Privacy Policy

KLAY Modern Introductions ('KLAY', 'we', 'us', 'our') is committed to handling personal information carefully and transparently.

This Privacy Policy explains how KLAY collects, uses, stores and discloses personal information, and how individuals may contact KLAY about access, correction, deletion requests or privacy concerns.

KLAY seeks to follow responsible privacy practices and will comply with the Privacy Act 1988 (Cth), the Australian Privacy Principles and other privacy obligations to the extent they apply to KLAY.

KLAY Modern Introductions is operated by Sydney Elise Strong trading as KLAY Modern Introductions, ABN 93 835 592 760, based in Victoria, Australia. This Policy should be read together with KLAY's Terms & Conditions and, for paying Clients, the applicable Membership Agreement.

2.1 Personal Information

To provide a personalised matchmaking and introduction service, KLAY may collect information voluntarily provided through applications, interviews, consultations, communications, website interactions and ongoing engagement. This may include:

• contact and identification information, such as name, email address, phone number, age or age range and general location;
• personal profile information, such as occupation, education, professional background, photographs and biographical details;
• lifestyle, interests and compatibility information, including hobbies, values, beliefs, personality traits and preferences;
• relationship information, including relationship status, relationship history, goals and partner preferences;
• family and personal circumstances, including information about children, family background and future plans;
• demographic information, including ethnicity, cultural background and languages spoken; and
• other information an individual chooses to provide that may assist KLAY in assessing suitability or identifying potential introductions.

2.2 Sensitive Information

Because matchmaking can involve highly personal compatibility factors, KLAY may collect sensitive information voluntarily disclosed by an individual, including:

• sexual orientation or gender identity;
• religious beliefs or affiliations;
• racial or ethnic origin; and
• health information voluntarily disclosed as relevant to compatibility, personal circumstances or safety.

KLAY will seek express consent before collecting or using sensitive information where required by applicable law. Individuals are not required to disclose sensitive information, although choosing not to provide information may affect KLAY's ability to assess particular compatibility preferences or facilitate certain introductions.

2.3 Payment Information

Membership fees are payable by direct bank transfer following invoice. KLAY does not collect or store card details. KLAY may retain ordinary business and accounting records relating to invoices, payments received and transaction references.

2.4 Information Collected Automatically

When an individual interacts with the Website, KLAY or its service providers may collect limited technical information such as IP address, browser type, device information and website usage data through standard website and analytics technologies.

KLAY may collect personal information directly when an individual:

• completes an online application form or submits an enquiry;
• participates in a complimentary conversation, interview or Understanding You Consultation;
• enters into a Membership Agreement;
• communicates with KLAY by email, telephone, video call, electronic messaging or in person;
• participates in the introduction and feedback process; or
• attends a KLAY event.

KLAY may also receive information from a referring person where the individual has been referred to KLAY. KLAY will not use referral information to create or share a matchmaking profile without appropriate engagement with the individual.

KLAY may use personal information to:

• respond to enquiries and conduct complimentary conversations;
• assess applications to the KLAY Network;
• understand a Client's relationship goals, values, lifestyle and preferences;
• source, screen, interview and assess potential matches;
• identify and curate potential introductions between Clients and Network Members;
• present relevant profile information for a specific proposed introduction;
• coordinate introductions and seek post-introduction feedback;
• refine ongoing search and matching considerations;
• administer Membership Agreements, invoices, payments and service communications;
• maintain the safety and integrity of the KLAY Network;
• send marketing communications and event invitations where consent has been given or otherwise permitted by law;
• improve the Website and Services; and
• comply with legal and regulatory obligations.

Sensitive information will be used only for purposes reasonably connected with matchmaking, introductions, compatibility, service delivery or safety, and otherwise in accordance with consent and applicable law.

5.1 Specific Proposed Introductions

A Network Member's relevant profile information may be shared with a paying Client for a specific proposed introduction only after KLAY has personally interviewed or engaged with the Network Member as part of its process and the Network Member has confirmed interest in the specific proposed introduction.

Information shared will be limited to information KLAY reasonably considers relevant to the proposed introduction, such as first name, age or age range, photographs, occupation, lifestyle information, interests, values and other relevant profile information.

KLAY does not ordinarily share home addresses, financial information or full contact details as part of the initial profile presentation. Contact details will generally only be exchanged where an introduction is proceeding or the relevant individuals have agreed.

5.2 Third-Party Service Providers

KLAY may disclose personal information to service providers that assist KLAY to operate, including:

• secure electronic record-keeping, CRM, cloud storage and business software providers;
• email, website, analytics and marketing platforms;
• accounting, invoicing and professional administration providers; and
• legal, accounting or other professional advisers where reasonably necessary.

KLAY will only disclose information reasonably necessary for the relevant service or business purpose.

5.3 Required or Authorised by Law

KLAY may disclose personal information where required or authorised by law, including in response to a lawful court order, warrant or request from an authorised law enforcement or regulatory body.

5.4 No Sale of Personal Information

KLAY does not sell, rent or trade personal information to third parties for their own marketing purposes.

Profile photographs are used for matchmaking and introduction purposes and will not be used in KLAY marketing without express prior written consent.

Written or video testimonials may be published only in accordance with the consent given by the individual. KLAY will protect anonymity unless the individual expressly agrees to be identified.

KLAY does not conduct criminal background checks, formal identity verification or social media screening on Clients or Network Members as part of its Services. KLAY's interview and matchmaking process is not a criminal, legal, identity or safety background check.

KLAY relies on individuals to provide true, accurate and complete information. If KLAY becomes aware of information that reasonably raises concerns about eligibility, honesty, conduct or safety, KLAY may take action in accordance with its Terms & Conditions and any applicable Membership Agreement.

Personal information is primarily stored within electronic record-keeping, CRM, cloud and business systems. KLAY takes reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, modification or disclosure.

Access to personal information is limited to people and service providers who reasonably require access for KLAY's business and service purposes. No method of electronic storage or transmission is completely secure.

KLAY retains personal information for as long as reasonably necessary to provide the Services, manage the KLAY Network, fulfil the purposes described in this Policy and meet legal, accounting or legitimate business requirements.

Where a person withdraws from the KLAY Network or a Membership ends, KLAY may retain information for a reasonable period in case the person re-engages or where records are reasonably required for business, dispute, legal or compliance purposes. Information may then be securely deleted or de-identified where appropriate.

An individual may contact KLAY at info@klayintroductions.com to:

• request access to personal information KLAY holds about them;
• request correction of inaccurate, out-of-date or incomplete information;
• request deletion or de-identification of personal information, subject to legal, record-keeping and legitimate business retention requirements;
• withdraw consent to marketing communications;
• withdraw or change a consent relating to use of sensitive information or profile sharing, noting that this may affect KLAY's ability to provide matchmaking or introduction services; or
• raise a privacy concern or complaint.

KLAY will consider and respond to requests within a reasonable timeframe. KLAY may need to verify the identity of the person making a request before providing access to or changing personal information.

KLAY may send marketing communications, event invitations or promotional content where an individual has consented or where otherwise permitted by applicable law. Service communications relating to an enquiry, application, Membership or introduction are not marketing communications.

Marketing preferences may be changed at any time using an unsubscribe facility or by contacting info@klayintroductions.com.

Some service providers used by KLAY may store or process information on servers located outside Australia. Where applicable, KLAY will take reasonable steps required by law in relation to overseas handling of personal information.

KLAY's matchmaking and introduction services are for individuals aged 18 years and over. KLAY does not knowingly create matchmaking profiles for individuals under 18. If KLAY becomes aware that it has inadvertently collected information from a person under 18 for matchmaking purposes, it will take reasonable steps to delete that information where appropriate.

Privacy concerns or complaints should be sent to info@klayintroductions.com. KLAY will review the concern and respond within a reasonable timeframe.

Where applicable, an individual may also have the right to contact the Office of the Australian Information Commissioner or another appropriate privacy regulator.

KLAY may update this Privacy Policy to reflect changes in practices, technology or legal obligations. The updated Policy will be published with a revised effective date. Where appropriate, KLAY may notify existing Clients or Network Members of material changes.

KLAY Modern Introductions

Operated by Sydney Elise Strong trading as KLAY Modern Introductions

ABN 93 835 592 760

Victoria, Australia

Email: info@klayintroductions.com