1.1. Snug Technologies Pty Ltd (ACN 616 484 292) (Snug) and it’s related Bodies Corporate is committed to safeguarding the privacy of its members and the users of its website, www.snug.com. It therefore adheres to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth), and to the extent applicable, the EU General Data Protection Regulation (GDPR).
1.2. This policy explains what personal information Snug collects, and how it is collected, used, disclosed and stored.
2.1. 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.
3.1. Snug collects a range of personal information in order to provide its services to you, communicate with its members and improve the range of services it offers.
3.2. The types of personal information we collect from you will depend upon the services you obtain from us.
3.3 For all Members, the information we collect includes your contact details (such as your phone number, physical address, postal address and email address), photo identification, your credit card information, tenancy information and your transaction history with us. We may also collect additional information, including the following:
3.4. 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.
3.5. 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 and/or promotions, or communicate with our customer support.
3.6. 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 prevented from obtaining certain services from us.
5.1. Snug uses the personal information it collects to provide you with information, updates and to provide you with our services. Depending upon the nature of your Membership, these services may include, but are not limited to, matching Owners with potential Renters, the collection of rent and our marketplace services which enable Members to interact with and provide services to each other.
5.2. Snug may also use your information in order to improve the products and services we offer to you and to better understand your needs. We may make you aware of these new and additional products, services and opportunities.
5.3. If you withhold your personal information, it may not be possible for us to provide you with our products and services or for you to fully access our website.
5.4. Snug also anonymises information provided by Members and analyses information on a collective basis in order to identify trends and market insights. These trends and insights are shared with our Members.
5.5 Snug and referral partners will use personal information only for the purposes that you consent to. This may include to:
6.2. 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.
6.3. 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.
6.4. If there is a change of control in our business, or a sale or transfer of business assets, we reserve the right to 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.
7.1. Snug will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.
7.2. We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.
7.3. We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.
7.4. We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure.
7.5 We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.
7.6 We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.
7.7 We do not collect or process any personal information from you that is considered "Sensitive Personal Information" under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.
7.8 You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.
8.1. If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used. Snug complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU.
8.2. Except as otherwise provided in the GDPR, you have the following rights:
8.4. We may ask you to verify your identity before acting on any of your requests.
9.1. 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.
9.2. We and our other group companies have or intend to open offices and/or facilities globally. Transfers to each of these countries will be protected by appropriate safeguards, these include one or more of the following:
9.3. The hosting facilities for our website are situated globally. Transfers to each of these Countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from Snug's Data Protection Officer.
9.4. Our Suppliers and Contractors are situated primarily in Australia but may be global. Transfers to each of these Countries will be protected by appropriate safeguards, these include one or more of the following:
9.5. You acknowledge that personal data that you submit for publication 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.
10.1. 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.
10.2. 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 GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.
11.1. You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act 1988 (Cth), and to the extent applicable the EU GDPR. 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 email@example.com.
11.2. 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.
12.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to firstname.lastname@example.org or to our office address listed on our contact page. We take complaints very seriously and will respond shortly after receiving written notice of your complaint
14.1. In additional to personal information, Snug also collects other, non-identifiable, information when you visit our websites. This information includes:
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