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Thank you for using KeyNinja. This privacy policy sets out how Jump Private Equity Pty Ltd ACN 619 280 072 trading as KeyNinja (“we”) treat the privacy of users of our platform and services (“Service”) and others with whom we interact.

In this privacy policy, the term “personal information” includes information about identifiable individuals, including names, user names (where such names include actual names or other information that identifies a person), addresses, telephone numbers, email addresses, photographs, dates of birth, credit and banking details, identity verification information (such as drivers’ licence, passport, or other ID cards) and if and where applicable, includes information that constitutes “sensitive information”. 

1. Collection and Storage of Personal Information 

We may collect and store personal information in circumstances including:

      1. when a person signs up to become a user of the Service or otherwise becomes a customer;
      2. for identity verification purposes (e.g. when exchanging/delivering keys);
      3. when a user sends an enquiry through email, or makes a comment or other post through our website or via a social media platform; 
      4. when obtaining information about a guest from a host or vice-versa (whether directly or indirectly, including through the Airbnb platform);
      5. when an individual telephones or emails or meets with one of our representatives;
      6. when users communicate with each other using our platform;
      7. when a user signs up to our email marketing list;
      8. when we meet with a person or organisation wishing to do business with us (and a person or an individual from that organisation provides details), or when a person requests a demonstration of the Service and provides their details for that purpose;
      9. when a person enters into a transaction with us using a credit card or payment method other than cash;
      10. when an individual (either on their own behalf or on behalf of a business they work for) enters into an agreement with us for the supply of services and/or goods; and
      11. when evaluating job applicants and personnel which may include collection of details such as employment history and educational qualifications.  This may include “sensitive information” as defined in the Privacy Act (1988)(Cth). 

2. Anonymity

Where practicable, users of the Service and others have the right to interact with us and each other anonymously.  Given the nature of the transactions conducted through our Service, in many cases anonymity is not practical.

We may assign users a unique identifying number for internal purposes and data analytics purposes.  These numbers do not reveal any personal information about the corresponding individual.  Details of the individual assigned the unique number are not disclosed outside our organisation and cannot be used to identify an individual by others who do not have access to our private database which correlates the details of an individual with their unique identifying number.

3. Cookies

We may use or engage other service providers who use ‘cookies’ to collect data relating to your general usage of the Service.  This data may include IP-addresses, geographic location, browser versions, number of visits and similar such data relating to your navigation of our Service and linked services and online stores.  Cookies help us to improve and deliver a better and more tailored service.

You may refuse to accept cookies by activating settings on your device.  However, please note that if you select such settings you may be unable to access certain parts of our Service.  

4. Use of Personal Information

We use the personal information collected from you for the purpose it was provided or collected, including in the following ways:

      1. To facilitate your interaction with and use of the Service (whether as a host, guest or otherwise) and to interact with other users of the Service;
      2. For use for the purposes of collection described in (1) above;
      3. To enable our personnel to coordinate key exchange;
      4. To enable us to provide or facilitate the provision of housekeeping services or other maintenance services, including through third parties;
      5. To allow you to participate in interactive features of our Service when you choose to do so;
      6. To perform authorised financial transactions with you;
      7. To verify your identity (including for the purposes of key exchange) and to assist you if you have forgotten any user ID, user name or password;
      8. To communicate with you and provide you with information  about our products or Service (including to notify you of changes to the Service), where you have requested or consented to receiving this from us or where this provision is otherwise permitted under the Australian Privacy Principles or other applicable law;
      9. To receive and address feedback or complaints about us or our Service from you;
      10. To protect our legal interests and fulfill our regulatory obligations (if and to the extent necessary);
      11. In other circumstances, with the relevant individual’s prior consent.

We may use personal information for the purpose of marketing to users but only where such use complies with applicable legislation.

All users and others with whom we interact have the option to opt-out of receiving marketing communications from us.  If you do not wish to continue to receive electronic marketing communications from us and/or selected third parties you should opt-out by clicking on the “unsubscribe” link in any email communications that we might send you.

5. Disclosure to third parties

We may disclose your personal information to any of our related group companies. They will only use it for the same purposes that we may under this policy.  We may also disclose your personal information to third parties outside our group of companies: 

      1. Where we have your express permission to do so;
      2. To facilitate transactions and interactions between hosts and guests and other users of the Service;
      3. Where it can reasonably be inferred from the circumstances that you consent to the disclosure to the third parties;
      4. For the purposes of enabling us to operate our Service, where third parties are involved, for example, IT service providers, data storage businesses, web-hosting and server providers, debt collectors, maintenance providers, professional advisors and payment systems operators;
      5. If our company or substantially all of its assets are acquired by a third party, in which case personal information which we hold about our customers and users may be one of the transferred assets (subject to the same constraints on use and disclosure as under this policy); and
      6. If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions or to protect the rights, property, or safety of Loop Platform Pty Ltd, its personnel or customers . This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. 

We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services to you.   

6. Disclosure and transfer of information overseas

We store personal information on a secure server operated by Amazon Web Services in Sydney, Australia.

We transfer limited amounts of personal information to our personnel located in the Philippines for the purpose of them coordinating and organising key exchange, housekeeping services and other administrative matters.

7. Security of personal information

We hold personal information in our own secure databases.

We take all reasonable steps to protect your personal information, including by internal and external security and restricting access within the organisation to personal information to those who have a need to know. We implement and maintain technological products to prevent unauthorised computer access and regularly review our technology to maintain security.

We treat website and credit card security seriously and endeavour to provide a secure, safe platform through which to conduct transactions (if any).

8. Questions and concerns and access to/ correction or updating of your personal information

You have a right to access the personal information we hold about you. To obtain a copy of the personal information we hold about you, please write to us at:

The Privacy Officer
Jump Private Equity
by email to [email protected]  .

Please provide sufficient detail about the information in question to help us locate it.  We will then use commercially reasonable efforts to promptly determine if there is a problem and take the necessary corrective action within a reasonable time.

9. Changes to our privacy policy

We may modify, alter or otherwise update this privacy policy at any time.  We will post revisions on our website.

We encourage you to review this policy from time to time.

Last update:  December 2019