Ailo Pty Ltd (ACN 603 174 714) and its related bodies corporate, including Ailo Pay Pty Ltd (ACN 621 914 163) (we, our, us) recognises the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our Privacy Policy and it tells you how we collect, use, disclose and manage your personal information.

When used in this Privacy Policy, the term 'personal information' has the meaning given to it in the Privacy Act 1988 (Cth) (the Privacy Act). In general terms, personal information is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If any of the information we collect personally identifies you, or you are reasonably identifiable from it, it will be considered personal information.

What personal information do we collect and hold?

If you are an Ailo user 

The Ailo platform (Ailo) is used by many different types of people. Users include:

If you are a user of Ailo, we collect information about you to enable you to make use of the services offered via Ailo. This information may include:

• your contact details such as name, address, email and telephone number; 
• identification information such as your date of birth and occupation, and identification documents such as your drivers' licence and passport; 
• your nominated credit card and/or bank account details (when you use our payments service, Ailo Pay); 
• information about your use of Ailo (for example, the relationships and interactions you have with other Ailo users, and the payments you make and receive); and 
• any other data you share, upload or create when interacting with Ailo. 

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 interact with and use our website and mobile applications.

If you, or your employer, does business with us or has other dealings with us, we collect information about you to facilitate those arrangements. This information may include your name, position, contact details, and any other information you provide. 

If you are an employee or a job applicant, we collect information about you to administer your employment or process your application. This may include qualification and identification information, residency / visa status information and results from records checks. If you are offered a position, we may also collect details such as your tax file number and bank account details. 

In many cases, we collect personal information directly from you. For example, if you are an Ailo user, we collect information about you during the registration process and when you contact us. We also collect information about you when you interact with Ailo or when other users of Ailo interact with you. 

Some other examples are set out below. 

• If you work with us or apply for a job with us. 
• If you access and use our website. 
• If you make an enquiry, for example via email or phone. 
• If you enter our competitions or promotions. 
• If you complete surveys, provide feedback or make a complaint. 

From other Ailo users

We may collect information about you from other Ailo users that you have a relationship with. For example (and as explained further in the Ailo Terms of Use):

if you use Ailo to manage properties, leases and associated relationships, other Ailo users may provide feedback on you, which will feed into your overall rating; and

if you allow another person (such as your spouse or agent) to use Ailo on your behalf, we may collect information about you from that other person. 

To provide products and services to our customers who are real estate agencies or franchises, we collect their business information. This business information may include information about you if you are an employee, property investor, renter or service provider of one of these real estate agencies or franchises. For example, if you are a renter and your real estate agency wishes to use Ailo to facilitate your rental payments, your real estate agency may provide us with information about you in order to assist you to become an Ailo user. 

We may also collect your personal information through other means, for example:

• from third parties such as credit reporting agencies, law enforcement agencies and government entities; or
• from publicly available sources.

If you do not provide us with the personal information described above, some or all of the following may happen:

• we may not be able to provide the requested products or services to you, either to the same standard or at all;
• we may not be able to provide you with information about products and services that you may want; or
• we may be unable to tailor the content of our websites and mobile applications to your preferences and your experience of our websites and mobile applications may not be as enjoyable or useful.

We collect general information about how our users use Ailo and use it to create insights for you and other users. These insights, however, are always aggregated and anonymised – we will never sell your personal information to third parties.

Other purposes for which we use your personal information are as follows:

• to provide products and services to you, for example to operate and manage Ailo (including by generating and sharing ratings for you and other users of Ailo);
• to answer enquiries and provide information or advice about existing and new products or services;
• to assess the performance of our website and mobile applications and to improve their operation; 
• to undertake analytics activities for the purposes of determining which of our products or services might be of interest to you; and
• as otherwise required or authorised by law.

Ailo allows you to interact with other Ailo users with whom you have a relationship (for example, if you are an investor, Ailo allows you to interact with your property manager and tenants). As you interact with other Ailo users, the information you create and share via Ailo will be accessed by those other Ailo users.

Ailo does not otherwise share your personal information with third parties, except to the following persons for ordinary business purposes:

• our employees and related bodies corporate; 
• our contractors or service providers (including payments facilities providers, web hosting providers, IT systems administrators, mailing houses, payment processors, electronic network administrators, debt collectors, and professional advisors );
• anyone to whom our assets or businesses (or any part of them) are transferred; and
• any organisation for any authorised purpose with your consent.

We may also combine, aggregate, analyse or share any information that we collect from you with information collected by any of our related bodies corporate. 

You should also note that if you are an Ailo user, the information you create and share via Ailo will be accessed by other Ailo users that you have a relationship with, as you interact with those persons via Ailo. 

We may use your personal information to provide you with offers for products and services from us or our partners. These communications may be sent in various forms, including mail, SMS and email. Any communications will be sent in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). You may opt-out of receiving marketing communications from us by contacting us at any time (see the details below), or by using the opt-out or unsubscribe facilities provided in the marketing communication themselves.

You may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge you for simply making the request and we will not charge you for making any corrections to your personal information.

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others. If that happens, we will give you the reasons for any refusal.

If you believe that any personal information we hold about you is incorrect, incomplete or inaccurate, then you may request that we amend it. Once an amendment request has been made, we will consider if the information requires amendment. If we do not agree that there are grounds for amendment then you may request that we add a note to the personal information stating that you disagree with it.

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it. We will deal with the complaint in accordance with our then current Complaints Handling Procedure.

 Do we disclose your personal information to anyone outside Australia?

We may disclose personal information to our related bodies corporate, third party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information handle it in a manner that is consistent with the Privacy Act. 

We may disclose your personal information to entities located outside of Australia, including the following:

• our related bodies corporate located in New Zealand;
• our data hosting and other IT service providers located in various jurisdictions, including the United States, the United Kingdom, Japan and the Philippines; and

We may also combine, aggregate, analyse or share any information that we collect from you with information collected by any of our related bodies corporate. 

We may use your personal information to provide you with offers for products and services. These communications may be sent in various forms, including mail, SMS and email. Any communications will be sent in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). You may opt-out of receiving marketing communications from us by contacting us at any time (see the contact details below), or by using the opt-out or unsubscribe facilities provided in the marketing communication themselves.

You may request access to any personal information we hold about you at any time by contacting us (see the contact details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you).

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others. If that happens, we will give you the reasons for any refusal.

If you believe that any personal information we hold about you is incorrect, incomplete or inaccurate, then you may request that we amend it. Once an amendment request has been made, we will consider if the information requires amendment. If we do not agree that there are grounds for amendment then you may request that we add a note to the personal information stating that you disagree with it.

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it. We will deal with the complaint in accordance with our then current Complaints Handling Procedure.

 Do we disclose your personal information to anyone outside Australia?

We store all data securely in Australia. However, to operate our business we sometimes use the services of third party IT service providers located overseas. This means that third party IT service providers located in the US, France and Spain may at times have access to your personal information so that we can continue to operate our product and services. We will never sell your personal information to third parties.

While we do not use browsing information to identify you personally, we may record certain information about your use of our platform and website, such as the time and date of your visit and the internet protocol address assigned to your device. We may also use 'cookies', 'pixels' or other similar tracking technologies that help us collect data about your use of our platform and website. You can disable cookies through your internet browser but our platform and website may not work as intended if you do so.

By using our platform and website, you consent to the processing of anonymised data about you by third party services as described below. Our platform and website hosts cookies and pixels and other tracking technologies from third party services (such as Google, Facebook and LinkedIn) for the purposes of collecting data to enable personalised advertising services. These technologies allow information about how you interact with our platform and website to be transmitted to those third party services. The third party services use the information (along with other information they hold about you, including information collected from cookies on other web pages) to:

• enable personalised marketing services on their platforms; and
provide us with de-identified, aggregated information about how you interact with such marketing.
• enable personalised marketing services on their platforms; and

Although the information we receive does not identify you personally, we use it to identify usage trends, administer our platform and website and gather demographic information about our users collectively. Our platform and website also use Google Analytics to gather statistical information on how users interact with our platform and website. Google Analytics uses cookies. Although these cookies do not identify you personally, they allow information about your use of our platform and website (including your IP address and device ID) to be transmitted to Google. For more information, please see Google’s site “How Google uses information from sites or apps that use our services – Privacy & Terms – Google. It is important to note that we do not control how these third party services use the information they collect through their cookies on our platform or website. You may refuse to accept cookies and pixels by activating settings on your Internet browser. However, if you select such settings, you may be unable to use certain features of our platform or website.

You can also:

• look under your account settings for those third party services to opt out of targeted advertising from those services; and
• visit websites such as YourOnlineChoices.eu - Your Ad Choices to opt out of targeted advertising from organisations who have signed up to Your Online Choices.

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:

• implement encryption measures;
• store credit card details under the PCI/DSS standard set by Visa and MasterCard;
• store data securely in Australia, using the infrastructure of a leading hosting technology provider; and
• implement a series of monitoring and alert systems to track and, where appropriate, block unauthorised use of our systems and products.

Our website and mobile applications may contain links to websites operated by third parties. The privacy policies that apply to those other websites may differ substantially from our Privacy Policy, so we encourage individuals to read them.

If you have any questions about this Privacy Policy, any concerns or feedback regarding the treatment of your personal information, please use the contact link on our website, or contact our Privacy Officer using the details set out below.

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline the options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

Please contact our Privacy Officer at:

Privacy Officer

Ailo Pty Ltd

2/80 Clarence St

Sydney NSW 2000

Australia

Email: privacy@ailo.io

We may change this Privacy Policy from time to time. A link to any updated version of this Privacy Policy will be posted on our website and mobile applications.