In this Privacy Policy and Collection Notice, 'us' 'we' or 'our' means Dragon Bay Group Pty Ltd (ACN 85 638 026 623).

We are committed to respecting your privacy. Our Privacy Policy sets outs out how we collect, use, store and disclose your personal information in accordance with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act).

Privacy collection notice

We must collect personal information about you to provide services, respond to enquiries, perform marketing and promotion activities, and for purposes otherwise set out in our Privacy Policy. We may disclose that information to third parties that help us deliver our services, in accordance with the Australian Privacy Principles contained in the contained in the Privacy Act, or otherwise as set out in this Privacy Policy.

If you do not provide this information, we may not be able to provide our services or products to you. Our Privacy Policy explains:

If you do not provide this information, we may not be able to provide our services or products to you. Our Privacy Policy explains:

How you can lodge a complaint regarding the handling of your personal information;


How we will handle any complaint.

If you would like any further information about our privacy policies or practices, please contact us.

By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us. We may change our Privacy Policy from time to time by publishing changes to it on our mobile application. We encourage you to check our mobile application periodically to ensure that you are aware of our current Privacy Policy.

Personal information includes information or an opinion about an individual that is reasonably identifiable. For example, this may include your name and contact details.

What personal information do we collect?

We may collect the following types of personal information:

your name, mailing address, email address, personal and work telephone number, and other contact details;

your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;

financial information, such as your bank account and credit card details;

details of the products and services that you have purchased or enquired about, including any additional information necessary to process payments and respond to your enquiries.

any additional information relating to you that you provide to us directly or indirectly through WeChat, third party payment merchants, and/or WeChat application/mini programs that we own or license (Apps); and/or

any other personal information that may be required to facilitate your dealings with us and is provided to us.

We may collect these types of personal information either directly from you, or from third parties.

We may collect this information when you:

use our website;

use the Apps;

enquire about our services;

receive services from us;

deposit, or direct a third-party payment merchant or financial institution to deposit, an amount into our bank account;

request a refund of an amount that was paid into our bank account;

communicate with us through correspondence, social networking sites (e.g. WeChat, Facebook, Twitter, Instagram), email, online chat bots, Apps, or when you share information with us from other social applications, services or websites;

direct or otherwise consent to a third party disclosing your personal information to us; and/or

interact with content, advertising, and marketing campaigns – these may be produced by us or third parties.

Why do we collect, hold, use and disclose personal information?

We may collect, hold, use and disclose your personal information for the following purposes:

to provide services to you;

to facilitate your full use and enjoyment of our website and the Apps;

to provide appropriate information and opinions about our services to you;

to operate, protect, improve and optimise our website, the Apps, our services and your user-experience - such as to perform research and analytics;

to send administrative messages, reminders, technical notices, updates, security alerts, and information about our services, or as otherwise requested by you;

to send you advertising, marketing and promotional messages, and other information that may be of interest to you;

to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;

to provide information to credit reporting agencies and courts, tribunals and regulatory authorities if you fail to pay for the services we have provided;

to courts, tribunals, regulatory authorities, and law enforcement officers as required by law, in connection with any actual or prospective legal proceedings, or to establish, exercise or defend our legal rights; and

to comply with our legal obligations, resolve any disputes that we may have with any of our mobile application users or clients, and enforce our agreements with third parties.

We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

When no longer required by us, unless required by law to retain it, we will take reasonable steps to destroy or de-identify your personal information securely.

Do we use your personal information for direct marketing?

We may send you direct marketing communications and information about us and our services. This may take the form of emails, SMS, mail or other forms of communication. You may opt-out of receiving marketing communications and information from us by directing your request using the contact details set out below or by using the opt-out facilities provided (e.g. an unsubscribe link).

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this Privacy Policy to:

third party suppliers, including cloud-based storage solution service providers and other service providers;

other users, in circumstances where:

you are selling products and services to other users of an App, via that App; or you are buying products and services from other users of the App, via that App, to the extent reasonably necessary to facilitate that primary transaction and any secondary transactions (e.g. refunds) pertaining to that buying and selling activity; if we are the licensee of an App, the licensor of that App;

third party payment service providers (e.g. Stripe, banks) that we rely on to process your payments to us;

our employees and contractors, for administrative purposes and to the extent reasonably necessary to engage in the every day operations of our business; our sponsors or promoters of any competition that we conduct via our services; our related bodies corporate;

anyone to whom our assets or businesses (or any part of them) are transferred; specific third parties authorised by you to receive information held by us; and/or persons that we are required, authorised or permitted to disclose your personal information to by law (e.g. government agencies, regulatory bodies and law enforcement agencies).

Disclosure of personal information outside Australia

We may disclose personal information outside of Australia to third party suppliers of payment processing services (e.g. Stripe) located in the United States of America.

We may also disclose personal information outside of Australia to third parties located in China – in particular, to: Tencent Holdings Limited and its related bodies corporate to the extent required under WeChat’s terms and conditions; Aliyun, to the extent necessary to provide cloud storage services on a database hosted in Australia; and Hangzhou Aoyunhui Technology Co. Ltd, to the extent necessary to provide services to you via the App known as the Feng Xiang Jie Long Little App which is licensed to us by that entity.

When you provide your personal information to us, you consent to the disclosure of your information outside of Australia and acknowledge that we are not required to ensure that overseas recipients handle that personal information in compliance with the Privacy Act. We will, however, take reasonable steps to ensure that any overseas recipient will deal with such personal information in a way that is consistent with the Privacy Act (including the Australian Privacy Principles).


'Cookies' are small files containing small amounts of information that store information on your computer, mobile phone or other device. Cookies are downloaded to your device when you log in to our website or the Apps, or use certain website and/or App features, and are then sent back to the originating server on each subsequent visit, or to another server that recognises that cookie.

We may use cookies or other similar tracking technologies on our website and the Apps that help us track your usage, remember your preferences, and generally improve your user experience. These cookies are in addition to any cookies that third parties (eg the WeChat platform) may use.

They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies, but our website and/or the Apps may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Privacy Policy.


We may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. In particular:

personal information is stored and secured in a database hosted in a Australia by cloud-based storage provider, Aliyun;

payment transaction data (including credit card details) stored and secured in either the WeChat or third party payment merchants’ (e.g. Stripe’s) encrypted databases;

access to our information systems is controlled through identity and access management, including password protection and.

However, we cannot guarantee the security of your personal information.


Our website and the Apps may contain links to websites, WeChat mini-programs and other online locations that are operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked locations, and have no control over or rights in those linked locations. The privacy policies and other terms that apply to those other locations may differ substantially from our Privacy Policy, so we encourage individuals to read them before using those websites, WeChat mini-programs and other online locations.

Accessing or correcting your personal information

You can access the personal information we hold about you by contacting us using the below contact information. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

If you think that any personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the below contact information and we will take reasonable steps to ensure that it is corrected.

Making a complaint

f you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, you can contact us about your complaint using the below contact information. Please include your name, email address and/or telephone number and clearly describe your complaint. We will acknowledge your complaint and respond to you regarding your complaint within a reasonable period. If you think that we have failed to resolve the complaint satisfactorily, please let us know and we will provide you with information about the further steps you can take.

Contact Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the following contact details:

By email

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