Laava Corporate Privacy Policy

1. About this Corporate Privacy Policy

We think so many companies can do better with regards to consumer privacy and we want to lead the way.  Just because you can collect data, doesn’t mean you should. We value and respect your privacy and take the protection of your personal information seriously.

This Corporate Privacy Policy is NOT about what happens to you or your personal information when you scan a Laava Fingerprint.  Our policy of not collecting personal information when scanning Laava Fingerprints is covered in our separate Privacy Manifesto.  

This Corporate Privacy Policy sets out how Laava ID Pty Ltd (ABN 99 617 775 578) (Laava, we, our, us) handles your personal information in the limited circumstances in which we have to collect personal information, such as if you apply for a job with us, or seek to invest in, or work with Laava (as a representative of a partner, customer, supplier or service provider), or if you contact our help desk or submit query.  

It outlines the personal information we collect about you, when and how we use it.  It also outlines your privacy rights as an individual and how to contact us if you have any privacy concerns.  This Privacy Policy may change from time to time and so you may wish to review it regularly.

2. When do we collect your personal information?

As set out in our Privacy Manifesto, we do not collect any personal information in connection with the scanning of a Laava Fingerprint.

We also do not see or collect your personal information when you choose to share personal information with the owners of brands that use our Laava Fingerprints (Brands).  This is also covered in our Privacy Manifesto.

However, there are some limited circumstances in which we need to collect your personal information directly from you, including when you:

  • communicate with us by telephone, email, online (including through our website or help desk), or in person;

  • when you apply for a position with us;

  • when you apply to become an investor; or

  • when you interact with us as a potential or ongoing customer, partner, supplier or service provider.

3. What personal information do we collect and handle?

Personal information is any information or opinion (whether true or not, and whether recorded in a material form or not) about you as an identified individual, or an individual who is reasonably identifiable.  The types of personal information we collect and handle may include:

  • contact information, such as your name, address, phone number, email and/or IP address;

  • information about your role within your organisation, if you are an existing or potential partner, customer, supplier or service provider of ours;

  • financial and other relevant details you share with us if you apply to be an investor;

  • if you apply for a position with us, we might collect information about your qualifications, skills experience, character, screening checks and employment history; and

  • other information you provide to us via our help desk (or in any query you send to us).

4. Why do we collect your personal information?

We collect, hold, use and disclose personal information primarily to respond to queries, to consider your application for a position with us, or to consider you as an investor, customer, supplier or partner of ours.  We may also collect your personal information for related reasons, including:

  • administrative purposes including record-keeping and internal reporting;

  • to communicate with you;

  • for marketing purposes; and

  • to comply with applicable laws and regulations.

5. Who might we disclose your personal information to?

In the limited circumstances listed in section 2 above where we have collected your personal information, we may disclose your personal information to third parties.  The types of third parties with whom we exchange personal information include:

  • our service providers, including accounting, auditing, legal, banking, payment, delivery, data hosting, research, recruitment, insurance, superannuation, payroll, training and technology services;

  • for people who apply to work with us, referees and screening check providers (e.g. for background, eligibility to work, suitability and criminal record checks); and

  • to law enforcement agencies and other organisations where required or permitted by law.

We will not disclose your personal information to any overseas recipients. However, we may store your personal information with secure data hosting providers such as Google, who may store that information in the following locations https://www.google.com/about/datacenters/inside/locations/?hl=en.  Where possible we will require that your personal information remain stored in Australia.  If we need to disclose your personal information to any overseas recipients, we will update this Privacy Policy by specifying the countries in which they are located.   

6. What if we can’t collect your personal information?

If you do not provide us with the personal information when required, we may not be able to:

  • consider your application to join us as an employee;

  • consider your application to become an investor, customer, partner; supplier or service provider; and

  • respond to your queries or requests for information.

7. Visitors to our website and cookies

A browser cookie is a small piece of data that is stored on your device to help websites and mobile applications remember things about you.  Although we don’t use cookies in the Laava mobile app, we do use cookies on our website. Cookies help us see which parts of our website are the most popular, which allows us to focus on improving those aspects of the website that will improve your experience, and to provide you with a better, more intuitive, and satisfying experience.  Your browser or device may allow you to block or otherwise limit the use of cookies. You may also be able to remove cookies from your browser.

To help improve the service we provide through our website, certain information may be collected from your browser.  This information is collected as statistical information and includes the IP address, browser type, language and access times.  In many cases, the tools used on our website record information in a way that does not identify you as an individual. In other cases, information may be personal information in which case this Privacy Policy will apply.

Our website may also use third party website tools from time to time, for example Google Analytics and online survey tools.  For more about how Google collects and processes data, please see Google’s privacy policy and their information at www.google.com/policies/privacy/partners/.

8. How do we protect your personal information?

We take all reasonable steps to keep personal information protected from loss, interference, misuse or unauthorised access, modification or disclosure. These steps may include access controls, encryption, and secure premises. We store personal information in both physical and electronic form, sometimes with the assistance of third parties such as data hosting providers.

9. Direct marketing communications

From time to time, if you have opted-in to receive marketing information from us, we may send you direct marketing communications regarding our services.

We may contact you by electronic messages (e.g.  email), online (e.g. through our website), by mail, and by other means, unless you subsequently opt-out or we are subject to legal restrictions.  You may opt-out of marketing communications, by contacting us using the contact details below.

10. How can you access and correct your personal information?

The accuracy of the personal information we hold and use is important to us.  We take reasonable steps to ensure that the personal information we handle is accurate, complete and up-to-date.  To help us keep your personal information accurate, please let us know if there are any errors or changes in your personal information.

You can request access to and correction of the personal information we hold about you at any time by contacting our Privacy Officer via the contact details at the bottom of this Privacy Policy.  In most cases, we can help you promptly and informally with these requests. In other cases, we may need to verify your identity and ask you to make your request in writing.

11. How can you make a privacy complaint?

You can contact our Privacy Officer using the contact details at the bottom of this Privacy Policy if you have any concerns about how we have handled your personal information.  We will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concern, and we may need to engage or consult with other parties to investigate and deal with your issue.  We will keep records of your request and any resolution. If you are not satisfied with the manner in which we have dealt with your complaint, you may contact the Office of the Australian Information Commissioner.

12. How to contact us

If you have any questions or comments about this Privacy Policy, please don’t hesitate to contact us as follows:

Contact: Privacy Officer

Address: Ground 1, 1 Francis Street,
Darlinghurst NSW 2010
Australia

Email: privacy@laava.id

Phone: +61 2 6190 0618

Last updated: 26 November 2018