Okuru’s Privacy Notice

Introduction  

Okuru Pty Ltd (“Company” or “We”) respect your privacy and is committed to protecting it through our compliance with the practicesdescribed in this notice.

The Company operates “Okuru” (“Service”), a software as a service (“App”). This policy together with our Terms of Service (“Termsof Service”) applies to your use of the App and any other services that we provide through the App. 

This notice describes our privacy practices for collecting, using, maintaining, protecting, and disclosing the personal data we may collect from you or that you may provide when you use the App. This notice applies to the personal data collected through the App, regardless of the country where you are located.

Please read this notice carefully to understand our practices for processing and storing your personal data. By engaging with and using the App, you accept and consent to the practices described in this notice. This notice may change from time to time. Your continued engagement with the App after any such revisions indicates that you accept and consent to them, so please check the notice periodically for updates.

When we refer to the term “GDPR” in this policy, we mean the European Union’s General Data Privacy Regulations. When we refer to the term “EEA”, we mean the European Economic Area.

This Privacy Notice is presented in a layered format. Please click on the relevant heading to go to a specific section.

1. Data we may collect about you

The following are general types of data that we may collect about you:

(a) Personal data that we could reasonably use to directly or indirectly identify you, such as your name, address, email address, telephone number, display name, profile picture, user name or other similar identifier, and any other information the App collects that is defined as personal or personally identifable information under any applicable law (“Personal Data”).

(b) Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific feature of the App.

(c) Technical information, including the Internet protocol (IP) address used to connect your mobile device or your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, or operating system and platform.

(d) Non-personal details about your interactions with the App, including the full Uniform Resource Locators (URLs), clickstream to, through, and from the App (including date and time), products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to call our customer service number.

If we combine or connect non-personal, technical, or demographic data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal data.

In summary, we may collect, use, store and transfer the following specific personal data about you including:

(a) Identity Data:user name, display name.

(b) Contact Data: email address

(c) Transaction Data: includes details about payments to and from you.

(d) Profile Data: includes your username, profile picture, your interests, preferences, feedback and survey responses (if you do not wish other users to know your real name or any other personal identication, we recommend that you do not include your real name or personal identifier in your user name or profile, including your photo).

(e) Usage Data: includes details of your use of any of our Services or your use of the App including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise.

(f) Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

(g) Location Data: includes your current location disclosed by GPS technology or location technologies available via your devices.

2. How we collect data about you

We use different methods to collect data from and about you including through:

(a) Direct interactions. You may give us information about you by signing up for a user account, entering into a transaction (including payment transactions) with us, filling in forms or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you create an account, subscribe to our Service, participate in social media functions on the App, enter a competition, promotion or survey, report a problem with the App and any other activity or interaction available through the App.

(b) Automated technologies or interactions. As you interact with the App, we may automatically collect technical data about your equipment, browsing actions and patterns as specified above. We collect this information by using cookies, server logs and other similar technologies (see Cookies and Automatic Data Collection Technologies).

(c) Third parties or publicly available sources. We may receive information about you if you use other apps or visit other websites that employ our cookies or from third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, our service providers, advertising networks, analytics providers, search information providers, credit reference agencies, data brokers, or aggregators.

3. Cookies and automatic data collection technologies

The App uses cookies (small files placed on your device) or other automatic data collection technologies to distinguish you from other users. This helps us deliver a better and more personalised service when you use the App. Some cookies are necessary to enable a feature to function properly and to allow your user experience to continue from one session to another. Cookies also allow us to improve the App by enabling us to:

(a) Estimate the size of our user population and usage patterns.

(b) Store your preferences so we may customise the App according to your individual interests.

(c) Speed up your searches.

(d) Recognise you when you return to the App.

4. How we use your personal data

Generally, we use your personal data to provide you with an efficient and customised experience when you use the App. We may use your personal data to provide you with products, offer you services, communicate with you, deliver advertising and marketing, or to conduct other business operations, such as using data to improve and personalise your experiences. Examples of how we may use the personal data we collect include to:

(a) Verify your identity when you make contact with us.

(b) Enable us to provide technical support and respond to your inquiries.

(c) Enable us to develop, deliver and improve the Service.

(d) Send out importance notices or communication to you, including changes to our Terms of Service or this policy.

(e) Notify you about changes to the App, products, or services.

(f) Meet our obligations and enforce our rights arising from any contracts with you, including for billing or collections, or comply with legal requirements.

(g) Fulfil the purposes for which you provided the data or that were described when it was collected.

(h) Ensure that we present the App in the most effective manner for you and for your mobile device.

(i) Administer the App and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.

(j) Improve the App, products or services, marketing, or customer relationships and experiences.

(k) Enable your participation in the App's interactive, social media, or other similar features.

(l) Distribute marketing, promotion and advertisements to you.

(m) Measure or understand the effectiveness of the advertising we provide to you and others, and to deliver relevant advertising to you;

(n)Make suggestions and recommendations to you and other users of the App about goods or services that may interest you or them.

We may also use personal data to contact you about our own and third-parties' goods and services that may be of interest to you. If you do not want us to use your data in this way, please adjust your user preferences in your account profile. For more information, see Your Personal Data Use Choices.

We may use personal data to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal data for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may use non-personal data for any business purpose and our use is not restricted by this policy.

We will only send you direct marketing communications by email or text if we have your express opt-in consent. You have the right to withdraw that consent at any time by contacting us.

5. Disclosure of your personal data

We may share your personal data with:

(a) Any member of our corporate group, which means our subsidiaries, our ultimate holding company and its subsidiaries, and our affiliates (any use of your personal data by our corporate entities will comply with this privacy notice).

(b) Business partners, suppliers, service providers, developers, sub-contractors, and other third parties we use to support our business (such as data analytics and search engine providers that assist us with the App improvement and optimisation). We contractually require these third parties to keep that personal data confidential and to use it only for the permitted purposes.

(c) For any other purposes that we disclose in writing when you sign up for an account or provide your data or information to us.

(d) For any other purposes with your consent.

We may also disclose your personal data to third parties:

(a) To comply with any court order, law, or legal process, including responding to any government or regulatory request.

(b) To enforce or apply our Terms of Service and any other agreements that we may have with you.

(c) To protect the rights, property, or safety of our business, our employees, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of cybersecurity, fraud protection, and credit risk reduction.

(d) In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.

(e) To a buyer or other successor in the event of merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, where one of the transferred assets is the personal data we hold.

We may share non-personal data without restriction.

6. Consent to personal data transfer

We may process, store, and transfer the personal data we collect, in and to a country outside your own, with different privacy laws that may or may not be as comprehensive as your own.

By submitting your personal data or engaging with the App, you consent to this transfer, storing, or processing.

If you live in the EEA, please note that we may have external third party processors or service providers who are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

(a) We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

(b) Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

(c) Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Your personal data use choices

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising:

(a)Promotional Offers. If you do not want us to use your email address or contact information to promote our own products and services, or third parties' products or services, you can opt-out by adjusting your user preferences in your account settings, or by sending us an email with your request to customer.care@okuru.app.

You may also opt-out of further marketing communications following the opt-out or unsubscribe links on that message.

The App may include links to and from third-party websites, advertisers, plug-ins, services, social networks or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. We do not control these third-party websites, and it is important that you read the privacy notice of every website you visit. We do not accept any responsibility or liability for their policies, your interactions with any third party and for any personal data that may be collected through these websites or services. Please check their policies before you submit any information or personal data to these third parties or use these services.

8. Accessing and correcting your personal data

You can access, review, and change your personal data (except for your email) by logging into the App and visiting your account profile page. If you wish to change your email or to replace your account with another email, you have to delete the existing account and create a new account.

You may also send us an email at customer.care@okuru.app to request access to, correct, or delete personal data that you have provided to us. We cannot delete your personal data except by also deleting your user account. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively affect the information's accuracy.

9. Data security

The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure. We store all information you provide to us on our secure servers.

Any payment transactions carried out by our third party processor will be subject to the third party processor's privacy policy. We strongly encourage you to read their privacy notice carefully before you use their service for your payment transactions.

The safety and security of your information also depends on you. As you will be using your email address or social media account to create and use your account, you are responsible for keeping your log-in details confidential. We are not responsible for any unauthorised access or security breaches involving your email account or social media account that you use in conjunction with the Service.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted to the App. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on the the App.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

10. Data retention

We will store the personal data for no longer than is necessary for the purposes for which the personal data are processed. We may store the personal data for longer periods if there are overarching legitimate reasons. For instance, we may be required by applicable laws to retain certain information about our customers (including contact, identity, financial and transaction data) for relevant statutory period for tax purposes. If we are required to retain the personal data for longer periods, we will ensure appropriate technical and organisational measures will be in place to protect the data.

In some circumstances you can ask us to delete your data. Please refer to your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for legitimate business purposes (for example, to make improvements to our products or services or to offer a new product), research and development purposes or statistical purposes, in which case we may use this information indefinitely without further notice to you.

11. Children's online privacy

The App is not intended for minors and we do not knowingly collect data relating to minors. The age of majority may differ from country to country. Under the GDPR, the processing of the personal data of a child will be lawful where the child is at least 16 years old. Where the child is a minor, we will not process the personal data unless the child's parent, guardian or an adult with parental responsibility gives consent to us. If we learn that we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent or under parental supervision, we will delete it. If you believe we might have unintentionally collected or received any information from or about a child, please contact us at customer.care@ok-uru.com. A minor who uses the App must be supervised by a responsible parent or a responsible adult.

We encourage you to remind your children not to disclose their personal information online.

12. Rights of users from the EEA

If the GDPR applies to us, the Company will be considered the Data Controller of your personal data.

If you are accessing the App or using the Service from within the EEA, you may have the following rights under the GDPR. You may also have the following rights if the data protection laws in your jurisdiction provide for them.

(a) Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data that we hold about you and to check that we are lawfully processing it.

(b) Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data that you provide to us.

(c) Request erasure of your personal data. This enables you to ask us to delete or remove your personal data when the personal data is no longer necessary for our processing, when you withdraw your consent or there are no longer legitimate grounds or purposes for us to continue to process the data. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Please note that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you (for instance, if we are required to comply with a legal obligation orfor reasons of public interest), if applicable, at the time of your request.

(d) Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

(e) Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(f) Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

13. Changes to our privacy notice

We will post any changes we may make to our privacy notice from time to time. If the changes materially affects how we use or treat your personal data we will notify you [by email to the primary email address specified in your account and/or through a notice on the App's home page. We encourage you to check the App regularly for any updates or changes to our privacy notice.

14. Dispute

Any dispute relating to or arising from this policy or our obligations will be subject to arbitration as provided in the Terms of Service. Please refer to the Terms of Service.

15. Our contact information  

If you have any question or feedback concerning your personal data or our privacy practices, please contact us at customer.care@okuru.app

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Our Company's office is located in Western Australia. Our registered address is 24 Augusta Street, Willetton, Western Australia 6155, Australia.

Last updated: 29 Feb 2024