Introduction

This Privacy Policy explains how LOKAL handles information.

It covers information shared through this website or directly with our team. Use of the website is covered by our Terms, and our AI practice is set out in How LOKAL uses AI.

Grounds for data collection

We process personal information only when we have a legal basis.

Those bases include consent, contract performance, legal obligations and legitimate business interests such as improving services or preventing fraud.

When you use the Site, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy.

We encourage our Users to carefully read the Privacy Policy and use it to make informed decisions.

What information we collect

We collect two types of data and information from Users.

The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site ("Non-personal Information"). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Site. We may also collect information on your activity on the Site (e.g. pages viewed, online browsing, clicks, actions, etc.).

The second type of information is Personal Information which is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual. Such information includes:

Device Information: We collect Personal Information from your device. Such information includes geolocation data, IP address, unique identifiers (e.g. MAC address and UUID) and other information which relates to your activity through the Site.
Enquiry Information: When you fill in a form on our Site, you give us details such as your full name, email address, phone number and company or organisation name.
Communication Information: If you contact us directly, we may receive additional information about you such as your name, email address, the contents of your message, and any attachments you may send.
Usage Data: We collect information about how you interact with our services, including features accessed, actions taken, and preferences set within the platform.

How do we receive information about you?

We receive your Personal Information from various sources:

When you voluntarily give us your details through a form on our Site;
When you use or access our Site in connection with your use of our services;
From third party companies, services and public registers (for example, traffic analytics companies).

How we use the information

We do not rent, sell, or share Users' information with third parties except as described in this Privacy Policy.

We may use the information for the following:

Providing and managing our services – delivering the services and features you have requested;
Communicating with you – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have;
Keeping you informed – sending updates about new features, service changes, and relevant announcements;
Serving you advertisements – displaying tailored advertisements when you use our Site (see more under "Advertisements");
Marketing – promoting our website and products (see more under "Marketing");
Analytics and improvement – conducting statistical and analytical purposes intended to improve the Site, diagnose technical issues, and understand user behavior;
Security and fraud prevention – monitoring and investigating suspicious activity to protect the integrity of our platform and our users;
Legal obligations – fulfilling our obligations under applicable laws and regulations.

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third party companies, who may be located in different jurisdictions across the world, for any of the following purposes:

Hosting and operating our Site (e.g., cloud infrastructure companies);
Providing you with our services, including providing a personalized display of our Site;
Storing and processing such information on our behalf;
Processing payments securely on our behalf (e.g., payment gateway companies);
Serving you with advertisements and assisting us in evaluating the success of our advertising campaigns and helping us retarget any of our users;
Providing you with marketing offers and promotional materials related to our Site and services (e.g., email marketing platforms);
Performing research, technical diagnostics or analytics (e.g., analytics service companies);
Providing customer support tools and services.

We may also disclose information if we believe in good faith that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

User Rights

You may request to:

Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information.
Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format.
Request rectification of your personal information that is in our control.
Request erasure of your personal information.
Object to the processing of personal information by us.
Request to restrict processing of your personal information by us.
Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

If you wish to exercise any of the aforementioned rights, or receive more information, please contact us using the details provided below:

Email: [email protected]

By post, to either office:

LOKAL, Sydney
Level 35, Tower One, International Towers
100 Barangaroo Avenue
Sydney NSW 2000
Australia

LOKAL, Philippines
Unit 10-01 One Global Place
5th Ave, Corner 25th St
Taguig, 1634 Metro Manila, Philippines

We will endeavor to respond to your request within 30 days of receipt.

Retention

We retain personal information only as long as necessary.

The period reflects its purpose, our legal obligations, dispute handling and policy enforcement. We remove outdated information when the applicable requirements allow it.

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Site or access our services.

A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.

The Site uses the following types of cookies:

a. Session cookies – stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;

b. Persistent cookies – read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;

c. Third party cookies – set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.

Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Site may not operate properly and your online experience may be limited.

We also use a tool called "Google Analytics" to collect information about your use of the Site. Google Analytics collects information such as how often users access the Site, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Site and services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google's ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

Third party collection of information

Our policy only addresses the use and disclosure of information we collect from you.

To the extent you disclose your information to other parties or sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to.

This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals whom we do not employ or manage, including any of the third parties which we may disclose information as set forth in this Privacy Policy.

How do we safeguard your information?

We take great care in implementing and maintaining the security of the Site and your information.

We employ industry-standard procedures and policies to ensure the safety of the information we collect and retain, and prevent unauthorized use of any such information. These measures include encryption of data in transit using TLS/SSL protocols, encryption of sensitive data at rest, access controls and authentication requirements for our personnel, regular security assessments and vulnerability testing, and incident response procedures. We require any third party handling Personal Information on our behalf to comply with similar security requirements, in accordance with this Privacy Policy. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Site, and we make no warranty, express, implied or otherwise, that we will prevent such access.

Transfer of data outside your country (DRAFT for legal review)

LOKAL works from Australia and the Philippines, with clients in Australia, Canada, the United States and the Philippines.

Information you share from any of those countries may be processed in Australia and the Philippines. The AI tools we use process information in the regions where the AI companies operate, mainly the United States and the European Union.

If you are in the European Economic Area, we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

If you are in Australia, we take reasonable steps so that overseas recipients handle your information consistently with the Australian Privacy Principles.

If you are in Canada, your information may be processed outside Canada and is subject to the laws of those jurisdictions.

Artificial intelligence and automated processing (DRAFT for legal review)

LOKAL uses AI tools in its work, including for research, audits, drafts, reporting and quality checks.

Much of this runs on LOKI, our in-house AI system. We use business, team and enterprise accounts only, under terms that stop the AI companies training on client data.

We do not use automated decision-making that produces legal or similarly significant effects on individuals without a person involved. A senior strategist owns every plan, and a person is responsible for every decision.

This disclosure is prepared ahead of the automated decision-making transparency obligation under the Privacy Act (Australia), which commences on 10 December 2026.

If you believe a decision about you involved automated processing, you can ask for a person to review it by emailing [email protected]. A person will review your request within one business day.

Marketing

We may use your contact details to send relevant information about our services. Approved subcontractors may help us deliver those communications.

Out of respect for your privacy, every marketing message gives you a way to decline further marketing from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists.

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

Australia (DRAFT for legal review)

In Australia, we handle personal information under the Privacy Act 1988 and the Australian Privacy Principles.

If you have a concern about how we have handled your information, contact us first at [email protected] and we will respond. If we cannot resolve it, you can complain to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au ↗.

Canada (DRAFT for legal review)

In Canada, we handle personal information under the Personal Information Protection and Electronic Documents Act (PIPEDA).

If you are a Quebec resident, Law 25 also applies: we will tell you when a decision about you is based exclusively on automated processing, and you may ask for it to be reviewed by a person. Complaints can go to the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d'accès à l'information du Québec.

Ely guest chat (DRAFT for legal review)

Ely is LOKAL's AI guest-chat product for hotels, live in client hotels, with a hotel waitlist open.

Ely tells guests it is an AI assistant. Guest conversations are not used to train any model.

When a guest chats with Ely, we collect the messages, the time of the conversation, the hotel the guest is contacting and any details the guest chooses to share. We use this information to answer from hotel-approved information and to pass requests to hotel staff. Guest chat information is retained for 30 days, or longer where the law requires it.

The hotel's team and the LOKAL staff who support the service can see guest chat information. The hotel decides what Ely may answer and is the primary party for guest information; LOKAL operates the service on the hotel's behalf.

Corporate transaction

We may share information during a merger, sale or similar corporate transaction. The acquiring company would assume the rights and obligations described in this policy.

Minors

We understand the importance of protecting children's privacy, especially in an online environment.

The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at [email protected].

Updates or amendments to this Privacy Policy

We may revise this Privacy Policy.

Material changes take effect when the revised policy appears here, and the last-modified date records the update. Continued use means you acknowledge the revised policy.

How to contact us

Questions about this website or your information can go to [email protected].

Last Modified: 1 October 2026 (draft sections pending legal review)

LOKAL Privacy Policy