Privacy Policy

We are Staivo Holdings Pty Ltd (“Staivo”).

Our principal places of business are at 462 Constitution Avenue, Parkes ACT 2600 / 700 American Ave King of Prussia, PA 19406, USA.

In this Privacy Policy, when we say “we”, “us”, and “our”, we mean Staivo. As an organisation, we are committed to protecting your Personal Information.

By accessing, using, and browsing our Website and Software, online booking platform as a “Guest” and property marketing platform and tools as a “Property Owner”, including any associated services and functionality, and social media pages (collectively, “Services”) you consent to us collecting, using, and disclosing Personal Information that you supply in accordance with this Privacy Policy.

The Privacy Policy applies to the Services we provide to you. We will ensure we handle Personal Information responsibly.

Personal Information is any information or opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not (“Personal Information”).

In essence, it is any information that can be used to personally identify you.

If the information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as Personal Information and will not be subject to this Privacy Policy.

This Privacy Policy is designed to cover:

• what information we might collect about you;
• how we might use that information;
• where we store that information;
• who we might share that information with; and
• your rights in connection with that information.

We will collect Personal Information that is reasonably necessary to operate our business and provide Services to you through our Website and Software or any other mode of interaction with us. We may also collect information to fulfil administrative functions associated with the Services, for example, billing and managing client relationships.

The type of information that we collect will depend on the Services we provide to you and the nature of your interactions with us.

The Personal Information that we typically collect and hold about you may include:

• your full name, postal and residential address, phone number, email address and any other contact details;
• identification information such as driver’s licence, gender, age, date, and place of birth;
• payment information (including credit card and banking details);
• information about the Services and Products you purchase or inquire about, or your dealings with us;
• Property Owner Information including information about your Properties and Guest reviews and feedback; and
• any other Personal Information provided by you or other third parties during the course of our relationship with you, including via the Services.

We generally collect Personal Information in the course of operating our business, and in providing our Services to you.

We may collect Personal Information from you whenever you input such information into our Website and Software for the purpose of inquiring or receiving the Services. We may also collect cookies from your computer when you use our Website and Software as reasonably necessary to customise your experience of our Website and Software.

Additionally, we may collect your Personal Information when:

• responding to requests concerning the Services, information, and other general inquiries;
• you contact us by any means including email, social media, or our Website and Software; and
• we are otherwise required or authorised by law.

Where reasonable and practicable we will only collect Personal Information directly from you.

However, sometimes we may receive information about you from third parties, such as through Hosting Platforms, and in cases like this we will take steps to make you aware of the information that was provided by a third party. Personal Information that we receive from third parties will be treated in accordance with this Privacy Policy. We will only collect Personal Information from third parties if it is unreasonable or impracticable to collect this information directly from you or if we are otherwise permitted to do so.

We collect Personal Information to provide you with the best Services experience possible.

We collect, hold, use, and disclose your Personal Information in order to:

• provide you with our Services, including facilitating and arranging bookings and providing Property Owner Services and Guest Services;
• communicate with you regarding the Services and your Property;
• process your payments, managing accounting, billing, and other administrative and operational functions;
• enable you to access and use our Services; and
• comply with our legal obligations.

Know Your Customer (KYC) Requirement and Refund Policy

As part of complying with our legal obligations, we require certain identification information to satisfy **Know Your Customer (KYC)** obligations in accordance with specific local or state rental laws. The collection of your identification information (e.g., driver’s license, age, place of birth) is used for this purpose, which may include a **100-point identification check**.

Note on Cancellations and Refunds: Failure to provide the required identification documentation for KYC purposes may result in the **cancellation of the booking and forfeiture of any fees paid**, in line with the Rental Agreement’s terms.

We otherwise collect, hold, use, and disclose your Personal Information where we are required or authorised to do so by law or for any other purpose for which you give your consent.

We may disclose Personal Information for the above purposes to:

• third parties involved in the provisions of Services to you;
• third-party service providers to whom we outsource services including agents and contractors such as imaging firms, marketing companies, IT support and couriers;
• regulatory authorities, government agencies, and law enforcement agencies or as otherwise required or authorised by law; and
• others where you have expressly provided your consent for us to do so.

Disclosure of Personal Information Overseas

We do not routinely disclose Personal Information overseas. However, we may disclose Personal Information overseas when it is appropriate to do so, including to third-party service providers. For example, we may disclose Personal Information to our service providers who assist us in operating our Website and Software.

If we disclose your Personal Information outside Australia, we will take all reasonable steps to ensure that the overseas recipient will deal with the Personal Information for the purpose intended and in a way that is consistent with the Privacy Act.

When we share such Personal Information, we take reasonable steps to ensure that third-party recipients have policies and controls in place to ensure that your Personal Information remains secure.

It is important to understand that when Personal Information is disclosed to third parties, we cannot control how they will use the information and this may result in them using your information in a manner inconsistent with the law. If you have any questions or concerns on this, please contact us as set out below.

We store most Personal Information in computer systems and databases operated by us or our external service providers.

We take all commercially reasonable steps consistent with industry practice to protect your Personal Information by using established security standards and procedures. To prevent the loss, misuse, unauthorised access, disclosure, alteration, and destruction of your Personal Information, we have established physical, electronic, and managerial security procedures appropriate to the risks represented and the nature of the Personal Information to be protected.

It is your responsibility to protect the security of your login information by using a strong password.

We will store your Personal Information for as long as needed to continue to provide the Services to you or for as long as a subscription to our mailing list is active. We take reasonable steps to securely destroy or de-identify all Personal Information where it is no longer necessary to retain the information for the purposes for which it was requested or as required by law.

You may access Personal Information we hold about you in certain circumstances and correct inaccurate Personal Information subject to certain exceptions. If you would like to obtain such access, please contact us as set out below.

For certain requests, we must first verify your identity before processing your request. We may request information about you to confirm your identity, as well as the nature of your request, before acting on your request.

We will respond to your request within a reasonable time, and we may charge you a reasonable fee for processing your request.

We will only send you marketing material if you have elected to receive it, or we believe you would reasonably expect to receive from us.

If you do not wish to receive promotional or marketing communications from us, you can opt-out by using the unsubscribe facility on the messages that we send you, or by contacting us as set out below.

When you visit our Website or use our Software, small files known as cookies may be downloaded by your web browser and stored in the cache of your computer or device. These cookies contain a unique identification number that allows us to recognise your device during your next visit. Importantly, these cookies cannot be used to access any Personal Information.

Additionally, we may log your Internet Protocol (IP) Address through our Website to determine your country of origin.

If you disable cookies in your web browser, some of the Website and Software features may be unavailable.

If you have a complaint concerning the way we maintain the privacy of your Personal Information, please contact us as set out below.

All complaints will be considered by our privacy officer, and we may seek further information from you to clarify your concerns. If we agree that your complaint is well-founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.

We may modify or amend this Privacy Policy from time to time and reflect this by updating our Website and Software and the above revision date in this Privacy Policy. The amended Privacy Policy will apply from the revision date. We encourage you to periodically review this Privacy Policy to be informed about how we are protecting your Personal Information.

If you have any questions or comments about our Privacy Policy, or if you wish to opt-out of any marketing that we direct to you, please feel free to contact us through:

Email: Help Desk
Mail: 62 Constitution Avenue, Parkes ACT 2600.