- What is personal information? In general terms, legislation defines ‘personal information’ as information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information is true or not and whether the information or opinion is recorded in a material form or not.
- Our obligations We comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, security, accessibility and disposal. The Privacy Act also includes a data breach notification regime, which requires Growland to address data breaches involving personal information held by Growland. We also comply with more specific privacy legislation in some circumstances, such as the Spam Act and the Do Not Call Register Act.
What we collect
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, contact details (such as address, telephone number and email address), date of birth, gender, employment details, details of the property that you are interested in or have agreed to purchase, what prompted you to inspect the project, how you heard about us, confirm whether you are an Australian resident, information relating to your financing arrangements
- are a supplier to us, we will collect your name and contact details, details about the goods or services you supply and payment details
- send us an enquiry, complete a registration of interest or provide us with feedback, we may collect your name, contact details, details of your enquiry or feedback and information about our response
- fill in a contact form at one of our sales offices, we will collect your name, age, address, contact details, details of the properties you are interested in (including price ranges), what prompted you to inspect the project, whether you are an owner occupier or investor and how your heard about us or the relevant property development
- ask us to send you information about our developments or other products and services, we will collect your name, address, contact details, details of the properties you are interested in and how you heard about us or the relevant property development
- apply for a job with us, we will collect the information you include in your job application, including your cover letter, resume, contact details and referee reports
- enter into any promotions, competitions or special offers, we will collect the information you provide when submitting your entry
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:
- the individual has consented; or
- we are required or authorised by or under law (including applicable privacy legislation) to do so.
- 2.4 What if you don’t provide us with your personal information? 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 register your interest or purchase a property at any Growland development.
- General The type of personal information that we collect about you depends on the type of dealings you have with us. For example, if you:
How we collect personal information
Methods of collection
We collect personal information in a number of ways, including:
- directly from you in person (for example, if you visit our sales office or development, or at events or at conferences)
- through our website (for example, by making an online enquiry)
- through our social media pages (for example, through Twitter, LinkedIn or our Facebook page)
- over the telephone
- through written correspondence (such as letters, faxes and emails)
- on hard copy forms (for example, competition entry forms and surveys)
- through surveillance cameras at our corporate premises and on some of our sales suites or development sites
- from third parties, including:
- your representatives, including your lawyers, financiers and other authorised agents
- the Land Titles Office
- relevant State and Territory Valuers General
- our sales agents
- other real estate agents
- the Australian Securities and Investment Commission
- mortgage brokers and/or financial service providers
- Unsolicited information 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.
- Methods of collection We collect personal information in a number of ways, including:
Why we collect personal information
The main purposes for which we collect, hold, use and disclose personal information are set out below:
- to verify your identity and conduct credit checks
- designing, engineering, constructing and delivering our developments
- to carry out our obligations arising from any contracts entered into between you and us and to provide you with the products, services and information that you request from us
- outlining our development products and services to prospective and existing purchasers
- obtaining finance for our developments
- providing you with information and the services that you have requested
- to communicate with you, including by email, mail or telephone
- processing transactions for the sale of land and/or houses and any applicable payments and for our billing and account purposes
- to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes
- promoting ourselves and our products and services, including through direct marketing, events and competitions
- performing research and statistical analysis, including for customer satisfaction and service improvement purposes
- protecting the security of our offices, staff, customers and the property held on our premises
- to assist you with enquiries, resolving complaints or to improve our customer service
- recruiting staff and contractors
- to update our records
- to enforce the terms of any agreement that you enter into relating to our products and services
- complying with legal and regulatory obligations including notifying you of matters that we may be required by law to notify you of
- which are required or authorised by or under law (including, without limitation, privacy legislation); and
- for which you have provided your consent.
You consent (until such time as you opt out, as described below) that we may use your personal information to let you know about us and our products and services (including promotions, special offers and events) and our third party products and services, 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 online advertising.
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:
- contacting us (details under heading 13 below)
- advising us if you receive a marketing call that you no longer wish to receive these calls
- using the unsubscribe facility that we include in our commercial electronic messages (such as emails and SMS’s)
Who we may share your personal information with
Growland may disclose your personal information, and you consent to Growland disclosing your personal information, to it’s related bodies corporate and associated entities (as those terms are defined in the Corporations Act 2001 (Cth)).
Growland may also disclose your personal information, and you consent to Growland disclosing your personal information, to the following third parties:
- responsible authorities, such as local councils and water authorities
- builders and their housing consultants
- the Land Titles Office
- relevant State and Territory Valuers General
- real estate agents
- Australian Securities and Investment Commission
- financiers and prospective financiers
- financial institutions for payment processing
- an individual’s agent or authorised representative
- referees whose details are provided to us by job applicants
- third parties who support our information technology or handle mailings on our behalf
- our contracted service providers (including payment processors). 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;
- law enforcement agencies, other governmental agencies or third parties if we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud or cyber-crime or to protect our website, our products or our technology assets or the rights, property or personal safety of any person)
- our professional advisers
Use of government related identifiers
We will not:
- use a government related identifier of an individual (such as a Medicare number or driver’s licence number) as our own identifier of individuals; or
- otherwise use or disclose such a government related identifier
Data quality and security
Growland is committed to keeping your personal information secure and confidential. All reasonable precautions will be taken to protect personal information from loss, misuse, unauthorised access or alteration. Paper documents are held in locked drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. Additionally, we also take reasonable steps to:
- make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
- protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and
- destroy or permanently de-identify personal information that is no longer needed for any purpose that is permitted by the APPs.
- General Growland is committed to keeping your personal information secure and confidential. All reasonable precautions will be taken to protect personal information from loss, misuse, unauthorised access or alteration. Paper documents are held in locked drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. Additionally, we also take reasonable steps to:
- How long we keep your information We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required. If you close an account you have with us or you decide not to go ahead with purchasing a property for which you have registered, we may still keep your information.
- Mail and email information If you wish to stop receiving any e-mails or other communications from Growland which may be sent to you in the future, or if you have submitted personal information through the website and would like to have that information deleted from our records, please unsubscribe through the link at the bottom of any email or notify us at www.oaic.gov.au or by calling the OAIC’s enquiry line at 1300 363 992.
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