BlueKee Pty Limited
Privacy Policy

1.       We respect your privacy

1.1.    BlueKee respects your right to privacy and is committed to safeguarding the privacy of our customers, website visitors and BlueKee App users.

1.2.    We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (the Act) and to the extent applicable, the EU General Data Protection Regulation (GDPR).

1.3.    This policy sets out how we collect and treat your personal information.

2.       What is "personal information"?

2.1.    According to the Act, "personal information" is information we hold which is identifiable as being about you. This might include information such as your name, email address, an identification number which is linked to your identity, or any other type of information that can reasonably identify an individual, either directly or indirectly.

2.2.    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.

3.       How do we collect information?

3.1.    BlueKee collects personal information from you in a variety of ways, including when you interact with us electronically or in person, when you access or enter information into the BlueKee App and when we provide our services to you.

3.2.    We may also collect cookies from your computer which enable us to tell when you use the website and also to help customise your website experience. As a general rule, however, it is not possible to identify you personally from our use of cookies.

3.3.    We may receive personal information from third parties. If we do, we will protect it as set out in this Privacy Policy.

3.4.    By providing us with personal information, you consent to the supply of that information subject to the terms of this Privacy Policy.

4.       What information do you collect?

4.1.    In order to provide identity verification services to you and those who rely on our identity verification services, we will collect various identifying information from you, including:

a.       basic information such as your name, phone number, address and email address; or

b.       more detailed personal information such as your date of birth, drivers’ licence, passport, birth certificate, credit history, organisational memberships, qualifications and other information which may be specifically required by a particular client of ours to verify your identity.

c.       A photograph “selfie” of you taken during onboarding for the purpose of ongoing identity verification.

4.2.    We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support (Feedback and Customer Support Information).

5.       How do you use the personal information you gather? 

5.1.    BlueKee will use personal information only for the purposes that you consent to. This may include to:

a.       provide you or our clients with products and services, including through the disclosure of your information to our subcontractors and third party verification service providers in the ordinary course of our business activities;

b.       administer our business activities;

c.       manage, research and develop our products and services;

d.       provide you with information about our products and services;

e.       communicate with you by a variety of measures including, but not limited to, by telephone, email, sms or mail; and

f.        investigate any complaints.

5.2.    Importantly, as a provider of identity verification services, BlueKee may provide verification of your personal information to registered third party clients (Enterprise Customers) in order for them to confirm your identity. The type and quantity of disclosure may vary depending on the Enterprise Customer relying on our services.

5.3.    Before disclosing your personal information to third parties for identity verification purposes, we ask that those third parties are compliant with the Act or the GDPR as appropriate and comply with this Policy regarding the handling of your personal information.

5.4.    BlueKee may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this privacy policy.

5.5.    BlueKee may use personal information collected from you to provide you with information about our products or services. We may also make you aware of new and additional products, services and opportunities available to you.

5.6.    If you withhold your personal information, it may not be possible for us to provide you with our products and services or to provide identity verification services to the standard required by our Enterprise Customers.

5.7.    We may disclose your personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, legal proceedings or in response to a law enforcement agency request.

5.8.    If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases.

5.9.    Information that we collect may from time to time be stored, processed in or transferred between parties located in countries outside of Australia.

5.10.    The purpose for which we collect personal information on our website is to provide you with the best service experience possible on the website. We customarily disclose personal information only to our service providers who assist us in operating the website. Your personal information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.

5.11.    By using our website, you consent to the receipt of direct marketing material. We will only use your personal information for this purpose if we have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from us. We do not use sensitive personal information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature.

6.       Security of your personal information

6.1.    BlueKee is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

6.2.    Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the Act and, if applicable, the GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft.

6.3.    The transmission and exchange of information is carried out at your own risk. We cannot guarantee the security of any information that you transmit to us, or receive from us. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

7.       BlueKee App

7.1.    Data Collection: When you come to the BlueKee App we may collect certain information such as mobile unique device ID, the IP address of your mobile device, mobile operating system, the type of mobile internet browsers you use, and information about the way you use the BlueKee App.  We will also collect photos and video of you during our onboarding process. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

7.2.    Selfie: When you use the BlueKee App, we may save a photo of you on your device, captured at the time of your identity verification, for the purpose of the future verification of your identity against the previously captured image. This image will only be stored on your device.

7.3.    Cookies: We may from time to time use cookies on the BlueKee App. Cookies are very small files which a website uses to identify you when you come back to the BlueKee App and to store details about your use of the BlueKee App. Cookies are not malicious programs that access or damage your computer, tablet or smartphone. Most devices automatically accept cookies but you can choose to reject cookies by changing your device settings. However, this may prevent you from taking full advantage of the BlueKee App.

7.4.    Automatic collection: The BlueKee App may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile devices unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browsers you use, and information about the way you use the BlueKee App.

7.5.    Third parties: The BlueKee App may from time to time have links to other applications or websites not owned or controlled by us. These links are meant for your convenience only. Links to third party applications and websites do not constitute sponsorship or endorsement or approval of these third parties. Please be aware that BlueKee is not responsible for the privacy practises of other such applications or websites. We encourage our users to be aware, when they leave the BlueKee App or website, to read the privacy statements of each and every application or website that collects personal identifiable information.

7.6.    Geo-location: When you visit the mobile application, we may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located within for the purpose of executing our Identity Contracts, onboarding/identity verification and fraud detection. We will not share your current location with other users.

7.7.    Opt-out right: You can stop all collection of information by the BlueKee App easily by uninstalling the BlueKee App. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out via email, at info@bluekee.tech

8.       Website

8.1.    Data Collection: When you come to our website (https://bluekee.tech/), we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.

8.2.    Cookies: We may from time to time use cookies on our website. Most web browsers automatically accept cookies but you can choose to reject cookies by changing your browser settings. However, this may prevent you from taking full advantage of our website. Our website may from time to time use cookies to analyses website traffic and help us provide a better website visitor experience. In addition, cookies may be used to serve relevant ads to website visitors through third party services such as Google AdWords. These ads may appear on this website or other websites you visit.

8.3.    Third party sites: Our site may from time to time have links to other websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that BlueKee is not responsible for the privacy practises of other such websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

9.       General Data Protection Regulation (GDPR) for the European Union (EU)

9.1.    BlueKee will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.

9.2.    We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.

9.3.    We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.

9.4.    We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure.

9.5.    We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation.

9.6.    We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.

9.7.    We do not collect or process any personal information from you that is considered "Sensitive Personal Information" under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.

9.8.    You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.

10.       Your rights under the GDPR

10.1.    If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used. BlueKee complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU

10.2.    Except as otherwise provided in the GDPR, you have the following rights:

a.       to be informed how your personal information is being used;

b.       access your personal information (we will provide you with a free copy of it);

c.       to correct your personal information if it is inaccurate or incomplete;

d.       to delete your personal information (also known as "the right to be forgotten");

e.       to restrict processing of your personal information;

f.        to retain and reuse your personal information for your own purposes;

g.       to object to your personal information being used; and

h.       to object against automated decision making and profiling.

10.3.    Your data may be retained by BlueKee until we have used it for the purposes for which it was collected. This includes for the purpose of demonstrating the integrity of our identity verification services, providing assurance services to Enterprise Customers and contract counterparties, security, fraud prevention and detection, investigations and process auditing.

10.4.    Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy.

10.5.    We may ask you to verify your identity before acting on any of your requests.

11.       Overseas transfer

11.1.    Your personal information may be transferred overseas or stored overseas for a variety of reasons. It is not possible to identify each and every country to which your personal information may be sent, but we note that:

a.       The hosting facilities for the BlueKee App are situated in Australia;

b.       The hosting facilities for our website are situated in Australia;

c.       Our Suppliers and Contractors are situated in Australia;

d.       Our Enterprise Customers may be located outside Australia, or located in both Australia and overseas.

11.2.    If your personal information is sent to a recipient in a country with data protection laws which are at least substantially similar to the Australian Privacy Principles, and where there are mechanisms available to you to enforce protection of your personal information under that overseas law, we will not be liable for a breach of the Australian Privacy Principles if your personal information is mishandled in that jurisdiction.

11.3.    Such transfers will be protected by appropriate safeguards, including, where the GPDR is applicable, the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website.

11.4.    If your personal information is transferred to a jurisdiction which does not have data protection laws as comprehensive as Australia's, we will take reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the Australian Privacy Principles.

11.5.    You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

12.       Access and correction

Australian Privacy Principle 12 permits you to obtain access to the personal information we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct inaccurate personal information subject to certain exceptions. If you would like to obtain such access, please contact us as set out below.

13.       Complaint procedure

If you have a complaint concerning the manner in which 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.

14.       Changes to Privacy Policy

Please be aware that we may change this Privacy Policy in the future. We may modify this Policy at any time, in our sole discretion and all modifications will be effective immediately upon our posting of the modifications on our website or notice board. Please check back from time to time to review our Privacy Policy.

15.       How to contact us about privacy

If you have any queries, or if you seek access to your personal information, or if you have a complaint about our privacy practices, you can contact us through: info@bluekee.tech.