1. INTRODUCTION
This document sets out the privacy policy of Billy. When we talk about “Billy”, “we,” “our,” or “us” in this Privacy Policy, we are referring to Rento Australia Pty Ltd ABN 80 669 387 473, an Australian business trading as “Billy”.
The Privacy Act 1988 (Cth) (Privacy Act) requires entities bound by the Australian Privacy Principles to have a privacy policy. We take our privacy obligations seriously and we’ve created this privacy policy to explain how we store, maintain, use and disclose personal information.
By providing personal information (including sensitive information) to us, you consent to our storage, maintenance, use and disclosing of personal information in accordance with this privacy policy.
We may change this privacy policy from time to time by posting an updated copy on our website, and we encourage you to check our website regularly to ensure that you are aware of our most current privacy policy.
2. TYPES OF PERSONAL INFORMATION WE COLLECT
The personal information we collect may include the following:
(a) name;
(b) mailing or street address;
(c) email address;
(d) social media information;
(e) telephone number and other contact details;
(f) age;
(g) date of birth;
(h) credit card or other payment information;
(i) sensitive information (such as e.g. amenities usage, and billing data and information) as set out below in clause 8;
(j) information about your personal circumstances;
(k) information in connection with client surveys, questionnaires and promotions;
(l) your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information;
(m) information about third parties; and
(n) any other information provided by you to us via our mobile application or our online presence, or otherwise required by us or provided by you.
3. HOW PERSONAL INFORMATION IS COLLECTED
We will collect your personal information in a lawful and fair way. We will only collect your personal information where you have consented to it, or otherwise in accordance with the law.
How we collect information from you
We may collect personal information where you:
(a) contact us through our mobile application;
(b) register an account through our mobile application or otherwise;
(c) access or use our mobile application;
(d) input, upload or insert files, data or other information to our mobile application;
(e) receive services from us;
(f) submit any of our online inquiry forms;
(g) communicate with us via email, telephone, SMS, social applications (such as LinkedIn or Facebook) or otherwise;
(h) interact with our mobile application, social applications, services, content and advertising; and
(i) invest in our business or enquire as to a potential purchase in our business.
How we collect information from third parties
Where possible, we collect your personal information directly from you. However, there may be occasions when we collect personal information (including sensitive information) about you from someone else. For example, your housemates in your house share.
How you provide information for someone else
If you are providing personal and/or sensitive information on behalf of someone else, you must have the consent of that person to provide their personal and/or sensitive information to us to be collected, used, and disclosed in accordance with this privacy policy. We reserve the right to request evidence of this consent.
How we collect information from cookies
We may also collect personal information from you when you use or access our mobile application or our social media pages. This may be done through use of web analytics tools, ‘cookies’ or other similar tracking technologies that allow us to track and analyse your website usage. Cookies are small files that store information on your computer, mobile phone or other device and enable and allow the creator of the cookie to identify when you visit different websites. If you do not wish information to be stored as a cookie, please email us and we will disable cookies in your mobile application.
We may use Google Analytics to collect and process data, including when you use third party websites or apps. To find out more see How Google uses data when you use our partners’ sites or apps.
4. USE OF YOUR PERSONAL INFORMATION
We collect and use personal information for the following primary purposes:
(a) to provide services or information to you;
(b) for record keeping and administrative purposes;
(c) to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing services to you;
(d) to improve and optimise our service offering and customer experience;
(e) to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
(f) to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act). In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);
(g) to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and
(h) to consider an application of employment from you.
We may also use your personal information for:
(i) secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use;
(j) such purposes where we reasonably believe that use of your personal information is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
(k) any other purpose for which we receive consent from you; or
(l) any other purpose which is permitted or required under applicable privacy laws.
5. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We respect your privacy, and we will take reasonable steps to keep your personal information confidential and protected. We may disclose your personal information to:
(a) our online payment partner (currently Zai Australia Pty Ltd (ABN 96 637 632 645)) to collect and pay your bill payments on the mobile application;
(b) our professional advisors such as lawyers, accountants and auditors;
(c) our related entities; or
(d) any third parties you have consented personal information to be disclosed to.
We may also disclose personal information to third party contractors as required for us to provide our services to you, such as cloud-service providers, IT professionals, marketing agencies and debt collection agencies.
We take care to work with such third parties who we believe maintain an acceptable standard of data security and require them not to use your personal information for any purpose except for those activities we have asked them to perform on our behalf.
We will not otherwise disclose your personal information unless:
(a) you have consented to us disclosing your personal information for particular circumstances;
(b) as needed in an emergency or in investigation suspected criminal activity;
(c) we are required to disclose under a subpoena, court order or other mandatory reporting requirements;
(d) we reasonably believe that disclosure of your information is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety, and it is unreasonable or impracticable to obtain your consent;
(e) it is reasonably necessary for the establishment, exercise or defence of a legal claim; or
(f) it is otherwise authorised or required by law.
6. STORAGE OF YOUR PERSONAL INFORMATION
We use our best endeavours to store all personal information we collect on servers located in Australia and, for the most part, we do not disclose or transfer personal information overseas.
However, the cloud service providers we engage to provide us Australian-based servers may operate overseas disaster recovery sites or have personnel overseas who may access the personal information we hold to assist us in managing our servers.
We also may use Google Analytics to track web traffic information which is operated by Google which stores information across multiple countries.
When you communicate with us through a social media service such as Facebook or Twitter, the social media provider and its partners may collect and hold your personal information overseas.
7. ACCOUNT INFORMATION
We operate a mobile application known as ‘Billy’ which is designed to help streamline the process of sharing bills with housemates. We may collect personal and sensitive information about you during your account registration process, continued use of the mobile application and the course of providing you with our services.
To use the mobile application, all users are required to sign-up, register, and receive an account on the mobile application (Account). There are different types of Accounts, which will include the below users and any other types of users as communicated to you by us:
Home Account: the account that each household will have in the App that will include all User’s living in the household together;
Home Admin: the primary account holder for the Home Account, who is responsible for initiating the Home Account and removing Additional Home Members from the Home Account as required; and
Additional Home Members: the Users of the Home Account, authorised and invited by the Home Admin to access the Home Account on the mobile application.