Privacy Policy
WE Wumbo Pty Ltd (ABN 58 615 373 610) (“we”, “our” or “us”), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us. We are a cloud-based building management system and through our platform (WE Wumbo platform). We provide resident management capabilities to strata managers and a platform for residents to interact with each other and with management, where residents may book building facilities, lodge and track maintenance requests, store and share documents, engage third party services, and make general enquiries (Services).
This Privacy Policy takes into account the requirements of the Privacy Act 1988 (Cth) and the Australian Privacy Principles, as well as the New Zealand Privacy Act 2020 and the Information Privacy Principles.
The information we collect:
- Identity Data including first name, middle name, last name, maiden name, title, date of birth, gender, job title, photographic identification, marital status, pronouns, your company or business name, ABN, and images of you.
- Contact Data including billing address, delivery address, email address, fax number and telephone numbers.
- Financial Data including bank account and payment card details.
- Background Verification Data including your driver licence number, photographic identification or other details requested as part of our onboarding process to comply with our due diligence obligations and related ongoing monitoring commitments.
- Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us, or we have purchased from you.
- Technical and Usage Data including internet protocol (IP) address, your login data, your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries made by you and/or browsing behaviour, information about your access and use of the WE Wumbo platform, including through the use of Internet cookies on our website and your communications within WE Wumbo platform.
- Profile Data including your username and password for WE Wumbo platform, profile picture, purchases, or orders you have made with us, third party services you have engaged through WE Wumbo platform, support requests you have made, content you post, communications you send and receive through our platform, information you have shared with our social media platforms, your interests, preferences, feedback, and survey responses.
- Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys, promotions, activities, or events.
- Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.
- Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorized by law.
How we collect personal information
- Directly: We collect personal information which you directly provide to us, including when a strata manager creates your account and requests your name and email, via email, face to face or over the telephone.
- Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as in emails, over the telephone and in your enquiries via WE Wumbo platform.
- From third parties: We collect personal information from third parties, such as third-party service providers integrated into the WE Wumbo platform.
Why we collect, hold, use, and disclose personal information
| Purpose of use / disclosure | Type of Personal Information |
| To verify your identity and enable you to access and use the WE Wumbo platform, including to provide you with a login. |
|
| To provide our Services to you, including to notify you of delivered parcels, book building facilities, connect you to third party services (e.g., home cleaning, end of lease cleaning and removals), manage your car spaces and guest access. |
|
| To contact and communicate with you about our Services including in response to any support requests you lodge with us (e.g., maintenance, defects, home cleaning etc), any building updates or news about new features, events, products or services or other enquiries you make with us. |
|
| To connect you with other building residents so you can communicate with them |
|
| For internal record keeping, administrative, creation of a client base, audits, reporting requirements, invoicing, and billing purposes. |
|
| For analytics, market research and business development, including to operate and improve our Services and associated applications and providing the ratings and reviews you submit to third parties. |
|
| To provide you with technical support or training. |
|
| For advertising and marketing, including to send you promotional information about our Services and information that we consider may be of interest to you. |
|
| To comply with our legal obligations or if otherwise required or authorised by law. |
|
Sensitive information: We only collect, hold, use, and disclose sensitive information for the following purposes:
|
|
Our disclosures of personal information to third parties
- any third-party service providers integrated into our WE Wumbo platform such as Too Ezy (home services);
- our employees, contractors and/or related entities;
- IT service providers, data storage, webhosting, and server providers such as AWS;
- marketing or advertising providers;
- payment systems operators such as Stripe;
- our existing or potential agents or business partners;
- anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
- courts, tribunals, regulatory authorities, and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights; and
- any other third parties as required or permitted by law, such as where we receive a subpoena
Overseas disclosure
Australian Residents
While we store personal information in Australia, where we disclose your personal information to the third parties listed above, these third parties may store, transfer or access personal information outside of Australia, including but not limited to, Japan and England. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.
New Zealand Residents
- you have authorised the disclosure after we expressly informed you that the overseas recipient may not be required to protect the personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020;
- we believe the overseas recipient is subject to the Privacy Act 2020;
- we believe that the overseas recipient is subject to privacy laws that, overall, provide comparable safeguards to those in the Privacy Act 2020;
- we believe that the overseas recipient is a participant in a prescribed binding scheme;
- we believe that the overseas recipient is subject to privacy laws in a prescribed country; or
- we otherwise believe that the overseas recipient is required to protect your personal information in a way that, overall, provides comparable safeguards to those in the Privacy Act 2020 (for example pursuant to a data transfer agreement entered into between us and the overseas recipient).
Your rights and controlling your personal information
Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use, and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.
Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.
Restrict and unsubscribe: To object to processing for direct direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Correction: If you believe that any information, we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant, or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.
Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (if you are an Australian resident), or the Office of the New Zealand Privacy Commissioner (if you are a New Zealand resident).
Storage and security
We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic, and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorized access, modification, and disclosure.
We utilise and host data on Amazon AWS Cloud services. Amazon is one of the largest, globally renowned cloud service providers in the world, with high level security. Amazon servers are fully monitored with hardware firewall systems for the protection of your data and information. Amazon server provider does not have access to your personal information and is limited to only providing a hosting and service to us for Australian properties. Amazon servers are located in Sydney, Australia. If you would like to read more information on Amazon and how we store data, it can be found here: aws.amazon.com
While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk.
Cookies
We may use cookies on our website from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.
We may use cookies for a number of purposes, such as to prevent the same ad from displaying repeatedly or to display ads that are likely to be more relevant to your interests. We may use a set of cookies, including conversion cookies, to collect information and report website usage statistics without personally identifying individual visitors. The main purpose of conversion cookies is to help determine how many times people who click on ads filled out a guest card or signed a lease; conversion cookies are not used for interest-based ad targeting and persist for a limited time only. Conversion cookie data may also be used in combination with your Google account to link conversion events across different devices you use. Only anonymous conversion data gathered from these cookies is shared with advertisers.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
Use of Google API Services (this section applies to personal information accessed through Google API Services)
We limit our use of the personal information that we collect to providing or improving our Services. We do not use the personal information for any other purposes.
We only transfer the personal information to others if it is necessary to provide or improve our Services or as necessary to comply with applicable law or as part of a merger, acquisition or sale of assets where we notify you of this.
We do not use or transfer the personal information for serving ads, including retargeting, personalised or interest based advertising.
We don’t allow humans to read the personal information unless
- we have first received your consent to view specific messages, files or other data;
- it is necessary for security purposes (such as investigating a bug or abuse);
- our use is limited to internal operations and the personal information (including derivations) have been aggregated and anonymised.
These restrictions apply to the raw data we obtain from the restricted scopes and data that is aggregated, anonymised or derived from them.
We have policies and procedures in place setting out appropriate safeguards for protecting your personal information obtained with the Google APIs. We will also ensure that our employees, agents, contractors and successors comply with the Google API Services Data Policy.
Use of Wumbo Works
By using Wumbo Works, you agree to WE Wumbo’s Privacy Policy.
Amendments
We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website and WE Wumbo platform. We recommend you check our website and WE Wumbo platform regularly to ensure you are aware of our current Privacy Policy.
For any questions or notices, please contact us at:
WE Wumbo Pty Ltd (ABN 58 615 373 610)
Email:info@wewumbo.io
Last update: 10/10/2023
© LegalVision ILP Pty Ltd