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(a) The products and services are provided, and the www.a-d.com.au website (site) is operated, by AD Group (Australia) Pty Ltd (ACN 601 035 125) (we, us or our).
(b) We are bound by the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act) and the General Data Protection Regulation (EU 2016/679) (GDPR), which applies across the European Union (collectively, Privacy Laws). Your privacy is very important to us and we will always act to protect your personal information. We take this responsibility seriously and are very careful about how and when your personal information is collected, processed, stored, altered, used, shared or destroyed.
2. WHAT PERSONAL INFORMATION DO WE COLLECT?
We collect and use personal information from customers, users, authorised contacts, account holders or visitors of our site, including information or opinions which are capable of identifying visitors (Personal Information). The type of Personal Information that we collect and use depends on the type of dealings that you have with us and includes:
(a) full name;
(b) date of birth;
(d) contact details, such as address, mobile and telephone number and email address;
(e) information about the products or services you have ordered or enquired about;
(f) information from enquiries or communications you have made with us (which may include occupation and salary details);
(g) the content of your enquiries or any communications between us;
(h) billing information (such as credit card and bank account details);
(i) method of payment;
(k) information about your interest in property, the property market, property values, property investment and the First Home Owner grant, including your intention to purchase, finance details and property requirements, such as the location, size and configuration, and price range; and
(l) any other Personal Information provided by you to us when making an enquiry or subscribing to our services and/or site.
3. COLLECTING YOUR PERSONAL INFORMATION
3.1 Collection from you
(a) We will collect Personal Information about you in a variety of ways, including:
(i) through your use, or orders of, of our products and services (and our records thereof);
(ii) when you visit our site or submit information through our site, contact us with a query or request information about products and services, complete any forms or agreements for our products or services, participate in surveys, competitions or promotional events;
(iii) from third parties (including our related bodies corporate, business partners and service providers, credit reporting bodies and government agencies); and
(iv) from publicly available sources of information, such as if you use our social media sites or applications, pages or plugins.
(b) We do not use or share Personal Information for any purpose other than for the purpose for which it was disclosed. We will only collect Personal Information that is necessary for one or more of our functions or for the purpose disclosed to you. The Personal Information collected by us will track your use, or enhance your use, of the foregoing and assist us in providing a better service.
3.2 Information about someone else
(a) If you provide to us Personal Information about someone else (as their authorised representative), we rely on you to inform them that you are providing their Personal Information to us and to advise them that we can be contacted for further information.
(c) Where requested to do so by us, you must also assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.
4. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (EU ONLY)
We rely on several legal bases under the GDPR to collect, process, store, use and disclose the Personal Information of individuals residing in the European Union (EU), including:
(a) where you have freely and expressly consented to the collection, use, processing and disclosure of your Personal Information for a specific purpose. The provision of Personal Information to us is voluntary. However, if you do not provide your Personal Information to us, we may not be able to provide you with access to, and use of, our products, services or site. You may withdraw your consent at any time by contacting us using the details below;
(b) where the collection, use, processing and disclosure of your Personal Information is necessary for the performance of a contract to which you are a party. For example, when collection and use is necessary to fulfil our obligations to provide you with access to, and use of, our products, services or site;
(c) for our legitimate business interests, including, but not limited to:
(i) providing, operating and improving our products, services or site;
(ii) marketing new promotions, deals, offers, competitions, products, services provided by us or our Authorised Affiliates that we consider may interest or benefit you;
(iii) managing, analysing, understanding and developing our relationship with you; and
(iv) responding to your queries or complaints; and
(d) where there is a legal obligation to collect, use, process or disclose your Personal Information. For example, we may be obliged to disclose your Personal Information by reason of any law, regulation or court order and/or to protect our interests and legal rights.
5. USE OF YOUR PERSONAL INFORMATION
(a) We use, process and disclose your Personal Information for the purposes for which the information is collected.
(b) We may also use your Personal Information to:
(i) provide or deliver our products, services and site to you (or those of our related entities, (as defined in the Corporations Act 2001 (Cth)));
(ii) administer, improve, develop and manage our products, services and site (including maintaining, testing and upgrading our site and systems);
(iii) inform you about our site, products, services, offers, competitions, promotions, questionnaires or surveys or other matters which we believe are of interest to you;
(iv) charge and bill you for the use of our products and services;
(v) customise the advertising and content on our site and to contact you about specials deals;
(vi) provide offers that are of interest or benefit to you;
(vii) share with Third Parties;
(viii) verify your identity;
(ix) conduct creditworthiness and fraud checks; and
(x) perform research and analysis.
6. Use by Third Parties
6.1 Disclosure to Third Parties
We may disclose your Personal Information to the following recipients:
(a) our employees, related entities (as defined in the Corporations Act 2001 (Cth)), business partners, third party contractors, suppliers and agents (Authorised Affiliates) from time to time for the purpose of delivering, providing and administering products, services or websites;
(b) third-party service providers who process or use your Personal Information or the purpose of performing functions on our behalf, but may not process or use such information for any other purpose. Examples of these third-party service providers include, but are not limited to, marketing and analysis organisations, financial and credit card institutions in order to process any payments, hosting companies, web developers, internet service providers, telecommunication providers, customer service providers, customer support specialists, fulfilment companies, external business advisors (such as auditors and lawyers), research and data analysis firms, debt collectors and insurers (Third Party Data Processers); and
(c) third-party advertising and commercial partners specified in section 9 below (Partners) for direct marketing purposes (see section 10 below),
(collectively, Third Parties).
6.2 Third Party disclosure to us
(a) Third Parties may provide us with Personal Information collected from you.
(b) If you disclose Personal Information to a Third Party, we rely on you to provide the Third Party with consent for us to collect, store, use, process or disclose your Personal Information.
7. Overseas Disclosure
(b) Where we do transfer your Personal Information to Overseas Recipients, we take steps reasonably necessary to ensure that:
(i) there is a legal basis for the transfer of your Personal Information; and
(ii) your Personal Information is treated securely (including, using reasonable endeavours to ensure that each Overseas Recipient receiving your Personal Information are bound by Standard Contractual Clauses approved by the European Commission, which can be found at http://ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.html ).
(c) By accessing or using our products, services or Site, or providing your Personal Information to us, you explicitly and freely consent to the transfer of your Personal Information to Overseas Recipients. If you subsequently decide that you do not wish to receive information from Overseas Recipients you may let us know by contact us using the details below.
8. STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
8.1 Protecting your Personal Information
(a) Your Personal Information may be stored in storage facilities (owned and operated either by ourselves or our services providers) in hard copy or electronic format. We will use our reasonable endeavours to store your Personal Information securely and to make our sites and storage facilities as secure as possible against unauthorised access.
(b) We will use our reasonable endeavours to protect and maintain the security of your Personal Information. Our officers, employees, agents and third party contractors are expected to observe the confidentiality of your Personal Information.
8.2 No guarantee
Despite our reasonable endeavours, we are unable to ensure or warrant the security of any Personal Information transmitted to us via the internet. Accordingly, all Personal Information disclosed by you to us is at your own risk and we are not liable for any unauthorised access to and disclosures of the Personal Information.
8.3 Destruction of Personal Information
We will take reasonable steps to destroy or de-identify Personal Information where it is no longer required for any purpose, unless we are required or authorised by a relevant Privacy Law or a court or tribunal to retain the information.
8.4 Suspected data security breach
(a) We have procedures in place to deal with any suspected data security breach.
(b) We will notify you and any applicable supervisory authority of a suspected data security breach where we are legally required to do so.
9. DISCLOSURE OF PERSONAL INFORMATION
9.1 Disclosure to Partners
We may disclose any information, including Personal Information, to any of our Partners, who may include:
(a) real estate agents, property developers, buyer advocates and agents, builders, property consortiums and owners corporations that have listings or advertising on our site and which you have requested information from, by submitting an enquiry or when you visit our site; or
(b) third party providers of goods or services to the real estate or property industry with whom we have commercial relationship, such as:
(i) ApartmentConcierge.com.au Pty Ltd (ACN 623 819 581) and Developments ID Pty Ltd (ACN 610 919 090), for the purpose of us or those third parties providing you with details of offers, goods or services that may be of interest to you;
(ii) a credit provider or financial institution, for the purpose of providing financial products or services that may be of interest to you; and
(iii) utilities providers, for the purpose of providing gas, electricity, telecommunications and internet products and services that may be of interest to you.
9.2 Disclosure to Law Enforcement
We may also disclosure your Personal Information to law enforcement bodies or regulatory authorities to assist with their functions, courts of law or as otherwise required or authorised by relevant Privacy Laws.
9.3 Merger and Acquisition
10. DIRECT MARKETING
10.1 Your Consent
(a) At the time of accessing, or using, our products, services, site or otherwise from time to time, we may seek your express consent for us or our Partners to send you marketing or promotional materials and other information.
(b) Where we have obtained your prior consent or are otherwise permitted under the GDPR, we may, from time to time:
(i) use your Personal Information to send you information about the promotions, deals, competitions, products or services we offer, and any other information that we consider may be relevant to you; and
(ii) disclose your Personal Information to a specified Partner for the purpose of that Partner contacting you for promotional or marketing purposes. For example, a specified Partner may send you information about special deals, products or services they offer and other information that may interest you.
10.2 Communication channels
(a) We or our Partners may send this information to you via the communication channels specified at the time you provide your consent.
(b) These communication channels may include mail, email, SMS telephone, social media or by customising online content and displaying advertising on our site.
(a) You can unsubscribe or opt-out from receiving marketing or promotional materials at any time by:
(i) emailing us at firstname.lastname@example.org; or
(ii) using the unsubscribe facility included in our commercial electronic messages (ie email or SMS).
(b) If you have subscribed to receiving marketing or promotional materials relating to Apartment Concierge, Development ID and/or House & Land Developments (being related entities), opting out of receiving AD Group (Australia) Pty Ltd related communications does not necessarily mean you have opted out of receiving communications relating to those websites (or their products or services). Please visit those website(s) (as applicable) to unsubscribe to those communications, or otherwise activate the appropriate unsubscribe function using the unsubscribe facility included in our commercial electronic messages (ie email or SMS).
(c) You may re-subscribe at any time by re-registering.
11. LINKS TO OTHER SITES FROM OUR SITE
(a) Although our site may contain hyperlinks or banner advertising to or from external websites, those websites are not subject to our privacy standards, policies and procedures. We recommend that you make your own enquires as to the Privacy Policies of these third parties.
(b) We are in no way responsible for the privacy practices of these third parties.
12. COOKIES AND IP ADDRESSES
(i) enable us to identify you as a return user; and
(ii) personalise and enhance your experience and your use of our site. Most browsers are initially set up to accept cookies.
(b) You can reset your browser to refuse all cookies or to warn you before accepting cookies. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie. If you reject our cookies, you may still use our site, but you may be limited in the use of some of the features and this may affect the functionality of our site.
13. YOUR RIGHTS IN RELATION TO PRIVACY
13.1 Privacy rights (EU only)
(a) Under the GDPR, you have a number of important rights. Subject to certain exceptions, you have the right to:
(i) fair and transparent processing of your Personal Information and processing in accordance with the GDPR;
(ii) require us to rectify or correct any Personal Information we hold about you that is inaccurate or incomplete;
(iii) require us to erase your Personal Information in certain situations;
(iv) obtain a copy of your Personal Information in a commonly used electronic format so that you can manage and move it, or request we send it to a third party;
(v) object or withdraw your consent at any time to the collection, use, processing or disclosure of your Personal Information (including for direct marketing purposes), but this does not:
(A) apply where we have other legal justifications to continue to collect, use, process or disclosure your Personal Information; or
(B) affect the lawfulness of any collection, use, processing or disclosure that occurred before you withdraw your consent;
(vi) object to decisions being made by automated means which produce legal effects concerning you or significantly affecting you; or
(vii) otherwise restrict our collection, use, processing or disclosure of your Personal Information in certain circumstances.
(b) You can exercise any of these rights by contacting us using the details below.
13.2 Access rights
(a) We will use our reasonable endeavours to keep your Personal Information that we collect accurate, up-to-date and complete.
(b) Subject to some exceptions provided by law, you have the right to access your Personal Information. If you wish to access or change Personal Information which we have collected about you, we require you to put your request in writing to us. Proof of identity may be required before such information will be provided.
(c) If we do not allow you access to any part of the Personal Information we hold about you, we will tell you why.
(d) We will not charge you for lodging a request to access your Personal Information, but we may charge you for our reasonable costs in supplying you with access to this information.
14. CHILDREN’S POLICY
(a) We do not knowingly seek or collect Personal Information from or about persons under the age of 16 years of age (Children) without the consent of a parent or guardian.
(b) If we become aware that any Personal Information relating to a Child has been provided without the consent of a parent or guardian, we will use reasonable endeavours to:
(i) delete the Personal Information from all relevant files as soon as possible; or
(ii) ensure, where deletion is not possible, the Information Personal Information is not used further for any purpose or disclosed further to any Third Parties.
(c) Any parent or guardian with queries regarding our collection, use, processing or disclosure of Personal Information relating to their Child should contact us using the details below.
17. HOW TO CONTACT US
If you would like further information about the Personal Information we hold about you, or to opt-out of receiving any promotional communications from us or our Partners, please contact us at email@example.com.
18. CONTACTING US AND RESOLVING YOUR PRIVACY ISSUES
(b) When making a privacy complaint please provide our Privacy Officer with full details of your complaint and any supporting documentation.
(c) Our Privacy Officer will endeavour to:
(i) provide an initial response to your query or complaint within 15 business days, and
(ii) investigate and attempt to resolve your query or complaint within 30 business days or such longer period as is necessary and notified to you by our Privacy Officer.
(d) If you are dissatisfied with the outcome of your complaint, you may refer the complaint to:
(i) the Australian Information Commissioner who may be contacted at https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint; or
(ii) the supervisory authority in the relevant EU member state.
Last updated on: 25/02/19