Privacy Policy

1. We respect your privacy

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. What is personal information?

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.

2.2. You may contact us in writing by email at privacy@snug.com or Level 3, 201 Sussex St, Sydney, NSW Australia 2000, for further information about this Privacy Policy.

3. What personal information is collected?

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:

  1. or Owners, we collect information regarding your rental properties, proof that you own or have the right to manage your rental properties, your ABN or your ACN (if applicable);
  2. for Specialists and Service Providers, we collect information regarding your professional qualifications, your employment history and your ABN or ACN (if applicable);
  3. for Renters, we may collect information regarding your professional qualifications, your employment history, your rental history and information regarding your social media accounts and social media activity.
  4. for third parties, we may collect contact information for you if you have been nominated as a referee by a Member, or if a Member asks you to verify information regarding them. However, we always ask Members to seek permission before they provide us with third party contact information.

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.

4. How do we collect your personal information?

4.1. Snug collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you respond to surveys, when you respond to questions we ask of you when you create a membership account with us, when you access our website and when we provide our services to you. By providing us with personal information, you consent to the supply of that information subject to the terms of this Privacy Policy.

4.2. We may also receive personal information from third parties, such as social media providers and other Members. Circumstances where we may collect information from third parties includes where a Member nominates a person as a referee in order to verify information that they have provided to us. If we do collect information from third parties, we will protect it as set out in this Privacy Policy.

5. How do we use your personal information?

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 will use personal information only for the purposes that you consent to. This may include to:

  1. provide you with products and services during the usual course of our business activities;
  2. administer our business activities;
  3. manage, research and develop our products and services;
  4. provide you with information about our products and services;
  5. communicate with you by a variety of measures including, but not limited to, by telephone, email, sms or mail. If you do not wish to be contacted by Snug by any of these means, please contact us at privacy@snug.com.

6. To whom do we disclose your personal information?

6.1. 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.

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.

6.5. 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.

7. General Data Protection Regulation (GDPR) for European Union (EU) resident users

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. Your rights under the GDPR for European Union (EU) resident users

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:

  1. to be informed how your personal information is being used;
  2. to access your personal information (we will provide you with a free copy of it);
  3. to correct your personal information if it is inaccurate or incomplete;
  4. to delete your personal information (also known as "the right to be forgotten");
  5. to restrict processing of your personal information;
  6. to retain and reuse your personal information for your own purposes;
  7. to object to your personal information being used; and
  8. to object against automated decision making and profiling.

8.3. Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy.

8.4. We may ask you to verify your identity before acting on any of your requests.

9. What are our hosting and international data transfer arrangements?

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:

  1. the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website;
  2. the use of binding corporate rules, a copy of which you can obtain from Snug's Data Protection Officer.

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:

  1. the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website;
  2. the use of binding corporate rules, a copy of which you can obtain from Snug's Data Protection Officer.

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. How do we securely store your personal information?

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.

10.3. 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.

11. How can you gain access to your personal information?

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 privacy@snug.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. Can I make a complaint about privacy?

12.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to privacy@snug.com 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

13. Changes to this Privacy Policy

13.1. Please be aware that we may change this privacy policy at any time, in our sole discretion. Any amendment to this privacy policy will be effective immediately upon the amended policy being posted to our website which we may also email to you. Please check back from time to time to review our Privacy Policy.

14. What other information is collected when I visit the Snug websites?

14.1. In additional to personal information, Snug also collects other, non-identifiable, information when you visit our websites. This information includes:

  1. Website History: We may collect certain statistical information in order to analyse how people use our site. This information is collected in an aggregate manner only. This information includes your browser type, information regarding your operating system, the website you visited immediately before coming to our site.
  2. Cookies: Our websites use cookies. Cookies are very small files which a website uses to identify you when you come back to the site and to store details about your use of the site. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website and us offering you helping services like remembering your details to pre-fill forms you submit. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google Adwords. These ads may appear on this website or other websites you visit.
  3. Third party sites: Our site may from time to time have links to other websites not owned or controlled by us. These links are for your convenience only. Links to third party websites do not constitute sponsorship, endorsement or approval of these websites and Snug is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.
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