Last K Ventures / Groundfloor™ Privacy Policy

V1 – April 2018

In this Privacy Policy, ‘us’ ‘we’ or ‘our’ means Last K Ventures Pty Ltd
(ACN 613 910 571), operating as Groundfloor™. We are committed to
respecting your privacy. Our Privacy Policy sets outs out how we collect,
use, store and disclose your personal information.

By providing personal information to us, you consent to our collection, use
and disclosure of your personal information in accordance with this Privacy
Policy and any other arrangements that apply between us. We may change our
Privacy Policy from time to time by publishing changes to it on our
website. We encourage you to check our website periodically to ensure that
you are aware of our current Privacy Policy.

Personal information includes information or an opinion about an individual
that is reasonably identifiable. For example, this may include your name,
age, gender, postcode and contact details.

What personal information do we collect?

We may collect the following types of personal information:

  • name;
  • mailing or street address;
  • email address;
  • telephone number and other contact details;
  • age or date of birth;
  • credit card information;
  • your device ID, device type, geo-location information, computer and
    connection information, statistics on page views, traffic to and from the
    sites, ad data, IP address and standard web log information;
  • details of the products and services we have provided to you or that you
    have enquired about, including any additional information necessary to
    deliver those products and services and respond to your enquiries;
  • any additional information relating to you that you provide to us
    directly through our website or app or indirectly through your use of our
    website or app or online presence or through other websites or accounts
    from which you permit us to collect information;
  • information you provide to us through customer surveys; or
  • any other personal information that may be required to facilitate your
    dealings with us.

We may collect these types of personal information either directly from
you, or from third parties. We may collect this information when you:

  • register or are registered on our website, web application or mobile app;
  • communicate with us through correspondence, chats, email, or when you
    share information with us from other social applications, services or
    websites;
  • interact with our sites, services, content and advertising; or
  • invest in our business or enquire as to a potential purchase in our
    business.

In addition, when you apply for a job or position with us we may collect
certain information from you (including your name, contact details, working
history and relevant records checks) from any recruitment consultant, your
previous employers and others who may be able to provide information to us
to assist in our decision on if to make you an offer of employment or
engage you under a contract. This Privacy Policy does not apply to acts and
practices in relation to employee records of our current and former
employees, which are exempt from the Privacy Act.

Why do we collect, use and disclose personal information?

We may collect, hold, use and disclose your personal information for the
following purposes:

  • to enable you to access and use our mobile app, web application and
    lockers;
  • to operate, protect, improve and optimize our business and our users’
    experience, such as to perform analytics, conduct research and for
    advertising and marketing;
  • to send you service, support and administrative messages, reminders,
    technical notices, updates, security alerts, and information requested by
    you;
  • to send you marketing and promotional messages and other information that
    may be of interest to you, including information sent by, or on behalf of,
    our business partners that we think you may find interesting;
  • to administer rewards, surveys, contests, or other promotional activities
    or events sponsored or managed by us or our business partners;
  • to comply with our legal obligations, resolve any disputes that we may
    have with any of our users, and enforce our agreements with third parties;
    and
  • to consider your employment application.

We may also disclose your personal information to a trusted third party who
also holds other information about you. This third party may combine that
information to enable it and us to develop anonymized consumer insights so
that we can better understand your preferences and interests, personalize
your experience and enhance the products and services that you receive.

Do we use your personal information for direct marketing?

We and/or our carefully selected business partners may send you direct
marketing communications and information about our services. This may take
the form of emails, SMS, mail or other forms of communication, in
accordance with the Spam Act and the Privacy Act. You may opt-out of
receiving marketing materials from us by contacting us using the details
set out below or by using the opt-out facilities provided (e.g. an
unsubscribe link).

To whom do we disclose your personal information?

We may disclose personal information for the purposes described in this
privacy policy to:

  • our employees and related bodies corporate;
  • third party suppliers and service providers (including providers for the
    operation of our websites and/or our business or in connection with
    providing our products and services to you);
  • professional advisers, dealers and agents;
  • payment systems operators (e.g. merchants receiving card payments);
  • our existing or potential agents, business partners or partners;
  • our sponsors or promoters of any competition that we conduct via our
    services;
  • anyone to whom our assets or businesses (or any part of them) are
    transferred;
  • specific third parties authorised by you to receive information held by
    us; and/or
  • other persons, including government agencies, regulatory bodies and law
    enforcement agencies, or as required, authorised or permitted by law.

Disclosure of personal information outside Australia

We may disclose personal information outside of Australia to our software
partner based in Singapore.

When you provide your personal information to us, you consent to the
disclosure of your information outside of Australia and acknowledge that we
are not required to ensure that overseas recipients handle that personal
information in compliance with Australian Privacy Law. We will, however,
take reasonable steps to ensure that any overseas recipient will deal with
such personal information in a way that is consistent with the Australian
Privacy Principles.

Using our website and cookies

We may collect personal information about you when you use and access our
website.

While we do not use browsing information to identify you personally, we may
record certain information about your use of our website, such as which
pages you visit, the time and date of your visit and the internet protocol
address assigned to your computer.

We may also use ‘cookies’ or other similar tracking technologies on our
website that help us track your website usage and remember your
preferences. Cookies are small files that store information on your
computer, TV, mobile phone or other device. They enable the entity that put
the cookie on your device to recognise you across different websites,
services, devices and/or browsing sessions. You can disable cookies through
your internet browser but our websites may not work as intended for you if
you do so.

We may also use cookies to enable us to collect data that may include
personal information. For example, where a cookie is linked to your
account, it will be considered personal information under the Privacy Act.
We will handle any personal information collected by cookies in the same
way that we handle all other personal information as described in this
Privacy Policy.

Security

We may hold your personal information in either electronic or hard copy
form. We take reasonable steps to protect your personal information from
misuse, interference and loss, as well as unauthorised access, modification
or disclosure and we use a number of physical, administrative, personnel
and technical measures to protect your personal information. For example,
we have software security around our system and have tested with an
external provider. However, we cannot guarantee the security of your
personal information.

Links

Our website may contain links to websites operated by third parties. Those
links are provided for convenience and may not remain current or be
maintained. Unless expressly stated otherwise, we are not responsible for
the privacy practices of, or any content on, those linked websites, and
have no control over or rights in those linked websites. The privacy
policies that apply to those other websites may differ substantially from
our Privacy Policy, so we encourage individuals to read them before using
those websites.

Accessing or correcting your personal information

You can access the personal information we hold about you by contacting us.
Sometimes, we may not be able to provide you with access to all your
personal information and, where this is the case, we will tell you why. We
may also need to verify your identity when you request your personal
information.

If you think that any personal information we hold about you is inaccurate,
please contact us and we will take reasonable steps to ensure that it is
corrected.

Making a complaint

If you think we have breached the Privacy Act, or you wish to make a
complaint about the way we have handled your personal information, you can
contact us at [email protected]. Please include your name, email
address and/or telephone number and clearly describe your complaint. We
will acknowledge your complaint and respond to you regarding your complaint
within a reasonable period. If you think that we have failed to resolve the
complaint satisfactorily, we will provide you with information about the
further steps you can take.

Contact Us

For further information about our Privacy Policy or practices, or to access
or correct your personal information, or make a complaint, please contact
us using the details set out below:

Chris van Raay
[email protected]

Effective:
February 2018