Privacy Policy

1 · Scope & Applicability

This policy applies to the Havo mobile apps, website and related services. By installing or using Havo you consent to the practices described in this policy.

2 · Information We Collect

Category	Examples	Source
Account & profile	Name, email, phone, profile photo	Provided by you
Verification & payouts	Photo ID (passport, licence), date of birth, address, bank account and/or card details	Provided by you
Marketplace activity	Listings, rentals, item locations, reviews, earnings	Generated through use
Device & usage	IP address, device model, OS, logs	Collected automatically
Location (optional)	Approximate suburb or city for nearby searches	With device-level permission

We do not intentionally collect special-category data (health, ethnicity, etc.).

3 · How We Use Information

Operate the service — create listings, match renters and lenders, disburse payouts, manage platform.
Identity verification and fraud prevention.
Payment processing and payouts.
Service improvement & analytics via Firebase aggregated insights.
Marketing in accordance with user consent and the Spam Act 2003 (opt-out link in every message).
Legal obligations such as tax or anti-money-laundering checks.

4 · Legal Bases

Region	Basis
Australia	APP 3 (collection) & APP 6 (use/disclosure) legitimate business functions.
EU / EEA / UK	GDPR Art 6 (1)(a) consent, (b) contract, (c) legal obligation, (f) legitimate interests.
California (CCPA / CPRA)	“Business purposes”; right to opt-out of “sale” or “sharing”.

5 · Sharing & Disclosure

We do not sell personal information. We share it only with:

Stripe, Inc. & Stripe Payments Australia Pty Ltd for identity verification, card processing and payouts (see Stripe’s privacy policy & PCI-DSS level 1 certification).
Google LLC / Google Ireland Ltd (Firebase) as a processor under Google’s Data Processing & Security Terms and SCCs.
Law-enforcement, regulators or dispute-resolution providers when required by law.
Counterparties to a rental (limited to essential data and/or data you elect to provide).

6 · International Transfers

Firebase and Stripe may process data in multiple jurisdictions. Transfers rely on Google’s and Stripe’s Standard Contractual Clauses and comparable safeguards.

7 · Marketing & Communications

Commercial emails, SMS and push notifications follow the consent, sender-ID and unsubscribe requirements of the Spam Act 2003. Similar opt-out mechanisms apply for GDPR and CCPA compliance.

8 · Data Retention

We retain personal data only as long as needed for the purposes described in this policy, then delete or de-identify.

9 · Security Measures

All traffic uses TLS.
Firebase encrypts data at rest and in transit.
Stripe handles card data directly.

10 · Your Rights & Choices

Region	Rights	How to exercise
EU / EEA / UK	Access, rectify, erase, restrict, object, port, withdraw consent.	Email us
Australia	Access & correction under APP 12–13.	Email us
California	Know, delete, correct, opt-out of sale/sharing, limit sensitive data use.	Email us

We respond within one month (45 days for CCPA requests).

11 · Children

Havo is not directed to, and must not be used by, anyone under 18. If we learn we have collected data from a minor we will delete it promptly.

12 · Changes to This Policy

We may update this policy and will give at least 14 days’ notice via email or in-app banner. Continued use after the effective date indicates acceptance.

13 · Contact & Complaints

No Friction Pty Ltd (ABN 53 630 365 936)
Email: privacy@havo.app

If you have concerns, contact us first. If unresolved, you may lodge a complaint with:

The Office of the Australian Information Commissioner (OAIC)
Your EU supervisory authority
The California Privacy Protection Agency