Privacy policy

 

Thanks for using Kweo.   Your privacy is very important to us.  Kweo is committed to being transparent about how and when we collect, use and safeguard your information.  Our privacy policy is designed to help you understand our privacy practices so you can make make informed decisions.

Kweo (“Kweo”, “our”, “we” and “us” in this Privacy Policy) is operated by M-Square Pty Ltd, Australian Business Number 68 151 893 328, of Level 6, 115 Pitt St, Sydney, New South Wales 2000, Australia.   As part of our normal operations we may collect your personal information.   We recognise the importance of protecting the privacy of information we collect that is capable of identifying an individual (“personal information”). We believe you should be made aware of our practices so you can make informed decisions about how you allow us to use your personal information.

This Privacy Policy outlines the type of personal information that Kweo may collect and how we use, store and disclose this personal information.   It applies to your conduct on Kweo Sites, which includes kweo.com as well as Sites on which Kweo Services are embedded, (the “Kweo Network”).

This Privacy Policy is in addition to the general Terms of Service governing Kweo and should be read in conjunction with such Terms of Service.

By using Kweo, or entering into an agreement with us in relation to our Services you are taken to have read, and agreed to the collection, use, disclosure and handling of your personal information in accordance with, this Privacy Policy.

Kweo may, from time to time, review and update this Privacy Policy to take account of new laws, technologies and changes to Kweo’s operations. All personal information held by Kweo will be governed by Kweo’s most recent Privacy Policy. The most recent Privacy Policy will always be available on our website or by contacting the Kweo Privacy Officer at [email protected]. You should review this Privacy Policy periodically so that you are updated on any changes.

In collecting and handling personal information, Kweo is bound by the National Privacy Principles (“NPPs”) contained in the Privacy Act 1998 (Cth) (the “Privacy Act”), and any other applicable privacy laws in Australia. This Privacy Policy governs the manner in which personal information will be dealt with.

There may be circumstances in which we need to transfer personal information outside Australia. If we do so, we strive to ensure that any organisation to which the information is transferred will be subject to binding privacy obligations.

 

Personal Information Collection

The types of personal information we collect will vary depending on the nature of your dealings with Kweo and the Kweo Network. In general, the type of personal information Kweo collects and holds could include (but is not limited to) your name, address (postal and email), age , contact details, geographic location (including your suburb or post code), gender, transaction details relating to your use of Kweo products and services and any preferences you tell us about.  We also collect information about what you do when you use Kweo, for example when you post comments on the service we may collect the User Content you post.

We may collect your personal information over the internet, over the phone, when you write to us or when you participate in a survey, questionnaire, competition or other marketing campaign.

In order to access some Kweo services and products, you will be asked to sign in with an email address and password, or social sign-on which we refer to as your “Sign On credentials”. You can use your Sign On credentials to sign in to many different Kweo services, websites and products. By signing in on one Kweo website, product or service, you may be automatically signed into other Kweo websites, products and services.  If you access services via a mobile phone, you may also use your telephone number and a PIN as an alternative credential to your username and password. As part of creating your credentials, you may also be requested to provide questions and secret answers, which we use to help verify your identity and assist in resetting your password, as well as an alternate email address. Some services may require added security, and in these cases, you may be asked to create an additional security key. Finally, a unique ID number will be assigned to your credentials which will be used to identify your credentials and associated information.

If we do not collect this personal information from you, we may not be able to provide you with the services or assistance you have requested.

When you use Kweo, you may set up your profile, perform searches and voluntary share information online that may be viewed and used by others.     When you update information, we usually keep a backup copy of the prior version for a reasonable period of time to enable reversion to the prior version of that information.

If you use our invitation service to tell a friend about our site, we will collect information needed to send the invitation, such as that person’s email address, Facebook username or Twitter username. By providing us with the information of third parties, you represent that you have all necessary rights to share that information with us. Your friend may contact us at [email protected] to request that we remove this information from our database.

 

Collection of information which is not ‘Personal Information’

We also collect additional information about your interaction with the Kweo Network websites, services and products without identifying you as an individual. For example, we use website analytics tools on our websites to retrieve information from your browser, including the website you came from, the search engine(s) and the keywords you used to find our site, the pages you view within our site, your browser add-ons, and your browser’s width and height. We also use technologies, such as cookies (described below), to collect information about the pages you view, the links you click and other actions you take on our sites and services. Additionally, we receive certain standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times and referring Web site addresses.

When you receive newsletters or promotional emails from Kweo, we may use customised links or similar technologies to determine whether the email has been opened and which links you click in order to provide you with more focused email communications or other information.

 

Collection of Posted Information

The Service provides a means for communiation and you should be aware that any information which you voluntarily include and transmit online may be viewed and used by others. We are unable to control such uses of your information, and by using such services you assume the risk that the information provided by you may be viewed and used by third parties.

 

Information we collect from other sources

In order to offer you a more consistent and personalised experience in your interactions with Kweo, information collected through one Kweo service may be combined with information obtained through other Kweo services. We may access information about you from third party sources and platforms (such as social networking sites, databases, and online marketing companies) and supplement the information we collect with information obtained from those third party sources. For example,

  • we may use services from other companies that enable us to derive a general geographic area based on your IP address in order to customise certain services to your geographic area; and,
  • if you connect your third party social networking service profile (such as Facebook or Twitter) to the Kweo Network, we may access and use your username, profile image, location information, interests, activities, ‘likes’, connection list and age for those services.

To customise your User experience on the Kweo Network we provide you with the opportunity to connect, access and/or interact with third party social networking services, such as Facebook and Twitter. When you connect to the Kweo Network through these social networking services, you will be able to see the social sharing habits of your friends and connections and participate seamlessly in our social capabilities, including commenting, live blogging, reactions, ratings, and sharing Content. By connecting to the Kweo Network through these third party social networking services, you are authorising Kweo to access and use certain information from your social network profile.  You should always review, and if necessary, adjust your privacy settings on third party websites and services before linking or connecting them Kweo’s website or Service.

 

Use of Personal Information

Kweo’s use of the personal information we collect, and your consent to us using your personal information, includes Kweo:

  • operating and improving our Service
  • providing you with news and information about our Service;
  • providing you with more effective customer service;
  • enabling us to conduct customer research;
  • making the Services that form part of the Kweo Network easier to use by eliminating the need for you to repeatedly enter the same information;
  • performing research and analysis aimed at improving our products, services and technologies;
  • displaying Content and advertising that are personalised and customised to your interests, preferences and experiences.
  • sending marketing and promotional material that we believe you may be interested in. This material may relate to any of Kweo’s businesses or a third party business which we believe may be of interest to you;
  • conducting promotions on behalf of Kweo and selected third parties;
  • verifying your identity;
  • investigating any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our Terms of Service or Policies, or that you are or have been otherwise engaged in any unlawful activity; and/or
  • using personal information as otherwise required or permitted by any law (including the Privacy Act).

We may state a more specific purpose at the point we collect your personal information

We also use your personal information to communicate with you, including by email, mail or telephone. With your permission, we may occasionally send you product surveys or promotional mailings to inform you of other products or services available from Kweo and its related entities and information about other Kweo products and services.

Following termination or deactivation of your Kweo account, we may retain your profile information and Content for a commercially reasonable time for backup, archival, or audit purposes. Furthermore, we may retain and continue to use indefinitely all information (including Content) contained in your communications to other Users or posted to public or semi-public areas of the Service after termination or deactivation of your Kweo account.

Any personal information or Content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings. To change your privacy settings on the Service, please change your profile setting. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users have copied or saved that information.

 

Use of information which is not ‘Personal Information’

We may share information which is not ‘personal information’, including information obtained through tools such as cookies and log files: (i) in any manner permitted for personal information; and (ii) with our third-party business partners for the purposes described in the section above. We may also aggregate or otherwise strip data of all personal identity characteristics and may share that aggregated, anonymized data with third parties.

 

Opting Out

You will generally be given the opportunity to “opt out” from receiving communications from us or from third parties that send communications to you in accordance with this Privacy Policy. For example, you will be given the option to unsubscribe from newsletters, emails and other marketing or promotional material sent by us. You may “opt out” from receiving these communications by clicking on an unsubscribe link at the end of an email.

If you receive communications purporting to be connected with us or our services that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact the Kweo Privacy Officer at [email protected]

 

Links to Third Party Websites from the Kweo Network

To the extent that the Kweo Network contains links to sites operated by third parties that are not related to Kweo products or services (“Linked Websites”), the Linked Websites are not controlled or maintained by Kweo. We may collect personal information from Linked Websites in our role as a website portal. However, we are not responsible for the privacy practices of those companies. Before disclosing your personal information to Linked Websites, we advise you to examine their privacy policies. These Linked Sites may collect personal information from you that may be shared with Kweo. This Privacy Policy will apply to any personal information we obtain in this manner.

 

Cookies and Log Files

Cookies are data that a web site transfers to an individual’s hard drive for record-keeping purposes. Cookies, which are industry standard and are used by most web sites, including our Network, can facilitate a User’s ongoing access to and use of a Site. All pages on the Site are coded with measurement software which is transparent to the User. The software makes use of an invisible image at the bottom of the web page. This software stores a “cookie” in the browser, which contains a unique string. This information is collected and aggregated, and in no way does this unique identifier identify a User personally.

When you visit any of the Kweo Sites, including this website, and other Sites that have our Services embedded, we may place one or more cookies on your computer in order to recognise your computer each time you visit these Sites. These cookies allow us to collect certain information about your web browsing behaviour.  We use cookies to enable you to sign in to our services and to help personalise your online experience. One of the primary purposes of cookies is to store your preferences and other information on your computer in order to save you time by eliminating the need to repeatedly enter the same information and to display your personalised Content.

When you sign in to a website using your Sign-On credentials, your unique ID number is stored in an encrypted cookie on your hard disk. This cookie allows you to move from page to page at the site without having to sign in again on each page. When you sign out, these cookies are deleted from your computer. Cookies are also used to improve the sign in experience. For example, your email address may be stored in a cookie that will remain on your computer after you sign out. This cookie allows your email address to be pre-populated, so that you will only need to type your password the next time you sign in. If you are using a public computer or do not otherwise want this information to be stored, you can select the appropriate radio button on the sign-in page, and this cookie will not be used.

Log file information is automatically reported by your browser each time you access a web page. When you use our Service, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information.

The Kweo Network also use cookies and Log Files as described in the sections of this Privacy Policy titled Personal Information Collection, Collection of information which is not ‘Personal Information’, and Information we collect from other sources.

 

Declining cookies

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to sign in or use other interactive features of the Kweo Network websites and services that depend on cookies. If you choose to accept cookies, you also have the ability to later delete cookies that you have accepted. If you chose to delete cookies, any settings and preferences, controlled by those cookies will be deleted and may need to be recreated.

 

Disclosing your Personal Information

Except as described in this Privacy Policy, Kweo will not disclose your personal information outside of Kweo and its affiliates without your consent.

Kweo may disclose personal information it collects about you for a variety of purposes in connection with Kweo providing its products, services and special offers to you (including to our agents, related bodies corporate and contractors).

We occasionally engage other companies to provide limited services on our behalf, such as handling the processing and delivery of mailings, providing customer support, hosting websites, providing debt recovery services, processing transactions, facilitating the connection of your third party social networking service profile with the Kweo Network or performing statistical analysis of our Services. Those service providers will be permitted to obtain only the personal information they need to deliver the service. They are required to maintain the confidentiality of the information and are prohibited from using it for any other purpose than for delivering the service to Kweo in accordance with Kweo’s instructions and policies.

We may access or disclose information about you, including the content of your communications to relevant public authorities, our legal representatives or other concerned parties, in special situations where, either: we have reason to believe that disclosing your personal information is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, Users or anyone else who could be harmed by such activities; or we believe, in good faith, that the law requires disclosure.

We may also access or disclose information about you, including the content of your communications to protect the rights or property of Kweo or our customers, including the enforcement of our agreements or policies governing your use of the Services; or act on a good faith belief that such access or disclosure is necessary to protect the personal safety of Kweo employees, customers or the public.

We may also disclose personal information, as part of a corporate transaction such as a merger or sale of shares or assets.

 

Treatment of Sensitive Information

In referring to ‘sensitive information’ Kweo means information relating to a person’s racial or ethnic origin, membership of political bodies, religions, trade unions or other professional or trade association, sexual preferences, criminal record and health information.

If you decide to provide Kweo with sensitive information, it is Kweo’s policy that this information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise or use or disclosure of this information is allowed by law.

 

Storage and Security

We strive to ensure the security, integrity and privacy of personal information submitted to our Services, and we review and update our security measures in light of current technologies. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure.

Personal information collected on the Kweo Network may be stored and processed in Australia or any other country in which Kweo or its affiliates, subsidiaries or service providers maintain facilities. Some of Kweo’s third party contractors and service providers may perform some of their services overseas. For instance, a third party contractor may utilise a server hosted overseas as a method to send emails to Kweo customers. In all instances where this occurs, Kweo takes reasonable steps to ensure that all personal information is handled in a manner that is consistent with this Privacy Policy.

We take physical, electronic and managerial steps to ensure that the personal information we hold is secure from unauthorised access, destruction, use, modification or disclosure. We only permit your details to be accessed by authorised personnel and we educate our staff about their responsibilities under the National Privacy Principles . Kweo has also appointed a Privacy Officer to oversee Kweo’s management of personal information in accordance with this Privacy Policy and the Privacy Act.

Additionally, we take reasonable steps to destroy or permanently de-identify personal information when we no longer need it. We also impose strict requirements of security and confidentially on all third parties as to how they store, handle and deal with personal information.

In striving to ensure that the security, integrity and privacy of personal information submitted to our site is maintained to the highest level, Kweo regularly reviews and updates its security measures in light of current technologies. Unfortunately, no data transmission over the internet or publically available website can be guaranteed to be totally secure and you need to be aware of this when using any websites on the Kweo Network.

 

Correction and access

We will endeavour to take all reasonable steps to keep accurate, complete and up to date any information which we hold about you.   We encourage you to contact us as soon as possible in order to update any personal information we hold about you.

You can also gain access to the personal information we hold about you, subject to certain exceptions provided for by law. To request access to your personal information, please contact us. Kweo will require you to verify your identity and specify what personal information you require.

To delete your account entirely, please email us at [email protected]. However, you understand and agree that we are not able to remove your personal information from the records of any third party who has been provided with your information in compliance with the use and sharing policy outlined above.

 

Further Information on Privacy

For more information about privacy issues in Australia and protecting your privacy, visit the Office of the Australian Information Commissioner website http://www.oaic.gov.au/.

 

Kweo Privacy Officer Contact details

If you have any questions regarding this Privacy Policy, complaints regarding how we handle your personal information or would like to make an access request, please contact Kweo by emailing [email protected].

Last Modified: 29  June 2015