Privacy Policy

Steley Pty Ltd (ABN 47 618 998 477) (“Justlo”, “us” or “we”) owns and operates the website www.justlo.com.au, which is a communication platform with a variety of services, including a chatroom (Website), and the Justlo app (App). Justlo is dedicated to ensuring that we comply with our obligations under the Privacy Act 1988 (Cth) (the Act) and the Australian Privacy Principles (the APPs). This Privacy Policy explains how we manage the personal information that is collected, used, disclosed and stored about you.

Acceptance

By visiting or using our Website and/or using the App or by otherwise providing your personal information to us, you confirm your acceptance of the terms of this Privacy Policy and your consent to the handling of your personal information as set out in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not use the Website and/or App or otherwise provide us with your personal information.

What is personal information?

“Personal information” means information or an opinion that is capable of reasonably identifying an individual, whether that information or opinion is true or not and whether the information or opinion is recorded in a material form or not. For example, this may include your name, age, gender, photo and contact details. We may also collect sensitive information with your consent, such as details of sexual orientation, political opinions, religious beliefs and health information.

What personal information do we collect?

We may collect the following types of personal information from you, including your:

  • name and nickname;
  • email address;
  • date of birth;
  • country of residence;
  • post code; and
  • gender.

During the registration process, we will collect your geo-location data where you have provided consent. However, this geolocation data is not disclosed to any users of our Website or App.

We also collect details of your gender preferences in respect of people you wish to meet via the Website and/or App (which is sensitive information for the purposes of the Act).

If you connect to the Website via your Facebook account, the following personal information may also be collected:

  • email address (if you agree to its collection);
  • name; and
  • profile image.

From time to time, you may be able to visit our Website and/or App and deal with us anonymously or by pseudonym. However, please be aware that, if you do not provide us with certain information that we require, we may not be able to provide you with the particular services that you seek.

We may also collect non-personal information, which by itself cannot be used to identify or contact you. Non-personal information may include user IP addresses, browser types and anonymous statistical data involving the use of our Website and App.

From time to time, non-personal information may be connected to other information we collect from you and, when this occurs, this non-personal information will be treated as personal information for the purposes of tthis Privacy Policy.

How do we collect personal information?

We may collect personal information from you in variety of ways, including when you:

  • register to use our services directly on the Website or the App;
  • purchase flirt coins;
  • visit our social media pages and channels, including on Facebook and Instagram, Twitter or YouTube;
  • participate in the chatroom via the Website or App;
  • manage/change your account information;
  • contact us by phone, email, post or on our Website enquiry forms;
  • subscribe to our mailing list or to receive promotional materials; and
  • participate in surveys, competitions or other promotional activities.

We may also collect your personal information from third parties, including in the following circumstances:

  • from Facebook when you connect to our Website or App via Facebook;
  • when you share information with us from other social applications, services or websites;
  • law enforcement agencies and other government entities;
  • payment processors; and
  • market research providers.

Why do we collect your personal information and how do we use it?

Justlo may collect and use your personal information for the purposes of providing you with our services and for our internal business purposes. These purposes include (but are not limited to):

  • to enable you to access and use our Website, App and services, including to:
    • enable you to chat with other users of the Website and/or App;
    • where you have consented, send you push notifications (which you can disable any time);
    • enable you to use the SMASH function of the App so that you can see other users of the App who are in close proximity to you (but not their geo-location). You can disable this function at any time;
  • to operate, protect, improve and optimise our Website, App and services and our users’ experiences, including to conduct research and analysis and for advertising and marketing purposes;
  • for processing transactions and fulfilling orders for products or services, such as flirt coins;
  • for registering, setting up and managing user accounts;
  • responding to your submissions, questions, comments, requests and complaints and to otherwise provide customer services, including to send you support and administrative messages, updates and information you have requested;
  • marketing our products and services and providing you with company information and updates such as newsletters or offers of promotional events or opportunities (such as competitions or surveys) that you may be interested in;
  • the prevention of fraud and/or identifying and investigating any suspicious use of our Website, App or services;
  • assessing and processing employment applications and conducting due diligence as part of pre-employment screening;
  • for our internal business and management processes, for example accounting or auditing purposes;
  • for any other purpose to allow us to comply with our obligations under law and to resolve disputes; and
  • for any other purposes that would reasonably be expected by you.

Should you use the chat service, which is available on the Website and App, your nickname / pseudonym and age will be accessible to other chat participants so that they can contact you via our chat service.

The non-personal information we collect may be used for a variety of purposes, including but not limited to:

  • help us understand who uses our Website and App, how they are used and to improve our services, including the chat room services and entertainment features available on the Website and App; and
  • perform statistical analysis of user behaviour, to evaluate and improve our services, the Website and the App.

We may provide aggregated data to third parties to be used or evaluated for advertising purposes or for inclusion in, for example, demographic surveys.

Any personal information, chat data and IP addresses may be stored for limited periods of time for monitoring and correction purposes and for the protection and security of other users of the Website and/or App.

Personal data deletion and storage period

For the processing operations carried out by us, we indicate below how long the data will be stored by us and when it will be deleted or blocked. If no explicit storage period is specified below, your personal information will be deleted or blocked as soon as the purpose or legal basis for the storage no longer applies. In principle, your data will only be stored on our servers in Australia, subject to any transfer that may take place in accordance with the regulations below.

However, storage may take place beyond the specified time in the event of a (threatened) legal dispute with you or other legal proceedings, or if storage is provided for by legal regulations to which we are subject as the responsible party. If the storage period prescribed by the legal regulations expires, the personal information will be blocked or deleted, unless further storage by us is necessary and there is a legal basis for this.


How long we retain your information or personal data/request data deletion 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for (as set out above), including for the purpose of satisfying and legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

From all customers who have not paid, the personal data will be irrevocably deleted after 8 weeks. For paying users, a retention period of 10 years is mandatory, but this applies only to the data collected during registration and the transaction itself. Other data (profile picture, dialogs etc.) will be deleted after the legal deletion period which are 4 weeks according to Australian law.

You may ask us to delete or remove your personal data, or you may have any further questions about the process of resolving your account with the personal data contained therein, you can find more information in our T&C via this link https://www.justlo.com.au/en/conditions.html  here under the category 4 and 15 or you can also send a request via email to our privacy email address service(at)justlo.com.au.

Direct Marketing

Justlo may use your personal information for the purposes of marketing our services and products and to inform you of new products, promotions or events that we believe you may be interested in. If you would like to stop receiving any of these marketing communications, you can opt out by writing to us at the contact details listed below (“Contact Details”) and informing us that you no longer wish to receive these materials. If at any time you would like to stop receiving future emails, you can click the “unsubscribe” at the bottom of each direct marketing email we send.

Who will we disclose your information to?

From time to time, Justlo may disclose your personal information to third parties, both within and outside Australia, for the purposes of conducting our business. These third parties may include:

  • to other users of our Website and/or App if you use our chat service;
  • our related companies, which are located in Europe, including but not limited to in Malta, Germany and Denmark;
  • third party service providers, dealers and agents, contractors, advisors and suppliers who assist us in managing our business or operating our Website and App, for example, business support services, payment processors, webhosting service providers, cloud storage providers, mailing houses etc;
  • our sponsors or any promoters of any competition that we conduct;
  • our professional advisors including lawyers, accountants, tax advisors and auditors;
  • law enforcement bodies to assist in their functions, courts of law or as otherwise required or authorised by law;
  • regulatory or government bodies for the purposes of resolving customer complaints or investigations;
  • anyone to whom our assets or businesses (or any part of them) are transferred; and
  • specified third parties authorised by you to receive information held by us.

Please be aware that the privacy laws in other countries might not be the same as in Australia. However, where we do disclose your personal information to overseas third parties, we will take such steps as are reasonable to ensure that your personal information is handled in accordance with this Privacy Policy.

Where we do disclose your personal information to overseas recipients, such as our related companies or service providers, they are most likely to be located in Europe.

Cookies

Our Website uses cookies on various pages in order to design our Website attractively and to enable the use of certain functions. Cookies are small data files with text, which are stored on your computer or peripheral equipment. Some cookies (called “session” cookies) will be deleted at the end of the browser session i.e. after you close your browser. Other cookies (called “persistent” cookies) remain on your computer or peripheral equipment and enable us to recognise your browser again when you next visit our Website.

Cookies cannot be used to gain access to the other data files on your computer or to ascertain your email address.

Most browsers are set so that that they accept cookies automatically. All of these processes run in the background, unnoticed by you, if your browser has standard settings for cookies. You can, if you wish, change these settings.

You can set your browser in such a way that you will be informed about the use of cookies, so that you will be able to decide whether to accept them, or so that you can exclude accepting them generally in specific cases.

However, some websites - including ours - cannot be used correctly without cookies as these data files are needed for specific sequences such as the chat function.

Google Analytics

Our Website uses Google Analytics, which is the web-analytical service of Google Inc. (Google). Google Analytics utilises cookies, which are data files of text that are stored on your computer and enable an analysis about the use of websites to be made. The information about your internet usage generated by the cookie is normally transmitted to a Google server in the USA and stored there.

Google will use this information to evaluate how the Website is used and to compile reports about Website activities. Google will also provide us, as the Website operator, with further details of internet usage and related services. The IP address that is transmitted from your browser by Google Analytics will not be bundled together with other Google data.

For example, you can prevent cookies from being stored by setting your browser's software appropriately; however, you might not then be able to make full use of all the functions of this Website.

You can prevent data referring to your usage of the Website (including your IP address) generated by a cookie from being recorded and processed by Google and also prevent Google from using this data by downloading and installing the browser's plug-in software that is available from the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

Alternatively, please click on the following link (http://tools.google.com/dlpage/gaoptout?hl=en) in order to set an opt-out cookie for the browser's plug-in software or within the browser on portable equipment, which will prevent Google Analytics from recording data from this Website in the future. (This opt-out cookie only functions in this browser and only for this domain. If you delete your cookies in this browser, then you must click on this link again.)

You can find more detailed information about the conditions of use and data protection at https://policies.google.com/privacy?hl=en.

How do we secure and protect your personal information?

We take such steps as are reasonable, in the circumstances, to maintain the integrity and store securely your personal information to protect it from interference, misuse and loss and from unauthorised use, access, modification or disclosure.

In order to protect your personal information, we use Secure Socket Layer (SSL) technology, encrypted payment gateways and firewalls.

To the extent permitted by law, Justlo takes reasonable steps to destroy or permanently de-identify your personal information if it is no longer needed for any purpose under this Privacy Policy, except in circumstances where Justlo is required or authorised to retain this personal information (including as a result of the operation of tax, financial services or other applicable law).

Where you have consented to the collection of your geo-location data, this data will be stored. Your geolocation data will be deleted 8 weeks after your account is cancelled.

Third Party Links

Our Website may contain links to websites operated and maintained by third parties over which we have absolutely no control. These third party websites are not subject to this Privacy Policy or our privacy standards and procedures. Any information you provide to third party websites will be governed by the terms of the websites’ privacy policies. We have no responsibility or liability whatsoever for the content, actions or policies of third party websites. The inclusion of third party links on our Website in no way constitutes an endorsement of such websites’ content, actions or policies.

How do we maintain the accuracy of the personal information we hold about you?

We take such steps as are reasonable, in the circumstances, to ensure that the personal information that we collect is up-to-date and complete.

However, in order to maintain the accuracy of the personal information, we rely on the quality of the personal information that you provide to us. To ensure that we always have your most up-to-date personal information, please contact us as soon as possible when your details change. This might include when you change your name, mailing address or use a new email address.

Accuracy and requests for access and correction of personal information

You are entitled to access and correct the personal information we hold about you and to have any inaccuracies in the information corrected.

If you would like to access, update or correct any of the personal information we hold about you, you may do so by sending us an email at service@justlo.com.au or by contacting us using the contact page https://www.justlo.com.au/community/support  https://www.justlo.com.au/community/and informing us that you wish to access or correct your personal information.

There are some circumstances specified by law where we may refuse your request for access to and/or the correction of your personal information. However, if one of these circumstances applies, we will provide you with a written explanation of the reasons for refusal, unless it would be unreasonable to provide that notice. If we refuse your correction request, we will also include a statement with your personal information about the requested correction (if you request us to do so).

Once we receive your request for access or correction, we will endeavour to respond to your request within 30 days after the request is made. We may also charge reasonable costs for responding to your access request.

Complaints

You may contact Justlo at any time if you have any questions or concerns about this Privacy Policy or about the way in which your personal information has been handled.

You may make a complaint about privacy to our Privacy Officer using the contact details set out below.

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint.

Your complaint will then be investigated. We may ask you to provide further information about your complaint and the outcome you are seeking. We will then typically gather relevant facts, locate and review relevant documents and speak with individuals involved.

In most cases, we will investigate and respond to a complaint within a reasonable time, usually within 30 days of receipt of the complaint. If the matter is more complex or our investigation may take longer, we will let you know.

If you are not satisfied with our response to your complaint, or you consider that Justlo may have breached the Australian Privacy Principles or the Privacy Act, you may make a complaint to the Office of the Australian Information Commissioner (OAIC). The OAIC can be contacted by telephone on 1300 363 992 or by using the contact details on the website www.oaic.gov.au.

Changes to Our Privacy Policy

Justlo reserves the right to make changes to this Privacy Policy from time to time. We will publish any changes to the Privacy Policy on our Website at https://www.justlo.com.au/en/privacy.html and on the App. Where the changes are material, we will provide you with reasonable notice of the changes (usually by email) before they take effect. We encourage you to review the Privacy Policy regularly for updates and amendments. By continuing to use our Website and/or the App or our services, or by continuing to provide us with your personal information after these changes have taken effect, you confirm your acceptance of these changes.

Contact Details

If you have any questions or comments about this Privacy Policy, please contact us:

Steley Pty Ltd
Level 12
60 Carrington Street
Sydney NSW 2000.

Email: service@justlo.com.au
Tel: +61291889399
Internet: http://justlo.com.au