We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and we comply with all of the Act’s requirements in respect of the collection, management and disclosure of your personal information.
What personal information do we collect and hold?
We may collect the following types of personal information, depending on your interaction with us:
We may collect some sensitive information about you such as any pre-existing medical conditions, but such information will only be collected where you choose to provide it to us through the website portals.
We are required, in certain circumstances such as where you wish to purchase a property, to collect your name, address, date of birth and other verification information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or the Foreign Acquisitions and Takeovers Act 1975 (Cth) to verify your identity and your residential status.
We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous or aggregated information using web tracking technologies about how users use our website.
How do we collect your personal information?
We collect your personal information generally directly from you unless it is unreasonable or impracticable to do so (for example, where you engage one of our agents). When collecting personal information from you, we may collect in ways including:
To the extent permitted by, law, we may also collect personal information from third parties including from third party companies such as credit reporting agencies, law enforcement agencies and other government entities. Otherwise we do not generally collect personal information from third parties, except that we may collect limited personal information about a person from users of our website portals (for example, where you are listed as an emergency contact of a residence in one of our properties).
Cookies and other tracking technologies
We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.
We and our advertising partners also use advertising cookies and other web-tracking technologies, such as pixel tags and web beacons to collect information about browsing habits, analyse trends, administer our websites, track users web movements, gather broad demographic information and
other marketing purposes. These are also used to make advertising more relevant to you and your interests.
What happens if we can’t collect your personal information?
If you do not provide us with the personal information described above, some or all of the following may happen:
You are never required to provide us with sensitive information to be able to use our website portals.
For what purposes do we collect, hold, use and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and to provide best possible quality of customer service
We utilise the services of third parties for marketing purposes, including online platforms and social media platforms, and we will disclose personal information about you to the third party service provider for our marketing purposes. While these third parties generally only use the personal information for our marketing purposes, some may retain certain personal information about you for their own purposes.
To whom may we disclose your information?
We may disclose your personal information to:
Our website portal may include functionality that permits you to post information (such as bulletin boards). Such information will be disclosed to other users of the website portal.
We may combine or share any information that we collect from you with information collected by any of our related bodies corporate or joint venture partners (within Australia).
Direct marketing materials
We (or our service providers and advertising partners) may send you direct marketing communications and information about our properties, opportunities and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, targeted advertisements, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications.
Please note that we also carry out digital advertising campaign from time to time that do not rely on your personal information. Your opt-out will not have effect on such advertising campaigns.
We do not use your sensitive information for the purposes of direct marketing.
How can you access and correct your personal information?
You may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your personal information.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.
What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.
We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Our Privacy Officer deals with privacy complaints and any complaints should be directed to our Privacy Officer using the contact details below. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.
After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.
If you are not satisfied with the way your privacy-related complaint is handled by us, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC). Details of how to lodge a complaint with the OAIC may be found at www.oaic.gov.au or by calling 1300 363 992.
Do we disclose your personal information to anyone outside Australia?
We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above. Our IT systems that hosts our data (which may include your personal information) may also reside outside Australia.
We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed.
Our security measures include:
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
Time & Place (Melbourne)
Post: Level 26, 35 Collins Street Melbourne, Victoria 3000 and PO Box 18023,
Melbourne VIC 3000
Tel: +61 (3) 9900 6212
Email: [email protected]