Privacy Policy for Luksave

1. Information We Collect

We collect the following types of information to provide and improve the App’s functionality:

a. Personal Information

• Registration and Profile Data: When you register, we collect details such as your name, email address, phone number, and AppID.
• Passport and Worker Details: The App collects passport information (e.g., passport number, expiry date) and worker-related data (e.g., employment details, pre-departure briefing, and flight information) to facilitate labour mobility processes.
• Documents: You may upload, download, or view documents (e.g., PDFs) related to your worker profile, which are processed and stored securely using Cloudflare R2.

b. Automatically Collected Information

We collect limited information automatically, only as necessary for specific App functionalities:

• Device Information: Minimal details, such as device type and operating system, are collected to ensure compatibility and optimize performance.
• Usage Data: Anonymized data about how you interact with the App (e.g., navigation patterns) is collected via Firebase Analytics to improve user experience and troubleshoot issues.
• Log Data: Limited logs, such as IP addresses and timestamps, are collected for security and debugging purposes.
• Location Data: When you press buttons like the "check-in" feature on the home screen, we request location information (e.g., GPS data) through Android’s permission dialog. This is used only with your explicit consent to provide features such as finding nearby churches, supermarkets, or sports clubs for workers overseas.
• Any temporary data (e.g., in authentication tokens for Cloudflare R2) is used solely for specific features and not retained beyond their intended purpose.

c. Third-Party Data

• Cloudflare R2: If you upload, download, or access files, we collect only the data necessary to authenticate and perform the requested actions, such as file metadata or content.
• Firebase Analytics: We use Firebase Analytics to collect anonymized usage data to understand app performance and user engagement.

2. How We Use Your Information

We use your information only as necessary to provide specific App functionalities and ensure a secure, seamless experience:

• Manage worker profiles, including updating and displaying passport details and employment information for PALM/RSE program participation.
• Facilitate document uploads, downloads, and storage via Cloudflare R2, using temporary access tokens to authenticate and process file-related requests securely.
• Enable location-based features, such as identifying nearby services (e.g., churches, supermarkets, sports clubs) when you use the check-in feature, with your explicit permission via Android’s permission dialog.
• Improve the App through anonymized analytics (e.g., Firebase Analytics) to identify usage trends and resolve technical issues.
• Communicate with you regarding updates, account status, or labour mobility requirements.
• Ensure compliance with legal obligations and protect against unauthorized access or fraud.
• Data processed through tokens (e.g., for Cloudflare R2 authentication) is limited to what’s required for the specific feature and is not used beyond its intended purpose.

3. How We Share Your Information

We do not sell or rent your personal information. Your data is sent to our secure servers, and we may share it in the following cases:

• Service Providers: We work with trusted third-party services (e.g., Cloudflare for R2, Google for Firebase) to enable App features. These providers are bound by strict data protection agreements.
• Legal Compliance: We may disclose your information if required by law or to protect the rights, safety, or property of the App, its users, or others.
• Labour Mobility Authorities: Relevant worker data (e.g., passport details, employment status) and uploaded documents stored on Cloudflare R2 may be shared with PALM or RSE program authorities or the Vanuatu Government’s In-Country Recruitment Database (IRD) system to facilitate compliance and program participation, only with your consent or as required by law.

4. Data Storage and Security

• Storage: Your data is stored securely on our servers and, where applicable, on Cloudflare R2 for document-related features. We prioritize compliance with Vanuatu Government preferences for data storage related to Labour Mobility Programs. Data, including uploaded documents, may be shared from Cloudflare R2 with the Vanuatu Government’s In-Country Recruitment Database (IRD) system for compliance purposes. Note that our servers and Cloudflare R2 may be located outside Vanuatu, consistent with government practices for their main databases.
• Security: We use industry-standard encryption (e.g., HTTPS, secure API authentication) and access controls to protect your data. However, no system is completely secure, and we cannot guarantee absolute security.
• Retention: We retain your data only for as long as necessary to fulfill the purposes outlined in this policy or as required by law. You may request deletion of your data (see Section 7).

5. Third-Party Services

The App integrates with:

• Cloudflare R2: Used for secure document uploading, downloading, and storage. Cloudflare’s privacy policies apply to data processed through their services.
• Firebase Analytics and Cloud Messaging: Used for usage analytics and push notifications. Google’s privacy policies apply.
• iText PDF Library: Used for PDF document handling. Only local processing occurs, with no data shared externally.

We ensure these services comply with data protection standards, but we encourage you to review their respective privacy policies.

6. Your Rights and Choices

You have the following rights regarding your personal information:

• Access: View the data we have collected about you through the App’s profile or worker details screens.
• Correction: Update your information directly in the App (e.g., via the “edit worker details” feature).
• Deletion: Request deletion of your data by contacting us (see Section 8). Note that some data may be retained for legal or program compliance purposes.
• Opt-Out: Disable Firebase Analytics, push notifications, or location services (e.g., denying location permission when prompted) through your device settings or the App’s preferences.

7. International Data Transfers

The App is designed for use in Vanuatu but sends data to our servers and Cloudflare R2, which may be located outside Vanuatu. We ensure such transfers comply with applicable data protection laws, using safeguards like encryption and standard contractual clauses. This aligns with practices for government databases in Labour Mobility Programs.

8. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, contact us at:

• Email: support@empowerswr.com
• Address: Luksave Support Team, Port Vila, Vanuatu

9. Changes to This Policy

We may update this Privacy Policy to reflect changes in the App’s functionality or legal requirements. We will notify you of significant changes through the App or via email. The updated policy will be posted here with a revised “Last Updated” date.

10. Google Play Requirements

This Privacy Policy complies with Google Play’s Developer Program Policies, ensuring transparency about data collection, usage, and sharing. For more details on Google’s requirements, visit the Google Play Developer Policy Center.