Privacy Policy

Karava Tech Pty Ltd (ABN 55 658 067 157) (we, us or our), understands that protecting your personal information is important. This Privacy Policy sets out our commitment to protecting the privacy of personal information provided to us, or otherwise collected by us when providing our website and mobile application services (Services) or when otherwise interacting with you. 

The information we collect

Personal information: is information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

  • Identity Data including first name, last name, date of birth, gender, and place of origin in Cyprus. 

  • Contact Data including email address and telephone numbers.

  • Financial Data including bank account and payment card details (through the relevant third party payment processor, App Store or Google Play Store.

  • Transaction Data including details about payments to you from us and from you to us and other details of products and services you have purchased from us or we have purchased from you.

  • Technical and Usage Data including internet protocol (IP) address, your login data, your browser session, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour, information about your access and use of our website, including through the use of Internet cookies, your communications with our website, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider.

  • Profile Data including your username and password for our Services, profile picture, purchases or orders you have made with us, support requests you have made, content you post, send receive and share through our platform, information you have shared with our social media platforms, your interests, preferences, feedback and survey responses.  

  • Interaction Data including information you provide to us when you participate in any interactive features of our Services, including surveys, contests, promotions, activities or events.  

  • Marketing and Communications Data including your preferences in receiving marketing from us and our third parties and your communication preferences.

  • Professional data including where you are a worker of ours or applying for a role with us, your professional history such as your previous positions and professional experience.

  • Sensitive information is a sub-set of personal information that is given a higher level of protection. Sensitive information means information relating to your racial or ethnic origin, political opinions, religion, trade union or other professional associations or memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information or biometric information. We do not actively request sensitive information about you. If at any time we need to collect sensitive information about you, unless otherwise permitted by law, we will first obtain your consent and we will only use it as required or authorised by law. The types of sensitive information we collect include:

    • your or your family’s ethnic origins in Cyprus.

How we collect personal information

We collect personal information in a variety of ways, including:

  • Directly: We collect personal information which you directly provide to us, including when you register for an account, or when you request our assistance via email, or over the telephone.

  • Indirectly: We may collect personal information which you indirectly provide to us while interacting with us, such as when you use our website, in emails, over the telephone and in your online enquiries.

  • From third parties: We collect personal information from third parties, such as details of your use of our website from our analytics and cookie providers and marketing providers. See the “Cookies” section below for more detail on the use of cookies.

Why we collect, hold, use and disclose personal information

We have set out below, a description of the purposes for which we plan to collect, hold, use and disclose your personal information.

Purpose of use / disclosure:

To provide our Services to you including to enable you to access and use our mobile application and to provide you with a login.

  • Identity Data

  • Contact Data

To contact and communicate with you about our Services including in response to any support requests you lodge with us or other enquiries you make with us.

  • Identity Data

  • Contact Data

  • Profile Data

To contact and communicate with you about any enquiries you make with us via our website.

  • Identity Data

  • Contact Data

For internal record keeping, administrative, invoicing and billing purposes.

  • Identity Data

  • Contact Data

  • Financial Data

  • Transaction Data

For analytics including profiling on our website, market research and business development, including to operate and improve our Services, associated applications and associated social media platforms.

  • Profile Data

  • Technical and Usage Data

For advertising and marketing, including to send you promotional information about our events and experiences and information that we consider may be of interest to you.

  • Identity Data

  • Contact Data

  • Technical and Usage Data

  • Profile Data

  • Marketing and Communications Data

To run promotions, competitions and/or offer additional benefits to you.

  • Identity Data

  • Contact Data

  • Profile Data

  • Interaction Data

  • Marketing and Communications Data

If you have applied for employment with us; to consider your employment application.

  • Identity Data

  • Contact Data

  • Professional Data

To comply with our legal obligations or if otherwise required or authorised by law. 

  • Any relevant Personal Information

Sensitive information: We only collect, hold, use and disclose sensitive information for the following purposes:

  • any purposes you consent to;

  • the primary purpose for which it is collected to provide our mobile application to you; 

  • secondary purposes that are directly related to the primary purpose for which it was collected, including disclosure to the below listed third parties as reasonably necessary to provide our Services to you; and

  • if otherwise required or authorised by law.

Our disclosures of personal information to third parties

We may disclose personal information to:

  • our employees, contractors and/or related entities;

  • IT service providers, data storage, web-hosting and server providers such as Amazon Web Services, Apple App Store and Google Play Store;

  • marketing or advertising providers such as;

  • professional advisors, bankers, auditors, our insurers and insurance brokers;

  • payment systems operators such as Apple App Store and Google Play Store;

  • our existing or potential agents or business partners;

  • sponsors or promoters of any promotions or competition we run;

  • anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;

  • courts, tribunals and regulatory authorities, in the event you fail to pay for goods or services we have provided to you;

  • courts, tribunals, regulatory authorities and law enforcement officers, as required or authorised by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;

  • third parties to collect and process data; and

  • any other third parties as required or permitted by law, such as where we receive a subpoena.

Overseas disclosure

We may store personal information overseas, including in France. Where we disclose your personal information to third parties, those third parties may also store, transfer or access personal information outside of Australia, including France. We will only disclose your personal information overseas in accordance with the Australian Privacy Principles.

Data De-identification: Where practicable, we implement de-identification measures to protect your personal information when stored or processed overseas. We use de-identification efforts including technical and procedural safeguards to de-identify your voice recordings and other personal information. This may include removing or replacing identifying information with pseudonyms or other identifiers, aggregating data, or applying other technical measures to reduce the risk of re-identification while maintaining the utility of the information for our business purposes. We still treat this de-identified information as personal information and apply the same privacy protections outlined in this Privacy Policy

Your rights and controlling your personal information

Your choice: Please read this Privacy Policy carefully. If you provide personal information to us, you understand we will collect, hold, use and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect our ability to provide our Services to you and your use of our Services.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us. 

Anonymity: Where practicable we will give you the option of not identifying yourself or using a pseudonym in your dealings with us

Restrict and unsubscribe: To object to processing for direct marketing/unsubscribe from our email database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Access: You may request access to the personal information that we hold about you. An administrative fee may be payable for the provision of such information. Please note, in some situations, we may be legally permitted to withhold access to your personal information. If we cannot provide access to your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal. If we can provide access to your information in another form that still meets your needs, then we will take reasonable steps to give you such access.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to promptly correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading. Please note, in some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will advise you as soon as reasonably possible and provide you with the reasons for our refusal and any mechanism available to complain about the refusal.

Complaints: If you wish to make a complaint, please contact us using the details below and provide us with full details of the complaint. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take in response to your complaint. 

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures, to safeguard and secure personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

While we are committed to security, we cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. 

Cookies

We may use cookies on our website from time to time. Cookies are text files placed in your computer's browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. However, they do recognise you when you return to our online website and allow third parties, such as Google and Facebook, to cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our online website with personal information, this information may be linked to the data stored in the cookie.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.

Use of Artificial Intelligence (AI)

Overview: We may use artificial intelligence and machine learning technologies, including AI Technologies provided by third parties (AI Technologies) in our business operations and the provision of our Services. We will only use AI Technologies when legally permitted and necessary for our business operations. 

How we use AI Technologies: We may use AI Technologies for the following purposes: 

  • to conduct analysis and processing; 

  • to generate and modify content and coding;

  • to improve and optimise our services and operations;

  • to listen to your voice recording and provide feedback on pronunciation; 

  • to automate certain processes and communications, such as routine tasks;

  • to personalise your experience with our services; 

  • for quality assurance purposes; and 

  • to assist with customer support and queries.

Data Protection and Security: Where we use service providers who provide AI Technologies to us, we will take reasonable steps to ensure that such service providers handle your personal information according to privacy law, including by ensuring that we have contracts in place requiring the service provider to protect personal information.

We may input your personal information into our proprietary AI models and platforms provided by AI Technology service providers which may then be used to train the service provider’s AI Technologies model based on that information. When using your personal information to train our proprietary AI models, we implement appropriate safeguards to protect your privacy and ensure compliance with applicable privacy laws.

Your Rights and our Commitments: We will treat information generated or inferred by the AI Technologies about individuals as personal information and you maintain all rights over your personal information as outlined in this privacy policy, regardless of whether AI Technologies are used in processing. When using AI Technologies with your personal information:

  • Transparency and control: we will inform you when AI Technologies are being used to make decisions that may significantly affect you. We will implement processes to verify the accuracy of AI-generated outputs and we will take reasonable steps to maintain human oversight and review of significant AI-generated decisions. Our staff are trained to understand the limitations of AI systems and verify outputs before they are relied upon; and 

  • Security: we implement appropriate technical and organisational measures to ensure that our use of AI Technologies maintains the security and integrity of your personal information. This includes regular testing and monitoring of AI outputs for accuracy and reliability; and

  • Risk mitigation: We regularly assess and document the risks associated with our use of AI Technologies in processing personal information and implement appropriate mitigation measures. This includes ongoing monitoring of AI Technologies and regular reviews of their performance and impact.

Links to other websites

Our website may contain links to other party’s websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our website. We recommend you check our website regularly to ensure you are aware of our current Privacy Policy.

For any questions or notices, please contact us at:

Karava Tech Pty Ltd (ABN 55 658 067 157)

Email: support@cyprusays.com 

Last update: 27 June 2025

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