1.1. We take privacy very seriously and respect your privacy
1.2. This privacy policy describes how we collect, use, share, store and manage your personal information.
1.3. Any time you engage with us (visit our websites, use our services or enter into an agreement or subscription with us) you confirm you have read and agreed to our Privacy Policy.
1.4. We’ll update this policy from time to time, and any amendment to this Privacy Policy will be effective immediately upon the amended policy being posted to our website. We may notify you via email or online. Continuing to engage with us means you have accepted the revised version of this policy.
2.1. Snug Technologies Pty Ltd (ACN 616 484 292) (“Snug”) as part of the Snug Group and its related Bodies Corporate (Covesta Group) are committed to safeguarding the privacy of customers across our websites, apps and services.
2.2. Snug adheres to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth), the Privacy Principles and to the extent applicable we aspire to the EU General Data Protection Regulation (GDPR).
2.3. You may contact us in writing by email at privacy@snug.com or write to us at: Level 16, 175 PItt Street, Sydney, NSW Australia 2000, for further information about this Privacy Policy.
3.1. For the purposes of this policy, “personal information” includes information about an individual where the identity of that individual is apparent or could reasonably be ascertained eg. an email address, phone number, application details or social media account if used as a login.
3.2. We do not collect or process any personal information from you that is considered "Sensitive Personal Information" such as personal information relating to your gender or ethnic origin unless we have obtained your explicit consent for a Primary Purpose eg. house share service or affordable housing program eligibility.
3.3. You must not provide us with your personal information if you are under the age of 16 without the consent of a parent or authorised alternative. We do not knowingly collect or process the personal information of children.
3.4. We may also collect ‘non-personal information’ such as the website pages you visit and use cookies to optimise your experience, the performance of our platform and the services we offer. We may make you aware of these new and additional products, services and opportunities via email or within the website.
3.5. If you purchase a product or subscribe to a service we will collect and store payment information either on our platform or with a payment provider such as Stripe.com. Credit card information is securely processed by our payment processing partner and is not stored by us. However, we may store the Bank Account details you provide if you select financial services such as bond and rent transactions.
3.6. We may also collect other personal information that you voluntarily communicate to us when you interact with us, such as when you provide us with your feedback or if you respond to surveys, advertising and/or promotions, or communicate with our customer support. Snug may also use your information in order to improve the products and services we offer to you and to better understand your needs.
3.7. Snug also de-identifies and anonymises information provided by users as well as analyses information on an aggregate basis in order to identify trends and market insights. These aggregate trends and insights may be shared with our users.
3.8. Some information that is requested is “optional” and some is “mandatory”. Where information is “mandatory”, you can choose not to provide the requested information, however this will mean that you may be unable to obtain or prevented from accessing certain services from us.
3.9. The types of personal information we collect from you will depend upon the services you obtain from us.
4.1. We may collect basic information when you register an account with us:
4.2. We may communicate with you to secure these accounts using multi-factor authentication and request proof of identity or usage if you use your credentials.
4.3 If you don't login for 3 years, we will delete your User Account and profiles automatically.
5.1. For all users that create a Snug Profile, the information you provide may be used with your consent in whole or in part for rental, financial and marketplace services. We may collect personal information including your contact details (such as your phone number, current/previous physical address, postal address and email address), photo identification, references, credit card information, social media information (if social-signon login used and further social content if additional sharing consented) and your transaction history with us.
5.2. We may also collect additional information, including the following:
6.1. For renters creating a Snug Profile, you can share this information with your Renter Profile for rental services and furthermore to submit a rental application. We will collect further information in a Renter Profile such as:
6.2. If you have not edited, viewed or used your Renter Profile to submit an application in 18 months, we will delete all your Renter Profile information except your Snug Profile.
7.1. We further detail information collection and disclosure for renters applying for properties and obtain your further agreement and consent in our document Personal Information Collection and Disclosure Authority for matters such as tenancy database checks.
7.2. Renter applications include:
7.3. Auto-withdrawal and deletion policies apply to rental applications:
7.4. You may reupload information to reuse your Renter Profile and Rental Application at anytime and this resets the auto-withdrawal and deletion policy.
8.1. Snug Group offers financial services such as credit and investment products.
8.2. For financial services, in addition to your Snug and Rental Profile, we may collect more information from you directly, such as your bank account details, occupation, number of dependents, partner or beneficiary, power of attorney or cohabitants, and sources of income and expenses.
8.3. To help you with, and to assess credit products, we may also get personal information about you and financial information from credit reporting agencies, existing or previous providers of goods or services, your bank, your accountant or lawyers.
9.1. If you use our marketplace services, Snug enables you to publish a Marketplace Profile so that you may interact directly with other users or providers using a unique username and limited Snug Profile.
10.1. Snug will endeavour to collect the minimal personal information required for a specific purpose and use personal information only for the purposes that you consent to. This may include to:
10.2. Snug may collect and use your personal information for a secondary purpose for example:
11.1. We may disclose your personal information to third parties where it is required for the delivery of our services and when requested by you to do so. We may also disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors in order to provide you with our services, and for the purposes set out in this privacy policy. This could include, for instance, disclosing your information to financial institutions who process credit card transactions. It may also include disclosing your information to fellow Snug Members, or referees nominated by you, where requested by you.
11.2. We reserve the right to disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
11.3. We may also use your personal information to protect our business, the copyright, trademarks, legal rights, property or safety of Snug, its websites, our Members and third parties. This could include disclosing your information as a part of any investigation where we have reason to suspect that you have committed a breach of our terms and conditions or engaged in unlawful activity.
11.4. If there is a change of control in our business, or a sale or transfer of business assets, we reserve the right to assign and or transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality.
11.5. Where we disclose your personal information to third parties, we will request that the third party comply with this privacy policy with respect to the handling and management of your personal information.
11.6. You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth). If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email us at privacy@snug.com
11.7. You have the following rights:
11.8. Please contact us at any time and please note that we may ask you to verify your identity before acting on any of your requests.
11.9. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law for example if the information relates to assessment (such as a rental reference) or commercial negotiations or for record keeping purposes (eg. tenancy applications held up to 3 years post vacate).
12.1. Snug is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure. This includes the use of SSL encryption and password restricted permission based access for limited personnel.
12.2. Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the Privacy Act and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
12.3. Although Snug has procedures in place to safeguard the security of your information, Snug cannot guarantee the security of any information you transmit to or receive from us. The transmission and exchange of information therefore is carried out at your own risk. We therefore cannot guarantee that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.
12.4. Sensitive information is stored in Australia. Limited personal and non personal information related to Support or Sales such as contact, subscription or billing information may be stored overseas. Nonetheless, information that we collect may from time to time be stored, processed in or transferred between parties or sites located in countries outside of Australia. Transfers will be protected by appropriate safeguards.
12.5. You acknowledge that personal data that you submit for publication (such as marketplace share house listing adverts with your contact details) through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
12.6. We anonymise and delete data when it is no longer required by you, by us or by law.
12.7. You may request to delete or self-serve a deletion of your User Account, Snug Profile or Rental Profile via your user account, and this process is permanent and irreversible.
12.8. If you have any complaint(s) about our privacy practices, please feel free to send in details of your complaint(s) to privacy@snug.com or to our office address.
12.9. We take complaints very seriously and will respond shortly after receiving written notice of your complaint. We will record your complaint and do everything possible to fix the problem and resolve the issue.
12.10. For financial services, if at any time you are not satisfied with the handling of your complaint or the resolution we have provided, you can lodge a complaint with the Australian Financial Complaints Authority (AFCA). AFCA provides fair and independent financial services complaint resolution that is free to consumers. You can contact AFCA online at www.afca.org.au or by phone: 1800 931 678 (free call) or by post: Australian Financial Complaints Authority, GPO Box 3, Melbourne VIC 3001. Time limits may apply to lodge a complaint with AFCA so you should act promptly or otherwise consult the AFCA website to find out if or when the time limit relevant to your circumstances expires.
12.11. If your complaint is about how we handle your personal information, you can also contact the Office of the Australian Information Commissioner: oaic.gov.au. Phone: 1300 363 992 or post address: Office of the Australian Information Commissioner, GPO Box 5218, Sydney NSW 2001.
| Auto delete <60 | 6 months / 18 months | 3 year | |
|---|---|---|---|
| User Account | Dont login | ||
| Snug Profile | Dont login | ||
| Address history | |||
| Income | |||
| BGC | |||
| Identity | Y | ||
| Rental Profile | Applied for property in SA | ||
| Employment | Y | ||
| Pets | Y | ||
| About Us | Y | ||
| Student | Y | ||
| Other Docs | Y | ||
| Personal references | Y | ||
| Next of Kin / Emergency Contacts | Y | ||
| Utility Connections | |||
| Renter Applications | |||
| App ID | |||
| Address Applied | |||
| Approved Apps | Y | ||
| Property Manager | |||
| Notes/Activities | Y |
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