KAVA CRM Privacy Policy 

1. Introduction
This website details KAVA CRM’s Privacy Policy, and other policies and information related to the provision of the KAVA CRM solution and related services.
KAVA uses and provides cloud-based solutions due to the exceptional reliability, scalability, security, redundancy and business continuity they offer.
KAVA’s key service provider, Zoho Corporation (Zoho), is a global provider of award-winning CRM (Customer Relationship Management) and other online business, productivity and collaboration applications. Zoho’s head office is in the United States, and it complies with both the U.S.-EU Safe Harbor framework and the TRUSTe Privacy Program.
As a customer of KAVA, you agree to comply with Zoho’s policies as listed in Section 3 below.

2. KAVA Privacy Policy
This policy explains how KAVA handles personal information and complies with the requirements of the Australian Privacy Act 1988 (Cth) (“Privacy Act”). If you have any questions in relation to this policy, please contact us at privacy@kavacrm.com .

Collection of Personal Information
Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable.
KAVA collects and holds personal information from customers, employees, contractors, suppliers and other individuals. We collect and hold this information when it is related to KAVA’s business purposes. KAVA does not knowingly collect, hold or use sensitive personal information unless our customers provide that information to us.
The main types of personal information KAVA collects and holds relate to the contact details and organisational roles of our customers, prospects, suppliers and other business contacts. Typically, this information includes names, addresses, telephone numbers, e-mail addresses, job titles, photographs (for use within our CRM system), web site details and social media profiles.
We collect most information directly from individuals when we deal with them. The personal information we collect may be provided in forms filled out by individuals, face-to-face meetings, email messages, telephone conversations or by third parties. If you contact us, we may keep a record of that contact.
Additionally, in providing services and solutions to our customers, we may collect, hold and use customer data that contains personal information of their customers and contacts. This customer-supplied data is used for uploading/migrating customer’s data to KAVA’s CRM solutions, and for backup and recovery purposes if needed.
We may also collect personal information from:

• customers and other contacts who provide us with leads for new business;
• suppliers of products and services to KAVA;
• social media and other virtual communities and networks where people create, share or exchange information;
• publicly available sources of information;
• industry relevant organisations; and
• any other organisation or person, where you’ve asked them to provide your personal information to us or asked us to obtain personal information from them.

Because of the nature of our business, it is generally impracticable for us to deal with individuals on an anonymous basis or through the use of a pseudonym, although sometimes this is possible (for example, when seeking staff or client feedback generally).

Use of Personal Information
The main purposes for which we collect, hold and use personal information are:

• to provide our services and solutions;
• to respond to an individual’s request;
• to maintain contact with customers;
• to keep customers and other contacts informed of the services we offer and developments that may be of interest to them, and to notify them of service offerings and events we are holding;
• to identify and pursue potential new business opportunities;
• to provide customer testimonials;
• for general management and reporting purposes, such as invoicing and account management;
• for recruitment purposes;
• for purposes related to the employment of our personnel and providing internal services to our staff; and
• other purposes related to our business.

KAVA provides no warranty about the Service. Without limiting the foregoing, KAVA does not warrant that the Service will meet your requirements or that it will be suitable for any particular purpose. To avoid doubt, all implied conditions or warranties are excluded in so far as is permitted by law, including (without limitation) warranties of merchantability, fitness for purpose, title and non-infringement.
If you choose not to provide us with personal information, we may be unable to do such things.
We may collect, hold and use personal information about individuals to market our services, including by email. However, individuals always have the opportunity to elect not to receive further marketing information from us. This can be done by either using the unsubscribe function in an email to notify us that you do not want to receive further marketing information from us by email, or by contacting us directly to make such a request.
Employee records are not generally subject to the Privacy Act and therefore this policy may not apply to the handling of information about employees by KAVA. For information about our practices relating to employee information, please contact us directly.

Disclosure of Personal Information
KAVA does not routinely disclose personal information to other organisations unless:

• use or disclosure is permitted by this policy;
• we believe it is necessary to provide you with a product or service which you have requested (or, in the case of a KAVA employee or contractor, it is necessary for maintaining or related to your role at KAVA);
• to protect the rights, property or personal safety of any member of the public or a customer of KAVA or the interests of KAVA;
• some or all of the assets or operations of KAVA are or may be transferred to another party as part of the sale of some or all of KAVA’s business;
• you give your consent; or
• such disclosure is otherwise required or permitted by law, regulation, rule or professional standard.

We may also share non-personal, de-identified and aggregated information for research or promotional purposes. Except as set out in this policy, we do not sell to or trade personal information with third parties.
KAVA uses a range of service providers to help us maximise the quality and efficiency of our services and our business operations. This means that individuals and organisations outside of KAVA will sometimes have access to personal information held by KAVA and may collect or use it from or on behalf of KAVA. This may include, but is not limited to,

• independent contractors and consultants;
• information technology providers;
• accounting or finance professionals and advisers;
• government, statutory or regulatory bodies and enforcement bodies;
• legal and any other professional advisers or consultants;
• administration or business management services, consultancy firms, auditors and business management consultants;
• marketing agencies and other marketing service providers;
• print/mail/digital service providers;
• imaging and document management services;
• travel service providers;
• off-site security storage providers;
• event managers; and
• credit managers and debt collecting agencies.

When dealing with Australian-based service providers, we require them to adhere to our privacy guidelines and not to keep, use or disclose personal information we provide to them for any unauthorised purposes. Regarding the use of overseas-based service providers, please refer to the “Transfer of Information Outside of Australia” section below.

Transfer of Information Outside of Australia
In providing our KAVA solutions to our customers, we need to provide personal information to persons or organisations located overseas. The collection, use and disclosure relating to this is as described in the sections above
When selecting overseas service providers who will have access to personal information, we chose recognised and proven providers that:

• recognise the importance of data security and the protection of personal information;
• have clear and documented security and privacy policies;
• comply with the provisions of the U.S.-EU Safe Harbor framework developed by the United Stated Department of Commerce in consultation with the European Commission; and
• comply with the TRUSTe Privacy Program, an independent, globally-recognised organisation whose mission is to build users’ trust and confidence in the internet by promoting the use of fair information practices.

Overseas recipients of personal information are currently based in the following countries:

• New Zealand; and
• United States

There may be situations where KAVA may need to disclose your personal information to, and collect your personal information from, parties in other countries not on this list. Nevertheless, we will always use reasonable efforts to disclose and collect personal information in accordance with privacy laws.

Privacy on Our Web Sites
This policy also applies to any personal information we collect via our websites. In addition to personal information you provide to us directly (such as where you make a request or complete a registration form), KAVA may also collect personal information from you via its websites.
Cookies may be used on some areas of our websites. A cookie is a small software application which allows a website to recognise a previous user and to observe how a user navigates within a website. Cookies are used as a standard by many websites. KAVA may use cookies to improve the navigational experience of visitors to our websites and to make them easier to use.
If you are concerned about cookies, most browsers recognise when a cookie is offered and permit you to opt out of receiving it. If you are not sure whether your browser has this capability, you should check with the software manufacturer or your internet service provider. In most cases, you can refuse a cookie and still fully navigate KAVA websites.
In order to properly manage our websites, we may log certain statistics about the users of the facilities, for example the users’ domains and browser types. None of this information specifically identifies an individual.
Whenever a registered member (such as a KAVA customer) logs in to our websites, they will be identified by their user name and password. The information we collect about members’ use of our websites may be used for measuring use and performance and in assisting to resolve any technical difficulties.
Because KAVA wants your user experience to be as informative and resourceful as possible, we may provide links to websites operated by third parties. KAVA is not responsible for the privacy practices or policies of those sites. We encourage you to review each website’s privacy policy, especially if you intend to disclose any personal information via that site. A link to another non-KAVA website is not an express or implied endorsement, promotion or warranty of the products or services offered by or accessible through that site or advertised on that site.

Security of Personal Information
KAVA will endeavour to take all reasonable steps to keep secure any information which we hold about you, whether electronically or in hard-copy, and to keep this information accurate and up to date. KAVA strives to ensure the security, integrity and privacy of personal information of our customers.
We use a combination of physical security measures including restricting physical access to our offices and files as well as electronic security of our systems to keep personal information secure from misuse, loss or unauthorised use or disclosure. Unfortunately, with internet-based systems, no data transmission over the Internet can be guaranteed to be 100% secure.
For details about security related to the CRM solutions provided by KAVA, please refer to Zoho’s Security Practices, Policies and Infrastructure (https://www.zoho.com/security.html).
Some or all personal information may be available to the directors and authorised staff of KAVA for use in accordance with this policy. Access to personal information is provided on a need-to-know basis and we require our staff to respect the confidentiality of any personal information held by KAVA.

Access to Information
We will provide access to personal information upon request by an individual, except in the limited circumstances in which it is permitted for us to withhold this information (for instance, where granting access would infringe another person’s privacy).
When you make a request to access personal information, we will require you to provide some form of identification (such as a driver’s licence or passport) so we can verify that you are the person to whom the information relates.
If at any time you want to know what personal information we hold about you, you may contact us via email at privacy@kavacrm.com.

Corrections and Concerns
If you believe that information we hold about you is incorrect or out of date, or if you have concerns about how we are handling your personal information, please contact us and we will try to resolve those concerns.
If you wish to have your personal information deleted, please let us know and we will take reasonable steps to delete it (unless we need to keep it for legal, auditing or internal risk management reasons).
If KAVA becomes aware of any ongoing concerns or problems concerning our privacy practices, we will take these issues seriously and work to address these concerns. If you have any further queries relating to our privacy policy, or you have a problem or complaint, please contact us. If you are not satisfied with our handling of your problem or complaint you may make a complaint to the Australian Information Commissioner.

Effect of Policy
KAVA operates in a dynamic business environment and we aim to review this policy annually to keep it current.
KAVA may update this privacy policy at any time by publishing an updated version on our website (www.kavacrm.com).
The amended policy will apply between us whether or not we have given you specific notice of any change.

3. Zoho Policies
Provided below are links to Zoho’s security and privacy related policies. These policies are subject to change without notice by Zoho.
Zoho Security Policy: https://www.zoho.com/security.html
Zoho Privacy Policy: https://www.zoho.com/privacy.html
Zoho Anti-Spam Policy: https://www.zoho.com/policy.html
If you require further information about the data security and privacy protection policies in place at KAVA or any of our service providers, please contact us via email at privacy@kavacrm.com.