CABINKEEP APP PRIVACY POLICY
1. Introduction
a. The CabinKeep App made available through a mobile application is owned and operated by The HouseHub Co Pty Ltd (ACN 690 827 117) (CabinKeep, we, our or us).
b. We are committed to ensuring your Personal Information is protected. We manage your Personal Information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).
c. By downloading, accessing and using the CabinKeep App, you agree to this Privacy Policy.
d. This Privacy Policy outlines we collect, store, process, share, use, and disclose your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.
2. The information CabinKeep collects about you
2.1. Personal Information
a. Personal information has the same meaning that it has under the Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not.
b. We will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, make the CabinKeep App available to you, or as otherwise permitted by law.
2.2. Your Personal Information
The type of Personal and Non-Personal Information that we collect and use depends on the type of dealings that you have with us and includes the following:
i. your account registration information (for example, your full name, email
address, mobile number, date of birth, and profile picture) and your account credentials (such as your username created by you as a user of the CabinKeep App);
ii. information or data created, uploaded, submitted, or published by you on, or via, the CabinKeep App (such as your inventory, task and shopping lists) and information about the individuals you invite to access your inventory and shopping and tasks lists through the CabinKeep App;
iii.marketing data and information relating to your dealings, or enquiries you have made, with us on or via the CabinKeep App;
iv. device information which is automatically collected from you when you visit and navigate through the CabinKeep App. Such information may include, but is not limited to, your device type, your device’s network connections, unique device identifier, your device’s name, your device IP address, screen size and calibration, information about your device’s web browser, and internet connection you use to access the CabinKeep App, geolocation information, browser characteristics, device characteristics, operating system and language preferences, dates and times of visits to the CabinKeep App and other usage statistics; and
v. other information that you provide to us or that we may collect in the course of our relationship with you.
2.3. Other Information
i. We may also collect some information that is not Personal Information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use the CabinKeep App.
ii. If you are a candidate seeking employment with us, we will use your Personal Information to process your application and assess your suitability for any role. We may retain your information for future reference.
2.4Sensitive Information
a. We do not intentionally collect your Sensitive Information (as defined by the Privacy Act). However, some of our services are automated and we may not recognise that you have accidentally provided us with Sensitive Information.
b. If you have accidentally sent us Sensitive Information, please contact us using the details below.
3. How CabinKeep collects Personal Information
3.1 Direct collection from you
a. We will collect Personal Information and Non-Personal Information about you in a number of different ways. We may collect Personal Information and Non-Personal Information directly from you or in the course of our dealings with you. For example, when you:
i. setup and create an account on the CabinKeep App (including when you edit or update your account information on the CabinKeep App);
ii. access and use the CabinKeep App (for example, when you create, amend, modify, manage and delete inventory, task and shopping lists, create alerts or reminders within the CabinKeep or when you manage your authorised users (such as when you invite or remove authorised users); or
iii. when you visit our website, use the CabinKeep App or contact or correspond with us online (for example, when you complete online forms, or subscribe to our publications, alerts and newsletters), lodge a complaint about another user, request customer support services, contact us via email or telephone with a query or request or make a comment on our social media sites or you participate in a promotion, competition or survey.
b.By providing your Personal Information to us, you acknowledge that you are authorised to provide such information to us.
3.2 Collection from third parties
a. We may also collect Personal Information and Non-Personal Information about you from your authorised users, publicly available sources and third parties, including:
i. when your authorised users create, upload, submit, or publish information or data about you on, or via, the CabinKeep App;
ii. when you provide your Personal Information to third parties (including to our related bodies corporate, business partners, service providers, and third party contractors);
iii. if you use our social media sites or applications or other third party products and services that interact with, or connect with, the CabinKeep App; and
iv. if third party payment processors are used by us to process payments made by you.
b. When we collect your Personal Information from third parties, we shall take reasonable steps to make sure you are aware of the collection.
c. You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy, including that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual's right to access that information, and who we are and how to contact us.
4. How CabinKeep uses your Personal Information
4.1 Purposes of use and disclosure
a. We only use, process and disclose your Personal Information for the purposes for which it is collected. In particular, we use, process and disclose your Personal Information and Non-Personal Information to:
i. provide you with access to, and use of, the CabinKeep App;
ii. informing you about the CabinKeep App, our website, or about our other products and services offered by us or our third party products and services, offers, competitions, promotions, events, sweepstakes, surveys, questionnaires about us, the CabinKeep App or other matters which we believe are of interest to you (such as recruitment or job opportunities);
iii. manage, administer, improve, test, develop and upgrade the CabinKeep and our website, informing you about scheduled maintenance or outages and managing our relationship with you;
iv. provide you with customer support or to otherwise investigate complaints about the CabinKeep App and other users;
v. to customise the content on the CabinKeep App;
vi. to verify your identity;
vii. to conduct fraud, risk reduction and creditworthiness checks;
viii. to perform research and analysis about the CabinKeep App and for data analytics purposes, including usage patterns, trends, benchmarking and other statistical or behavioural data. Before we use your Personal Information for this purpose, we ensure Personal Information is made anonymous by removing data that can identify you;
ix. for direct marketing purposes (see section 6 below);
x. to comply with regulatory or other legal requirements,
xi. for any purpose to which you have consented; and
xii. for any other purpose notified to you at the time of collection.
b. In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your Personal Information as part of the transaction, without your consent or notice to you.
4.2. Disclosure to Third Party Providers
a. With your consent, in order to provide or deliver the CabinKeep App to you, we may provide your Personal Information and Non-Personal Information to the following recipients:
i. our employees, related entities, business partners, third party contractors, suppliers and agents from time to time for the purpose of delivering, providing and administering the CabinKeep App (including customer support services and setup services);
ii. third party service providers who process or use your Personal Information and Non-Personal Information for the purpose of performing functions on our behalf, but may not process or use such information for any other purpose. Examples of these third-party service providers include, but are not limited to, such as cloud-based accounting software applications, marketing and analysis organisations, third party payment processors, hosting and data storage companies, website and app developers, internet service providers, customer service providers, customer support specialists, fulfilment companies and research and data analysis firms, government agencies, public registries, search agencies, regulatory and licensing bodies and parties to whom you refer us (for example, previous employers and referees); and
iii. external business advisors, such as auditors, lawyers, insurers and financiers,
(collectively, Third Party Providers).
b. When we disclose your Personal Information to any of our Third Party Providers, we will ensure that they undertake to protect your privacy. Third Party Providers are not permitted to use the information for any [m][n]purpose other than the purpose for which they have been given access.
c. Our Third Party Providers may also provide us with Personal Information collected from you. If you disclose Personal Information to any Third Party Providers, we rely on you to provide the Third Party Providers with consent for us to collect, storage, use, process, alter, and disclose your Personal Information.
d. We may also disclose any Personal Information we consider necessary to comply with any applicable law, regulation, legal process, governmental request, or industry code or standard.
4.3. Third party payment processors
We use third party payment processors to process payments made to us. In connection with the processing of such payments, we do not collect, process, use, hare, store, or disclose any payment information (such as credit card and bank account details). Rather, all such information is provided directly to our third party processors, Apple Pay and Google Pay, whose use of your Personal Information (including payment information) is governed by their privacy policy, which may be viewed at https://www.apple.com/au/legal/privacy/data/en/apple-pay/ and https://policies.google.com/privacy.
4.4. Overseas disclosure
a. In the course of providing you with access to, and use of, the CabinKeep App, it may become necessary or desirable to disclose Personal Information to Third Party Providers located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we commonly disclose Personal Information to our third-party payment processors located outside of Australia, including United States, Canada, Europe, and the United Kingdom.[o][p]
b. The laws where this overseas recipient may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas, we will take reasonable steps to ensure that your Personal Information is treated securely, and the means of transfer provides adequate safeguards.
c. By accessing or using the CabinKeep App or providing your Personal Information to us, you explicitly and freely consent to the transfer of your Personal Information to our overseas Third Party Providers. If you do not wish to receive information from any of our Third Party Providers, please let us know using the details below. However, if you do not provide your Personal Information to us or our Third Party Providers, we may not be able to provide you with access to, and use of, the CabinKeep App.
4.5. Disclaimer
a. We will not disclose your Personal Information to any third party (other than our Third Party Providers) without your written consent, unless:
i. we are otherwise required by the relevant Privacy Laws;
ii. we are permitted to under this Privacy Policy; or
iii. such disclosure is, in our opinion, reasonably necessary to protect our rights or property, avoid injury to any person or ensure the proper functioning of the CabinKeep App.
b. This Privacy Policy only covers the use and disclosure of information we collect from you. The use of your Personal Information by any third party is governed by their privacy policies and is not within our control.
5. Marketing communications
5.1. Direct marketing
a. We may use and disclose your Personal Information to send you information about the CabinKeep App and any other products or services we may offer from time to time, as well as other information that may be of interest to you.
b. These communications may continue, even after you stop using the CabinKeep App.
5.2. Communication channels
a. We may send this information to you via the communication channels specified at the time you provide your consent.
b. These communication channels may include mail, email, SMS telephone, social media or by customising online content and displaying notices or advertising on the CabinKeep App.
5.3. Opting-out
You can opt out of receiving these communications by:
a. contacting us using the details below; or
b. using the unsubscribe function in the email or SMS.
6. Notifiable Data Breaches Scheme
In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, we will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with notifiable data breach scheme contained in Part IIIC of the Privacy Act.
7. Storage and security
7.1. Protecting your Personal Information
a. We take reasonable steps in the circumstances to keep your Personal Information and Non-Personal Information safe. We use a combination of technical, administrative, and physical controls to protect and maintain the security of your Personal Information.
b. Our officers, employees, agents and third-party contractors are expected to observe the confidentiality of your Personal Information and Non-Personal Information.
c. Wherever possible, we procure that Party Providers who have access to your Personal Information and Non-Personal Information take reasonable steps to:
i. protect and maintain the security of your Personal Information and Non-Personal Information; and
ii. comply with the Australian Privacy Principles when accessing and using your Personal Information.
7.2. No guarantee
a. The transmission of information via the internet is not completely secure. While we do our best to protect your Personal Information and Non-Personal Information, we cannot guarantee the security of any Personal Information and Non-Personal Information transmitted through the CabinKeep App.
b. You provide your Personal Information (and Non-Personal Information) to us at your own risk, and we are not responsible for any unauthorised access to, and disclosure of, your Personal Information and Non-Personal Information.
7.3. Destruction of Personal Information
We will destroy or de-identify Personal Information where it is no longer required, unless we are required or authorised by law to retain the information. However, we may retain Personal Information (including basic registration information) in accordance with documentation retention and destruction laws.
8. Accessing and correcting your Personal Information
a. We shall use our reasonable endeavours to keep your Personal Information accurate, up-to-date and complete. You have the right to access any Personal Information we hold about you, subject to some exceptions under the Privacy Act.
b. You can access, or request that we correct, your Personal Information by writing to us using the details below. We may require proof of identity. If we do not allow you to access any part of your Personal Information, we will tell you why in writing.[u]
c. We will not charge you for requesting access to your Personal Information, but may charge you for our reasonable costs in supplying you with access to this information.
d. We will endeavour to respond to your request for access or correction within 30 days from your request.
9. Cookies and Analytics
9.1. Cookie policy
a. We use small text files placed on your computer called ‘cookies’ to collect standard log and visitor behaviour information in an anonymous form. We use this information to analyse how visitors use our website and the CabinKeep App and to compile statistical reports on website activity.
b. You can set your computer to reject cookies, but this may affect your ability to use certain parts of our website and the CabinKeep App.
9.2. Apple Analytics
a. Services that the CabinKeep App may use from time to time include Apple Analytics, which transmits app traffic data to Apple servers. Apple Analytics does not identify individual users or associate your IP address with any other data held by Apple. We use reports provided by Apple Analytics to help us understand traffic and usage on the CabinKeep App.
b. By using the CabinKeep App, you consent to Apple processing your data in the manner described in Apple’s Privacy Policy (https://www.apple.com/legal/privacy/) and for the purposes set out in this Privacy Policy.
9.3. Google Analytics
c. Services that the CabinKeep App may use from time to time include Google Analytics, which transmits website traffic data to Google servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand traffic and usage on our website. By visiting and using the CabinKeep App, you consent to Google processing your data in the manner described in Google’s Privacy Policy (www.policies.google.com/privacy) and for the purposes set out in this Privacy Policy.
d. Google may pass on cookies to its partners and other third parties to achieve its purposes. For more information on how Google uses the information collected from cookies, and how you can opt out of this feature please see Google’s Privacy Policy. You can also view Google Analytics currently available opt-out (see https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh/related?hl=en-GB).
10. Privacy complaints
a. If you have any issues about this Privacy Policy or the way we handle your Personal Information, please contact us using the details below and provide full details of your complaint and any supporting documentation.
b. At all times, privacy complaints:
i. will be treated seriously;
ii. will be dealt with promptly;
iii. will be dealt with in a confidential manner; and
iv. will not affect your existing obligations or your commercial arrangements with us.
c. We will endeavour to:
i. respond to you within 14 business days; and
v. investigate and attempt to resolve your concerns within 30 business days or any longer period necessary and notified to you by our Privacy Officer.
d. If you are dissatisfied with the outcome of your complaint, you may refer the complaint to Office of the Australian Information Commissioner.
11. How to contact us
We can be contacted by email at contact@thehousehubapp.com
12. Changes to this Privacy Policy
a. From time to time, it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on the CabinKeep App.
b. We encourage you to check the CabinKeep App from time to time to ensure you are familiar with our latest Privacy Policy.