Privacy policy

Palo is operated by Dharma Corporation Pty Ltd ("Palo", "we", "us" or "our"). We respect your privacy and want to be clear about the information Palo collects and how we use it. This Privacy Policy applies when you use Palo or contact us.

1. Information we collect#

1.1. Depending on how you use Palo, we may collect:

• (a) your name, email address and account information;
• (b) your profile name and profile photo;
• (c) location information where you give Palo permission to access it;
• (d) food listings, photographs and information you upload;
• (e) messages you send through Palo;
• (f) information about food you give, claim or collect;
• (g) reports, complaints and communications with Palo;
• (h) identity verification information, including the outcome of identity checks carried out by our identification verification provider; and
• (i) technical information such as device information, app version, IP address, crash information and information about how Palo is used.

1.2. We try to collect only information reasonably necessary to operate, protect and improve Palo.

2. How we collect information#

2.1. We collect information:

• (a) directly from you when you create an account, create a listing, send a message, make a report or contact us;
• (b) automatically when you use certain features of Palo;
• (c) from your device where you have granted permission, including location information; and
• (d) from other users where they communicate with or report something involving you.

3. How we use your information#

3.1. We may use your information to:

• (a) create and manage your account;
• (b) show food available near you;
• (c) calculate approximate distances;
• (d) enable Givers and Collectors to communicate;
• (e) facilitate collection arrangements;
• (f) display and manage listings;
• (g) operate and improve Palo;
• (h) provide support;
• (i) investigate safety concerns and complaints;
• (j) prevent fraud, misuse and unlawful activity;
• (k) enforce our Terms of Service and Community Guidelines;
• (l) protect Palo and our users;
• (m) maintain the security and reliability of the service; and
• (n) comply with legal obligations.

3.2. We may use de-identified or aggregated information to understand how Palo is being used and improve the service.

4. Location#

4.1. Location is important to Palo because we connect people sharing food nearby.

4.2. If you give Palo permission, we may use your device's location to identify nearby listings and calculate distances.

4.3. Enabling location does not mean your precise location will automatically be publicly displayed to other users.

4.4. Other users may instead see an approximate location or distance.

4.5. If you choose to give another user a particular address or collection location, that information will be visible to that user.

4.6. You can control Palo's access to your device location through your device settings.

5. Cookies and tracking technologies#

5.1. Palo’s website may use cookies, pixels and similar technologies to understand how our website is used, measure advertising and improve our marketing.

5.2. We may use third-party advertising services, including Meta Pixel, which may collect information such as your IP address, device and browser information, pages visited and actions taken on our website.

5.3. Information collected through these technologies may be disclosed to Meta and used to measure advertising performance and show relevant advertising on Meta services.

5.4. Where applicable, you can choose whether to allow advertising and marketing technologies through the options provided on our website.

6. What other users can see#

6.1. Palo is a community platform, so some information needs to be visible to other users.

6.2. Depending on how you use Palo, this may include:

• (a) your profile name and photo;
• (b) your listings and photographs;
• (c) an approximate location or distance;
• (d) food information you provide;
• (e) collection information you choose to share; and
• (f) messages you send to another user.

6.3. Don't include information in a profile, listing, photograph or message that you aren't comfortable sharing with the relevant users.

7. Who we share information with#

7.1. We don't sell your personal information.

7.2. We may disclose information to:

• (a) other Palo users where necessary to provide features you've chosen to use;
• (b) technology and service providers that help us operate Palo, such as hosting, database, authentication, mapping, analytics, communications and security providers;
• (c) professional advisers, insurers and other service providers where reasonably necessary;
• (d) police, regulators, courts or other authorities where required or authorised by law; and
• (e) other appropriate parties where reasonably necessary to respond to a serious safety incident, suspected unlawful activity or legal claim.

7.3. Information may also be disclosed as part of a genuine sale, restructure or other corporate transaction involving Palo or Dharma Corporation Pty Ltd, subject to applicable law.

8. Identity verification#

8.1. To help keep Palo safe, we may require users to verify their identity through Stripe Identity, a third-party identity verification service.

8.2. Stripe may collect and process information needed to verify your identity, including your name, date of birth, government-issued identification and a photograph or selfie, identity details and biometric information used to match your selfie with your identity document.

8.3. Palo does not store your identity document, selfie, identity document number, address or date of birth in its systems. Some information may be processed temporarily to complete verification or confirm that you meet Palo’s age requirement and is not retained by Palo for that purpose.

8.4. Palo records the outcome of the verification. Stripe handles information collected during identity verification in accordance with Stripe’s privacy policy.

9. Messages#

9.1. Messages sent through Palo may be stored by us.

9.2. We don't routinely read private conversations simply because users are communicating through Palo.

9.3. However, we may access, preserve or review relevant messages where reasonably necessary to:

• (a) investigate a report or safety incident;
• (b) respond to suspected fraud, abuse or unlawful activity;
• (c) enforce our Terms or Community Guidelines;
• (d) protect a user or Palo; or
• (e) comply with law.

10. Safety incidents#

10.1. If a food safety issue, personal safety incident, complaint or legal dispute is reported, we may preserve information relevant to the incident.

10.2. This may include listings, photographs, messages, account information, reports, declarations, collection records and technical records.

10.3. We may retain this information after a listing or account would otherwise have been deleted where reasonably necessary to investigate the incident, protect users, establish or defend legal claims or comply with law.

11. Service providers and overseas processing#

11.1. Some technology providers used to operate Palo may store or process information outside Australia.

11.2. The locations involved depend on the providers Palo uses from time to time.

11.3. Where applicable, we take reasonable steps in relation to overseas handling of personal information in accordance with Australian privacy law.

12. Security#

12.1. We take reasonable steps to protect personal information against misuse, interference, loss and unauthorised access, modification or disclosure.

12.2. No online service can guarantee absolute security.

12.3. You should keep your account credentials secure and contact us if you believe your account has been accessed without permission.

13. How long we keep information#

13.1. We keep personal information for as long as reasonably necessary for the purposes for which it was collected, including operating Palo, investigating safety incidents, resolving disputes, complying with legal obligations and protecting our legitimate interests.

13.2. When information is no longer reasonably required, we will take reasonable steps to delete or de-identify it where required by applicable law.

14. Accessing or correcting your information#

14.1. You can update some information directly through Palo.

14.2. You can also contact us if you would like to:

• (a) ask what personal information we hold about you;
• (b) request access to that information; or
• (c) ask us to correct inaccurate or out-of-date information.

14.3. We will deal with requests in accordance with applicable privacy law.

15. Deleting your account#

15.1. You may request deletion of your Palo account using the functionality provided in Palo or by contacting us.

15.2. Deleting your account does not necessarily mean every record will immediately be deleted.

15.3. We may retain information where reasonably necessary for safety, fraud prevention, dispute resolution, legal claims or compliance with law.

16. Users must be 18+#

16.1. Palo is for people aged 18 and over.

16.2. We don't knowingly permit people under 18 to create accounts.

16.3. If we become aware that someone under 18 is using Palo, we may suspend or delete the account and take appropriate steps in relation to their information.

17. Privacy questions and complaints#

17.1. If you have a question or complaint about how Palo handles your information, contact us at:

Dharma Corporation Pty Ltd

Palo Privacy Officer

Email: help@palo.life

17.2. Please provide enough information for us to understand your concern.

17.3. We will consider privacy complaints and respond within a reasonable time.

17.4. If applicable, you may also have the right to make a complaint to the Office of the Australian Information Commissioner.

18. Changes to this Privacy Policy#

18.1. Palo will evolve and the way we handle information may change.

18.2. We may update this Privacy Policy from time to time.

18.3. If we make a material change to how personal information is handled, we'll provide reasonable notice where appropriate.

19. Australian privacy law#

19.1. We will handle personal information in accordance with privacy laws applicable to Palo from time to time.

20. Information you provide through our website#

20.1. Our website at palo.life lets you register your interest in Palo before it launches, for example by becoming a founder member. This section covers what we collect when you do. Sections 1 to 19 apply to the Palo app.

20.2. When you submit an expression of interest, we may collect your name, email address, phone number, suburb or postcode, the kinds of food you might like to give, how often you might give, and any comments you choose to provide.

20.3. It is up to you whether you register. If you do, all the details are required except the free-text comment, which is optional. If you don't provide the required details you won't be registered, but you can still use the rest of the website.

20.4. We use this information to register and manage your expression of interest, to contact you about Palo's launch and availability in your area, to understand interest in Palo and plan where and how it becomes available, and to send you updates about Palo where you have agreed to receive them.

20.5. We will only send you marketing messages about Palo if you have consented to receive them, and every message will include a way to unsubscribe. You can opt out at any time.

20.6. This information is stored using our hosting and database providers and may be processed or stored outside Australia. Section 11 applies.

20.7. We keep it for as long as reasonably necessary for the purposes above, generally until Palo launches and for a reasonable period afterwards, and then delete or de-identify it, unless you ask us to remove it sooner.

20.8. You can ask us to access, correct or delete this information at any time by contacting us at help@palo.life. Sections 14 and 15 apply.

20.9. Palo is for people aged 18 and over. Please don't submit an expression of interest if you are under 18.