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PRIVACY POLICY


1. WE RESPECT YOUR PRIVACY

1.1. Snug Technologies Pty Ltd (ACN 616 484 292) (Snug) and it’s related Bodies
Corporate is committed to safeguarding the privacy of its members and the users
of its website, www.snug.com. It therefore adheres to the Australian Privacy
Principles contained in the Privacy Act 1988 (Cth), and to the extent
applicable, the EU General Data Protection Regulation (GDPR).

1.2. This policy explains what personal information Snug collects, and how it is
collected, used, disclosed and stored.


2. WHAT IS PERSONAL INFORMATION?

2.1. For the purposes of this policy, “personal information” includes
information about an individual where the identity of that individual is
apparent or could reasonably be ascertained.

2.2. You may contact us in writing by email at privacy@snug.com or Level 3, 201
Sussex St, Sydney, NSW Australia 2000, for further information about this
Privacy Policy.




3. WHAT PERSONAL INFORMATION IS COLLECTED?

3.1. Snug collects a range of personal information in order to provide its
services to you, communicate with its members and improve the range of services
it offers.

3.2. The types of personal information we collect from you will depend upon the
services you obtain from us.

3.3 For all Members, the information we collect includes your contact details
(such as your phone number, physical address, postal address and email address),
photo identification, your credit card information, tenancy information and your
transaction history with us. We may also collect additional information,
including the following:

 a. or Owners, we collect information regarding your rental properties, proof
    that you own or have the right to manage your rental properties, your ABN or
    your ACN (if applicable);
 b. for Specialists and Service Providers, we collect information regarding your
    professional qualifications, your employment history and your ABN or ACN (if
    applicable);
 c. for Renters, we may collect information regarding your professional
    qualifications, your employment history, your rental history and information
    regarding your social media accounts and social media activity.
 d. for third parties, we may collect contact information for you if you have
    been nominated as a referee by a Member, or if a Member asks you to verify
    information regarding them. However, we always ask Members to seek
    permission before they provide us with third party contact information.



3.4. Credit card information is securely processed by our payment processing
partner and is not stored by us. However, we may store the Bank Account details
you provide if you select financial services such as bond and rent transactions.

3.5. We may also collect other personal information that you voluntarily
communicate to us when you interact with us, such as when you provide us with
your feedback or if you respond to surveys and/or promotions, or communicate
with our customer support.

3.6. Some information that is requested is “optional” and some is “mandatory”.
Where information is “mandatory”, you can choose not to provide the requested
information, however this will mean that you may be prevented from obtaining
certain services from us.


4. HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

4.1. Snug collects personal information from you in a variety of ways, including
when you interact with us electronically or in person, when you respond to
surveys, when you respond to questions we ask of you when you create a
membership account with us, when you access our website and when we provide our
services to you. By providing us with personal information, you consent to the
supply of that information subject to the terms of this Privacy Policy.

4.2. We may also receive personal information from third parties, such as social
media providers and other Members. Circumstances where we may collect
information from third parties includes where a Member nominates a person as a
referee in order to verify information that they have provided to us. If we do
collect information from third parties, we will protect it as set out in this
Privacy Policy.


5. HOW DO WE USE YOUR PERSONAL INFORMATION?

5.1. Snug uses the personal information it collects to provide you with
information, updates and to provide you with our services. Depending upon the
nature of your Membership, these services may include, but are not limited to,
matching Owners with potential Renters, the collection of rent and our
marketplace services which enable Members to interact with and provide services
to each other.

5.2. Snug may also use your information in order to improve the products and
services we offer to you and to better understand your needs. We may make you
aware of these new and additional products, services and opportunities.

5.3. If you withhold your personal information, it may not be possible for us to
provide you with our products and services or for you to fully access our
website.

5.4. Snug also anonymises information provided by Members and analyses
information on a collective basis in order to identify trends and market
insights. These trends and insights are shared with our Members.

5.5 Snug and referral partners will use personal information only for the
purposes that you consent to. This may include to:

 a. provide you with products and services during the usual course of our
    business activities;
 b. administer our business activities;
 c. manage, research and develop our products and services;
 d. provide you with information about our products and services;
 e. communicate with you by a variety of measures including, but not limited to,
    by telephone, email, sms or mail even if your number is on the Do Not Call
    Register. If you do not wish to be contacted by Snug by any of these means,
    please contact us at privacy@snug.com.


6. TO WHOM DO WE DISCLOSE YOUR PERSONAL INFORMATION?

6.1. We may disclose your personal information to third parties where it is
required for the delivery of our services and when requested by you to do so. We
may also disclose your personal information to any of our employees, officers,
insurers, professional advisers, agents, suppliers or subcontractors in order to
provide you with our services, and for the purposes set out in this privacy
policy. This could include, for instance, disclosing your information to
financial institutions who process credit card transactions. It may also include
disclosing your information to fellow Snug Members, or referees nominated by
you, where requested by you.

6.2. We reserve the right to disclose your personal information to comply with a
legal requirement, such as a law, regulation, court order, subpoena, warrant, in
the course of a legal proceeding or in response to a law enforcement agency
request.

6.3. We may also use your personal information to protect our business, the
copyright, trademarks, legal rights, property or safety of Snug, its websites,
our Members and third parties. This could include disclosing your information as
a part of any investigation where we have reason to suspect that you have
committed a breach of our terms and conditions or engaged in unlawful activity.

6.4. If there is a change of control in our business, or a sale or transfer of
business assets, we reserve the right to transfer to the extent permissible at
law our user databases, together with any personal information and non-personal
information contained in those databases. This information may be disclosed to a
potential purchaser under an agreement to maintain confidentiality.

6.5. Where we disclose your personal information to third parties, we will
request that the third party comply with this privacy policy with respect to the
handling and management of your personal information.


7. GENERAL DATA PROTECTION REGULATION (GDPR) FOR EUROPEAN UNION (EU) RESIDENT
USERS

7.1. Snug will comply with the principles of data protection set out in the GDPR
for the purpose of fairness, transparency and lawful data collection and use.

7.2. We process your personal information as a Processor and/or to the extent
that we are a Controller as defined in the GDPR.

7.3. We must establish a lawful basis for processing your personal information.
The legal basis for which we collect your personal information depends on the
data that we collect and how we use it.

7.4. We will only collect your personal information with your express consent
for a specific purpose and any data collected will be to the extent necessary
and not excessive for its purpose. We will keep your data safe and secure.

7.5 We will also process your personal information if it is necessary for our
legitimate interests, or to fulfil a contractual or legal obligation.

7.6 We process your personal information if it is necessary to protect your life
or in a medical situation, it is necessary to carry out a public function, a
task of public interest or if the function has a clear basis in law.

7.7 We do not collect or process any personal information from you that is
considered "Sensitive Personal Information" under the GDPR, such as personal
information relating to your sexual orientation or ethnic origin unless we have
obtained your explicit consent, or if it is being collected subject to and in
accordance with the GDPR.

7.8 You must not provide us with your personal information if you are under the
age of 16 without the consent of your parent or someone who has parental
authority for you. We do not knowingly collect or process the personal
information of children.


8. YOUR RIGHTS UNDER THE GDPR FOR EUROPEAN UNION (EU) RESIDENT USERS

8.1. If you are an individual residing in the EU, you have certain rights as to
how your personal information is obtained and used. Snug complies with your
rights under the GDPR as to how your personal information is used and controlled
if you are an individual residing in the EU.

8.2. Except as otherwise provided in the GDPR, you have the following rights:

 a. to be informed how your personal information is being used;
 b. to access your personal information (we will provide you with a free copy of
    it);
 c. to correct your personal information if it is inaccurate or incomplete;
 d. to delete your personal information (also known as "the right to be
    forgotten");
 e. to restrict processing of your personal information;
 f. to retain and reuse your personal information for your own purposes;
 g. to object to your personal information being used; and
 h. to object against automated decision making and profiling.

8.3. Please contact us at any time to exercise your rights under the GDPR at the
contact details in this Privacy Policy.

8.4. We may ask you to verify your identity before acting on any of your
requests.


9. WHAT ARE OUR HOSTING AND INTERNATIONAL DATA TRANSFER ARRANGEMENTS?

9.1. Information that we collect may from time to time be stored, processed in
or transferred between parties or sites located in countries outside of
Australia.

9.2. We and our other group companies have or intend to open offices and/or
facilities globally. Transfers to each of these countries will be protected by
appropriate safeguards, these include one or more of the following:

 a. the use of standard data protection clauses adopted or approved by the
    European Commission which you can obtain from the European Commission
    Website;
 b. the use of binding corporate rules, a copy of which you can obtain from
    Snug's Data Protection Officer.

9.3. The hosting facilities for our website are situated globally. Transfers to
each of these Countries will be protected by appropriate safeguards, these
include one or more of the following: the use of standard data protection
clauses adopted or approved by the European Commission which you can obtain from
the European Commission Website; the use of binding corporate rules, a copy of
which you can obtain from Snug's Data Protection Officer.

9.4. Our Suppliers and Contractors are situated primarily in Australia but may
be global. Transfers to each of these Countries will be protected by appropriate
safeguards, these include one or more of the following:

 a. the use of standard data protection clauses adopted or approved by the
    European Commission which you can obtain from the European Commission
    Website;
 b. the use of binding corporate rules, a copy of which you can obtain from
    Snug's Data Protection Officer.

9.5. You acknowledge that personal data that you submit for publication through
our website or services may be available, via the internet, around the world. We
cannot prevent the use (or misuse) of such personal data by others.


10. HOW DO WE SECURELY STORE YOUR PERSONAL INFORMATION?

10.1. Snug is committed to ensuring that the information you provide to us is
secure. In order to prevent unauthorised access or disclosure, we have put in
place suitable physical, electronic and managerial procedures to safeguard and
secure information and protect it from misuse, interference, loss and
unauthorised access, modification and disclosure. This includes the use of SSL
encryption.

10.2. Where we employ data processors to process personal information on our
behalf, we only do so on the basis that such data processors comply with the
requirements under the GDPR and that have adequate technical measures in place
to protect personal information against unauthorised use, loss and theft.

10.3. Although Snug has procedures in place to safeguard the security of your
information, Snug cannot guarantee the security of any information you transmit
to or receive from us. The transmission and exchange of information therefore is
carried out at your own risk. We therefore cannot guarantee that personal
information that we collect will not be disclosed in a manner that is
inconsistent with this Privacy Policy.


11. HOW CAN YOU GAIN ACCESS TO YOUR PERSONAL INFORMATION?

11.1. You may request details of personal information that we hold about you in
accordance with the provisions of the Privacy Act 1988 (Cth), and to the extent
applicable the EU GDPR. If you would like a copy of the information which we
hold about you or believe that any information we hold on you is inaccurate, out
of date, incomplete, irrelevant or misleading, please email us at
privacy@snug.com.

11.2. We reserve the right to refuse to provide you with information that we
hold about you, in certain circumstances set out in the Privacy Act or any other
applicable law.


12. CAN I MAKE A COMPLAINT ABOUT PRIVACY?

12.1. If you have any complaints about our privacy practices, please feel free
to send in details of your complaints to privacy@snug.com or to our office
address listed on our contact page. We take complaints very seriously and will
respond shortly after receiving written notice of your complaint


13. CHANGES TO THIS PRIVACY POLICY

13.1. Please be aware that we may change this privacy policy at any time, in our
sole discretion. Any amendment to this privacy policy will be effective
immediately upon the amended policy being posted to our website which we may
also email to you. Please check back from time to time to review our Privacy
Policy.


14. WHAT OTHER INFORMATION IS COLLECTED WHEN I VISIT THE SNUG WEBSITES?

14.1. In additional to personal information, Snug also collects other,
non-identifiable, information when you visit our websites. This information
includes:

 a. Website History: We may collect certain statistical information in order to
    analyse how people use our site. This information is collected in an
    aggregate manner only. This information includes your browser type,
    information regarding your operating system, the website you visited
    immediately before coming to our site.
 b. Cookies: Our websites use cookies. Cookies are very small files which a
    website uses to identify you when you come back to the site and to store
    details about your use of the site. Most web browsers automatically accept
    cookies but you can choose to reject cookies by changing your browser
    settings. However, this may prevent you from taking full advantage of our
    website and us offering you helping services like remembering your details
    to pre-fill forms you submit. In addition, cookies may be used to serve
    relevant ads to website visitors through third party services such as Google
    Adwords. These ads may appear on this website or other websites you visit.
 c. Third party sites: Our site may from time to time have links to other
    websites not owned or controlled by us. These links are for your convenience
    only. Links to third party websites do not constitute sponsorship,
    endorsement or approval of these websites and Snug is not responsible for
    the privacy practises of other such websites. We encourage our users to be
    aware, when they leave our website, to read the privacy statements of each
    and every website that collects personal identifiable information.

Built with love in Australia

Snug supports inclusivity and diversity

Snug acknowledges Aboriginal and Torres Strait Islander people as the
Traditional Custodians of the land and acknowledges and pays respect to their
Elders, past and present. Snug is committed to safe and inclusive work places,
policies and services for people of LGBTIQ communities and their families.




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Level 16, 175 Pitt Street
Sydney NSW 2000

© Snug Technologies Pty Ltd ABN 82 616 484 292. 'Snug' is a Trademark.
All rights reserved.

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