1.1 Unilodgers (also referred to as “we”, “us”, and “our”), recognises the importance of Privacy of the Users (referred to as “you” and your”) and is committed to protect the confidentiality of information provided by you when visiting the Platform.
1.4 Unilodgers uses the information collected from you only to provide you the service requested by you. We do not share or sell your personal information to any other company for their marketing purposes or otherwise unless consented by you, except where mentioned in this policy. All the personal information collected is processed in accordance with the privacy legislation applicable to you.
1.5 In this policy, phrase ‘privacy legislation applicable to you’ means:
(a) in the case of a resident of Australia, the Privacy Act 1988 (Cth);
(b) in the case of a resident of a country in the European Union and the United Kingdom during the transition period of Brexit, the General Data Protection Regulation (GDPR) & national implementing laws and regulations;
(c) in the case of a resident of the United Kingdom after the transition period of Brexit, any privacy legislation that may be legislated to replace the UK implementing laws and regulations of the GDPR; and
(d) in the case of a resident of California, the Online Privacy Protection Act 2003 and the Right to Know Act 2013;
(e) in the case of a resident of India, Information Technology Act, 2000, and if the Personal Data Protection Bill 2019 is passed, that legislation;
(f) in the case of a resident of any other nation, the relevant privacy legislation in force in that nation from time to time,
in each, case as amended from time to time and including any regulations, guidelines or principles made under the applicable legislation.
2.1 The controller of the personal information is Unilodgers who operates the Platform.
3. What Data Do We Collect?
Unilodgers collects and uses information that you provide to us. We will only collect personal information if the information is reasonably necessary for, or directly related to, one or more of our functions or activities. When you use our Platform and subscribe for different services, update your registration details, your social media details or your payment information, or when you agree to act as a guarantor or an emergency contact for another person, report a problem, contact our customer support team, review a Property or our services, your personal information is collected by us. You may also give us your personal information while communicating with us by phone, email or otherwise. We collect, store, safe-guard and use your personal information as set out in this policy.:
4. Personal data you communicate to us.
4.1 ‘Personal information’ is information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
4.2 The personal information we may collect and hold varies and is dependent on the nature of our dealings with you. The kinds of personal information can include but is not limited to:
(a) Name, date of birth, gender, passport number and any other identification details;
(b) Contact details including address, email address, phone number and fax number;
(d) Payment information collected from you may include payment card details and bank details;
(e) Username and passwords, bookings made by you, information on your university, course of study, duration of the course, city and Property;
(f) Preference of room type, roommates, dates and budget;
(g) Information collected through feedbacks, reviews and various surveys;
(h) Any other information from which you can be identified and which you may disclose to us at any time; and
(i) Information about your use of our Platform.
4.3 In most cases, if we do not collect the information we require, then we may be unable to undertake certain activities, such as providing you with the requested information or services.
5. How do we collect it
5.1 You give your personal information to us by filling in a form on our Platform or when you contact us in one of the ways outlined below:
(a) Subscribe to use our Platform;
(b) Enquire about our services;
(c) Make a Property Enquiry;
(d) Reviews our services, a Property or give your feedback;
(e) Take a survey or enter a competition;
(f) Subscribe to get regular marketing information;
(g) Contact us on a social media platform;
(h) Correspond with us via phone, email or instant messaging services; and
(i) Speak to us in person.
6. Sensitive information
6.1 ‘Sensitive information’ is information relating to a person’s racial or ethic origin, political opinions, religion, trade union or other professional or trade association membership, sexual orientation, criminal record and health information about an individual.
6.2 We may collect the following sensitive information about our customers:
(a) medical conditions; and
(b) roommate preferences.
6.3 we will not collect sensitive information about you unless you consent to the collection and the information is reasonably necessary for one or more of our functions or activities, or as otherwise permitted under the privacy legislation applicable to you.
7. Personal information we collect automatically.
7.1 Even when you do not subscribe on our Platform, when you visit our Platform and use the interactive tools of the Platform, we automatically collect some information relating to your browser, the sections of our Platform that you visit and spend time on, browsing actions and patters. This helps us improve our Platform and services constantly and provide you with a good experience by using cookies. This information includes:
(a) IP address, login information, date and time of access, time zone and location, hardware and software information, browser type and version, browser plug-in types and versions, UTM parameters, operating system and platform and any other technology on the device you use to access our Platform;
(b) When you use our Platform using a mobile phone, we collect data that identifies your mobile device, device settings, characteristics and other system activity; and
(c) Information about how you use our Platform, including URL clickstream, page response times, length of visits to certain pages, download errors and page interaction information.
8. Personal information we receive from other sources.
We may also receive your information from other sources - third parties that we work closely with. These third parties may include business partners, such as affiliate partners, sub-contractors in technical and payment services, advertising networks, credit reference agencies, search information providers and any other companies that we may work with in the future, including but not limited to utility providers, telecoms, banks, insurance companies and third party payment services providers. Also, when you log in using social media, depending on how you log in, we may also collect your personal information associated with your social media account.
9. Australian Commonwealth Government identifiers
9.1 This clause is applicable only to residents of Australia.
9.2 We will not use Australian Commonwealth Government identifiers (such as drivers licence numbers) as our own identifier of individuals. We will only use or disclose such identifiers in circumstances permitted by the Privacy Act 1988 (Cth).
10. How Do We Use Your Personal Information?
10.1 We use the information collected from you for various purposes. We use your information in the following ways:
(a) To process and complete your booking;
(b) To deal with any complaints, queries and feedback, we share your information with our global customer service staff;
(c) To create account facilities for you when you first subscribe on our Platform in order to help you track your enquiries with us, manage your enquiries,, manage your personal settings and save your preferences;
(e) Invite you to be a part of market research or survey and participate in a contest;
(f) We use your information such as personal, contact, technical, usage and profile data for marketing activities. Based on the data provided by you, we may form a view of the type of information that maybe of interest to you. If you have requested information from us or subscribed to our services or provided your data for a promotion, we send you marketing communications, as long as you have not opted out of receiving such communication from us. If at any point you wish to stop receiving such communication from us, you can click on the “Unsubscribe” link in the communications;
(g) We may get in touch with you by email, post, phone or by texting in order to your query or handle your enquiry; invite you to review the Property leased or give feedback on our services; send information we feel might be useful to you; other administrative messages or security alerts;
(h) For analytical purposes to constantly improve our website, better our services, marketing and customer relationships to give you a great browsing and booking experience;
(i) To provide relevant content and advertisements on the website and measure or understand the effectiveness of the advertising we serve to you;
(j) To make suggestions and recommendations to you about goods or services that may be of interest to you;
(k) In order to administer and protect our Platform and for internal operations including troubleshooting, data analysis, testing, system analysis, data maintenance, support, reporting and hosting of data; and
(l) To handle and resolve any legal disputes, for regulatory investigations and compliance with lawful requests from law enforcement agencies.
10.2 To process your personal information as outlined above, we rely on the below legal bases:
10.3 For purposes (a) to (e), we rely on the legal basis that the processing of personal information is necessary for the performance of the contract with you to finalise and administer your enquiry. If the personal information is not provided, it is not possible to respond to the enquiry or to provide customer service. For the purposes outlined in (c) to (k), we rely on the legal basis that processing of personal information is necessary for our legitimate commercial business interest to provide and improve our services, better user experience, to provide network security and to prevent fraud. For purposes (k) and (l), we rely on the legal basis that processing of personal information is necessary to comply with legal obligations.
10.4 We use your personal information only for the purpose for which we collect it. If you wish to object to the information processing under purposes outlined in (c) to (j) and would like to opt out, please contact us at [email protected].
11. When Do We Share Your Information?
11.1 We do not share your personal information with any third party except as set out below and to the extent required by any applicable law or judicial body:
(a) We may disclose your personal information to our employees and those people that work on our behalf where we deem it necessary for providing services to you;
(b) We may share your personal information with the Housing Provider who will be supplying the Property you intend to lease so that they can get in touch with you to help you with your enquiry or resolve any queries;
(c) We may share your personal information with third parties acting as our service providers based across the world who provide IT services, infrastructure, data processing and system administrative services;
(d) We may provide general information about our users, their search patterns, traffic volumes and other related matters with third parties, but these details will not include information that personally identifies you;
(e) We may disclose your personal information to police, legal advisers or the regulatory bodies in connection with any alleged criminal offense or suspected breach of any terms and conditions required by law;
(f) We may share your personal information with revenue and taxation regulators and government authorities in the countries we operate, in addition to professional advisers including lawyers, auditors, insurers or bankers based across the world who provide us legal, accounting, insurance, banking or consultancy services; and
(g) We may also disclose your personal information to any third parties to whom we may sell, transfer or buy any business or our assets.
12. What are Our Security and Retention Procedures to Safeguard Your Personal Information?
12.1 The information that we may collect from you may need to be transferred to, and stored overseas.. Your information may be processed by staff operating overseas, who work for us or one of our suppliers and may be engaged on completing your booking request, processing your payment or provide you any customer support. By submitting your personal information, you agree to transfer to this transfer, storing or processing.
12.2 We take physical, electronic and procedural security measures to safeguard your data and store all information provided by you on secure servers to avoid any misuse, loss, interference from and unauthorized access, modification or disclosure. Where you have been given a password that enables you to access parts of our Platform, you are responsible for keeping this password confidential and not share it with anyone.
12.3 We use reasonable means to secure your personal information when transmitting it to third party in order to complete a service request made by you. However, we cannot guarantee the security of data intercepted, altered or misused while transmitting over the internet. Once we have received your information, we will use strict measures to try to prevent any unauthorised access.
12.5 We will take reasonable steps to destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the privacy legislation applicable to you.
13. Ensuring personal information is up to date
13.1 To provide our services to you in a quality manner, it is important that the personal information that we hold about you is up to date. We will take reasonable steps to ensure that your personal information is accurate, complete and up to date. If you find that the information we hold is not up to date or is inaccurate, please advise us as soon as practicable so that we can update our records and continue to provide quality services to you.
14. How Can You Control the Personal Information Given to Us?
14.1 We want you to be in control of how your personal information is used by us. You have the following rights.:
(a) Request access to the personal information we hold about you and ensure that it is lawfully processed;
(b) Request changes to any existing personal information we hold about you;
(c) Request removal of your personal information;
(d) Object to processing of your personal information;
(e) Restrict us from processing your personal information;
(f) Request transfer of your personal information to you or a third party; and
(g) Withdraw consent at any time from the use of your personal information.
14.2 If you wish to exercise any of your rights, please write to us at [email protected].
15. Accessing your personal information
15.1 If the privacy legislation applicable to you sets out circumstances in which you may request details of personal information that we hold about you, you may access that personal information in those circumstances.. If permitted by the privacy legislation applicable to you, we may charge you an administrative fee for access to personal information we hold about you, to cover our reasonable costs of retrieving that information.
15.2 If we cannot provide access to your information, we will generally provide you with the reasons why and the mechanisms available to complain about that refusal.
16. Correcting your personal information
16.1 If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, or if you would like any of your personal information to be erased, please contact us by email. We rely in part upon customers advising us when their personal information changes. We will respond to any request within a reasonable time. We will endeavour to promptly correct any information found to be inaccurate, incomplete or out of date.
16.2 If the personal information we hold about you is not accurate, complete and up to date, we will take reasonable steps to correct the information so that it is accurate, complete and up to date. If we cannot take reasonable steps to correct the information because such correction is not technically possible or would be impracticable for us to perform, we may be unable to continue to provide services to you. In these cases, we will provide reasons for denial of your correction request.
16.3 If we refuse to correct your personal information, you have the right to associate with a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading. We will take such steps that are reasonable in the circumstances to associate that statement with records containing the relevant information.
17.1 If you believe that we have breached the privacy legislation applicable to you and wish to make a complaint about that breach, please contact us by email at [email protected] setting out details of the breach. We will promptly investigate your complaint and respond to you in writing setting out the outcome of our investigation, what steps we propose to take to remedy the breach and any other action we will take to deal with your complaint.
17.2 If you are a resident of Australia and you feel that we have not satisfactorily addressed your complaint, you may also make a complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, emailing [email protected] or writing to GPO Box 5218 Sydney NSW 2001