactional communications.

6.1 We will retain Your personal information only for as long as is necessary for the purposes set out in this Privacy Policy, or as required or authorized by law, in accordance with APP 11.1 of the Privacy Act 1988 (Cth).

Specifically, We retain:

Account information for the duration of Your account plus seven (7) years following account closure, unless a longer retention period is required by law

Transaction data for seven (7) years to comply with tax, financial and Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) laws and regulations

Communications with Our customer service team for three (3) years

Marketing preferences for two (2) years from Your last interaction with Us, or until You withdraw consent, whichever occurs first

When a retention period ends, We will take reasonable steps to securely destroy or de-identify the information in accordance with APP 11.2 of the Privacy Act 1988 (Cth)

6.2 In some circumstances, We are legally obligated to retain information for longer periods to comply with legal obligations under Australian law, UAE law, and UK law, including but not limited to crime prevention, anti-money laundering requirements under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), tax regulations, or other specific legal requirements in the jurisdictions in which We operate.

6.3 At the end of the retention period, Your personal information will be securely deleted or de-identified in accordance with APP 11.2 of the Privacy Act 1988 (Cth), the UAE PDPL, and the UK GDPR. Our destruction methods ensure that information cannot be recovered or reconstructed.

You can contact Us in relation to information protection and this Privacy Policy by:

Email: privacy@ewings.com