Vuvale Privacy Policy

Helping you understand the information that we collect and why we collect it and assisting you to update, manage and delete your information.

This Policy was last updated in November 2021.

We are committed to treating the personal information we collect in accordance with the Australian Privacy Principles in the Privacy Act 1988 (Cth) (the Privacy Act).

This Privacy Policy sets out how we handle personal information.

Privacy at Vuvale

This Privacy Policy explains our personal data practices and the choices you can make about how your personal data is used. This Privacy Policy gives effect to our commitment to protect your personal data and serves as the guidelines to be observed across all Vuvale locations and activities. We are committed to safeguarding the privacy of all guests who interact with us at any moment during their Vuvaleexperience. We treat all the personal data of our guests with great care.

This Policy is designed to inform you about our privacy practices, including the collection of personal data, how we use it and the rights that exist for you to be in control of it. In addition, we love to interact with our guests to learn and improve the services we offer to the Vuvale community. This means data is exchanged (Vuvale Platform) and used when you use our mobile applications and websites, make a reservation, visit one of our locations, purchase food & beverage, visit our coworking spaces, bar, dining spaces, or any other serviceprovidedbyVuvale.

Users of this Website are entitled to expect that any information collected as a result of that use will be treated within the terms of the NSW Government's privacy responsibilities and obligations.

The NSW Government's privacy practices are regulated by the New South Wales Privacy and Personal Information Protection Act 1998.

By using this Website, applications and services, or otherwise providing us with your information, you acknowledge and agree to collect, hold, use, and disclose your personal information as described in this Privacy Policy.

If you do not wish to be bound by this privacy statement, you should not access or otherwise use this Website or services.

What is Vuvale?

Vuvale operates in housing and hospitality, including hotel-related services, food and beverage facilities, coworking spaces, learning, experiences and amenities.

This Privacy Policy applies to the processing of personal data by Vuvale, more specifically, the relevant subsidiary that determines the particular purpose of the processed personal data. In practice, the primary data controller will be Vuvale, the applicable local Vuvaleentity you are engaging with.

Who is Vuvale?

Vuvale is a limited liability company registered under the laws of Australia within the Jurisdiction of New South Wales.

Application of this Policy

"Using" and "processing" of Personal Data include subjecting the personal information to statistical or other analysis and using or handling personal information in any way, including but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within the Vuvale organization or among our affiliates.

The terms of this Privacy Policy will govern the use of the Platform and contains important information on the collection and processing of Personal Data through the Platform by Vuvale.

By using the Platform, you consent to our Privacy Policy. If you do not agree with any of the provisions of this Privacy Policy, please do not use our Platform.

Vuvale ("we" or "us") provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use, and disclosure of Personal Data we receive from Users of the Platform. This Privacy Policy applies to all Personal Data that is provided to us through the Platform.

Purpose of information collection

To provide the Service as a manager for our guests, we may collect and use your Personal Data to:

Track your use of the Platform will allow us to personalise our Service to your needs and identify potential new Services
- Assess the suitability of long stay candidacy
- Manage your booking through any of the channels provided
- Process registrations and reservations
- Improve user experience
- Pre-fill rental agreements and event agreements
- Provide customer service
- Perform general customer administration of your Account by providing you with specific information and services available only to registered Users, sending you communications about the Platform (e.g. upcoming changes or improvements) as well as our other products and services and respond to your questions, treat your requests or troubleshoot any problems
- Managing the relationship
- Providing ease of use of our facilities
- Create payment tokens that substitute sensitive payment data with a non-sensitive equivalent and provide simplified payment processes during future payment transactions.
- Process and charge the agreed amounts across all facets of the business
- Preparing and managing the dealings of requests in a seamless way during the stay of our guests
- Notification of public authorities in situations where it is necessary to do so
- Legal and licencing obligations
- Perform marketing actions
- Carry out customer service surveys to assess our guest experience and to improve our service
Verify the compliance with your obligations set out in our Privacy Policy and investigate fraud and infringements on all applicable rules and regulations.
- Improve the safety of our guests
- Manage, process and respond to possible complaints or claims
- Comply with legal and ethical requirements

You can choose to opt-out of marketing promotions from Vuvale and/or third parties and/or mail/email correspondence from Vuvale if you do not want that your Personal Data is used for any of the purposes listed above. If you do not want to receive commercial communications from us, you can choose to unsubscribe from such commercial communications at any time.

What information do we collect?

The type of data Vuvale collects depends on the service you have subscribed to and the location in which the service may be provided to you.

There are two types of information we process at Vuvale:

Information users provide to us
Information relating to the User's use of our Platform in which we use to collect your Personal Data

Information you provide to Vuvale

Below is an overview of what information we will collect on our Vuvale Platform.

Account:

When you register to our Platform (make a reservation), you are voluntarily providing us with certain uniquely identifiable information that we collect and process. By voluntarily giving us this personal information, you consent to such personal information being collected, used, disclosed and stored by us, as described in this Privacy Policy.

After you've registered to the Platform, we will collect additional information you may choose to provide to us on your Account.

Correspondence:

When you contact our customer service or anyone of our Vuvale staff, we may keep a record of that correspondence and collect the necessary information to classify your question, respond to it and if applicable, investigate any breach of our Privacy Policy. While we do not use this information for advertising, we may also use this information to identify and track potential problems and trends and customise our Services to you.

Information we learn about you in your use of our Platform

We may collect or process certain non-personal information or aggregated data about how and when you use our Platform. This information is usually of a technical nature (device settings and information, including but not limited to the type of browser, Operating System, IP address,keyboard language, screen resolution, location, etc.) and behavioural nature (the actions taken by you on the Platform, including but not limited to access times, pages requested, actions executed etc.) and is used to compile statistical data about the Use of our Platform.

We may also collect additional information in connection with your participation in any promotions offered by us and information you provide when giving us feedback.

We will ask for your consent before using any Personal Data for a purpose other than those that are set out in this Privacy Policy noting that you can object at any time to the use of your Personal Data for direct marketing purposes free of charge.

Data Collection Variances

Browsing Vuvale websites

If you visit a Vuvale website (Platform), we use cookies, which we store on your computer, phone, or tablet. Cookies are small text files. We use the information in these files for the essential functioning of our sites and non-essential functions to improve user experience, performance/analytics and promotions. Many analytic activities concern primarily anonymized data to help us analyse how users use the Website so that Vuvale can improve the functionality and the content.

Amongst other data, we process the following personal data from visitors to our websites:

Website visit and use
IP address
Duration and time of visit to the Website
Use of social media

We will use the cookie preferences you select in the cookie setting banner to provide relevant offers on other websites you visit via online and third-party advertisements. We may also use this information for remarketing purposes to remind and assist you with potential bookings that were left incomplete.

When you join as a Vuvale member:

you will provide us with data collected on our Platform,which may include:

Name
Email address
Contact details
Home address
Postal address
Date of birth
Gender
Nationality
I.D. information
Employment status
Membership details
Stay preferences
COVID status
Signature
Payment details

If you register a business address at a coworking space, it may be necessary to provide additional information for Vuvale to comply with legal requirements.

This information will be used for processing the membership application, billing purposes, to comply with legal obligations and to allow us to communicate with you about your membership, including sending surveys to understand how we can improve the service offered. In addition, Vuvale may use a payment token whereby your payment details are stored as a secure unique payment token enabling simplified payment processes for future payment transactions associated with your Account.

We may also use this information to perform marketing activities regarding Vuvale more generally. We will only use the information submitted for marketing if you have provided consent for us to do so. You can unsubscribe from marketing emails at any time by clicking the unsubscribe link contained in the email.

When you make a reservation as a short/extended stay guest:

you will need to provide us with data, which may include:

Name
Email address
Contact details
Postal address
Date of birth
Nationality
I.D. information
Stay preferences
Opt-in preferences
COVID status
Signature
Payment details

If you are a minor, you may be required to provide us with the contact details of your parents and/or guardian, ensuring that they are aware that such data will be shared.

Depending on the location you have booked to stay, additional data may also be required. This information will be used for processing the hotel booking, billing purposes, complying with legal obligations, and allowing us to communicate with you about your booking, including sending surveys to understand how we can improve the service offered.

Vuvale may use a payment token whereby your payment details are stored as a secure unique payment token enabling simplified payment processes for future payment transactions associated with your Account.

We will also use this information to send general marketing emails about other Vuvale news, events, and deals, but only if you have given us consent to do. You can unsubscribe from marketing emails at any time by clicking the unsubscribe link contained in the email.

When you join as a Vuvale long stay guest:

you will provide us with data collected on our Platform, which may include:

Name
Email address
Contact details
Postal address
Date of birth
Gender
Nationality
I.D. information
Employment status
Membership details
stay preferences
Criminal record
COVID status
Signature
Payment details

This information will be used for processing the membership application, guest selection, improving safety for our guests, billing purposes, to comply with legal obligations and to allow us to communicate with you about your membership, including sending surveys to understand how we can improve the service offered. In addition, Vuvale may use a payment token whereby your payment details are stored as a secure unique payment token enabling simplified payment processes for future payment transactions associated with your Account.

When using the Vuvale App:

we collect the following types of data:

We use cookies, which we store on your device. Cookies are small text files, and we use the information contained in these files for essential functions in the App and non-essential procedures to improve user experience and perform analytics. Analytic services are provided by third parties and involve only the processing of anonymized data, which generates generic data such as how many users have downloaded the App.
Profile information that you provide for your user profile (e.g. first and last name, picture, phone number, interests)
User content (e.g. photos, comments, and other materials) that you post publicly within the Vuvale App.
Your preferred payment method. The payment intermediary will ask you to provide some payment data.
Communications between you and Vuvale. (e.g. account verification, changes/updates to features, technical, maintenance requests, notification of events, access control and security notices).
Laundry transactions when using the App to pay for laundry services.
When using the bike-sharing system Vuvale will temporarily process location data from the User’s mobile device to ensure that the bike can only be initially unlocked within a permitted radius of the property and can only be officially returned within an acceptable radius of the property. The functionality of the location data indirectly informs Vuvale that a user is on-premises when the bike is initially unlocked and officially returned. Vuvale does not collect or process any location data from the User’s device when the bike is used. Instead, a record of time is kept confirming when the bike was unlocked and returned to ensure the bike terms of use are respected. All data will be automatically overridden once the bike has been returned in accordance with the terms of use and a new user unlocks the bike.
When using the Vuvale bike-sharing system, Vuvale will keep a record of where the bike is locked using the location of the bike lock (not the User’s device), which will only be used if needing to retrieve a bike that has not been returned in accordance with the bike terms of use.
When using the Vuvale vehicle-sharing system, Vuvale will temporarily process location data from the User’s mobile device to ensure that the vehicle can only be initially unlocked within a permitted radius of the property and can only be officially returned within an acceptable radius of the property. The functionality of the location data indirectly informs Vuvale that a user is on-premises when the vehicle is initially unlocked and officially returned. Vuvale does not collect or process any location data from the User’s device when the vehicle is used. Instead, a record of time is kept confirming when the vehicle was unlocked and returned to ensure the vehicle's terms of use are respected. All data will be automatically overridden once the vehicle has been returned in accordance with the terms of use and a new user unlocks the bike.
When using the Vuvale vehicle-sharing system, Vuvale will keep a record of where the vehicle is locked using the location of the vehicle (not the User’s device), which will only be used if needing to retrieve a vehicle that has not been returned in accordance with the bike terms of use.
We note that Vuvale may provide bike and vehicle sharing via a third-party provider from time to time. In these instances, the prospective User will be notified of any associated parties and a separate privacy policy and separate consent may be required.
When using the Vuvale parcel storage and collection system. Vuvale will temporarily process data from the User’s mobile device to ensure that the parcel locker can only be initially unlocked within a permitted radius of the locker and can only be officially locked within an acceptable radius of the locker. The functionality of the location data indirectly informs Vuvale that a user (or their nominated delivery agent) is on-premises when the locker is initially unlocked and officially locked for use. Vuvale does not collect or process any location data from the User’s device when the locker is used. Instead, a record of time is kept confirming when the locker was locked and unlocked to ensure the locker terms of use are respected. All data will be automatically overridden once the locker has been vacated in accordance with the terms of use and a new user utilises the locker.
When using the Vuvale parcel storage and collection system, Vuvale will record when the locker is locked using the operation of the lock (not the User’s device).
When using the Vuvale access control system. Vuvale will temporarily process data from the User’s mobile device to ensure that they can utilise their phone. The access control device can only be initially unlocked within a permitted radius of the point of access. Likewise, it can only be officially operated within an acceptable radius of the point of entry. The functionality of the location data indirectly informs Vuvale that a user activates the point of access. Vuvale does not collect or process any location data from the User’s device when the access controller is used. Instead, a record of time is kept confirming when the lock was locked and unlocked. All data will be automatically overridden once the customer has vacated in accordance with the terms of use and a new user utilises the point of access.
When using the Vuvale access control system, Vuvale will record when the lock is locked using the operation of the lock (not the User’s device).

Subscribing using forms (online and offline)

When you subscribe to a newsletter, event, competition, waiting list, program or classroom, online or offline, you will be requested to provide personal data, which may request the following details:

Name
Email
The event details
On premise room no.
City
Gender
Phone
Date of birth
Other data that may be asked in completing the form

We use this information to contact you about the relevant topic you have indicated you are interested in. We will only contact you when we believe there is a legitimate interest and based on the information you have declared.

When you make a reservation at a Vuvaledining establishment

When you make a reservation, you will need to provide us with data, which may include:

Name
Email
Phone
Reservation details
Dietary requirements
COVID status
Payment details

This information will be used for processing the reservation and to communicate with you about the reservation.

We will also use this information to send general marketing emails about other Vuvale material, only if you have given us consent. You can unsubscribe from marketing emails at any time by clicking the unsubscribe link contained in the email.

When you make payments for Vuvale services on behalf of guests and contracting parties

When you make payments for services on behalf of Vuvale Guests or Contracting Parties, you will provide payment information that will be processed to complete the due amount.

When attending Vuvale events and using the hotel facilities

When you attend events and use the Vuvale facilities, you may be requested to provide personal data, such as using the photobooths or logging into the guest Wi-Fi network or setting up an account at the virtual gym.This information will be used for the processing activity specified when collecting personal data.

It may also be used to send general marketing emails about other VUVALE news, events, and deals, but only if you have given us consent to do so. You can unsubscribe from marketing emails at any time by clicking the unsubscribe link contained in the email.

When joining a “VuvaleExperiences” program that enables access to VUVALE services at discounted rates

When you sign up for a “VuvaleExperiences” program, you must provide your name and email address. This information will be used to process your subscription and generate a digital or physical card that can be shown to prove your subscription when visiting a Vuvale property to experience your wonderful benefits. It may also be used to send general marketing emails about other Vuvale news, events, and deals, but only if you have given us consent to do so by providing consent to receive such information during the subscription sign-up process.

After your Vuvale experience

Whilst we hope you never leave; we know that there will be times that our guests will choose or must leave. After your stay at Vuvale, we will continue to store your data in a profile that is strictly accessible by Vuvale and its affiliates only. Should you return to Vuvale in the future, we want to offer the best service, including the ability to customize your stay based on your previous personal preferences. We will only do this to the extent that we believe we have a legitimate interest to do so, which will be to improve the service we can offer to you in the future across all of our locations and services.

In the case of ‘Vuvale Learn’ Guests, you will be automatically enrolled into the Vuvale Alumni program and gain access to ‘Vuvale Experiences’ perks and benefits. Vuvale is enthusiastic about staying in touch with our Guests because the relationship between alumni and Vuvale can be mutually beneficial. You are part of an exciting, global network of people with inspiring ideas and we want to help keep that connection alive. You can of course unsubscribe anytime you like by following the link contained in the bottom of the email or contacting privacy@vuvale.com.au.

Security of your Personal Data

By registering your Account on the Vuvale Platform, you acknowledge and agree that the Personal Data you provide, including sensitive personal information, may be transferred outside the country you live in.

Vuvale will endeavour to process your data solely within the jurisdiction of Australia by saving your information on a server located in Australia wherever possible. However, for many of our business purposes, we use cloud-based services. Vuvale has implemented internal processes to ensure that your personal data will only be sent to parties and countries with an adequate level of personal data protection.

Modifications to this Policy

We may change this Privacy Policy from time to time to reflect changes in the operations of the business. The most recent version of the Privacy Policy is reflected by the version date located in the top left of this document. All updates and amendments are effective immediately upon notice, which we may give by posting a revised version of this Privacy Policy on the Website. We encourage you to review this Privacy Policy often to stay informed of changes that may affect you, as your continued use of our services signifies your continuing awareness of this Policy.In case of significant changes to the Policy that results in Vuvale using your Personal Data in a manner materially different from that stated at the time of the collection, we will provide you with a notice on the Platform and/or send you an email notification.

Sharing with third parties

We handle your personal data discretely and access is strictly limited to Vuvale and our third-party partners. However, we will need to know such information to fulfill our contractual obligations towards you to perform functions you have granted consent for us to do or any other identified legal ground under data protection law such as an identified legitimate interest.

We may be required to share your personal information with our partners and affiliates that in many cases will be necessary to provide the products and services you have purchased or otherwise carry out activities we have identified serve a legitimate interest and may also be of interest to you.

These parties include:

Professional service providers such as marketing agencies, advertising partners and website hosts who help us run our business.
Professional mailing companies that deploy our email campaigns and satisfaction surveys
Operational partners who maintain and service our propertiessuch as technical maintenance, housekeeping and night security.
Third party vendors who help us manage and maintain IT infrastructure such as onlinebooking engines, reservations systems, Vuvale App, internet connectivity, payment service providers and customer service channels.
Where relevant, our professional advisors, such as lawyers and consultant.
Third party partners that provide us with your data to validate referrals and corporate bookings under partnership agreements.

If you use the services provided by another company to interact with us, such as an online travel agency, please be aware that your data is also subject to the privacy policies of these companies.

If you would like to know more about the third parties that we may share personal data with, or how to find out more on how they will use your data, please contact us at the details below.

Your rights

We want to make sure that you are in control of your personal data. You have rights and we want to ensure they are respected. If you wish to exercise any of the rights listed below, please make your request by sending an email from the email address that you used when signing up for a Vuvale service to:

privacy@vuvale.com.au

Please state clearly in the subject what type of request you are making including details to assist us in completing your request as quickly as possible.

Please confirm:

Vuvale service you signed up for
Location
Dates
Supporting evidence to help identify the correct profile (e.g. booking confirmation)

If we are in doubt about your identity, we are entitled to ask you to provide proof of your identity first. We will complete your request within four weeks.

Right of access

If you want to know what personal data we have collected and/or processed from you, you can request Vuvale to provide an overview.

Rectification

If you believe that the personal data that we process is incorrect, inaccurate, or incomplete, you may ask us to change or remove such personal data.

Erasure (Right to be forgotten)

If you want us to remove the personal data we have collected and/or processed from you, you can request Vuvale to erase your personal data.

Restriction

Instead of requesting erasure, you may also ask us to restrict the way we are processing your personal data if this right to restriction does not conflict with a processing activity required for the performance of the contract, required by law and does not outweigh a Vuvale legitimate interest.

Portability

If you wish to transfer the processed personal data to another controller of your choice, you may request us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format.

Object

You have the right to object against the processing of your personal data by Vuvale. If it concerns a processing activity that requires consent, you areentitled to remove your consent. If you no longer wish to receive email messages or any other electronic messages from us, you can deregister by clicking on the unsubscribe button in an email message received. You can also unsubscribe by contacting us following the instructions above.

Limitations of your rights

When a data subject request is made,Vuvale will, provide typically provide this service free of charge, however in exceptional cases Vuvale reserves the right to charge a reasonable fee. Data subject requests will only be implemented after the individual has validated their identity, confirming that they are the subject that the request concerns. This can be achieved by sending the request from the same email address used when signing up for a Vuvale service.

In certain situations,Vuvale may be entitled to refuse requests. For example, if Vuvale believeslegitimate grounds override the data subjects' interest then Vuvale may reasonably refuse to fulfill the request.Vuvale will justify in writing why that is the case.

Right to contact the supervisory body

If you believe your data request is not being handled correctly, we request that you email privacy@vuvale.com.au. If you disagree with the outcome of the handling of your complaint, you can submit a complaint to the Information and Privacy Commission NSW.

How do we protect your personal data?

Vuvaletakes appropriate technical and organisational measures to prevent the loss or unlawful processing of personal data, including but not limited to:

a. Physical Access Controls:

Vuvale has taken reasonable measures to prevent physical access, such as security personnel and secured buildings to prevent unauthorized persons from gaining access to Personal Data or have ensured third-party partners operating data centres on our behalf are adhering to our controls.

b. System Access Controls:

Vuvale has taken reasonable measures to prevent Personal Data from being used without authorisation. The controls vary based on the nature of the processing undertaken. They may includeauthentication via passwords and two-factor authentication, documented authorisation processes and logging of access on several levels.

c. Data Access Controls:

Vuvale takes reasonable measures to ensure that Personal Data is accessible and managed by authorized staff only. Application access rights are established and enforced to ensure that persons entitled to use a system only have access to Personal Data to which they have the privilege of entry and a company-wide policy that Personal Data cannot be read, copied, modified or removed without authorisation in the course of processing.

d. Transmission Controls:

Vuvale has taken reasonable measures to ensure that it is possible to check and establish the transfer of Personal Data by means of data transmission facilities so Personal Data cannot be read, copied, modified or removed without authorisation during electronic transmission or transport.

e. Input Controls:

Vuvale has taken reasonable measures to ensure that it is possible to check and establish whether and by whom personal data has been entered, modified or removed from a system.

f. Data Backup:

Back-up of databases are undertaken on a regular basis and are secured and encrypted to ensure that Personal Data is protected against accidental destruction, loss or unauthorized disclosure.

g. Logical Separation:

Data collected for different Vuvale services and purposes is logically segregated in Vuvale systems to ensure that personal data is collected and processed for the particular purpose Vuvale collected it for.

h. Security Audit:

Vuvaleimplements a maturity plan that will continuously improve security standards and work towards a standardized ISO certification.

How long do we keep your data?

We do not process your Personal Data any longer than is necessary for the purposes outlined in this Privacy Policy. However, we store your Personal Data as long as your Account is active or when the processing of your Personal Data is necessary to allow you to use our Vuvale Platform.

Links to other websites

The Websites may contain links to other websites we do not control. Therefore, we will not be responsible for the content of these websites nor for the processing of personal data that may occur on these websites.

Definitions

‘Account’ contains all information and content that a registered User has provided on the Platform. This mayinclude personal information, history,purchase records, opt in arrangements, payment details, complaints and any other information that the guest chooses to provide etc.

‘Application’ relates to Vuvale mobile application that can be used by ourguests to log an incident, interact with other guests, check information, view upcoming events, book an event or amenity.

‘Guest’ is each person who has entered in a rental agreementfacilitated by Vuvale to stay or live or an event agreement facilitated by Vuvale or a nominated third-party providerin one of the locations that Vuvale manages.

‘Personal Data’ is the information collected from the guest in the creation of the ‘Account’, the collection and management of ‘Application’ and the ‘Platform’.

‘Platform’ relates to the "Site", "Application" and "Services" provided on an online application used by guests and future guests to discover Vuvale, look for a room or space, apply for a room or space, subscribe to additional services, sign a rental agreement etc. It is the property of Vuvale and its subsidiaries.

‘Services’ means the delivery of accommodation services and real estate management through its Platform and onsite services.

‘Site’ means Vuvale website available via www.vuvale.com.au.

‘User’ is any guest or acquaintance of a guest from time to time, a future guest or any other user that gives his email address on the Vuvale website.

‘Vuvale’ is a company that manages coliving and hybrid hotel spaces by finding guests, managing their move-in, stay and move-out and tracking payment of rents.

Questions

If you have any questions about this Privacy Policy, please email privacy@vuvale.com.au.