We are bound by and adhere to the Privacy Act 1988 (Cth) and the Australian Privacy Principles under that Act (“Privacy Act”), as amended from time to time. This policy sets out how we collect, use and disclose your personal information.
What is ‘personal information’ and what type of personal information do we collect?
Personal Information as defined in the Privacy Act 1988 is information or an opinion about an identified individual, or an individual who is reasonably identifiable; whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form or not. This includes all the personal information we collect. The kinds of ‘personal information’ that we collect and/or will collect include:
Your full name, address, and contact details;
Governance issued identifiers such as a Passport, Driver’s Licence or Tax File Number;
Information that can identify you such as your date of birth;
Financial information about you such as your income; and
How we collect your personal information?
We may collect your personal information in several ways: from you directly when you deal with us including via our website or over the phone (e.g. where you speak to one of our representatives from our client services team), by email and/or by you completing a form via our website and when you apply for employment with us.
When you access our website (including a client portal), we may collect your personal information about you using ‘cookies’. Cookies are files that are implanted in your hard drive or device to collect, store and receive identifiers and information about your usage of our App and website as well as information about where you are located at the time you access our App or website (using GPS, Bluetooth or Wi-Fi signals, depending on the permissions that you have granted).
There are instances where we collect personal information about you other than directly from you. Examples include:
Publicly available information and databases (e.g. World-Check);
Australian Securities and Investments Commission (ASIC);
Information from your website;
State/Territory Land Registry Services;
Social media (e.g. Facebook, LinkedIn);
Employers, accountants and/or referees nominated by you; and
Credit information from credit reporting agencies (e.g. CreditorWatch, Equifax).
We also may collect Government Issued Identifiers to verify the identity of your directors and signatories.
How do we use your personal information?
Verify your identity;
Manage our relationship with you, including contacting you;
Assess your application to use our products and services;
Assess creditworthiness and credit rating;
Provide our products and services to you;
Prevent or detect money laundering and terrorism financing;
Assist you with support requests;
Manage internal operations we conduct such as record keeping, auditing and training our staff;
Gather statistics and prepare internal reports for regulatory, management and research purposes;
Collect payments from you;
Provide information to brokers and/or to conduct referrals;
Engage in legal proceedings and/or enforcing judgements and/or orders;
Comply with our legal and regulatory requirements; and
For any purpose to which you have given your express consent at the time of collecting your personal information.
We may also aggregate the personal information that we collect for reporting and statistical purposes and to help us improve our App or website. If we disclose any aggregated information to a third party, the information will be de-identified and will not contain any personally identifiable information.
How we use it to keep you updated about our services (Direct Marketing)?
From time-to-time we use your personal information to keep you updated on products and services you have expressed interest in or requested information about and providing you with market research and promotional materials such as reports, newsletters, event invitations and/or property information relating to our services, which we believe may be of interest to you (“direct marketing communications”).
If you decide that you no longer wish to receive direct marketing communications from us, you may use the opt-out facility in the marketing communication or contact us using the details noted under “Our contact details” below. We will stop using your personal information for direct marketing within 30 days of receiving your request to opt out.
Where and to whom do we disclose your personal information?
We may disclose your personal information to third parties for the purposes outlined above. Such third parties include:
Third party service providers, credit reporting agencies and/or representatives (e.g. brokers, contractors, law firms, banks, financial institutions, insurers, IT providers and referral service providers) who provide services to us or on our behalf including to conduct valuations, market research, assist in obtaining payments and providing advice;
Media/marketing organisations for the purposes of promoting us or our services;
Anyone authorised by you to deal with us on your behalf; and
Any person where authorised or required by law (including legislation, regulations, court orders, subpoenas and warrants).
Will your personal information be sent offshore?
We use a number of third party service providers and agents in relation to the collection, storage and use of personal data. These third parties may be located outside Australia. Your personal information may also be stored in cloud. If we disclose your personal information to our third party service providers or agents, we will direct those providers to only use the personal information for the purpose authorised by us and safeguard the personal information.
How do we keep your personal information secure?
We take reasonable steps to protect your personal information from misuse, interference, loss and from unauthorised access, alteration and disclosure as we are committed to ensuring that the information you provide to us is secure.
How can you access and correct your personal information that we hold?
We take reasonable steps to ensure that personal information held by us about you is accurate, complete and up to date. However, we require you to advise us of any changes to your personal information. You may request details of the personal information that we hold about you. We may charge a small administrative fee to cover the cost of retrieving this information if such a request is made. We will advise you in advance if a cost applies.
To request a copy of the information we hold about you, please contact us using the details provided below. If we refuse to provide you access to your personal information we will provide you with a written notice that outlines the reasons for the refusal.
When you click on a Third Party Website Link what will happen?
How can you contact us?
If you have any questions or complaints about this Policy or our treatment of your personal information or if you would like to access or correct your personal information or make a complaint, please contact our Privacy Team.
We will try to provide an initial response to your query or complaint within 48 hours; and resolve your query or complaint within 10 business days. We will notify you in writing if we require any additional information and also of the outcome of the matter.
If you are not happy with the outcome you can contact the Office of the Australian Information Commissioner (“OAIC") or call 1300 363 992.
This Policy was last updated 7 July 2020.