Privacy Policy
1. ABOUT THIS POLICY
- This is the Privacy Policy of Haroob LLC. Haroob provides a wide range of technology products and services including “Service Connect App” to the community.
- Protecting your privacy is crucial to the way Haroob conducts our business. This Privacy Policy describes how we carefully manage and safeguard your Personal Information (including sensitive information), how we collect and use all of this information to provide our products and services to you and how we comply with our obligations.
- We take privacy seriously at Haroob and we are committed to protecting your privacy — not just because it is the law, but because handling Personal Information transparently and responsibly is a key part of creating a great customer, employee and business partner experience. Haroob does not sell, rent or trade your Personal Information.
Why Haroob’s Privacy Policy is important
- Haroob collects, holds, uses and discloses Personal Information to carry out Haroob’s functions or activities and to comply with our Privacy obligations.
- This Privacy Policy guides Haroob and regulates how we manage and protect your Personal Information.
Who is responsible for your Personal Information?
- Haroob is responsible for the safekeeping of Personal Information that is provided to us.
- This Privacy Policy should be read in conjunction with:
- any privacy or collection notice/statement that Haroob provide to you; and
2. TYPES OF PERSONAL INFORMATION WE COLLECT
If you are a customer or potential customer
- If you are a customer or potential customer, Haroob collects information about you to provide you with services and otherwise to facilitate your dealings with us. The main way Haroob collects Personal Information about you is when you provide it to us.
- The information Haroob collects may include:
- your contact information, such as your name, address, email address, telephone number and mobile phone number, and Meter number;
- payment information such as account details, data necessary for processing payments and other related billing information;
- details relating to the supply of water and/or energy to you and your use of our water and/or energy (including meter details and data related to your water and/or energy consumption, connection and interruptions);
- information you provide to us when participating in customer surveys or competitions; and
- In addition, with your express consent (except where otherwise allowed by law), Haroob may collect sensitive information about you, which may include:
- government related identifiers, such as your date of birth, driver’s licence, passport, details that you provide to us (for example, when Haroob need to verify who we are dealing with, who we are providing the product and/or service to and to ensure we are collecting any outstanding debts from the correct person);
- Haroob may also collect Personal Information about your secondary contact, or your life support contact or your authorised representative which may include their name, date of birth, phone and email contact details, address and the relationship with you as our customer. We rely on you to inform these individuals that their Personal Information is being provided to Haroob, that they should read this Privacy Policy and that they can contact us for further information.
- If you create a Portal profile either via the Haroob website or mobile App, you will need to provide your name, email address and customer number. Without this information, Haroob cannot create a Portal profile for you. By providing your Personal Information, you agree to Haroob using this to set up your Portal profile which you will need to complete by creating a password and accepting Haroob’s Terms of Use.
If you do business or have other dealings with us
- If you, or your employer, does business with Haroob or has other dealings with us, we collect information about you to facilitate those arrangements. This information may include your name, position, contact details, date of birth and any other information you provide to Haroob. For security reasons, we may also take your photograph when you sign into our office or site locations.
If you are an employee or applicant
- If you are an employee or a job applicant, Haroob collects information about you to administer your employment or process your application. This may include qualification and identification information, residency / visa status information, medical records and health information, reference details, screening check information (such as background, medical, drugs and alcohol, criminal records, police checks, bankruptcy, directorship and company checks), psychological testing results and results from records checks.
- In addition, when you apply for a job or position with Haroob, we may collect information about you from any recruitment consultant, your previous employers, referees, CV checking agencies or others who may be able to provide information to assist us to assess your application. Further details of what information is collected if you are offered a position are contained in Haroob’s Recruitment Privacy Statement.
3. HOW WE COLLECT PERSONAL INFORMATION
Directly from you
- In many instances, Haroob collects Personal Information directly from you. For example, if you are a customer, we may collect your information from an application form you have completed, or when you contact us by phone, email, through our website, mobile App or via social media sites.
- Your calls to Haroob’s customer contact centre are recorded and monitored for training, service quality control, verification and compliance purposes.
- Some other examples of how Haroob collects Personal Information include:
- If you use our registration system to visit our offices and site locations.
- If you work with us or apply for a job with us.
- If you engage with us via our website, officers or call centres regarding our activities.
- When you or your organisation offer to provide, or provide, products and or services to us.
- When you enter an Haroob competition or participate in a survey.
From our partners
- If you are a customer or potential customer, Haroob may collect information about you through our clients, partners and service providers who provide customer information to deliver services to you on their behalf. These partners may be companies who provide water and/or energy services. They collect your information from you and then provide it to Haroob for the purpose of assisting you to become our customer and provide service of our clients, partners and service providers.
From other third parties
- Haroob may also collect information about you from other third parties such as companies provide payment/billing services, government agencies and regulators and other third party service providers.
Through other means
- In the course of Haroob’s functions or activities, we may collect Personal Information (including Sensitive Information) about you indirectly from publicly available sources or from third parties such as:
- through our advanced metering infrastructure (e.g. through our monitoring of smart meter data); and
- from your secondary contact or authorised representatives.
- Haroob will only store this information for as long as it is needed to perform the function or activity for which it was collected. Haroob will destroy or de-identify information when it is no longer required for that purpose.
- Haroob may collect Personal Information via our website – see Part 5 Using our Website and Cookies below.
- Haroob may also collect Personal Information that you provide to us when signing up to mailing lists, creating a Portal profile, registering for our events, using our mobile App, or when submitting a form or feedback on your experience with our website or mobile App.
Anonymity
- Whenever it is lawful and practicable, Haroob will allow you to interact with us anonymously or by using a pseudonym.
- However, for most of our functions and activities Haroob usually requires your name, contact information and enough information about the particular matter to enable us to fairly and efficiently handle your inquiry, request, complaint or application, or to respond to you, the relevant authorities or to another effected individual/organisations.
WHY WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION
- Haroob collects, holds, uses and shares your Personal Information for our business functions and activities, which includes delivering our products and services, managing our business and complying with the law. We handle your information so we can:
- confirm and/or validate your identity;
- facilitate the provision of water and/or energy and related services to your supply address in collaboration with our clients;
- communicate with you (by sending service, support and administrative messages, reminders and notices) and to keep you updated regarding our activities;
- lessen or prevent a serious threat to the life, health or safety of any individual, or to public health;
- deal with customer care related activities;
- set or reset your password (where you have one) for Portal;
- respond to your enquiries and resolve complaints and disputes;
- send you marketing and promotional messages and other information that may be of interest to you;
- consider an individual for employment;
- administer our Rewards Program, customer surveys,contests and other promotional activities or events;
- improve and optimise our services and our customers’ experience (for example, by performing analytics and conducting research for advertising and marketing);
- comply with our regulatory obligations, report to regulators and authorities and assess our legal compliance (including through internal and external audits).
- If Haroob does not have your Personal Information, we may not be able to deliver the products or services you have asked for or respond to your questions or comply with the law.
Who we disclose Personal Information to?
- Haroob may disclose your Personal Information for the purposes described in this Policy to:
- our employees;
- our clients, partners, and service providers who assist us by, for example, providing IT services, installing meters, back office management services or customer acquisition and onboarding services;
- CV checking agencies (if you have applied for a position with us);
- third persons you have authorised us to provide your information to (such as secondary account holders or your authorised representatives);
- financial institutions and payment system operators (including merchants);
- our insurance brokers, providers and consultants;
- our professional advisers, dealers and agents (including independent auditors, legal and tax advisers);
- debt collection agencies and others that assist us with debt recovery;
- the sponsors or promoters of any competitions that we conduct;
- State and Federal Government Agencies;
- Regulatory bodies and Law Enforcement Agencies; and
- other persons as required or permitted by law.
- Haroob takes reasonable measures to ensure that the parties we share your information with are bound by confidentiality and the Privacy Act.
What we will not do with your Personal Information
- Haroob will not use or disclose your Personal Information for another purpose (a secondary purpose) unless:
- we first obtain your consent;
- you would reasonably expect us to use or disclose your Personal Information for a secondary purpose that is related to the primary purpose or, in the case of Sensitive Information, directly related to the primary purpose;
- it is set out in this Policy;
- we are required to by Law;
- a permitted general purpose exists;
- a permitted health situation exists;
- we believe it is reasonably necessary for one or more enforcement related activities conducted by, or on behalf of, an enforcement body.
- If Haroob collects Sensitive Information about you, you consent to us collecting, using and disclosing the Sensitive Information for the purpose for which it was collected as disclosed and as permitted by the Privacy Act or other relevant legislation.
Overseas disclosure
- Haroob may disclose your Personal Information to entities outside of our country for our business functions or activities or for the purposes of providing services to you. Where we do so, we will take reasonable steps to ensure that the disclosure of, and access to, your Personal Information is secure, that appropriate controls are in place and that your Personal Information is handled in a manner consistent with the Privacy Act.
- The entities we may share your information with may be located in, or have personnel that may access your information from, the following jurisdictions: United State, United Arab Emirates, Germany, India and the Australia.
Direct marketing
- Haroob and/or our business partners may send you direct marketing communications and information about products and services that we or third parties offer, including competitions that we think you might be interested in. This may take the form of emails, SMS, mobile App push notifications, mail or other forms of communication.
- These marketing communications may also be sent to you even if you are not, or no longer, a customer of Haroob.
- Where push notifications are available and you have enabled to receive them, the mobile App will use an installation ID and token to identify your mobile App for the purpose of receiving the push notification. You can deactivate mobile App push notifications by changing the notification setting in the mobile App or on your mobile device at any time.
- You may opt-out of receiving these marketing communications by clicking on the unsubscribe link in the electronic communication.
- Even if you opt-out of receiving marketing communications, Haroob may still contact you to send important administrative and safety messages, as well as to manage your account.
USING OUR WEBSITE/MOBILE APP AND COOKIES
- Haroob’s website, www.haroob.com, hosted in hosted in Germany or United States or Australia or India and there are a number of ways in which we collect information through our website. Our mobile App can be downloaded from the Apple App Store or Google Play App Store and all data viewed on the App is hosted in Germany or United States or Australia or India.
- Haroob may collect Personal Information about you when you use and access our website or mobile App (for example, when you submit an enquiry or online form, set up your account on the Portal platform, sign up to our newsletter, or enter a competition on our website or mobile App).
- Haroob’s website includes pages that use cookies which are small amounts of data sent by our website and other third parties and stored on your computer’s hard drive. This allows our servers to recognise your computer when you visit our website in the future. Although cookies are used to collect data about your browser type, the operating system you are using, the web page you visited, your internet service provider and your State location, Haroob does not use this data to identify you personally.
- Haroob’s website and mobile App also uses Google Analytics, a web analytics service provided by Google, Inc. (Google). Google Analytics also uses cookies. Although these cookies do not identify you personally, they allow information about your use of our website (including your IP address and installation ID) to be transmitted to Google. For more information, please see Google’s site “How Google uses data when you use our partners’ sites or apps”, located at google.com/policies/privacy/partners/. By using our website and/or mobile App, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
- Haroob also collects data crash reports which contain information such as IP addresses and installation ID.
- You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. If you refuse the use of cookies in this way you may not be able to access the full functionality of Haroob’s website. Please refer to your internet browser’s instructions or help screens to learn more about these functions.
- To assess the effectiveness of Haroob’s website and mobile App design and layout, as well as monitor traffic to the website, we may contract with third parties to collect statistical data. However no Personal Information is collected during this process.
- Haroob’s website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, Haroob is not responsible for the privacy practices of, or any content on, those linked websites, and we have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from this Privacy Policy, so we encourage individuals to read them before using those websites.
- Haroob generally hold Personal Information in our electronic databases, but we may also store Personal Information in hard copy form and in various third party databases and platforms.
- Haroob is committed to the security of your Personal Information and takes reasonable steps to protect your Personal Information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
- Haroob uses a number of physical, administrative, personnel and technical measures to protect your Personal Information, which include, but are not limited to:
- implementing internal processes and policies in relation to the collection, use and secure storage of Personal Information and educating our personnel in relation to these obligations;
- storing Personal Information in secure, encrypted data centres;
- using secure networks or encryption when transmitting electronic customer data and Personal Information;
- using ID cards, cameras and sign in procedures to prevent unauthorised access to our offices and buildings;
- requiring the third parties we engage to take adequate security measures and handle your Personal Information in a manner consistent with the Privacy Act;
- regularly assessing the risk of misuse, interference, loss, and unauthorised access, modification or disclosure of that information;
- taking measures to address those risks; and
- having mandatory annual training for all our staff on our privacy obligations, with a focus on how to keep your information safe and secure.
REQUEST TO ACCESS PERSONAL INFORMATION
- You can request access to the Personal Information that Haroob holds about you at any time by contacting us using the details at the end of this Policy. We will ask you to verify your identity before we provide access to your information and we will try to make the process as simple as possible.
- Haroob will endeavour to respond within a reasonable period of receiving your request. Where reasonable, we will provide you with a copy or details of your Personal Information in the manner requested.
- Sometimes Haroob may be unable to provide you with access to some or all of your personal information (for example we reasonably believe that providing access would have an unreasonable impact on the privacy of other individuals, would pose a serious threat to the life, health or safety of any individual/to public health/public safety or would be unlawful/prejudicial). Where this is the case, we will tell you why.
REQUEST TO CORRECT PERSONAL INFORMATION
- Haroob takes reasonable steps to ensure that the Personal Information we collect, use and disclose is accurate, complete, up to date and relevant.
- If you believe the Personal Information that we hold about you is inaccurate, incomplete or outdated, please contact us using the details at the end of this Policy. We will endeavour to respond within a reasonable period of receiving your request.
- We will ask you to verify your identity before we make any corrections.
- If we do not think that the information needs to be corrected, we will tell you why. If we do not correct your Personal Information, you can ask us to include a statement (that will be attached to that information) that you believe the information is incorrect and why.
DESTRUCTION/DE-IDENTIFYING OF PERSONAL INFORMATION
- When Haroob no longer needs the Personal Information collected for any purpose for which the Personal Information may be used or disclosed, Haroob will destroy/de-identify the Personal Information in accordance with the Privacy Act requirements.
PRIVACY COMPLAINTS
- If you believe that we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your Personal Information, we encourage you to contact us using the details at the end of this Policy.
- Please include your name, email address and/or telephone number and clearly describe your complaint. We will respond within a reasonable period of receiving your complaint.
- If we receive a complaint from you about how we have handled your Personal Information we will determine what (if any) action we should take to resolve the complaint.
- If we decide that a complaint should be investigated further, the complaint will usually be handled by a more senior officer than the officer whose actions you are complaining about.
HOW TO CONTACT US
- Haroob welcomes your views about our Privacy Policy.
- To ask us a question, access your Personal Information, request a correction to your Personal Information, make a complaint, or get a copy of this Policy, you can contact Haroob on support@haroob.com.
REVIEW OF POLICY
- Haroob’s Privacy Policy will be reviewed by our Privacy Officer at least every two years or more frequently if changes are required, including when there are legislative changes or changes to our information handling practices. The next scheduled review will be July 2025.
- When we change our Privacy Policy, we update it on our website. This Policy was last reviewed in October 2024.