LINGA NETWORK PTY LTD ACN 646 164 196 (LINGA NETWORK, us or we) is committed to responsible privacy practices, and seeks to comply with its obligations under the Privacy Act 1988 (Cth) (Privacy Act).

Your privacy is important to us. This Privacy Policy describes how we collect, use, disclose, store, and handle your personal information.

What is personal information?

In this Privacy Policy, ‘personal information’ has the meaning set out in the Privacy Act. Under the Privacy Act, ‘personal information’ is information or an opinion about an identified individual or an individual who is reasonably identifiable. Common examples may include a person’s name, address, telephone number or date of birth.

Some types of personal information are designated as ‘sensitive information’. Sensitive information is subject to additional protection under the Privacy Act. For example, this can include information about a person’s health.

Exemptions

Where applicable, we will rely on the employee records exemption in the Privacy Act and any other applicable exemptions in the Privacy Act or other legislation.

What types of personal information do we collect?

Types of personal information we may collect include:

• the names, contact details and positions of staff members of an operator of a venue, for example a restaurant or a museum (a Venue);
• the names and phone numbers of customers or patrons of a Venue that has entered a Services Agreement with Linga Network (a Patron) and any other personal information concerning a Patron that is required to be collected by law in respect of their attendance or visitation at that Venue;
• if you have contacted us online, by phone or otherwise, for example to provide feedback, submit an enquiry or make a complaint, your name, address, email address and telephone number;
• if you are an individual contractor to Linga Network or are seeking employment by Linga Network, information relevant to your engagement including qualifications, resume, pay rate and salary, bank details, feedback from referees and training records; and
• in the case of suppliers of products and services (and their staff), your name, position, street address, email address, and telephone number.

Generally, we will not collect sensitive information about you. However, in certain circumstances, we may collect limited sensitive information, for example, if you suffer an injury whilst on our premises.

If you access our website we may also collect technical information such as your web browser type and browsing preferences, internet service provider, referring/exit pages, date/time stamps, IP address and time zone. As you browse our website, we may collect information about the individual web pages or products that you view, what websites or search terms referred you to our website, and information about how you interact with our website.

How do we collect your personal information?

We collect personal information directly from you, including when you:

• access and use our website;
• apply to work with Linga Network or are engaged by Linga Network as a contractor;
• request information or material from us;
• communicate with Linga Network by email, by telephone, via our website or otherwise; or
• provide goods or services to us.

Where it is reasonable and practical to do so, we will only collect personal information about you from you directly and not from third parties.

In some circumstances, we may collect personal information about you:

• from publicly available sources (such as the internet); or
• from third parties, for example
• from your referees during the recruitment process if you apply for a job with us; or
• from our service providers who we engage to assist us with our activities.

We may also use the following technologies to collect technical information:

• cookies, which are data files that are placed on your device and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit allaboutcookies.org;
• log files, which track actions occurring on our website; and
• web beacons, tags and pixels, which are electronic files used to record information about how you browse our website.

How do we use your personal information?

Generally, we use your personal information for purposes connected with our business operations.

Some specific purposes for which we may use your personal information include:

• to record it as required by law so that you may enter a Venue during the COVID-19 pandemic;
• to communicate with you;
• to consider you for a job at Linga Network (whether as an employee or contractor) or another relationship with Linga Network;
• to provide goods or services to you or to receive goods or services from you; and
• to address any enquiries or complaints that you raise.

We may contact you regarding the above, including via electronic messaging such as SMS and email, by phone or in any other lawful manner.

We may also use your personal information for our service development purposes and for other purposes to which you have consented, or as otherwise permitted or required by law.

To whom do we disclose your personal information?

We may disclose your personal information to third parties in connection with the purposes described above.

This may include disclosing your personal information to the following types of third parties:

• our service providers who assist us with our activities, for example IT service providers such as our cloud services provider, insurers and professional advisors;
• any third parties to whom you have directed or permitted us to disclose your personal information (e.g. referees if you are applying for a job with us);
• in the unlikely event that we or our assets may be acquired or considered for acquisition by a third party, that third party and its advisors;
• third parties that require the information for law enforcement or to prevent a serious threat to public safety; and
• any other person as authorised or permitted by law.

We may also share your personal information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to protect our rights.

How do we protect your personal information?

We will take reasonable precautions to protect the personal information we hold from misuse, loss, or unauthorised access, modification or disclosure. However:

• as the internet is inherently insecure, we cannot guarantee the security of transmission of personal information you disclose to us online. Accordingly, you transmit your personal information to us online at your own risk; and
• except to the extent liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of any unauthorised access to, modification of, disclosure of, misuse of or loss or corruption of your personal information.

Nothing in this Privacy Policy restricts, excludes or modifies or purports to restrict, exclude or modify any statutory consumer rights under any applicable law including the Competition and Consumer Act 2010 (Cth).

Please notify us immediately if you become aware of any breach of security.

Third party websites

Our website may contain links to other websites operated by third parties. These websites are outside of our control and we make no representations or warranties in relation to their privacy practices. We recommend you review these websites’ separate privacy policies.

Venues’ privacy policies and practices

Venues and their owners and operators are independent of Linga Network and may have privacy policies and practices which differ from ours. They are responsible for their own privacy policies and practices. Please contact Venues (or their owners or operators) directly for further information.

How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting us. We will provide access to that information in accordance with the Privacy Act, subject to any exemptions that may apply. We may charge an administration fee for providing access in limited circumstances.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it by contacting us.

How can you raise a question or complaint about privacy?

If you have any questions, concerns or complaints about our collection, use, disclosure or management of your personal information, please contact us in writing using the contact details below.

We will make inquiries and your complaint will be assessed by an appropriate person with the aim of resolving any issue in a timely and efficient manner.

If you are unsatisfied with the outcome, we will advise you about further options including, if appropriate, review by the Privacy Commissioner within the Office of the Australian Information Commissioner.