Privacy Policy

1. Introduction

Keyvision Pty Ltd (ABN 50 061 055 176) (Keyvision, we, our, us) understands the importance of protecting the privacy of an individual’s personal information. This privacy policy sets out how we aim to protect the privacy of your personal information including with respect to your access to and use of:

• our website located at https://www.kindredbykeyvision.com.au/;

• the cloud based platform made available to subscribers and other users via our website or any other electronic means;

• any mobile application we may make available to you from time to time, including in connection with our platform.

Where the GDPR applies to our collection and handling of your personal information, we are the data controller. In some circumstances, a third party may be the controller of your personal information, in which case we are the data processor.

2. What is personal information?

For the purposes of this privacy policy, personal information means, to the extent applicable:

• personal information as defined in the Privacy Act 1988 (Cth) (Privacy Act), the 13 Australian Privacy Principles in the Privacy Act and all relevant Australian privacy laws; and

• personal data as defined in the EU General Data Protection Regulation (2016/679) (GDPR), the UK Data Protection Act 2018 and any legislation that replaces or supersedes them.

For instance, the Privacy Act states that personal information includes information or an opinion about an identified, or reasonably identifiable, individual and the GDPR states that personal data is any information relating to an identified or identifiable natural person.

3. What kinds of personal information does Keyvision collect?

We may collect your personal information during the provision of our services to you, including the provision of our cloud based software solutions, platform and mobile app.

Generally, the kinds of personal information Keyvision collects are:

(a) contact, identification and verification information such as your name, age, gender, address, telephone number and email address;

(b) contact and identification information about you provided to us via online forms through our website, platform or mobile app;

(c) information relevant to creating and updating your account with us, including through our website, platform or mobile app;

(d) information relating to any request or notification you provide us through our website, platform or mobile app, including in relation to reporting any problems with a property you are residing at or visiting, or submitting a help desk or service ticket in relation to the mobile app or platform;

(e) where you are a tenant in a residential premises where the building manager has subscribed to our platform, details relating to your lease or your relationship with the building owner;

(f) where you interact with us through our mobile app or platform, your IP address, user booking information, help desk and inquiry information, concierge and parcel delivery information, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, and geolocation where platform or mobile app functionality requires location services to be activated;

(g) where you are acting on behalf of another entity (whether as an employee, director or other representative), details of that entity and your relationship with it;

(h) banking details and financial information as required for our functions and activities, for example, to facilitate payments under our online platform or through our mobile app and in respect of contractors engaged by Keyvision;

(i) other information required for Keyvision’s functions and activities.

In some circumstances Keyvision may also hold other personal information provided by you.

4. How does Keyvision collect personal information?

Generally, Keyvision collects your personal information directly from you, through the completion of an online form, an interaction or exchange in person or by way of telephone, email, or through the use of our website, platform or mobile app.

There may be occasions when Keyvision collects your personal information from other sources such as from:

(a) an entity you represent (including but not limited to your employer or a company of which you are a director), where necessary for Keyvision to provide its products or services to that entity through you or where necessary for that entity to supply products or services to Keyvision;

(b) organisations that facilitate payment or identity verification services in connection with your use of our platform;

(c) an information services provider;

(d) a publicly maintained record or other publicly available sources of information including social media and similar websites, such as Facebook;

(e) via automated means when you visit our website or use our platform or mobile app, with such information generally being limited to your IP address, cookie information, geolocation of your device, your web activity and activity in relation to your use of our platform and mobile app;

(f) a government agency.

Generally, Keyvision will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect your personal information from you.

5. Why does Keyvision need your personal information?

Keyvision collects, holds, uses and discloses your personal information where it is reasonably necessary for the purposes of:

(a) providing the services you have requested, ordered or purchased from Keyvision including:

(i) to enable access to our online platform or mobile app, and provide associated services;

(ii) to process transactions you may enter with us, members and other users via our online platform;

(iii) to enable you to communicate with other members and users, including but not limited to sending them messages or other information during any facility booking process or other member communication functionality;

(iv) to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and any information requested by you;

(v) for invoicing purposes;

(vi) to respond to any inquiries, feedback or complaints made by you;

(b) providing Keyvision’s services to you or the organisation you represent and all associated purposes;

(c) enabling Keyvision to promote its products and services to you;

(d) assisting Keyvision to improve its products and services;

(e) accounting, billing and other internal administrative purposes;

(f) otherwise managing Keyvision’s internal business operations and processes; and

(g) any other legal requirements.

Keyvision may also use your personal information for purposes related to the above purposes and for which you would reasonably expect Keyvision to do so in the circumstances, or where you have consented, or the use is otherwise in accordance with law.

The principal legal grounds for Keyvision’s use and disclosure of your personal information are as follows:

• Consent: where you have consented to Keyvision’s use or disclosure of your personal information, including where we may be required to ask for your consent to process your personal information for certain purposes (such as automated information collection by our website using cookies and other technologies).

• Contract performance: where Keyvision is required to collect and handle your personal information to provide you (or the organisation you represent) with the products and services that Keyvision has contractually agreed to provide to you (including as a subscriber or user through our online platform and mobile app);

• Legal obligation: where Keyvision needs to use or disclose your personal information to comply with its legal obligations.

Where personal information is used or disclosed, Keyvision takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Keyvision. However, without certain information from you, Keyvision may not be able to provide its products and/or services to you.

6. To whom does Keyvision disclose your personal information?

Keyvision discloses your personal information for the purpose for which Keyvision collects it. That is, generally, Keyvision will only disclose your personal information for a purpose set out at paragraph 4. This may include disclosing your personal information to:

(a) members of our corporate group, including subsidiaries and any holding entity;

(b) where you are a tenant or other building user, third party organisations who provide products or services to persons in your building, to the extent they require personal information for the purpose of performing their obligations under contracts with you;

(c) third parties engaged to perform administrative or other business management functions, including debtor management, delivery and courier companies, call centres, mailing houses, financial institutions, mercantile agents, and web-hosting organisations;

(d) users of the platform through your public profile page or if you post content that contains personal information in a community forum or using other features on the platform that are visible to the public;

(e) our professional advisors, agents, contractors, consultants and related bodies corporate.

Keyvision’s disclosures of your personal information to third parties are on a confidential basis and/or otherwise in accordance with law. Keyvision may also disclose your personal information with your consent or if disclosure is required or authorised by law.

7. Direct marketing

Keyvision may use and disclose your personal information in order to inform you of products and services that may be of interest to you. In the event you do not wish to receive such communications, you can opt-out by contacting Keyvision via the contact details set out in paragraph 11 or through any opt-out mechanism contained in any marketing communication to you.

8. Security of your personal information

Keyvision takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference, and loss and from unauthorised access, modification, or disclosure. Keyvision holds personal information in both hard copy and electronic forms in secure databases on secure premises, accessible only by authorised staff.

Keyvision will destroy or de-identify personal information in circumstances where it is no longer required, unless Keyvision is otherwise required or authorised by law to retain the information.

9. Can you access and correct the personal information that Keyvision holds about you?

Keyvision takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading. Under relevant privacy laws, you have a right to access and seek correction of your personal information that is collected and held by Keyvision. If at any time you would like to access or correct the personal information that Keyvision holds about you, or you would like more information on Keyvision’s approach to privacy, please contact Keyvision’s Privacy Compliance and Data Protection Officer on the details set out in paragraph 11 below.

Keyvision will grant access to the extent required or authorised by the relevant privacy laws or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.

To obtain access to your personal information:

(a) you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;

(b) Keyvision requests that you be reasonably specific about the information you require; and

(c) Keyvision may charge you a reasonable administration fee, which reflects the cost to Keyvision for providing access in accordance with your request.

Keyvision will endeavour to respond to your request to access or correct your personal information within 30 days from your request or as otherwise required by law.

10. Links

Keyvision’s website may, from time to time, contain links to the websites of other organisations which may be of interest to you. Such links are provided as a convenience to you and should not in any way be interpreted as an endorsement of any company, content or product that may be linked. Any access to a third party website that is linked to Keyvision’s website is at your own risk and Keyvision has no control over and is not responsible for the accuracy, validity or ownership of any content of a linked site and the privacy practices of those linked websites. You should check those websites for their respective privacy policies.

11. Cookies

Keyvision’s website uses ‘cookies’ which are small pieces of information sent from the website and stored by your browser on your computer’s hard drive. Cookies that Keyvision uses enable its systems to provide features of its services and allow you to visit its website without re-entering your username and/or password, personalize and improve your experience, and to improve the functionality and user-friendliness of its services and monitor how its website is used through your computer.

This information is used by Keyvision to improve and tailor its website functionality and better understand how you interact with Keyvision’s services and to monitor aggregate usage and web traffic routing on its website. You can modify your browser setting by editing your browser options to reject Keyvision’s cookies or to prompt you before accepting a cookie. However, if a browser does not accept cookies or if you reject a cookie, some portions of Keyvision’s online services may not function properly.

The Keyvision platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain log data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.

12. Your other privacy rights

If you are based in the European Economic Area or the GDPR otherwise applies, you have the following rights in connection with our processing of your personal information:

• The right to access the personal information we hold about you. We will generally make your information available to you within 30 days of your written request.

• The right to have your information corrected. We will rectify any incorrect or inaccurate information we hold about.

• The right to have your information erased. Where we do not need your personal information to perform our contractual obligations or have another legal basis for using your personal information, we will delete your personal information on request.

• The right to object to us processing your personal information. If we process your personal information on the basis that we have a legitimate interest to do so, you may object to this unless we have a reason that justifies overriding your interests of rights.

• The right to withdraw consent to processing. You may withdraw any consent given to us to processing your personal information by contacting us.

• The right to data portability. Where we hold your personal information with your consent or to perform a contract with you, you may request us to transmit this information to another party.

13. How to contact us

For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications, please contact Keyvision’s Privacy Compliance and Data Protection Officer at:

sales@kindredbykeyvision.com or by submitting a form through www.kindredbykeyvision.com

14. Privacy complaints

Please direct all privacy complaints to Keyvision’s Privacy Compliance and Data Protection Officer. At all times, privacy complaints:

(a) will be treated seriously;

(b) will be dealt with promptly;

(c) will be dealt with in a confidential manner; and

(d) will not affect your existing obligations or affect the commercial arrangements between you and Keyvision.

Keyvision’s Privacy Compliance Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, you may refer the complaint to the Office of the Australian Information Commissioner or the relevant privacy regulatory body in your jurisdiction.

If you are based in the European Economic Area, you have to the right to lodge a complaint with the local data protection authority if you believe we have not complied with applicable data protection and privacy laws.