LOKE - Privacy Policy

Last Updated: 01/04/2019

1. LOKE Mobile Limited [11252565] and our affiliates (“LOKE”) collect personal information about you when you register to use and/or use the LOKE application or website (together “Application”). Personal information is any information or opinion about you from which your identity can be ascertained, including your name, email address, telephone number and other information you provide that may assists LOKE in conducting its business or meeting its legal obligation

2. By using the Application, you accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of your information as described herein (including to contact you), and for all other purposes permitted under applicable personal information privacy statutes, anti-spam legislation and consumer protection laws.

This Privacy Policy applies to information we collect when you interact with our Application, even if you have not registered for the LOKE Application or accessed one of our Applications. For clarity, this Privacy Policy does not describe the manner in which other persons or users of our Applications may collect or use information.

3. Amendment

(a)      We may amend this Privacy Policy from time to time by posting a revised version and updating the ‘Last Updated’ date above. The revised version will be effective at the time we post it. If we update our Privacy Policy we will notify you and encourage you to review this Privacy Policy whenever you use our Services to stay informed about our information practices and the choices available to you.

4. Legislation

LOKE is compliant with the Data Protection Act 2018 (UK) (Privacy Act) when dealing with your personal information. The Privacy Act sets out minimum standards regarding the collection, use and storage of personal information.

(a)      In addition to the Privacy Act, individuals located in the European Union (EU) may also have rights under EU based rules known as the General Data Protection Regulation (GDPR). The GDPR has harmonised the data privacy laws of each individual EU country, giving more rights to individuals located in the EU and more obligations to organisations holding their personal information. Details of additional rights of individuals located in the EU and how we meet them are outlined in paragraph 11.

 

5. Use of personal information

(a)      LOKE may use and disclose your personal information for the primary purpose for which it is collected, for reasonably expected secondary purposes which are related to the primary purpose and in other circumstances authorised by the Privacy Act. For example, LOKE collects and holds personal information about you for the purposes of:

(i)         providing you with the LOKE Application and enabling you to effectively use it;

(ii)      conducting the LOKE business;

(iii)   customising promotional or advertising material made available via the LOKE Application;

(iv)   contacting you regarding the LOKE Application;

(v)      monitoring your use of the LOKE Application;

(vi)   informing you about goods and services that LOKE thinks might interest you (you may elect not to receive this information). You can elect not to receive information about third party goods or services; and

(vii)  providing our clients with insights and analysis based on your usage of the Application.

(b)     In most cases, if you do not provide LOKE with requested personal information, LOKE may not be able to supply you with full access to the LOKE Application.

(c)      Ordinarily, personal information will only be collected directly from you, and LOKE will not use your personal information for purposes unrelated to the LOKE Application unless LOKE obtains your consent.

(d)     If you agree, LOKE will collect personal information from you via social networking and other mediums you nominate, such as via a connection with Facebook.

(e)      LOKE will always use fair and lawful means of collecting personal information, and wherever possible, will give you the option of interacting with us anonymously, provided it is practicable and lawful to do so.

 

6. Disclosure

LOKE may disclose your personal information to:

(a)      our related bodies corporate;

(b)     third parties (including the merchants for which LOKE develops branded apps) or individuals who assist us in providing the LOKE Application, who contribute to the LOKE Application or who perform functions on our behalf (such as consultants, agents, lawyers etc); or

(c)      if we believe that disclosure is reasonably necessary (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., with tax authorities), (ii) to protect our rights or property, or the security or integrity of our Services, or (iii) to protect us, users of our Services or the public from harm or potentially prohibited or illegal activities;

(d)     anyone else who you authorise us to make a disclosure to.

  1. LOKE will not send your personal information to recipients outside of the UK without:

(a)      obtaining your consent (in some cases this consent will be implied by your use of the LOKE Application); or

(b)     otherwise complying with the Privacy Act.

7. Cookies and Third Parties

When you use LOKE’s Applications, we may use cookies and other tracking technologies (collectively, “Cookies”) to recognise you as a User and to customise your online experiences, the Services you use and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud and to promote trust and safety across our Applications. If you choose to disable or decline Cookies, your use of the Applications may be limited or not possible.

(a)      This Privacy Policy does not apply to, and we are not responsible for, third-party cookies, web beacons or other tracking technologies, which may be covered by such third parties’ privacy policies. We encourage you to check the privacy policies of these third parties to learn more about their privacy practices.

LOKE does not represent that all third parties who may receive your personal information will have privacy policies equivalent to this one or be subject to the Privacy Act.

 

8. Storage and Security

(a)      During transmission, LOKE cannot guarantee the privacy or security of personal information you submit. However, once received, LOKE takes reasonable steps to securely store your personal information and to protect it from loss, misuse or unauthorised access, disclosure or modification. For example, LOKE may implement measures to safeguard your information in the form of written privacy policies and physical, electronic or procedural protection. Information is destroyed or permanently de-identified when it is no longer needed for any purpose for which it was collected.

9. Access and Correction

(a)      If you believe that any personal information held by LOKE about you is not accurate, complete or up to date please contact LOKE. On your request, LOKE will give you access to the personal information held about you, except in limited circumstances prescribed by the Privacy Act. LOKE may require you to reasonably identify yourself as part of an access request and may also charge a fee for providing access (which will be limited to the amount of our reasonable expenses incurred in responding to your request. More information about the Privacy Act is available from the Information Commissioners Officer at https://ico.org.uk/ .

10. Additional rights under the GDPR

(a)      Any information relating to an identified or identifiable natural person (the meaning given to “personal data” in the GDPR) (“Personal Data”) must be processed in a lawful, fair and transparent manner if you are based in the EU or UK.

(b)     The GDPR provides additional protection for Personal Data about your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, biometric data (for example fingerprints), or data concerning your health, sex life or sexual orientation. We will only process this type of Personal Data with your consent or where otherwise lawfully required to do so.

(c)      You acknowledge that LOKE is part of the LOKE Group and hereby authorise LOKE and any member of the LOKE Group to transfer Personal Data to any other member of the LOKE Group for the purposes of providing the Services. To the extent that LOKE processes Personal Data, LOKE will ensure that its sub-contractors shall not transfer to or access any Personal Data from a country outside of the European Economic Area without prior written consent.

(d)     LOKE maintains a record of its processing activities in accordance with Article 30(1) of the GDPR and will make available information necessary to demonstrate compliance and contribute to audits, including inspections, conducted by or on behalf of the Information Commissioners Office (“ICO”) pursuant to Article 58(1) of the GDPR.

(e)      By submitting a user access request, also known as a Subject Access Request (“SAR”) you can obtain information from LOKE free of charge about your Personal Data, LOKE will complete such a request within 30 days and provide you a copy of the personal information.

11. Contact

Please contact us with any questions or concerns regarding this Privacy Policy on

Email:                     support@loke.com.au

Phone:                   +44 7884058797

If you raise any concerns, we will respond to let you know who will be handling your matter and when you can expect a further response. We may request additional details from you regarding your concerns and may need to engage or consult with other parties in order to investigate and address your issue. We will keep records of your request and any resolution.

If you are dissatisfied with the results of our investigation or any resulting corrective measures, you may be entitled to make a written submission to the Personal Data Protection Commission Singapore, whose contact details are as follows:

Information Commissioners Officer (UK)

Phone:                   +44 1625 545 700

Email:                     casework@ico.org.uk

Address:               Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF