This document sets outs the way in which Coburg Group Holdings Pty Ltd ACN 607 124 354 and Future Estate Group Pty Ltd ACN 155 880 363 (each a Company) manage personal information.
The Company is committed to maintaining compliance with its privacy regulatory requirements. The Company has implemented practices and procedures to:
- maintain compliance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs); and
- deal with inquiries or complaints from individuals as to its compliance with the Privacy Act and the APPs in accordance with this document.
By using the Company’s website or services, you consent to the Company’s collection and use of information in accordance with this document.
If you do not agree to any part of this document, you must immediately cease using the Company’s website and services.
TYPE OF INFORMATION COLLECTED
The Company collects personal and sensitive information, including any information about you and an identified or reasonably identifiable individual, whether recorded in a material form or not, including:
- your name, age, gender, occupation and contact details;
- your payment information, collected directly or from third party providers;
- your company name and any identifiers (if applicable);
- the date and time you access the Company’s website;
- your geographic location, including IP address;
- your website or service history;
- operating system, browser version and capabilities;
- cookies and related browser data; and
- internet address of the website from which you linked directly to the Company’s website.
COLLECT OF YOUR PERSONAL INFORMATION
When possible, the Company will collect personal information directly from you when you provide your details to the Company or when it is provided to the Company with your permission.
Information is generally sought when you:
- register for, or update your, Company account;
- access or use the Company’s website or services;
- communicate with the Company;
- attend the Company’s property roadshows; and
- attend seminars organised by the Company.
If you access the Company’s website via a third party website or the third party’s social media channels, or provide consent for a third party to provide the Company with your personal information, you understand that the Company may use any information you have made available.
WHY YOUR PERSONAL INFORMATION IS COLLECTED
The reasons the Company collects your personal information include:
- providing, managing and administering the Company’s website and services;
- establishing and maintaining your relationship with the Company;
- providing safety and security benefits (where required by law) and maintaining or addressing issues with the Company’s website or services;
- responding to enquiries and addressing customer service satisfaction concerns as a means of improving or developing the Company’s website and services;
- telling you about the nature of the Company’s services;
- providing you with information and marketing materials;
- generating employment screening; and
- carrying out community engagement exercises.
In general, the personal information the Company collects and holds is information which assists the Company in conducting its business and marketing its business. If the Company collects your personal information for a specific purpose not outlined above, the Company will, at the time of collection, disclose the purpose of the collection.
HOW YOUR PERSONAL INFORMATION IS HELD
The Company will use reasonable steps to protect your personal information from loss, misuse, inference, unauthorised access, modification or disclosure. Please be aware that the Company cannot guarantee the protection of the personal information you provide over the internet.
The Company may retain personal information for a commercially reasonable time for backup, archival or audit purposes, or to maintain and improve the Company’s website and services. Where the Company no longer requires your personal information, the Company will take reasonable steps to destroy it.
DISCLOSURE OF PERSONAL INFORMATION
In order to provide its services, the Company may be required to share your personal information with:
- third parties engaged by the Company, including its management, staff, joint venture partners, contractors, property valuers, real estate agents and solicitors (third party service providers); and
- the Company’s ‘related bodies corporate’ and ‘related entities’ (each as defined in the Corporations Act 2001 (Cth)), including any special purpose entity established in direct or indirect association with the Company.
If personal information is shared with a third party service provider that will be solely for the purpose of providing the Company’s services, those third party service providers will be bound by this document.
The Company will not rent or sell your personal information to any third party. The Company may be required to share your personal information to comply with a legal requirement, such as to:
- conform to the law, comply with legal process served on the Company or its affiliates or investigate, prevent or take action regarding suspected or actual illegal activities;
- enforce the Company’s terms of service, take precautions against liability, investigate and defend the Company against any third-party claims or allegations, assist government enforcement agencies or protect the security or integrity of the Company’s website; and
- exercise or protect the rights, property or personal safety of the Company, its users and others.
If you request that personal information not be disclosed to a third party in connection with providing the Company’s services and the Company is obliged to do so, you acknowledge and agree that the Company’s obligations in providing its services may not be met.
LINKS TO OTHER WEBSITES
From time to time the Company’s website and applications may contain links to other websites. The Company is not responsible for those websites and their privacy policies.
WHEN PERSONAL INFORMATION WILL BE USED FOR MARKETING
From time to time the Company may use your personal information to give you information about products or services the Company believes you may be interested in.
The Company will only use such information for the purpose of marketing where:
- the Company has collected the personal information from you directly;
- you would reasonably expect the Company to use or disclose the information for the purpose of marketing; and
- there is a means through which you can request not to receive marketing communications and you have not requested that such communications cease.
If you do not wish to receive information about the Company’s other products or services or the products and services of the Company’s related bodies corporate and related entities, please inform the Company at firstname.lastname@example.org.
HOW CAN I ACCESS PERSONAL INFORMATION COLLECTED
You may request access to personal information held about you at any time. If you wish to access your personal information, please contact the Company at email@example.com. The Company will require you to verify your identity and to specify the information you require.
The Company may be prevented from permitting access to personal information about you in certain circumstances, including where:
- access would unreasonably impact on the privacy of another individual;
- access would lead to the disclosure of the Company’s commercially sensitive information or the commercially sensitive information of any of the Company’s agents or contractors;
- the Company is prohibited by law or a court / tribunal order; or
- the information relates to existing or anticipated legal proceedings.
If the Company denies access to your personal information, the Company will provide a written explanation of the reasons for such a refusal.
ACCURACY OF PERSONAL INFORMATION COLLECTED
The Company will take reasonable steps to maintain the accuracy of personal information held about you. If you believe that the personal information the Company holds about you is incorrect, out of date or incomplete, please inform the Company at firstname.lastname@example.org. The Company will require you to verify your identity and to specify the information you require the Company to correct.
The Company will take reasonable steps to correct information where the Company is satisfied that it is inaccurate, out of date, incomplete, irrelevant or misleading for the purpose for which it is held.
Your personal information may be transferred, stored and processed in a state, country or governmental jurisdiction outside Australia. Similarly, if you are located outside Australia, the Company may transfer your personal information to Australia and store and process it in Australia.
By dealing with the Company, you agree and consent to the transfer, storage and processing of your personal information inside and outside of Australia in accordance with the terms of this document. By providing this consent, you acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia. However, the rights and obligations contained in this document apply internationally to the collection and use by the Company and third party service providers of your personal information.
If you have feedback regarding the terms or operation of this document, or if you would like to access or correct your personal information, please contact the Company at:
Phone: +61 (0)3 9988 2900
Post: Ground Floor, 5 Queens Road, Melbourne, Victoria 3004, Australia
In this document:
- headings are for reference only and do not affect interpretation;
- the singular includes the plural and vice versa, a gender includes other genders and different grammatical forms of defined expressions have corresponding meanings;
- no provision or expression is to be construed against a party on the basis that the party (or its advisers) was responsible for its drafting;
- examples and use of the word including and similar expressions do not limit what else may be included; and
- unless the context requires otherwise, a reference in this document to:
- a document or agreement includes that document or agreement as novated, altered, amended, supplemented or replaced from time to time;
- any thing includes any part of it and a reference to a group of things or persons includes each thing or person in that group;
- a person, corporation, trust, partnership, unincorporated body or other entity includes any of them; and
- legislation or other law or a provision of them includes regulations and other instruments under them, and any consolidation, amendment, re-enactment or replacement.