We appreciate that privacy is important to everyone, and we are committed to complying with the Australian Privacy Principles (APPs) which are contained in the Privacy Act 1988 (Cth) (Privacy Act).
1. Who is LUXit?
LUXit provides a platform for customers to book and pay for beauty, wellness and other personal care services (Personal Services), along with a platform for registered and approved contractors and employees (Service Providers) to provide, and be paid for the provision of, those Personal Services to LUXit’s customers (together these platforms comprising the Platform Services). LUXit’s customers include individual consumers, hotels, representatives for commercial properties and businesses and companies (Customers). Requests for Personal Services can be made by Customers (for themselves or for and on behalf of ther guests, tenants, employees and contractors) on LUXit’s Apps and website platforms.
2. What is personal information?
When we refer to “personal information”, we mean information or an opinion about you, being a Customer or Service Provider, from which you are, or may reasonably be, identified. This information may include (but is not limited to) your name, date of birth, driver’s licence number, phone number, email address, address and employment history.
Personal information may also include information which is “sensitive information” under the Privacy Act. Sensitive information includes, for example, information or an opinion about an individual’s health, racial or ethnic origin, criminal record or membership of a professional association, trade association or trade union.
3. What information do we collect?
The personal information we collect depends on the nature of our relationship with you. For example:
- If you are a Service Provider (or a prospective Service Provider), we may collect your name, email address, mobile phone number, work history and experience, referee details, Australian Business Number and engagement preferences (such as preferred Personal Services, location and times of availability). We may also, with your consent, undertake a police check about you.
- If you wish to use our Platform Services as a Customer, we may collect your name, address, mobile number, email address and other contact information, payment and credit details (including credit and debit card and banking details) and details of the Platform Services you wish to use and/or have used.
- If you apply for a job with LUXit or are an employee, we may collect, for example, your full name, contact details (including address, phone number and email address), driver’s licence details, job title, passport details, employment history and education details, names and contact details of referees, next of kin details (in the event of an emergency) and superannuation fund and Tax File Number details, if required by law, for example, under the Superannuation Guarantee (Administration) Act, the Superannuation Industry (Supervision) Act, the Income Tax Assessment Acts and Taxation Administration Act.
If you do not provide the information requested by us, we may not be able to provide you with our Platform Services (either in your capacity as a Customer or Service Provider).
4. Why do we collect your personal information?
If you are a Customer, we collect information from you for the purposes of providing you with access to our Platform Services to enable you to connect with Service Providers. From time to time, we may use personal information that you have provided to us for the purposes of offering other products and services to you.
If you are a Service Provider (or a prospective Service Provider), we collect information from you for the purposes of considering your engagement as a Service Provider and/or providing you with access to our Platform Services to enable you to connect with Customers. From time to time, we may use personal information that you have provided to us for the purposes of offering other products and services to you.
5. How do we collect your personal information?
We will collect personal information about you if you choose to provide it to us. Personal information may be collected from you in a variety of ways, including at different places and times on our website and Apps, such as when you sign-up to become an “Insider”. We may collect your personal information when you do any of the following, for example:
- book Personal Services via the website or Apps;
- apply to be a Service Provider or, alternatively, for employment with us;
- provide feedback about the Platform Services or the Personal Services;
- subscribe to receive our newsletter or promotional materials or sign up to a mailing list;
- enter competitions, surveys or other promotional activities available on the website or Apps;
- interact with us via any of our social media pages, for example, using Facebook, Instagram, LinkedIn, Pinterest and YouTube; or
- engage with us by phone, email, mail, or via the website or Apps, whether you are a Customer or a Service Provider or a representative or agent of a Customer or Service Provider.
We may also collect personal information about you from third parties. These third parties may include (but are not limited to):
- the Service Provider who provided you with the Personal Services you requested through the Platform Services;
- your employer, for example, if you are a key contact of one of our Customers;
- someone duly authorised to act on your behalf;
- where you have provided consent, for example, from third parties providing police checks;
- recruiters we have retained, from referees you have provided in support of a job application and any third party we may engage to conduct background checks on job applicants; and
- third parties who may have requested/arranged the Personal Services on your behalf, e.g. from a hotel arranging a Personal Service on behalf of a guest.
From time to time, we may also purchase lists containing personal information about individuals from organisations offering such lists for marketing purposes.
6. How is personal information used?
We may use your personal information for the following purposes:
- to provide you with the Personal Services you have requested, for example, to connect you with a Service Provider;
- to respond to your inquiry;
- to verify your identity;
- for complaints handling;
- data analytics;
- to improve our Platform Services;
- manage appointments you may schedule through the Platform Services;
- send you direct marketing messages which we consider may be of interest to you;
- the prevention of fraud and/or identifying and investigating any suspicious use of our website, Apps or Platform Services;
- for our internal business and management processes, for example, accounting or auditing purposes;
- for any other purpose to allow us to comply with our obligations under law; and
- for any other purposes that would reasonably be expected by you.
If you are a job applicant, employee or contractor, we will use your personal information for purposes relating to your engagement, training, performance management, payroll, superannuation, health and safety, for administration and staff management purposes. Where we consider it appropriate, we may also conduct background checks (or engage a third party to do so on our behalf).
If you are a representative of a Customer or Service Provider, we will use your personal information to administer and manage our relationship with your company.
The non-personal information, which we collect may be used for a variety of purposes, including but not limited to:
- helping us understand who uses our website, Apps and Platform Services and how they are used; and
- performing statistical analysis of user behaviour and/or to evaluate and improve the website, Apps and Platform Services.
7. Will personal information be disclosed to anyone else?
In the circumstances described below, personal information may be disclosed outside of our organisation.
7.1 Service Providers and Third party contractors
Personal information collected by us about both Customers and Service Providers may also be disclosed to third parties to whom we contract out specialised functions. Functions which are outsourced include hosting and maintaining the website and Apps, WeChat account, credit card and payment processing, mailing and marketing services, website development and email services and transportation services such as Uber.
From time to time, these third parties may be located overseas such as our software developers and providers located in India and the United States of America, our cloud storage providers located in India and the United States of America, third party payment processors and our call centre located in the Philippines. Please be aware that the privacy laws in other countries might not be the same as in Australia.
7.2 Disclosures required by law
For legal reasons, other disclosures may need to be made to law enforcement agencies, government agencies, courts or external advisors or in accordance with other laws.
7.3 Sale of Business
7.4 Overseas Disclosures – Important Notice
As stated above, we may from time to time transfer personal information outside Australia in accordance with the Privacy Act to countries whose privacy laws do not provide the same level of protection as Australia’s privacy laws. For example, we may transfer your personal information to the Asia-Pacific, European Union or the United States of America. We may also use cloud storage and IT servers that are located offshore.
By providing us with your personal information, you consent to us disclosing your information to entities located outside Australia and, when permitted by law to do so, on the basis that we are not required to take such steps as are reasonable in the circumstances to ensure that any overseas recipient complies with Australian privacy laws in relation to your information.
8. Direct marketing
From time to time, we may use your personal information to provide you with current information about our products and services, special offers you may find of interest, changes to our organisation, or new products or services being offered by us or any company we are associated with. By providing us with your personal information, you consent to us using your information to contact you on an ongoing basis for this purpose, including by mail, email, SMS, social media and telephone.
If you do not wish to receive marketing information, you may at any time decline to receive such information by contacting our Privacy Officer using the contact details below or by using the opt-out facilities provided (eg an unsubscribe link). We will take all reasonable steps to meet your request at the earliest possible opportunity.
When you use our Service, cookies will be placed on your device to keep track of your use of our Service. Cookies are small files that store information on your computer, TV, mobile phone or other device. Cookies do not capture or track any personal information. However, you can disable cookies through your internet browser but our website or Apps may not work as intended for you if you do so.
10. Updating your personal information
It is important to our relationship that the personal information we hold about you is accurate and up to date. If at any time you are of the view that personal information about you is not accurate, complete or up to date, please write to us with your request for correction. Our policy is to consider any requests for correction in a timely manner.
11. Access to your personal information
Under the Privacy Act, you have a right to seek access to personal information which we hold about you.
If you wish to exercise your right under the Privacy Act to seek access to the personal information that we hold about you, we ask that you write to us and we will explain how we handle your access request. We may charge you for the cost of providing access to these records.
There may be situations where we are not required to provide you with access to your personal information. For example, such a situation would be information relating to an existing or anticipated legal proceeding with you, or if your request is vexatious.
A written explanation will be provided to you if we deny you access to your personal information, which we hold.
12. Is personal information stored safely?
We take reasonable steps to ensure the security of personal information held by us from such risks as loss or unauthorised access, destruction, use, modification or disclosure. Our IT systems are password protected and comply with our security standards, and if personal information is held on paper files, it is stored in premises that are locked when unattended.
13. Business without identifying you
In most circumstances, it will be necessary for us to identify you in order to successfully do business with you, however, where it is lawful and practicable to do so, we will offer you the opportunity of doing business with us without providing us with personal information.
14. Third party websites
Sometimes our Platform Services contains links to other websites and mobile applications for your convenience and information. When you access a website through our Platform Services, please understand that we are not responsible for the privacy practices of that site. We recommend that you review the privacy policies of each site you visit.
Any information you provide to third party websites will be governed by the terms of the websites’ privacy policies. We have no responsibility or liability whatsoever for the content, actions or policies of third party websites.
15. Further information and complaints
You may request further information about the way we manage your personal information or lodge a complaint by contacting our Privacy Officer using the contact details below.
We will deal with any complaint by investigating the complaint, and providing a response to the complainant within a reasonable time, provided that we have all necessary information and have completed any investigation required. In cases where further information, assessment or investigation is required, we will seek to agree alternative time frames with you.
If, after receiving our response you still consider that your privacy complaint remains unresolved, you may then, for example, refer your concern to the Office of the Australian Information Commissioner at www.oaic.gov.au.
16. Contacting us
You can contact our Privacy Officer by:
- emailing us at firstname.lastname@example.org; and
- writing to us at Level 1, 377 New South Head Road, Double Bay NSW 2028.
Last Updated: 24th April 2018