We are also required to comply with more specific privacy legislation in some circumstances, such as
The type of personal information that we collect about you depends on the type of dealings you have with us. For example, if you:
are a purchaser or prospective purchaser of a property – we will collect your name, age, address, contact details, details of the property that you are interested in or have agreed to purchase (such as the location and size of the property and the design and specifications of the apartment), what prompted you to inspect the project, how you heard about us, details of price points and apartment types you are interested in (eg one bedroom or two bedroom) and whether you are an owner-occupier or investor. If you are purchasing from us, we will also collect a copy of your passport or driver's licence (to verify your identity), confirm whether you are an Australian resident and record the terms of your contract (including price), payment details, information
relating to your financing arrangements (such as your bank details and how much money you are borrowing) and contact details for your authorised representatives (such as your lawyer)
Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection, such as health information. We only collect sensitive information where it is reasonably necessary for our functions or activities and either:
For example, if you purchase a property from us, we will collect information about your residency status, which may indicate your racial or ethnic origin.
When you visit our website, some of the information that is collected about your visit is not personal information, as it does not reveal your identity.
For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.
We use and disclose this information in anonymous, aggregated form only, for purposes including statistical analysis and to assist us to improve the functionality and usability of our website. You are not individually identified, however we reserve the right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.
A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users, although they do identify the user's internet browser.
We only use non-persistent cookies. That is, they are held on your browser's memory only for the duration of your session.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website.
We will provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to an individual’s actual name
For example, you can access our website and make general phone queries without having to identify yourself.
In some cases however, if you don't provide us with your personal information when requested, we may not be able to provide you with the product or service that you are seeking. For example, you must identify yourself to a member of our accounts team in order to check on the status of a payment made to or by us.
We may collect personal information in a number of ways, including:
- the Land Titles Office
- relevant State and Territory Valuers General
- real estate agents
- Australian Securities and Investment Commission
- mortgage brokers and/or financial service providers
Where we collect personal information about you, we will take reasonable steps to provide you with certain details about that collection (such as the purpose for which we are collecting the information and the type of third parties to which it is usually disclosed). We will generally include this information in a collection notice.
Unsolicited personal information is personal information we receive that we have taken no active steps to collect (such as an employment application sent to us by an individual on their own initiative, rather than in response to a job advertisement).
We may keep records of unsolicited personal information if the Privacy Act permits it (for example, if the information is reasonably necessary for one or more of our functions or activities). If not, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.
The main purposes for which we collect, hold, use and disclose personal information are set out below:
We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or:
We may use or disclose your personal information to let you know about us and our products and services (including promotions, special offers and events), either where we have your express or implied consent, or where we are otherwise permitted by law to do so. We may contact you for these purposes in a variety of ways, including by mail, email, SMS, telephone and facsimile.
Where you have consented to receiving marketing communications from us, your consent will remain current until you advise us otherwise. However, you can opt out at any time, by:
We may share personal information with third parties where appropriate for the purposes set out under heading 4, including:
- suppliers of building materials and fittings;
- delivery and shipping providers
- information technology and data storage providers
- venues and event organisers
- marketing and communications agencies
- research and statistical analysis providers
- call centres
- mail houses
- external business advisers (such as consultants, recruitment advisors, accountants, auditors and lawyers)
In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services.
We hold personal information in a number of ways, including in electronic databases, email contact lists, and in paper documents held in drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. We take reasonable steps to:
You can help us keep your information up to date, by letting us know about any changes to your details, such as your address, email address or phone number.
The steps we take to secure the personal information we hold include website protection measures (such as firewalls and anti-virus software), security restrictions on access to our computer systems (such as login and password protection), controlled access to our corporate premises, policies on document storage and security, personnel security (including restricting access to personal information on our systems to staff who need that access to carry out their duties, staff training and workplace policies.
We process payments using EFTPOS and online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.
While we endeavour to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone or post (details under heading 11 below).
Please contact our Privacy Officer (details under heading 11 below) if you would like to access or correct the personal information that we hold about you. We may require you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.
We will generally provide you with access to your personal information, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (eg by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask us to correct personal information that we hold about you, we will take reasonable steps to correct that information
Except in the case of more complicated requests, we will endeavour to respond to access and correction requests within 30 days.
If we do not agree to your access or correction request, or if we do not agree to give you access in the manner you requested, we will provide you with a written notice setting out:
In addition, if we refuse to correct personal information in the manner you have requested, you may ask us to associate your request with the information and we will take reasonable steps to do so.
If you have a complaint about how we have collected or handled your personal information, please contact our Privacy Officer (details under heading 11 below).
We will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week. If we are not able to do so, we will ask you to submit your complaint in writing.
In most cases, we expect to investigate written complaints and provide a response within 30 days of receipt. If the matter is more complex and our investigation may take longer, we will contact you and tell you when we expect to provide our response.
If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner (see here for further information).
Please contact us if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details are set out below.
Mail: Suite 501, Level 2 UL40/1341 Dandenong Road, Chadstone
Telephone: +61 450 308 198
Further general information about privacy is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au or by calling the OAIC's enquiry line at 1300 363 992.