Privacy Policy


1.     Introduction

 

(a) This website application (hirespyspaces.com.au) (the HireSpy Spaces Platform) is created and controlled by HireSpy Pty Ltd trading as HireSpy Spaces (ACN 663 042 224) (we, us or our).


(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) The HireSpy Spaces Platform is a portal or online marketplace through which Guests can hire Spaces made available by Hosts on, or via, the HireSpy Spaces Platform. By accessing and using the HireSpy Spaces Platform or services you agree to this Privacy Policy. 


(d) This Privacy Policy outlines how we collect, store, 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.


(e) For the purposes of this Privacy Policy:


(i) Guest means a user of the HireSpy Spaces Platform that hires or rents Space from a Host on, or via, the HireSpy Spaces Platform; 


(ii) Host means a user of the HireSpy Spaces Platform that advertises and provides Space to a Guest on, or via, the HireSpy Spaces Platform; and


(iii) Space means any property, premises, vehicle, caravan, boat or other space or locations (any part thereof) owned, leased or licensed to a Host and which is made available to hire by a Guest for a period not exceeding 24 hours on, or via, the HireSpy Spaces Platform.


2.     The information we collect about you


2.1.  Personal information


(a) Personal information has the same meaning that it has under Privacy Laws, 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 collect and use Personal Information and Non-Personal Information from Hosts and Guests who access and use the HireSpy Spaces Platform, our products and services and any other individual who interacts with us.


(c) We will only collect and hold Personal Information about Hosts and Guests that are reasonably necessary to undertake our business activities and functions, to make the HireSpy Spaces Platform, our products and services available to Hosts and Guests, or as otherwise permitted by law. 


2.2.  Hosts and Guests 


We collect and hold Personal Information about Hosts and Guests as well as information or data that does not contain Personal Information. For example, the type of Personal Information and Non-Personal Information that we collect includes:


(a) Registration, account and profile details and information (for example, full name, date of birth, mobile number, profile picture and email address); 


(b) account credentials (for example, any username and password created by you as a user of the HireSpy Spaces Platform);


(c) Space profile (information relating to your space, such as location, the type or category of Space, amenities and extras at the Space, pictures of the Space, hire fees, availability and user rules as set out in the HireSpy Platform Terms and Conditions; 


(d) any other content, information and other data that you post or submit on, or via the HireSpy Spaces Platform;


(e) payment or billing details (for example, credit card and debit card);


(f) information relating to your dealings, or enquiries you have made, with us, including information about the HireSpy Spaces Platform, our products and services or complaints you have raised with us about a Space via our flagging system; and

     

(g) information about Spaces that you are interested in hiring from Hosts (including saved favourites) and Spaces that you have hired on, or via, the HireSpy Spaces Platform;


(h) other information that you provide to us or that we may collect in the course of our relationship with you.


2.3.  Other information


(a) 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 Hosts and Guests use the HireSpy Spaces Platform.


(b) information regarding your access and use of the HireSpy Spaces Platform, including location information, your computer’s internet protocol (IP) address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on the HireSpy Spaces Platform, dates, and times of visits to the HireSpy Spaces Platform and other usage statistics; 


(c) 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.


2.4.  Sensitive Information


(a) We do not collect your Sensitive Information (as defined by the Privacy Act) directly from you. However, some of our services are automated and we may not recognise that you have accidentally provided us with Sensitive Information or third parties may provide us with Sensitive Information about you from time to time.


(b) If you have accidentally sent us Sensitive Information, please contact us using the contact details set out in section 11 below.

 

3.     How we collect 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: 


(i) in the case of Hosts, when you:

(A) download, access and use the HireSpy Spaces Platform (including when you open an account or create or update your account or Space profile on, or, via, the HireSpy Spaces Platform); 

(B) upload, publish or display information about your Space or otherwise submit information or data on, or via, the HireSpy Spaces Platform; 

(C) use the HireSpy Spaces Platform to lease Spaces to a Guest on, or via, the HireSpy Spaces Platform; or

(D) contact, interact or communicate with Guests on, or, via, the HireSpy Spaces Platform.


(ii) in the case of Guests, when you:

(A) download, access and use the HireSpy Spaces Platform (including when you open an account or create or update your account on, or, via, the HireSpy Spaces Platform);

(B) use the HireSpy Spaces Platform to book and hire Spaces from a Host on, or, via, the HireSpy Spaces Platform; or

(C) contact, interact or communicate with a Host on, through, or, via, the HireSpy Spaces Platform.


(iii) contact or correspond with us via email or telephone or when you submit a query through our website in relation to the HireSpy Spaces Platform, the Spaces and our products and services.

(iv)  when you visit the website or submit information through the HireSpy Spaces Platform (including on, or via, our related social media accounts), contact us, complete any online forms or documents or when you enter or participate in competitions, promotions, events, sweepstakes, surveys and questionnaires; and


(v) when you otherwise contact, interact or communicate with us (such as by telephone, email or in person) with a query or request or make a comment on our social media sites or lodge a complaint; and


(vi) when otherwise legally authorised or required to do so.

(A) By providing your Personal Information to us, you acknowledge and consent to the supply of that information subject to the terms of this Privacy Policy. 


3.2.  Collection from third parties


(a) We may also collect Personal Information and Non-Personal Information about you from publicly available sources and third parties, including:

(i)when you provide your Personal Information to our Authorised Affiliates or other third parties;

(ii) in the case of Hosts, from Guests; 

(iii) in the case of Guests, from Hosts;

(iv) if you use: 

(A) our social media sites or applications, pages or plugins; or 

(B) third party products or services that interact with the HireSpy Spaces Platform, our products, services or website.


(b) If you provide us with Personal Information about another individual (as their authorised representative), we rely on you to: 

(i) inform them that you are providing their Personal Information to us; and  

(ii) advise them that they can contact us for further information. 


(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. 


(d) Upon our request, you must also assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.


3.3.  Third party payment processor


We use a third party payment processor to process payments made to us. In connection with the processing of such payments, we do not collect, process, use, share, store or disclose any Personal Information or payment information (such as credit card and bank account details). Rather, all such information is provided directly to our third party processor, Stripe, whose use of your Personal Information is governed by their privacy policy, which may be viewed at www.stripe.com/au/privacy


4.          How we use 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. 


(b) In particular, we use, process and disclose your Personal Information and Non-Personal Information to: 

(i) provide or deliver the HireSpy Spaces Platform and our products and services to you, including, without limitation, to provide the means through which Guests can access, schedule, order, hire, rent and use Spaces offered, or made available by, Hosts on, or via, the HireSpy Spaces Platform;

(ii) informing you about the HireSpy Spaces Platform, our products or services or about offers, competitions, promotions, events, sweepstakes, surveys, questionnaires about us, the HireSpy Spaces Platform 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 HireSpy Spaces Platform and our products and services, informing you about scheduled maintenance or outages and managing our relationship with you or to otherwise investigate complaints about the HireSpy Spaces Platform, Hosts, Guests and/or the Spaces;

(iv) share with our Authorised Affiliates;

(v) charge and bill you to access and use the HireSpy Spaces Platform and Spaces;

(vi) verify your identity;

(vii) for internal record keeping;

(viii) for direct marketing purposes (see below); 

(ix) complying with our legal and regulatory obligations;

(x) for any purpose to which you have consented; and

(xi) for any other purpose notified to you at the time of collection.


(c) 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 Authorised Affiliates


(a) In order to provide or deliver the HireSpy Spaces Platform, the Spaces, products or services to you, we may disclose your Personal Information and Non-Personal Information to:

(i) our related bodies corporate, business partners, service providers, third party contractors, agents or suppliers; 

(ii) authorised external service providers who perform functions on our behalf, such as internet and technology services providers, app and website software developers and any other service provider we use to improve the functions and features of the HireSpy Spaces Platform, hosting and data storage companies, marketing, advertising and security service providers, third party payment processors, fulfilment companies, credit reporting agents, debt collection agents, market research and recruitment service providers; and

(iii) external business advisors, such as auditors, lawyers, insurers, financiers.   

(collectively, Authorised Affiliates).


(b) In the case of Guests, we may share your Personal Information with Hosts for the purposes outlined in section 4.1 above and in the case of Hosts, we may share your Personal Information with Guests for the purposes outlined in section 4.1 above. For example, for safety purposes, we share the Host’s name, email and phone number to the Guest 7 days prior to the booking date and the Host’s location will be released to the Guest 24 hours prior to the booking date. 


(c) We may also disclose your Personal Information and Non-Personal Information:

(i) to any other party with your consent and direction; 

(ii) to law enforcement bodies or regulatory authorities to assist with their functions, or as otherwise required or authorised by law; or

(iii) where we consider necessary to comply with any applicable law, regulation, legal process, governmental request or industry code or standard. 


(d) When we disclose your Personal Information or Non-Personal Information to any of our Authorised Affiliates, we will ensure they have their own privacy policies in place. These Authorised Affiliates are not permitted to use the information for any purpose other than the purpose for which they have been given access. 


(e) Our Authorised Affiliates may also provide us with Personal Information and Non-Personal Information collected from you. If you disclose Personal Information to Authorised Affiliates, we rely on you to provide the Authorised Affiliates with consent for us to collect, store, use, process, alter and disclose your Personal Information.


4.3.  Overseas disclosure


(a) In the course of providing you with access to, and use of, the HireSpy Spaces Platform, our products or services, it may become necessary or desirable to disclose Personal Information to Authorised Affiliates 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:

(i) our third party payment processor; and

(ii) our website and app developers (including website app testers) located in Australia, Malaysia and the Philippines.


(a) The laws where these overseas recipients 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 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.


(b) If you have any questions in relation to the transfer of your Personal Information, please contact us using the contact details set out in section 11 below.


4.4.  Disclaimer


(a) We will not disclose your Personal Information to any third party (other than our Authorised Affiliates) 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 HireSpy Spaces Platform.


(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.      Notifiable Data Breaches 


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 laws as set out in the Privacy Act.


6.     Marketing communications


6.1.  Direct marketing


(a) We may use and disclose your Personal Information to send you information about the HireSpy SpacesPlatform, the Spaces or information about the 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 HireSpy Spaces Platform.


6.2.  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 on the HireSpy Spaces Platform.


6.3.  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.


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 and Non-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 Authorised Affiliates 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 HireSpy Spaces Platform.


(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 in circumstances where it is no longer required, unless we are required or authorised by law to retain the information.


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. 


(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 45 days from your request.


9.     Cookies Policy


9.1.  Cookies


(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 HireSpy Spaces Platform and to compile statistical reports on website activity. You can set your computer’s browser settings to reject cookies, but this may affect your ability to use certain parts of our website and/or the HireSpy Spaces Platform.


(b) We may also log your IP address. Your IP address is your computer’s electronic Internet address. We may collect your IP address to see trends, run our website, track user movements, and gather broad demographic information.


9.2.  Google Analytics


(a) Services that the HireSpy Spaces Platform 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 using the HireSpy Spaces Platform, 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.


(b) 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 function (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) Our Privacy Officer will endeavour to:

(i) respond to you within 15 business days; and

(ii) investigate and attempt to resolve your concerns within 45 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

 

If you have any complaints or issues you wish to raise with us regarding the way we have handled your Personal Information, or would like to discuss any issues about our Privacy Policy, please contact us directly by email at contact@hirespyspaces.com.au


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 our website or on the HireSpy Spaces Platform.


(b) We encourage you to check our website or the HireSpy Spaces Platform from time to time to ensure you are familiar with our latest Privacy Policy.