Legal

Privacy Policy

How we collect, hold, use and disclose your personal information.

Last updated: 4 September 2026

Issued by SLR Life Pty Ltd trading as Smart Life Rewards (SLR), Australia. ABN 99 696 467 473. Business address: 28 Welcome Parade, Wyndham VIC 3024, Australia.

Privacy & customer support email: [email protected]

1. Definitions

In this Privacy Policy:

SLR”, “we”, “our” or “us means SLR Life Pty Ltd trading as Smart Life Rewards (SLR).

Platform means the SLR website, mobile applications, Member portals, membership systems, promotional systems and associated services.

Member means a person registered with SLR who holds an eligible Red Membership, Blue Membership, or both. “Red Membership” and “Blue Membership” encompass all associated subscription sub-tiers offered by SLR (including, but not limited to, Standard, Plus, Premium, and Elite levels).

Paid Member means a Member holding an active paid Red or Blue Membership.

Member Account means the single personal SLR account established for a registered individual and identified through the person’s registered details and unique SLR Member ID.

Personal Information has the meaning given under the Privacy Act 1988 (Cth) and generally includes information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Promotional Activities means daily, weekly, monthly, bonus and special promotions, Promotional Draws, giveaways, promotional rewards, Spin Wheel activities, referral promotions, Member benefits and other promotional campaigns conducted or administered by SLR.

Promotional Draw means an SLR daily, weekly, monthly, bonus or special promotional game-of-chance activity.

Entry means a promotional participation allocation associated with an eligible SLR Membership level or Promotional Activity, as described in the applicable SLR Terms or Promotion Schedule. Each eligible Entry represents the promotional chance specified in that Promotion Schedule.

Prize Pool means the stated total value of prizes allocated to the promotion, period, Membership category or combination of promotional activities identified by SLR.

Promotion Schedule means the specific terms and conditions applying to an individual SLR promotion.

Spin Wheel means an optional promotional feature through which an eligible Member may receive a Membership reduction, promotional benefit, bonus or other displayed outcome.

Partner means an independent business or service provider whose product, discount, service or benefit may be made available through SLR.

Third-Party Providers means external businesses or service providers engaged or used by SLR, including payment processors, hosting providers, software providers, communications providers, analytics providers, benefit providers and promotional administration providers.

2. Purpose of this Privacy Policy

This Privacy Policy explains how SLR collects, holds, stores, uses, manages and discloses Personal Information connected with:

  • Red Membership;
  • Blue Membership;
  • Members participating in both Red and Blue Membership;
  • SLR Member Accounts;
  • Website and application use;
  • Promotional Activities;
  • Daily, weekly and monthly Promotional Draws;
  • Bonus and special promotions;
  • Promotional Entries;
  • Prize Pool administration;
  • Prize and winner administration;
  • Promotional odds and participation calculations;
  • Spin Wheel activities;
  • Referral and tag-a-friend promotions;
  • Member savings and benefits;
  • Grocery-related benefits and rewards;
  • BENY and other third-party Member benefits;
  • Partner discounts and offers;
  • Subscription and billing services;
  • Customer support;
  • Community initiatives; and
  • Other associated SLR products and services.

SLR intends to handle Personal Information in accordance with applicable Australian laws and regulatory requirements, including where applicable the Privacy Act 1988 (Cth), the Australian Privacy Principles, the Notifiable Data Breaches scheme, the Spam Act 2003 (Cth), Australian Consumer Law, applicable promotional and trade-promotion requirements, and other applicable Australian laws.

Use of the Platform is subject to this Privacy Policy and other applicable SLR Terms & Conditions.

3. Information we may collect

SLR may collect Personal Information where reasonably necessary for its functions, activities, Membership services, Promotional Activities, security, legal obligations and business operations.

3.1 Identity information

  • Full name;
  • Date of birth;
  • Age-verification information;
  • Residential address;
  • State or territory;
  • Postcode;
  • Identity-verification information where reasonably required; and
  • Unique SLR Member ID.

3.2 Contact information

  • Email address;
  • Mobile telephone number;
  • Residential or postal contact information;
  • Communication preferences;
  • Marketing preferences; and
  • Customer-support correspondence.

3.3 Member Account & Membership information

  • Red Membership status;
  • Blue Membership status;
  • Whether a Member participates in Red, Blue or both Membership tiers;
  • Membership plan or level;
  • Membership commencement dates;
  • 28-day Membership Cycle information;
  • Subscription and payment status;
  • Membership upgrade information;
  • Membership downgrade information;
  • Cancellation information;
  • Member-benefit eligibility;
  • Partner-benefit access;
  • Membership activity history; and
  • Account status.

3.4 Promotional & Entry information

  • Entry allocations;
  • Promotional entries;
  • Red promotional participation;
  • Blue promotional participation;
  • Daily, weekly and monthly Promotional Draws;
  • Bonus promotions;
  • Special promotions;
  • Spin Wheel participation;
  • Referral and tag-a-friend promotions;
  • Promotional codes;
  • Promotional eligibility;
  • Closing-time eligibility;
  • Promotional participation history;
  • Prize Pool administration;
  • Number of promotional opportunities;
  • Entry verification; and
  • Records used to calculate or verify published promotional odds.

3.5 Prize & winner information

  • Prize claim information;
  • Winner-verification information;
  • Identity information;
  • Age-verification information;
  • Residential and state eligibility information;
  • Membership status;
  • Entry validity;
  • Payment status where relevant;
  • Bank account or PayID information required for prize payment;
  • Winner-notification records;
  • Prize-payment records;
  • Prize-delivery information;
  • Information required for legally required winner publication, auditing or reporting; and
  • Information used for promotional winner announcements (for example, publishing a winner's first name and last initial on social media or email).

3.6 Billing & payment information

  • Stripe transaction references;
  • PayPal transaction references;
  • Billing references;
  • Membership-payment status;
  • Successful-payment records;
  • Failed or declined-payment information;
  • Refund references;
  • Chargeback or payment-dispute information;
  • PayID information where applicable; and
  • Limited payment-verification information.

SLR does not ordinarily receive or store complete credit-card details where those details are securely processed and stored by an authorised payment provider.

3.7 Member benefits, discounts & Partner information

  • Member-benefit eligibility;
  • Discount access;
  • Partner offers;
  • BENY or other third-party benefit access;
  • Voucher or grocery rewards;
  • Promotional rewards;
  • Merchandise;
  • Community benefits;
  • E-books, guides, and digital content access; and
  • Other SLR benefits.

3.8 Technical & Platform information

  • Device information;
  • Browser type;
  • IP address;
  • Approximate location derived from technical information;
  • Website and app usage;
  • Login records;
  • Cookies;
  • Analytics information;
  • Security events;
  • Referral-source information;
  • Session information; and
  • Platform-performance information.

SLR will not intentionally collect precise device-location information unless reasonably required for a feature and an appropriate notice, permission or consent process is provided where required.

4. How personal information is collected

SLR may collect Personal Information directly from individuals when they:

  • Create an SLR Member Account;
  • Join Red Membership;
  • Join Blue Membership;
  • Hold both Red and Blue Membership;
  • Purchase or renew Membership;
  • Upgrade or downgrade Membership;
  • Cancel Membership;
  • Use the SLR website, app or Member portal;
  • Participate in Promotional Activities;
  • Receive or use Entries;
  • Participate in Promotional Draws;
  • Use the Spin Wheel;
  • Use referral, tag-a-friend or promotional codes;
  • Submit forms;
  • Contact SLR;
  • Request customer support;
  • Claim prizes or rewards;
  • Access Partner benefits;
  • Respond to email, SMS or Platform communications; or
  • Interact with cookies, analytics or security technologies.

SLR may also receive Personal Information from Third-Party Providers where reasonably necessary to administer Membership, payments, Promotional Activities, Promotional Draws, Member benefits, identity verification, winner verification, fraud-prevention processes, customer communications, or legal and regulatory compliance.

5. Purposes of collection, holding, use & disclosure

SLR may collect, hold, use or disclose Personal Information for purposes including:

  • Establishing and administering Member Accounts;
  • Administering Red Membership;
  • Administering Blue Membership;
  • Administering Members who hold both Red and Blue Membership;
  • Managing 28-day Membership Cycles;
  • Processing Membership payments;
  • Managing payment failures;
  • Processing cancellations and refunds;
  • Managing upgrades and downgrades;
  • Allocating Entries;
  • Recording promotional entries;
  • Administering Promotional Draws;
  • Confirming promotional eligibility;
  • Administering daily, weekly and monthly Promotional Draws;
  • Administering bonus and special promotions;
  • Calculating and administering Prize Pools;
  • Calculating, verifying and publishing promotional participation figures and odds;
  • Selecting and verifying winners;
  • Paying or delivering prizes;
  • Administering Spin Wheel activities;
  • Administering referral and tag-a-friend promotions;
  • Providing discounts and Member benefits;
  • Providing BENY or other third-party benefits;
  • Administering Partner offers;
  • Sending necessary operational communications;
  • Providing customer support;
  • Detecting fraud or account manipulation;
  • Preventing duplicate-account abuse;
  • Protecting Platform security;
  • Maintaining audit and compliance records;
  • Improving SLR products and services;
  • Performing internal analytics;
  • Managing complaints and disputes;
  • Meeting legal and regulatory obligations; and
  • Sending marketing communications where permitted by law.

SLR may also use aggregated or de-identified information for business analysis, Platform improvements, promotional planning, statistical analysis, forecasting, prize planning and other legitimate business purposes, provided individuals are not reasonably identifiable from that information.

6. One person — one SLR Member Account

SLR generally operates on the basis of one person holding one SLR Member Account.

Subject to eligibility, one Member Account may hold:

  • Red Membership;
  • Blue Membership; or
  • Red and Blue Membership concurrently.

A Member does not need to create a second SLR account or provide a second email address merely to participate in both Red and Blue Membership.

Where a Member holds both Red and Blue Memberships, SLR may separately record information associated with each tier, including Membership status, Membership payments, Membership benefits, Entries, Promotional Draw eligibility and tier-specific entitlements.

For SLR’s unique individual Member count, a person holding both Red and Blue Membership generally remains one individual SLR Member unless a published statistic expressly measures Memberships, Membership tiers, Entries or tier participation rather than individual people.

SLR may use identity, email, telephone, payment, technical or other relevant information to detect and manage suspected duplicate accounts, fraud or misuse.

7. Promotional odds, member numbers & prize pools

SLR may use Membership and promotional participation information to calculate and publish information concerning the number of Members, Red and Blue Membership participation, the number and frequency of prizes, Prize Pools, the number of promotional Entries, promotional participation, promotional odds and annualised promotional probabilities.

Where annualised odds are calculated across the eligible Red and Blue Membership tiers, SLR may use relevant information concerning:

  • Number of eligible Members;
  • Valid Entries;
  • Red and Blue participation;
  • Number of prizes;
  • Frequency of prizes;
  • Applicable Promotional Draw periods; and
  • Whether an eligible Member may win more than once.

Where SLR publishes Membership numbers, odds or other promotional statistics to the public, SLR intends to use aggregated or de-identified information rather than identifying individual Members, except where identification is required for winner publication, required by law, necessary for prize administration or otherwise authorised. For promotional winner announcements on the SLR website, emails, or social media channels, SLR will generally only publish the winner’s first name and the first letter of their last name to protect their privacy.

An advertised overall SLR Prize Pool may include prizes allocated across:

  • Red Member promotions;
  • Blue Member promotions;
  • Daily Promotional Draws;
  • Weekly Promotional Draws;
  • Monthly Promotional Draws;
  • Bonus Draws; and
  • Special Promotions, where stated by SLR.

8. Third-party service providers

SLR may use Third-Party Providers including:

  • Stripe Australia;
  • PayPal;
  • TPAL Australia;
  • BENY or other Member-benefit providers;
  • SMS providers;
  • Email providers;
  • Website hosting providers;
  • Cloud-storage providers;
  • Website developers;
  • App developers;
  • Software-support providers;
  • Analytics providers;
  • Cybersecurity providers;
  • Identity-verification providers;
  • Professional legal advisers;
  • Accounting advisers;
  • Auditors; and
  • Compliance advisers.

Personal Information disclosed to a Third-Party Provider will generally be limited to information reasonably required for that provider to perform the relevant service. Third-Party Providers may have their own privacy policies, security arrangements, terms and legal obligations.

Where applicable, SLR will take reasonable steps required by Australian privacy law when engaging Third-Party Providers that handle Personal Information on SLR’s behalf.

9. Payments & electronic transfers

Membership payments may be processed through authorised third-party payment processors including Stripe, PayPal or another approved payment provider. Those providers may independently collect, process and retain payment-related Personal Information in accordance with their own privacy policies and terms.

SLR does not ordinarily store complete payment-card details where those details are handled by the relevant payment processor.

Where SLR pays a prize using PayID, electronic funds transfer or another banking method, SLR may collect information reasonably necessary to verify the winner, verify account ownership, process the payment and maintain appropriate payment records.

Members and prize recipients are responsible for ensuring payment and banking information they provide is accurate and current. SLR will take reasonable steps to address payment issues within its control but cannot guarantee the operation of independent banking or payment systems.

10. Cookies, analytics & digital technologies

SLR’s Platform may use cookies, analytics, session, device, security and similar technologies.

These technologies may be used for:

  • Website functionality;
  • Member login;
  • Account authentication;
  • Security;
  • Fraud detection;
  • Troubleshooting;
  • User-experience improvements;
  • Analytics;
  • Measuring marketing performance;
  • Platform development; and
  • Understanding how SLR services are used.

Users may be able to restrict certain cookies through browser or device settings. Disabling cookies may affect some Platform features. Where required, SLR may provide additional cookie notices or consent controls.

11. Marketing, email & SMS communications

SLR may send operational communications relating to Member Accounts, Membership, Membership payments, Membership renewals, security, Promotional Draw administration, prize notifications, Member benefits, customer support and important Platform information.

SLR may also send commercial marketing or promotional email, SMS or other electronic communications where permitted by applicable law. Where required, SLR will obtain or rely upon an appropriate form of consent before sending commercial electronic marketing.

Creating an account, making an enquiry or completing an isolated transaction does not automatically mean a person has agreed to receive every form of future SLR marketing.

Where required by law, SLR commercial electronic messages will:

  • Identify SLR or the authorised sender;
  • Provide appropriate sender or contact information; and
  • Provide a functional and reasonably accessible unsubscribe method.

SLR will process valid unsubscribe requests within the period required by applicable law.

Unsubscribing from marketing does not prevent SLR from sending necessary account, security, payment, Membership administration, prize or winner, or other service-related communications.

12. Disclosure of personal information

SLR may disclose Personal Information where reasonably necessary:

  • To payment processors;
  • To Promotional Draw administrators;
  • To Member-benefit providers;
  • To Partner service providers;
  • To hosting and software providers;
  • To communications providers;
  • To identity-verification providers;
  • To prize suppliers or delivery providers;
  • To legal advisers;
  • To accountants and auditors;
  • To compliance advisers;
  • To regulators;
  • To courts or tribunals;
  • To law-enforcement or government authorities where legally required;
  • In connection with an authorised corporate restructure, merger, acquisition, financing or sale; or
  • With the person's consent or where otherwise permitted by law.

SLR does not intend to sell Personal Information to unrelated third parties for those third parties’ independent marketing purposes.

13. Overseas disclosure & data storage

SLR primarily hosts and stores data within Australia (including via Digital Ocean Sydney). However, some Third-Party Providers used by SLR (such as payment processors and mailing services) may operate infrastructure, personnel or data-storage systems outside Australia.

Personal Information may therefore in some circumstances be processed, accessed or stored outside Australia. Where SLR is likely to disclose Personal Information to an overseas recipient, SLR will take reasonable steps required by applicable Australian privacy law.

The countries in which these overseas recipients are likely to be located include:

  • United States of America (for example, Stripe); and
  • European Union, including France (for example, Mailjet).

The specific countries may additionally depend on cloud-services providers, communications providers, analytics providers, payment providers, software providers and other Third-Party Providers used at the relevant time.

SLR will periodically review this section as its Third-Party Providers and data-hosting arrangements are confirmed or changed.

14. Data security

SLR intends to take reasonable administrative, technical and organisational steps to protect Personal Information from misuse, interference, loss, unauthorised access, unauthorised modification and unauthorised disclosure.

Security measures may include, where appropriate:

  • Access controls;
  • Authentication systems;
  • Password protections;
  • Secure payment processing;
  • Data-access restrictions;
  • Security monitoring;
  • Backup procedures;
  • Cybersecurity measures;
  • Vendor-management procedures; and
  • Staff and contractor access controls.

No internet-based or electronic storage system can be guaranteed to be completely secure.

Members should maintain secure passwords and login information and promptly notify SLR if they reasonably suspect unauthorised access to their Member Account.

15. Data breaches

SLR will assess suspected or known data breaches and take reasonable steps to:

  • Contain the breach;
  • Protect affected information;
  • Investigate the circumstances;
  • Reduce potential harm;
  • Remedy identified security weaknesses; and
  • Meet applicable legal notification requirements.

Where the Notifiable Data Breaches scheme applies and SLR experiences an eligible data breach, SLR will comply with applicable requirements concerning notification to affected individuals and the Office of the Australian Information Commissioner.

SLR may also notify relevant regulators, payment providers, service providers, insurers, professional advisers or law-enforcement authorities where required or reasonably necessary.

16. Data retention & deletion

SLR may retain Personal Information and related records for as long as reasonably necessary for Membership administration, payment administration, promotional administration, Entry records, prize administration, winner verification, fraud prevention, security, audit requirements, taxation and accounting requirements, regulatory obligations, complaints, dispute resolution, legal proceedings and other lawful business requirements.

Records retained may include:

  • Member Account information;
  • Membership records;
  • Payment references;
  • Promotional participation;
  • Entry records;
  • Prize and winner records;
  • Communications;
  • Compliance records;
  • Website and app activity;
  • Security logs; and
  • Audit records.

Where SLR no longer needs Personal Information for a lawful purpose and is not legally required or permitted to retain it, SLR will take reasonable steps to destroy or de-identify it where required by applicable privacy law.

17. Access & correction of personal information

Individuals may request access to Personal Information SLR holds about them.

Individuals may also request correction of Personal Information that they believe is inaccurate, out of date, incomplete, irrelevant or misleading.

Requests may be submitted to:

Privacy Contact — Smart Life Rewards
SLR Life Pty Ltd
28 Welcome Parade, Wyndham VIC 3024, Australia
Email: [email protected]
Website: Smart Life Rewards Website Contact Page

SLR may require reasonable evidence of identity before providing access to or correcting Personal Information. SLR will respond to requests in accordance with applicable law. If SLR refuses an access or correction request where permitted by law, SLR will provide any reasons or notices required by applicable law.

18. Privacy complaints

A person who believes SLR has not handled their Personal Information appropriately may submit a privacy complaint.

Complaints may be submitted to:

Privacy Contact — Smart Life Rewards
SLR Life Pty Ltd
28 Welcome Parade, Wyndham VIC 3024, Australia
Email: [email protected]
Website: Smart Life Rewards Website Contact Page

The complaint should provide enough information to allow SLR to understand and investigate the matter.

SLR will take reasonable steps to:

  • Acknowledge the complaint;
  • Review the circumstances;
  • Request further information if reasonably necessary;
  • Investigate the complaint;
  • Take appropriate corrective action where required; and
  • Respond within a reasonable period.

If a person remains dissatisfied following SLR’s response, they may have the right to contact the Office of the Australian Information Commissioner or another relevant regulator.

19. Account closure & deletion requests

Members may request:

  • Closure of their Member Account;
  • Cancellation of Membership;
  • Correction of Personal Information; or
  • Deletion of Personal Information where permitted by law.

Closure of a Member Account does not necessarily require SLR to immediately delete all information associated with that account.

SLR may retain relevant records where reasonably necessary or legally required for payment and financial records, prize administration, promotional audit records, fraud prevention, security, regulatory compliance, legal claims and dispute resolution.

Where a Member holds both Red and Blue Membership, the Member should clearly state whether they wish to:

  • Cancel Red Membership only;
  • Cancel Blue Membership only;
  • Cancel both paid Memberships; or
  • Close the entire SLR Member Account.

20. Membership payments & cancellations

Unless otherwise expressly displayed, paid SLR Membership operates on a recurring 28-day Membership Cycle. Members may cancel future recurring Membership payments using the cancellation method provided by SLR.

Cancellation generally prevents the next recurring Membership payment and does not automatically create an entitlement to a refund for the current paid Membership Cycle.

Where a Member holds both Red and Blue Membership, each tier may be administered and cancelled separately within the same Member Account.

Any entitlement to a refund, cancellation, remedy or other consumer right will be determined in accordance with SLR’s General Terms & Conditions and applicable Australian Consumer Law. Where SLR approves a refund, processing times may depend on the applicable payment provider and financial institution.

21. Children & age eligibility

Paid SLR Membership and Promotional Draw participation are intended for persons aged 18 years or older unless expressly stated otherwise. Specific free promotions may have separate age or eligibility conditions where permitted by law.

SLR does not knowingly seek to collect Personal Information from children contrary to applicable law. If SLR becomes aware that Personal Information has been collected in circumstances where it should not have been collected, SLR will take reasonable steps appropriate to the circumstances.

22. Third-party links & partner services

The SLR Platform may contain links to:

  • Partner websites;
  • BENY or other benefit providers;
  • Affiliate services;
  • Local businesses;
  • Community organisations;
  • External merchants; and
  • Other third-party services.

Unless expressly stated otherwise, those services are independent from SLR. SLR is not responsible for independent third parties’ privacy practices, website content or information-handling procedures.

Members should review the relevant third party’s privacy policy before providing Personal Information directly to that provider.

23. Community & charitable initiatives

SLR may support independent community or charitable organisations through donations, fundraising initiatives, promotional support, food-support initiatives, community campaigns or other initiatives.

Where Personal Information is specifically collected in connection with a community, charitable or fundraising activity, additional privacy notices or conditions may apply.

SLR will not disclose a Member’s Personal Information to a charity or community organisation for that organisation’s independent marketing merely because SLR supports or donates to that organisation unless the Member has authorised the disclosure, the disclosure is reasonably expected and permitted, or the disclosure is otherwise permitted or required by law.

24. Anonymity & pseudonyms

Where practicable and permitted by law, individuals may have the option of interacting with SLR without identifying themselves or by using a pseudonym.

Identification will generally be necessary where reasonably required for:

  • Establishing a Member Account;
  • Age verification;
  • Membership administration;
  • Payment processing;
  • Promotional eligibility;
  • Entry administration;
  • Winner verification;
  • Prize payment or delivery;
  • Fraud prevention;
  • Duplicate-account prevention;
  • Security; or
  • Legal and regulatory compliance.

25. Changes to this Privacy Policy

SLR may update this Privacy Policy where reasonably necessary because of:

  • Changes to SLR Membership;
  • Changes to SLR services;
  • New Member benefits;
  • New Promotional Activities;
  • New Promotional Draw structures;
  • New Third-Party Providers;
  • New technology;
  • Platform changes;
  • Regulatory developments;
  • Changes in privacy law; or
  • Changes in SLR's Personal Information handling practices.

The current Privacy Policy will be published on the SLR website. Where a material change requires additional notice or consent under applicable law, SLR will take appropriate steps.

The Last Updated date displayed at the beginning of this Privacy Policy identifies the date of the current version.

26. Contact information & Australian privacy rights

Smart Life Rewards (SLR)
SLR Life Pty Ltd trading as Smart Life Rewards
ABN 99 696 467 473
Business & privacy correspondence address: 28 Welcome Parade, Wyndham VIC 3024, Australia
Privacy & customer support email: [email protected]
Website support: Smart Life Rewards Website Contact Page

Nothing in this Privacy Policy is intended to exclude, restrict or modify privacy, consumer or other legal rights that cannot lawfully be excluded.

Where applicable, SLR will handle Personal Information having regard to:

  • Privacy Act 1988 (Cth);
  • Australian Privacy Principles;
  • Notifiable Data Breaches scheme;
  • Spam Act 2003 (Cth);
  • Australian Consumer Law; and
  • Other applicable Australian laws and regulatory requirements.

If this Privacy Policy is inconsistent with a mandatory legal requirement, the mandatory legal requirement prevails.

Questions about this document? Email us at [email protected].