Goki Pty Ltd Privacy Policy

Last updated: 1 September 2020

 

Goki Pty Ltd. (“Goki”, “we”, “our” or “us”) knows that you take your privacy seriously. We do, too. We are committed to being transparent with you about our privacy practices and giving you control over your data in connection with your use of Goki’s hostel room access and security hardware services and guest management software services (“Services”). Our Services are not available to individuals who are younger than 16 years old.

If you have questions or concerns regarding this Privacy Policy or our handling of your Personal Information collected under this Privacy Policy, contact us at privacy@goki.travel or 11 York St, CBD, Sydney, New South Wales 2000, Australia. We will make every effort to resolve your concerns. If you do not want us to process your Personal Information as set out in this policy, do not access or use our Services or interact with any other aspect of our business.

 

Scope

This Privacy Policy explains how Goki processes (e.g. collects, uses, stores, discloses, transfers and deletes) your personal information (“Personal Information”) and other data that Goki gathers when you are accessing Goki’s Services or our website(s) and mobile applications (“Sites”). Personal Information is any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal Information does not include information that is de-identified/ anonymised or is in an aggregate, non-personally identifiable form.

This Privacy Policy also tells you about your rights with respect to your personal information, and how you can reach us to correct, delete or update it or get answers to questions you may have about our privacy practices.

Additional information on our privacy practices may be provided in other documents such as offer descriptions, supplemental privacy policies, or notices provided prior to or at the time of Personal Information collection.

 

What Personal Information Does Goki Collect?

  • Personal Information You Provide to Us: We receive and store any Personal Information you provide directly to us through our Services. The types of Personal Information collected includes identifiers such as your name, email address, phone number, birthday, geographic location, information regarding your use of our Services, and browser information. We also collect information you provide when you interact with us in-person, online, or by phone or mail with our help desk, online store and customer support channels, your responses to customer surveys or additional information you provide to us to facilitate the delivery of our products and services, and to respond to your inquiries.
  • Personal Information We Collect Automatically: When you visit our Sites or use our Services, we may also collect certain information automatically from your device, browser or mobile platform, web applications and/or mobile applications, such as your IP address, online identifiers such as cookies, unique device identifiers, advertising identifiers, and other technical information. In some countries, including countries in the European Economic Area (“EEA”), this type of information may be considered Personal Information under applicable data protection laws.

We automatically receive your geo-location data (e.g. country or city-level location) when you use the Services. We use various technologies to determine your location, such as location services of the applicable mobile device operating system (i.e. iOS or Android) or browser and sensor data from your device that may, for example, provide information on nearby Wi-Fi- access points and cell towers.

Goki also automatically receives and records certain non-Personal Information from your device, browser or mobile platform, web applications and/or mobile applications on our server logs when you use the Services or visit the website, including your browser type, operating information, mobile carrier, device and application IDs, and the page you requested. Unless otherwise stated in this Privacy Policy, Goki only uses this data in aggregate form. We may provide aggregate information to our partners about how our users, collectively, use our Services, so that our partners may also understand how often people use their services and our Services.

  • Personal Information We Receive from Third Parties: We receive and store information from third parties that interact in some way with the Services or that provide services to us in connection with the Services. As a further example, you may choose to use apps that share your Personal Information, activities and/or content with Goki such as social media sites like Instagram. Please read the privacy policy of any such app so that you understand its sharing practices.

If you choose to provide us with a third party’s Personal Information (such as name, email, and phone number), you must ensure that you have the third party’s permission to do so and that you provide them with a copy of this Privacy Policy.

 

How Does Goki Use My Personal Information?

The Personal Information you provide is used only for legitimate business purposes such as:

  • to allow you to set up a user account and profile that can be used to interact with other users through the Services;
  • to maintain, improve and develop our Services; We will use your Personal Information to ensure our Services are working as intended and to make improvements to our Services.  We will also use the information we collect in existing Services to help us develop new ones for you;
  • to adapt the Services of our community to your needs, to research the effectiveness of our network and Services, and to develop new tools for the community;
  • to customize and send you and your friends marketing communications and content about products, services, new features, offers, specials, programs and promotions (including contests and any other marketing activities). These might be our own offers or products or offers for third-party products we think you might find interesting;
  • to protect our company, customers, website and apps, prevent fraud and secure our products;
  • to comply with applicable laws and regulations as required or further to a request by any judicial process or governmental agency having or claiming jurisdiction over Goki; and
  • to fulfill or meet the reason you provided the information to us. For example, if you share your name and contact information to ask a question about our Services, we will use that information to respond to your inquiry. If you contact us in relation to support for our Services, we will use your Personal Information to provide you with support and to respond to your inquiries, including investigating, addressing your concerns, monitoring and improving our responses; and
  • for other purposes for which we provide specific notice at the time of collection.

Your Services account will be associated with your email and this account will be used for all our Services that you use. Information you provide to one of our Services may be used with other Services you or your friends use. For example, location information we receive in connection with your use of one of our apps may be used to customize the content you and your friends see in another of our apps.

 

Does Goki Share My Personal Information?

Personal Information about our users is an integral part of our business so we only share your Personal Information when we have legitimate business reasons for doing so. We neither rent nor sell your Personal Information to anyone, though, as described more fully in this section below (under “Publicly Available Information, the Goki API, and Apps”), your publicly-available information is available to third parties, and we may provide it to these third parties, by license or otherwise.

  • Other people in your area: By default, other people in your area can see name, profile photo, hometown, a list of your mutual friends, the places you have visited, your interests, plans you write or comment on, activity feed posts, photos you post, and tips you write.  For certain of these categories of data, you can decide not to share the information through a setting on the Sites. Your location is shared in accordance with the section below titled “Determining and Sharing Your Location”.
  • Businesses, Locations, Events and Brands: One of the key purposes of the Services is to help our users learn about hostels, locations, events and brands that are relevant to them, and for these hostels or event organisers to provide information about themselves, their locations and events to our users, as well as to reward our users when they visit their location or event through offers and specials. When you visit, for example, a particular hostel that is a ‘claimed location’, your visits are shared with the hostel in order for it to better provide services to you. Additionally, hostels or event organisers may have access to aggregated and anonymous data, such as de-identified data about places that you visit.
  • Publicly Available Information, the Goki API, and Apps: When you use the Services, certain information is visible to others, such as your public user profile information, tips, likes, saves and public photos. We may also share or disclose aggregated and anonymous data, such as de-identified check-in data (that is, not tied to individual users), to third-parties such as Hostelworld.com for analytical or other purposes.
  • Partners, vendors, service providers, agents and representatives: We may share your Personal Information with our partners, vendors, service providers, agents, representatives and integrators who support our business and perform services on our behalf based on our instructions and in compliance with appropriate confidentiality and data security measures. Examples of services include payment processing by Stripe. These businesses may also provide services to you, sell items or provide promotions to you through the Services. In other situations, Goki provides services, or sells items jointly with these businesses. You can easily recognize when one of these businesses is associated with your transaction, and we will share your Personal Information that is related to such transactions with that business. We also share your Personal Information with partners with whom we engage in joint marketing activities such as Hostelworld.com. These vendors, service providers, agents and representatives do not have any right to use Personal Information we share with them (including for their own independent marketing or promotional purposes) beyond what is necessary to assist us. We take reasonable steps to ensure that they provide a comparable level of protection for your Personal Information.
  • Any successor to all or part of our business: We may sell, transfer or otherwise share some or all of our assets, including Personal Information, in connection with a merger, acquisition, reorganization, sale of assets, spin off of assets into a separate business, or similar transaction, or in the event of insolvency or bankruptcy. Should such an event occur, we will use reasonable efforts to direct the transferee to use your Personal Information in a manner that is consistent with this Privacy Policy.
  • Legal reasons: We will share your Personal Information with companies, organizations or individuals outside of Goki if we have a good faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
    • meet any applicable law, regulation, legal process or enforceable governmental request, including those outside your country of residence;
    • enforce our Sales Contract or End User Licence Agreement Terms of Use;
    • detect, prevent, or otherwise address fraud, security, credit risk reduction or technical issues;
    • protect or defend our rights, or for our operational business purposes; or
    • protect against harm to the rights, property or safety of Goki and its employees, our users or the public as required or permitted by law.

 

Determining and Sharing Location

  • Determining your location: The Services deal with location, so in order to work, the Services need to know your location. Whenever you open and use/interact with our apps on your mobile device or go to one of our Sites, we use the location information from your mobile device or browser (e.g. latitude and longitude) to tailor the Services experience to your current location (i.e., we’ll show you a list of nearby locations, friends and tips). This information is NOT shared with others outside of Goki. Also, the Services use your mobile device’s ‘background location’ to provide the Services, including to send you notifications of tips/friends/plans/interesting things etc. near you. If you have ‘background location’ turned on, the Goki app will, from time to time, tell us about your device’s location even if you are not directly interacting with the application.
  • Sharing Location with the Goki app: When you use the Goki app, your location data will be shared with other Goki app users, showing them that you’re at a particular place, for example at one of our amazing hostel partners in Brisbane or Dublin. Where you choose to share your location data by, for example by “checking-in” at a hostel on the app, the information shared with other third-party user will be the location of that hostel and the fact that you are currently there. The sharing of your location data is turned OFF by default which means that your location data will not be automatically shared with other Goki users in your neighbourhood. You will need to enable your location in your mobile device’s settings in order to share your location with other Goki users and allow us to tailor the Services experience to your location. When you agree to share your location, it will also be periodically updated using your background location.
  • Your Check-in History: Each of your check-ins using the Services is saved to your “Check-in History,” which allows you and your friends to look back at all the locations you have checked in since you created your Services account. You can delete any or all of your check-ins from the check-in details page on our website and in the apps. If for some reason you ever decide to delete your Services account, your entire check-in history will be removed from our database.

 

Services Features

The Services include several features that may allow you to share your information with others. Please remember that if you choose to provide personal information using certain features of the Services, that information may be available to the wider Services community, or may be published on our Sites, which is subject to indexing by third party search engines.

 

Email Communications

If you do not want to receive promotional or other emails from us, please indicate your preference by making a modification on your account settings page or through the ‘settings’ tab on our Sites once you’re logged into the Services. Please note that if you do not want to receive legal notices from us, those legal notices will still govern your use of the Services, and you are responsible for reviewing such legal notices for changes. We may receive a confirmation when you open an email from Goki if your computer supports this type of program. Goki uses this confirmation to help us make emails more interesting and helpful and improve our service.

 

Third Parties

Our Services may also be integrated into the products and services of third-parties. The manner in which any third parties use, store and disclose your Personal Information is governed by the privacy policies that apply to these third parties’ products and services. As Goki does not control the privacy policy of third parties, we encourage you to review the policies of any third party to whom you choose to share your Personal Information directly.

 

What About Cookies and Similar Technologies?

We may work with advertisers or other partners and advertising service providers to serve ads or services to computers, mobile phones or other devices, which may use a cookie, pixel or other similar tracking technology placed by Goki or the third party (although we would not share any other information that identifies you with an advertiser). This Privacy Policy covers the use of cookies by Goki and its service providers and does not cover the use of cookies by any advertisers. For information about how to opt out of receiving behavioural advertisements from our advertising partners, click here or click here. Also, certain versions of the iOS operating system permit you to limit ad tracking in the system settings.

 

Is Personal Information About Me Secure?

Your Goki account Personal Information is protected by a password for your privacy and security. You are therefore responsible for preventing unauthorized access to your account and Personal Information by selecting and protecting your password appropriately, and limiting access to your computer and browser by signing off after you have finished accessing your account.

Goki endeavours to safeguard user information to ensure that your Personal Information is kept private and we use industry-standard technical and organizational measures to secure the information we store. However, while we implement appropriate safeguards designed to protect your Personal Information, no security system is impenetrable due to the inherent nature of the Internet. Goki therefore cannot guarantee that user account information, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

 

International Users

If you are located outside of Australia, please note that our app is hosted on our computer servers in Australia. Therefore, your Personal Information may be transferred to, processed and stored in Australia in order for us to provide you with the Services under our agreement with you. As a result, Australian federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through laws applicable in Australia.

If we transfer your personal data outside of Australia, please rest assured that we will ensure that appropriate measures are in place to protect your personal data and to comply with our obligations under applicable data protection law. If you would like further details about the measures we have taken in relation to the transfer of your personal data, or copies of the agreements that we have put in place in relation to the transfers, please contact us using the details at the bottom of this notice.

 

EU General Data Protection Regulation

If you are located in the EU or EEA, Personal Information collected by Goki will be processed in compliance with the EU General Data Protection Regulation (“GDPR”).

Your use of our Services and/or Sites will require you to provide certain Personal Information to us, including your name, email address, phone number, birthday, geographic location, information regarding your use of our Services, IP address, online identifiers such as certain cookies, unique device identifiers, , and other technical information. If you do not provide this information to us, we will not be able to provide you with the Services and you may not be able to use the Sites.

Many obligations contained in the GDPR have equivalent obligations under the Australian Privacy Principles.  If you have any queries in relation to how your data is handled, please contact our data privacy manager at privacy@goki.travel.

If you are an individual in the EEA, we collect and process Personal Information about you only where we have an appropriate legal bases for doing so under the GDPR or other applicable EU privacy and data protection laws. The legal bases will vary depending on the service provided. This means we collect and use your information only where:

  • we need it to provide our Services to you, including the core features of Goki on the basis of our agreement with you;
  • we or a third party have a legitimate interest in collecting your Personal Information which is not outweighed by your fundamental rights, freedoms and interests in the protection of your data.  Our legitimate interests for processing your personal data include our legitimate interests in marketing and promoting our products and services and conducting our business in a responsible and commercially prudent manner;
  • you have given us consent to do so for a specific purpose or purposes; or
  • your data is required to comply with a legal obligation that Goki is subject to.

If you object to Goki’s use of your Personal Information, it may mean you are no longer able to use the Goki Sites or Services.

EEA residents have the following rights that they may exercise by notifying the Goki data privacy manager:

  • Right to erasure: You may have the right to request erasure of your Personal Information under the GDPR. If you notify Goki of a request under the GDPR, we will respond within one month confirming if your data has been erased. We may not comply with such a request if the right to erasure does not apply, for example if there is a legal obligation to retain the data.
  • Right of access: You are entitled to request a copy of the Personal Information held by Goki, together with details of how we process that Personal Information.
  • Right to data portability: You may request that Goki transfers your data directly to another party. Goki will provide the third party with a copy of your Personal Information in a structured, commonly used machine-readable format where it is technically feasible to do so.
  • Right to rectification: You have the right to ask us to correct or update your Personal Information.
  • Right to object: You may ask Goki to cease processing your Personal Information. You have the absolute right to object to the processing of Personal Information if it is for direct marketing purposes. There are other basis upon which you can object to your data being processed however there may also be circumstances where Goki will continue to process your Personal Information, such as if it relates to legal action.
  • Right to withdraw consent: If we have collected and processed your Personal Information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
  • Right to make a complaint: You have the right to complain to the relevant data protection supervisory authority about our collection and use of your Personal Information. For more information, please contact your local data protection supervisory authority, the details of which can be found here.
  • Right to restrict processing: You have the right to request that we no longer process your Personal Information for particular purposes.

When you use Goki, your Personal Information will be transferred to Australia where the app and relevant computer services are hosted. Data held in Australia is protected by the Australian Privacy Principles. If your data is then transferred to another country, Goki will ensure that any such transfer is not in breach of the GDPR and appropriate technical and organisational safeguards are in place.

Where Goki engages an external data processor we take steps to ensure that the data processor implements appropriate technical and organisational measures to ensure compliance with the GDPR and protect your rights in relation to your data.

Where we are using your personal data on the basis of your consent, you are entitled to withdraw that consent at any time, subject to applicable law. Where we process your personal data based on legitimate interest, you have the right to object at any time to that use of your Personal Information, subject to applicable law.  We rely on you to ensure that your Personal Information is complete, accurate and current. Please do inform us promptly of any changes to or inaccuracies of to your Personal Information. You can contact us at privacy@goki.travel in relation to any of the above rights.

 

What Personal Information Can I Access?

Goki allows you to access the following information about you for the purpose of viewing, and in certain situations, updating that information and ensuring that it is accurate and complete:

  • Other User profile information (for example, home city, photo)
  • Usage information (for example, check-in history)

You can access this information on the Services by visiting the user settings page (except usage information, which can be accessed in the “History” tab). This list will change as our Service changes.

 

How Long Does Goki Keep My Data?

Goki operates on the principle that Personal Data we collect is kept for no longer than is necessary for the purpose for which we collected it, and in accordance with any requirements that are imposed on us by applicable laws. This means that the retention period for your Personal Information will vary depending on the type of information, as described in further detail below.  After such time, we will either delete or completely anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

User account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes or defend legal claims, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyse personal characteristics about you.

Information you share on our Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow other users to make full use of the Services.  For example, we continue to display messages you sent to the users that received them and continue to display content you provided, but when requested details that can identify you will be removed.

Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your account.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.   

 

How Do I Delete My Goki App?

Should you ever decide to delete your app, you may do so by holding your finger on the Goki icon on your relevant app page, and then click the cross in the top left of the icon. If you terminate your account, your profile, including your check-in history, your User Submissions (as defined in Goki’s Terms of Service) and any promotional offers you received, will be removed from the Sites and deleted from Goki’s servers. Because of the way we maintain Goki, such deletion may not be immediate, and residual copies of your profile information or posts may remain on backup media for up to ninety (90) days.

 

How Is Information Removed From My Account?

Even after you remove information from your account or profile, copies of that information may remain viewable elsewhere, to the extent it has been shared with others, it was otherwise distributed pursuant to your privacy settings, or it was copied or stored by other users. Removed and deleted information may remain on backup media for up to ninety (90) days prior to being deleted from our servers.

 

Will There Be Changes To This Privacy Policy?

Goki may amend this Privacy Policy from time to time If we modify our Privacy Policy, we will post the revised version here, with an updated revision date. If we make material changes in the way we use Personal Information, we will also notify you by posting an announcement on our Services or sending you an email before those changes take effect. We recommend that you visit these pages periodically to be aware of and review any such revisions.

 

What If I Have Questions or Concerns?

If you have any queries or complaints in connection with our processing of your Personal Information, you can get in touch with us on privacy@goki.travel.

If you are a resident of the EEA, please contact our EU Representative:

Goki EU Representative

Hostelworld.com Limited

Floor 2, 1 Central Park, Leopardstown, Dublin D18 NH10, Ireland

EURepresentative@hostelworld.com