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PRIVACY POLICY

1. Personal information we collect

1.1 Information required when using the Onthelease Platform
We collect personal information about you when you use the Onthelease Platform. Without it, we may not be able to provide you with all services requested. This information includes:

1.1.1 Contact Information, Account, Profile Information
Such as your first name, family name, telephone phone number, postal address, email address, date of birth, and profile photo. Some of which will be depending on the features you will make use of.

1.1.2 Verification of Identity and Payment Information
Such as images of your ID issued by the government (as permitted by applicable laws), your ID number or other verification information, bank account or payment account information.

1.2 Information you opt to give us
You can choose to provide us with additional personal information. This information may include:

1.2.1 Additional Profile Information
Such as gender, preferred language(s), residential city, and personal description. Some of this information as indicated in your account settings will become part of your public profile page and will be visible publicly.

1.2.2 Other information
Such as information you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with our team and other Members, or share your rental experience with us. This may include health information if you choose to share it with us.

1.3 Information automatically collected by using the Onthelease platform and our payment services
When you use the Onthelease Platform and Payment Services, we automatically collect personal information. This information may include:

1.3.1 Usage Information
Such as the pages or content that you have viewed, searches for Listings, reservations you have made, and other actions on the Onthelease Platform.

1.3.2 Log Data and Device Information
Such as details about how you have used the Onthelease Platform (including if you clicked on links to third party applications), access dates and times, IP address, hardware and software information, device information, device event information, unique identifiers, cookie data, crash data, and the pages you have viewed or engaged with prior to or after using the Onthelease Platform. We may collect this information even if you haven not created an Onthelease account or logged in.

Details about Cookies and Similar Technologies in our Cookie Policy.

1.3.3 Payment Transaction Information
Such as payment method used, date and time, payment amount, expiration date of payment instrument and billing postcode, PayPal email address, IBAN information, your address and other related transaction details.

1.4 Personal Information We Collect from Third Parties
We collect personal information from other sources, such as:.

1.4.1 Third-Party Services
If you login, connect, or link to the Onthelease Platform with a third party service (such as Google, Facebook), you direct the third party service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorised by yourself via your privacy settings of that service you have chosen.

1.4.2 Background Information
For Members in Australia, to the extent permitted by applicable laws and with your consent where required, we may obtain the local version of police, background or registered sex offender checks when necessary. In order to obtain such reports, we may use your information, including your full name and date of birth.

1.4.3 Other Sources
To the extent permitted by applicable law, we may receive additional information about you, such as references, demographic data or information to help detect fraud and safety issues from third party service providers and/or partners, and combine it with information we have about you. For instance, we may receive background check results or fraud warnings from identity verification service providers for use in our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Onthelease Platform, or about your experiences and interactions from our partners. We may receive health information, including but not limited to health information related to contagious diseases.



2. How are these information used after we collect them

2.1 Provide, improve, and develop the Onthelease platform. 

We use personal information to:

  • Enable your access to the Onthelease Platform and make and receive payments,
  • Enable you to communicate with other Members,
  • Analyse, debug and conduct researches,
  • Provide customer service,
  • Send messages, updates, security alerts, and account notifications to you, and
  • Personalise and customise your user experience based on your interactions with the Onthelease Platform, your search and reservation history, your profile information and preferences, and other content you submit.

2.2 Create and maintain a trusted and safer environment.

We use personal information to:

  • Detect and prevent fraud, spam, abuse, security and safety incidents, and other harmful activity,
  • Study and fight discrimination in consistent with our Non-discrimination Policy, conduct security investigations and risk assessments,
  • Verify or validate information you provide,
  • Conduct checks against databases and other information sources, including   background or police checks,
  • Honour our legal obligations, guard the well-being of our members,
  • Resolve disputes amongst our Members,
  • Enforce our agreements with third parties,
  • Comply with law, respond to legal requests, prevent harm and protect our rights (refer to article 3.5)
  • Enforce our Terms and other policies (such as Non-discrimination Policy), and

in connection with the activities above, we may conduct profiling based on your interactions with the Onthelease Platform, information found in your profile and other content you submit to Onthelease, and information obtained from third parties. In limited cases, automated processes could restrict or suspend access to the Onthelease Platform if such processes detect activity that we assume poses a safety or other risk to Onthelease, our community, or third parties. If you would like to challenge the decisioning based on the automated process, please contact us via the Contact Information section below.

2.3 Provide, personalise, measure, and improve our Advertising and Marketing. 

We may use personal information to:

  • Send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms,
  • Personalize, measure, and improve our advertising,
  • Administer referral programs, rewards, surveys or other promotional activities or events sponsored or managed by Onthelease or its third-party partners,
  • Analyse characteristics and preferences to send you promotional messages, marketing, advertising and other information that you may be interested in and
  • Invite you to events and relevant opportunities.


2.4 Provide Payment Services.

Personal information is used to enable or authorize third parties to use Payment Services:

  • Spot and prevent money laundering, fraud, abuse, security incidents.
  • Conduct security investigations and risk assessments.
  • Comply with legal obligations (such as anti-money laundering regulations).
  • Enforce the Payment Terms and other payment policies.
  • With your consent, send to you promotional messages, marketing, advertising, and other information that you may be interested in based on your preferences.
  • Provide and improve the Payment Services.


3. Sharing and disclosure

3.1 Sharing with your consent or at your direction

Where you consent that we share your information as described at the time of consent, such as when authorising a third-party application or website to access your Onthelease account or participating in promotional activities by Onthelease partners or third parties.

To the extent permitted by applicable law, we may use certain information about you, such as your email address, de-identify it, and share it with social media platforms, to generate leads, drive traffic to Onthelease or otherwise promote our services.

3.2 Sharing Between Members

To help facilitate reservations or other interactions between Members, we may need to share certain information such as when a booking request is made or when a dispute is submitted, certain information may be shared between Customer(s) and Asset Owner(s), including name, profile, cancellation history, review contents, age of Customer (unless prohibited by applicable law), dispute outcome (when applicable) and other information you choose to share and submit. When a reservation is confirmed, additional information is shared to assist with coordinating the exchange, such as profile photo and phone number. When an Asset Owner has a confirmed reservation, certain information is shared with the Customer to coordinate the booking, such as your first and last name, profile, phone number, and Listing address.

3.3 Information you publish in profiles, listings, and other public information

You can opt to make certain information publicly visible to the other members, such as:

  • Your public profile page, which includes your profile photo, first name, description, and city you are
    located in.
  • Listing pages that include information such as the Asset or the approximate asset location or precise location description, availability calendar, profile photo, aggregated demand information (like page views over a period of time), and additional information you choose to share.
  • Reviews, ratings and other public feedback.
  • Content in a community or discussion forum, blog or social media post.
  • We may display parts of your public profile and other Content you make available to the public like listing details on third-party sites, platforms and apps.
  • Information you share publicly on the Onthelease Platform may be indexed through third-party search engines. In some cases, you may opt-out of this feature in your account settings.

3.4 Asset Owner service providers

Asset Owners may use third-party services to help manage or deliver their asset, such as delivery or cleaning services. Asset Owners may use features on the Onthelease Platform to share information about the Customers (like rental dates, Customer name, Customer phone number) with such third-party service providers.

3.5 Complying with law, responding to legal requests, preventing harm and guarding our rights 

if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary, we may disclose your information to courts, law enforcement, governmental or public authorities, tax authorities, or authorised third parties:

  • to honour our legal obligations,
  • to comply with a valid legal request or to respond to claims asserted against Onthelease,
  •  to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability (more information on Onthelease’s Law Enforcement Guidelines here), or to respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity,
  •  to enforce and administer our agreements with Members, or
  • to guard the rights, property or personal safety of Onthelease, its employees, its Members, or members of the public. For example, if permitted due to the forgoing circumstances, tax information of the Asset Owner may be shared with tax authorities or other governmental agencies.
  • Where appropriate, we may notify Members about legal requests unless:
  • Providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or
  • We believe that providing notice would be impractical, ineffective, create a risk of injury to an individual or group, or create or increase a risk of fraud upon or harm to Onthelease, our Members, or expose Onthelease to a claim of obstruction of justice.
  • For Taxes, we may disclose information of our Members such as transactions, and reservations, Taxes to the applicable tax authority, such as member names, transaction dates and amounts, and contact information.

3.6 Service providers

We share personal information with affiliated and unaffiliated service providers to support us in running our business, including service providers that help us:

  • verify your identity or validate your identification documents,
  • check information against public databases,
  • conduct background or police checks, fraud prevention, and risk assessment,
  • perform platform development, maintenance and debugging,
  • allow the provision of the Onthelease Services through third-party platforms and software tools (e.g. through the integration with our APIs),
  • provide customer service, payment services, or advertising,
  • process, handle or assess insurance claims or similar claims, or
  • facilitate non-profit and charitable activities consistent with Onthelease’s mission. These providers are contractually bound to protect your personal information and have access to your personal information to perform these tasks.

3.7 Business transfers

If Onthelease undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (such as due diligence). In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4. Other important information

4.1 Analysing your communications 

We may review, scan, or analyse your communications on the Onthelease Platform for reasons outlined in the section “How We Use Information We Collect” within this policy, including customer support purposes, enforcing our Terms of Service, analytics, research, platform development, investigation,  regulatory compliance, risk assessment and fraud prevention. For instance, as part of our fraud prevention efforts, we scan and analyse messages to conceal contact information and references to other sites. In some cases, we may also scan, review, or analyse messages to debug, improve, and expand service offerings. We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. Onthelease will not review, scan, or analyse your messaging communications to send third-party marketing messages to you and reviews or analyses of these communications will not be sold.

4.2 Linking third-party accounts

You can link your Onthelease account with certain third-party services like social networks. Your contacts on these third-party services are referred to as “Friends.” When you direct the data sharing by creating this link:

  • some of the information provided to us from linking accounts may be published on your public profile,
    your activities on the Onthelease Platform may be displayed to your Friends on the Onthelease Platform and/or that third-party service,
  • a link to your public profile on that third-party service may be included in your Onthelease public profile,
  • other Onthelease Members may be able to see any Friends that you may have in common with them, or that you are a Friend of their Friend if applicable,
  • other Onthelease Members may be able to see any schools, hometowns or other groups you have in common with them as listed on your linked social networking service,
  • information you provide to us from the linking of your accounts may be stored, processed and transmitted for fraud prevention and risk assessment purposes, and
  • publication and display of information that you provide to the Onthelease Platform through this linkage is subject to your settings and authorisations on the Onthelease Platform and the third-party service.

4.3 Third-party partners and integrations

Parts of Onthelease may link to third-party services, which are not owned or managed by Onthelease, such as Google Maps/Earth. Use of these services is subject to the privacy policies of those providers, such as Google Maps/Earth Additional Terms of Use, Google Privacy Policy (see here for more information on how Google uses information), and Citi Privacy Policy. Onthelease does not own or control these third parties and when you interact with them you are providing your information to them.

5. Your rights

You can exercise any of the rights described in this section consistent with applicable law. This section contains information on data subject rights requests and how to submit a request. We may ask you to verify your identity and request before we process your request any further.

Discover more about rights under Australian Privacy Act.

5.1 Managing your information. 

You can access and update some of your personal information through your Account settings. If you have connected your Onthelease Account to a third-party service, such as Facebook or Google, you can change your settings and unlink from that service in your Account settings. You are responsible for keeping your personal information up to date.

5.2 Data access and portability

In some jurisdictions, applicable law may entitle you to request certain copies of your personal information or information about how we handle your personal information, request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format, and/or request that we transmit this information to another service provider (where technically feasible).

5.3 Data erasure

In certain jurisdictions, you can request to delete your personal information. Please note that if you request the erasure of your personal information:

  • We may retain your personal information as necessary for our legitimate business interests, such as fraud detection and prevention, prevention of money laundering, and enhancing safety. For instance, we may retain information from that Onthelease Account if we suspend an Onthelease Account for fraud or safety reasons, to prevent that Member from opening a new Onthelease Account in the future.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For instance, Onthelease and Onthelease Payments may keep information for tax, legal reporting and auditing obligations.
  • Information you have shared with others (such as, Reviews) will continue to be publicly visible on Onthelease platform, even after your Onthelease Account is terminated. However, attribution of such information to you will be removed. Some copies of your information (such as, log records) will remain in our database, but are disassociated from personal identifiers.

Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.


6. Security

While no organisation can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorised access, loss, destruction, or alteration.

7. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you may terminate your Account. If you do not terminate your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Onthelease Platform will be subject to the revised Privacy Policy.