The protection of personal information is important to Sven Global Pty Ltd (ACN 648 221 210) (Sven). Sven is committed to respecting the right to privacy and the protection of personal information.

This document sets out how Sven may collect, hold and use personal information. By providing your personal information to Sven, you consent to its use, storage and disclosure in accordance with this Privacy Policy.

For the purposes of the General Data Protection Regulation 2016/679 (GDPR), Sven is a ‘data controller’ for the processing of personal information you provide to us in connection with our services.

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What personal and sensitive information does Sven collect?

Personal Information

Personal information is information or an opinion (including information or an opinion forming part of a database) from which it is possible to determine someone's identity (where the GDPR applies, personal information has the meaning of personal data given under the GDPR).

The information collected by Sven about a particular person will vary depending on the circumstances of collection. It may include, but is not limited to, a person's contact details (name, email and/or postal address, phone number), date of birth, gender, credit card details, driver's licence number, passport number, insurance details, employment history, qualifications or communication history with Sven. Sven may also collect online identifiers such as your IP address and data regarding your device and the network you are using to connect with Sven.

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Sensitive Information

Sensitive information is a type of personal information that also includes information or an opinion about someone's:

• racial or ethnic origin;
• political opinions;
• membership of a political association, professional or trade association or trade union;
• religious beliefs or affiliations or philosophical beliefs;
• sexual preferences or practices;
• criminal record; or
• health, genetic information or disability.

If it is reasonably necessary in the circumstances, Sven may also collect sensitive information such as a person's medical history, nationality, their ethnic background or disabilities.

Sven is required by law to obtain consent when collecting sensitive information. Sven will assume consent to the collection of all sensitive information that is provided to it for use in accordance with this Privacy Policy, unless told otherwise.

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How does Sven collect personal and sensitive information?

Information may be collected when you:

1. apply for an employment, engagement, contractor or volunteer position with Sven;
2. apply to promote services through Sven;
3. subscribe to any publication of Sven, including electronic publications;
4. provide details to Sven in an application, consent form, survey, feedback form or incident report;
5. enter personal information into, or agree to having your personal information entered into, one of Sven's systems;
6. access the Sven app or website;
7. contact Sven via email, telephone or mail or engage with Sven via social media;
8. participate in any program, activity, competition or event run by Sven;
9. purchase merchandise, products or services from Sven or an authorised agent or licensee; or
10. where Sven is required to do so by law (for education, child protection, work health and safety laws, charitable collections, medical treatment or other relevant legislation).

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Providing information‍

Sven will only process your information where:

• you have given your consent to such processing (which you may withdraw at any time);
• the processing is necessary to provide Sven services to you;
• the processing is necessary for compliance with our legal obligations; and/or
• the processing is necessary for our legitimate interests or those of any third party recipients that receive your personal information.

Depending on the circumstances, some types of information will be required and others might be optional. If you do not provide some or all of the information requested, this may affect Sven's ability to communicate with you or provide the requested products or services.

By not providing requested information, you may jeopardise your ability to participate in services, programs or competitions or apply for employment or services with Sven. If it is impracticable for Sven to deal with you as a result of you not providing the requested information or consent, Sven may refuse to do so.

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Collection from third parties

Sven or a related entity of Sven may also collect personal information. In some circumstances, Sven also collects information from other third parties. Examples of such third parties could include, without limitation travel organisations, industry associations or government and law enforcement bodies.

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Information storage and protection

Sven stores information in different ways, including in paper and electronic form.

Much of the information we collect from and about our users is added to Sven’s user database. When your information is entered into Sven's user database, the information may be combined or linked with other information held about you.

Security of personal information is important to Sven. Sven has taken steps to protect the information we hold from misuse, loss, unauthorised access, modification or disclosure. Some of the security measures Sven uses includes strict confidentiality requirements of our employees and service providers, security measures for system access and security measures for our app and website.

We seek to protect your personal information from any unauthorised loss, disclosure or access. However, if a serious data breach occurs, we must notify you as required under the Privacy Act regarding the circumstances of the breach and must also advise the Office of the Australian Information Commissioner.

We will destroy or de-identify personal information once we no longer require it for our business purposes, or as required by law.

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How does Sven use and disclose personal and sensitive information?

Use

Sven, and third parties to whom we may disclose personal information in accordance with this Privacy Policy, may use your personal information to:

1. verify your identity;
2. complete background checks;
3. research, develop, run, administer and market competitions, programs, activities and other events relating to Sven;
4. research, develop and market products, services, merchandise and special offers made available by us and third parties;
5. respond to emergency situations involving or requiring medical treatment;
6. administer, manage and provide you with access to the Sven app or website;
7. keep you informed of news and information relating to various Sven events, activities and opportunities via various mediums.

Sven may use health information to ensure that programs we operate are run safely and in accordance with any special health needs participants may require. Health information may also be kept for insurance purposes. In addition, we may use de-identified health information and other sensitive information to carry out research, customise services, prepare submissions to government, or to plan events and activities.

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Disclosure

Sven may disclose your personal information to a range of organisations which include, but are not limited to:

1. a related party of Sven or other organisations involved in Sven services or programs in Australia;
2. companies we engage to carry out functions and activities on Sven's behalf, including direct marketing;
3. our professional advisers, including our accountants, auditors and lawyers;
4. our insurers;
5. in other circumstances permitted by law.

In some circumstances, personal information may also be disclosed outside of Australia.  In such circumstances, Sven will use its best endeavours to ensure such parties are subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are suitably similar to the Australian Privacy Principles and your local data protection laws.

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Direct Marketing

We will assume consent to use non-sensitive personal information to provide better services and for marketing purposes (including disclosure of such information to service providers).

Every person whose data is collected by Sven has the option to refuse e-mail, SMS or posted offers by making a request in writing to Sven via the contact details set out below or by making use of the opt-out procedures included in any communications from us (however, information relating to the option to unsubscribe from those communications may be retained).

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Other disclosures

In addition, Sven may also disclose personal information:

1. with your express or implied consent;
2. when required or authorised by law;
3. to an enforcement body when reasonably necessary; or
4. to lessen or prevent a threat to an individual or public health or safety.

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Sven website and app

When users visit the Sven website or app, our systems may record certain information about their use, including the pages visited and the time and date of their visit. Sven uses this information to help analyse and improve the performance of the Sven website or app.

In addition we may use “cookies” on the Sven website or app. Cookies are small text files that help a website to remember the preferences of users to improve the experience of using that website or app. In some cases, the cookies that we use may collect some personal information. Sven will treat this information in the same way as other personal information we collect. You are free to disable cookies to prevent this information being collected; however, you will lose the benefit of the enhanced experience that the use of cookies may offer.

Websites or other pages linked to the Sven website or app are not subject to Sven's privacy standards, policies or procedures. Sven cannot take any responsibility for the collection, use, disclosure or security of any personal information that you provide to a third party website.

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Accessing and seeking correction of information held by Sven

Sven will take all reasonable steps to ensure that the personal information it collects, uses or discloses is accurate, complete and up-to-date. However, we rely on the accuracy of personal information as provided to us both directly and indirectly.

We encourage all users to regularly review and update their personal information. If you would like to access personal information that we hold about you, we require you to put your request in writing. If we do not allow you access to any part of the personal information we hold about you, we will tell you why.

Individuals may also request access to their personal information held by us by making a request via the contact details set out below. We will respond to your request as soon as possible. If you find that the personal information we hold about you is inaccurate, incomplete or out-of-date, please contact us immediately and we will see that it is corrected.

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Rights of European Union residents

If you are located in the European Union (EU), you may have additional rights which apply in certain circumstances. You:

• can withdraw your consent, where we rely on it for processing your personal information, at any time;
• can ask us to confirm if we are using your personal information;
• can ask us to delete your personal information. This right only applies in limited circumstances and will not usually apply where it remains necessary for Sven to process your information for the purposes for which it was collected, we are required by law to retain your information or your information is relevant to a legal dispute;
• can ask us to stop or restrict how we process your personal information. These rights will apply in limited circumstances and will not usually apply when Sven needs to process your information to carry out our day-to-day business functions or where we have compelling legitimate grounds for processing your information;
• can ask us to help you move your personal information to other companies, where this is technically possible and only if we have collected and used your data via automatic means; and
• have the right to be informed and know about any protections that we have put in place when we are transferring your data overseas.

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Resolving privacy issues and complaints

Any issues or complaints in relation to the collection, use, disclosure, quality, security of and access to your personal information may be addressed to the ‘Sven Privacy Officer’ at this address:

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Sven - Privacy Officer
Address: Level 13, 600 St Kilda Rd, Melbourne, VIC, 3004, Australia.
Email: hello@sven.global

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If we are unable to resolve your complaint, or you are unhappy with the outcome, you can contact the Office of Australian Information Commissioner via its enquiries line 1300 363 992 or website http://www.oaic.gov.au/ to lodge a complaint. If you are located in the EU, you have the right to complain to the local data protection authority within the EU, see here for more information.

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Sven may amend this Privacy Policy from time to time.

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