Privacy policy

‘Personal Information’ is any information or an opinion about you that identifies you or that could reasonably identify you. This could include information such as your name, contact detail, date of birth or employment details.

‘Sensitive Information’ is any information or opinion about you which is health information or which relates to your racial or ethnic origin, political opinion, religious beliefs, sexual orientation or criminal record. The APPs place more stringent obligations on us when we handle your sensitive information. We do not anticipate collecting any Sensitive Information.

The Personal Information that you disclose to us or which we obtain from third parties enables us to provide real property evaluation services to you. We will only collect and retain information that is reasonably necessary for the performance of our activities and functions so that we are able to provide you with the services you require or which we recommend to you.

The kinds of Personal Information we collect and hold depends on the specific services provided to you, but will generally include basic personal contact information, as well as other information that is deemed relevant, including the address/es of real property which you own.

If you do not provide us with the required information, we may not be able to perform the services which you require us to provide.

During the course of providing our services to you, we will collect Personal Information from you by requiring you to complete forms or documents necessary to enable us to provide you with our services.

We will take reasonable steps to store information in a secure manner, protected by a combination of physical and technical measures. We store all Personal Information electronically, in a secure cloud-based facility.

We will take all reasonable steps to protect the security of your Personal Information held by us. This includes appropriate technology to protect your Personal Information stored electronically, such as passwords, as well as limiting the number of personnel who have access to your Personal Information, whether stored electronically or in hard copy.

To limit the possibility of human error, we will regularly provide training to our staff regarding the collection, storage and handling of your Information.

When we no longer require your Personal Information, it will be destroyed or permanently de-identified. However, we will retain information for as long as the law requires.

A data breach is when Personal Information held by us is lost or subjected to unauthorised access, modification, disclosure, or other misuse or interference. Examples of a data breach are when a device containing personal information of clients is lost or stolen, an entity’s database containing personal information is hacked or an entity mistakenly provides personal information to the wrong person. A ‘data breach’ may also constitute a breach of the Privacy Act, however this will depend on whether the circumstances giving rise to the data breach also constitute a breach of one or more of the APPs.

We have a data breach response plan. Our actions in the first 24 hours after discovering a data breach are crucial to the success of our response. A quick response can substantially decrease the impact on the affected individuals.

However, despite our reasonable efforts, we cannot guarantee that the security of your Personal Information will not be breached. Therefore, to the fullest extent permitted by law, we disclaim all liability and responsibility for any damage you may suffer due to a data breach, except to the extent that our liability cannot be excluded by applicable laws and regulations which we are subject to.

We may ask you for Personal Information about other individuals, for example, joint owners of the property. If you provide us with this information, we rely on you to tell those individuals that you are giving their Personal Information and to us, and to make them aware of this Policy.

We may use your Personal Information for the following purposes:

• To confirm your identity;
• To provide you real property evaluation services;
• To contact you directly about your services;
• To share it with our subscriber agents, related entities, subsidiaries or other specialist providers as required to perform functions on our behalf;
• For other purposes communicated to you when your information is collected;
• For direct marketing;
• For disclosures required by law, regulation or court order; and
• To conduct internal client research and assessment.

This includes us using this information to communicate with you about our services, for internal administration, direct marketing and planning purposes. We will also use your Personal Information for purposes related to those described above which would be reasonably expected by you. You may request not to receive direct marketing communication from us.

We will not use your Personal Information for purposes other than those described above, unless we have your consent, or there are specified law enforcement or public health and safety reasons (as permitted under the Act).

We may outsource business functions to other organisations and as such, it is possible that your Personal Information will, as required from time to time, be disclosed or transferred to other organisations to allow them to assist us to provide you with services.

It is likely that we will disclose your Personal Information to overseas recipients, including (but not limited to) our third party service providers located in the Philippines and by using our services, you consent to this transfer and confirm that you understand that we will not be bound by Australian Privacy Principle 8.1. If we transfer your Personal Information outside Australia, we may endeavour to comply with the requirements of the Act that relate to transborder data flows, but we cannot guarantee compliance and you specifically agree that you understand this. Therefore, to the fullest extent permitted by law, we disclaim all liability and responsibility for any damage you may suffer due to our non-compliance with APP 8.1, except to the extent that our liability cannot be excluded by applicable laws and regulations which we are subject to.

• Any overseas recipient may not be subject to any privacy obligations or to any principles similar to the APPs;
• You may not be able to seek redress in the overseas jurisdiction; and
• Any overseas recipient may be subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.

This Privacy Policy discloses our current privacy practices. From time to time and in line with client expectations and legislative changes, this Privacy Policy will be reviewed, and, if appropriate, updated at any time without notice. We will endeavour to provide you with notice of the changes as soon as reasonably practicable to do so.

You can access the Personal Information we hold about you.

We will take reasonable steps to ensure that any Personal Information that we collect, use, store or disclose, is relevant, accurate, complete and up-to-date. If you believe the information we hold is inaccurate, incorrect, or incomplete, you may request that your information be corrected and we can then take reasonable steps to correct this information.

Please contact our Privacy Officer (details below) to access or request updates to any Personal Information which we hold.

If you have a complaint about the way we have dealt with your Personal Information, or about this Policy itself, we invite you to provide written details of your complaint to our Privacy Officer (contact details below).

1. Review the way we dealt with your Personal Information;
2. Conduct an internal investigation (if necessary) into how your Personal Information came to be handled in the way that it was; and
3. Provide a report to you within one month of the date we acknowledged receipt of your complaint.

If you believe we have breached the APPs, you may also lodge a complaint with the Office of the Australian Information Commissioner.