These Services are operated by EKT HOLDINGS PTY LTD. The Privacy Policy outlined below applies to the Eckode mobile application, website, and all other associated Services that we provide (“Services”). The privacy of our users is extremely important to us and therefore we encourage all users to read this policy very carefully because it contains important information regarding: 

• who we are; 

• how and why we collect, store, use and share personal information; 

• your rights in relation to your personal information; and 

• how to contact us and supervisory authorities in the event that you have a complaint. 

 
Who we are 

EKT HOLDINGS PTY LTD ('we' or 'us') (trading as ECKODE) collect, use and are responsible for storing certain personal information about you. When we do so, we are regulated under the General Data Protection Regulation which apply across the European Union and we are responsible as a 'controller' of that personal information for the purposes of those laws. 

 
The personal information we collect and use 

a. Personal information you provide to us 

We collect the following personal information that you provide to us: 

Name; date of birth; address; email address; phone number; location 

Some examples of when we collect this information include: 

During registration we collect name, date of birth, address, email address, phone number. When using the mobile application, we also collect your location data. 

 
b. Personal information you provide about third parties 

If you give us information about another person, you confirm that the other person has appointed you to act on their behalf and agreed that you: 

• shall consent on their behalf to the processing of their personal data; 

• shall receive any data protection notices on their behalf; and 

• shall consent on their behalf to the transfer of their personal data abroad. 

 
How we use your personal information 

We collect information about our users for the following purposes: 

To identify you and manage your accounts we use the following information; name, date of birth, address, email address, phone number. Your location is used to locate the items registered to your Eckode account. 

 

How we use your location information 

In order for Eckode to do perform its service, it is necessary to collect data about your location. We use the term “Location Information” to refer to the combined location data of your device and any assigned Eckode devices. 

While the mobile application is running on your device, it periodically transmits your Location Information. This allows the most recent place your Eckode device was last located. 

The Eckode application normally only displays the latest Location Information update for each of your Eckode devices on the map in your mobile application.  

We may also collect and update Location Information for your Eckode device from other Eckode users who are running the Eckode mobile application within Bluetooth range of your device. We do this to provide you with the most recent and accurate location of your Eckode device, even if they are out of your Bluetooth range. These updates are part of our community assisted location function. Likewise, your mobile application may anonymously help other community members find their Eckode devices. The Location Information is reported to Eckode device owner anonymously and does not identify the owner of an Eckode device to others. 

We use your Location Information to provide the Services and may use your Location Information to promote the Services or provide you with offers. However, your Location Information is never shared with other users unless you choose to share it through our Services. 

 
Who your information may be shared with 

We may share your information with law enforcement agencies in connection with any investigation to help prevent unlawful activity. 

We will not share your personal information with any other 3rd parties. 

 
Marketing 

We would like to send you information about products, services, offers, competitions and our business which may be of interest to you. Such information could be sent by post, email, telephone, text message or automated call. 

We will ask whether you would like us to send you marketing messages on the first occasion that you provide any relevant contact information (i.e. on purchase, signing up to a newsletter, entering a competition etc). If you do opt in to receive such marketing from us, you can choose to opt out at any time (see 'What rights do you have?' below for further information). If you have any queries about how to opt out, or if you are receiving messages you do not want you can contact us using the details provided below. 

 
Required personal information 

The provision of the following information is required from you: 

name; date of birth; address; email address; phone number; location 

 

This is to enable us to do the following: 

To register an account and provide our services 

We will inform you at the point of collecting information from you, whether you are required to provide the information to us. 

 
How long your personal information will be kept 

We will hold your personal information for the following periods: 

Eckode retains the information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfil the purpose(s) for which it was collected. 

These periods are no longer than necessary in each case. 

 
Reasons we can collect and use your personal information 

We rely on the following as the lawful basis on which we collect and use your personal information: 

(1). consent; 

(2). contract; 

(3). legal obligation; 

(4). vital interests; 

(5). public task. 

Consequence of our use of your personal information 

The consequence to you of our use of your personal information is: 

The location data will be used to pinpoint the location of any Eckode device currently registered to the network. 

Keeping your information secure 

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. 

We will also use technological and organisation measures to keep your information secure. These measures may include the following examples: 

 

User account information is secured by a unique username and password. No payment details are requested or retained. 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. 

Indeed, while we will use all reasonable efforts to secure your personal data, in using the site you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using the details below. 

 

Your Account May Be Deleted Upon Your Request 

If you want us to delete your account, please contact us at privacy@eckode.com with your request. We’ll take steps to delete your requested personal information as soon as we can, but some information may remain in archived/backup copies for our records or as otherwise required or permitted by law. 

Please note, however, that if you delete your account or other personal information, the Location Information associated with any active Eckode devices may still be collected anonymously from other Eckode users who are running the app within Bluetooth range of your device. However, any new Location Information that is collected will no longer be associated with your account. You may dispose of your Eckode devices at a local e-waste facility. 

Transfers of your information out of the EEA 

We may need to transfer your personal data to the following countries outside of the European Economic Area: 

Australia 

These transfers will be undertaken for the purpose of: 

Personal information and location data are sent to our database which is hosted in Australia 

For more information on the basis of any non-EEA transfers, our safeguards or Commission details, please contact us as described below. We will not otherwise transfer your personal data outside of the EEA or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries. 

 
Children and the validity of consent 

Where we obtain consent from any user, we will take reasonable steps to ascertain whether the user is over 13 years of age and whether the child is sufficiently informed to give valid consent. If the user is not, parental consent will be required to provide consent for the processing of any personal information. 

 
What rights do you have? 

Under the General Data Protection Regulation, you have a number of important rights free of charge. In summary, those include rights to: 

• fair processing of information and transparency over how we use your use personal information 

• access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address 

• require us to correct any mistakes in your information which we hold 

• require the erasure of personal information concerning you in certain situations 

• receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations 

• object at any time to processing of personal information concerning you for direct marketing 

• object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you 

• object in certain other situations to our continued processing of your personal information 

• otherwise restrict our processing of your personal information in certain circumstances 

• claim compensation for damages caused by our breach of any data protection laws 

For further information on each of those rights, including the circumstances in which they apply, see your rights under the General Data Protection Regulations. 

If you would like to exercise any of these rights, please: 

• email, call or write to us 

• let us have enough information to identify you 

• let us have proof of your identity (a copy of your driving license, passport or a recent credit card/utility bill) 

• let us know the information to which your request relates 

From time to time, we may also have other methods to unsubscribe (opt-out) from any direct marketing including for example, unsubscribe buttons or web links. If such are offered, please note that there may be some period after selecting to unsubscribe in which marketing may still be received while your request is being processed. 

 
Do you need extra help? 

If you would like this policy in another format (for example: audio, large print, braille) please contact us using the details below. 

How to complain 

We hope that we can resolve any query or concern you raise about our use of your information. 

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred.  

 

Changes to the privacy policy 

This privacy policy was published on 01st October 2021. 

We may change this privacy policy from time to time. You should check this policy occasionally to ensure you are aware of the most recent version that will apply each time you access our Services. We will also attempt to notify users of any changes by: 

Notifications upon opening of the mobile application and via email if email notifications are approved. 

 
Contacting us 

If you have any questions about this policy or the information, we hold about you, please contact us by: 

e-mail: privacy@eckode.com 

post: 77 Barwon Terrace, South Geelong, Victoria 3220, Australia

​

Last Updated: 22 October 2021

​

​