1. Privacy Statement
2. Collection of Personal Information
2.1 Personal information is defined in the Privacy Act 1988 (Cth) and means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
2.2 Property Focus Group AU Pty Ltd only collects personal information for the purposes of providing services to you. The personal information we collect from you will include information you give us when you:
- 2.2.1 register or subscribe to our website and or newsletters;
- 2.2.2 complete a transaction with us; and
- 2.2.3 contact us.
2.3 The personal information that we collect on individuals may include, but is not limited to:
- 2.3.1 your name, your contact details including your email address, home address, billing address, telephone number, age, date of birth, anniversary dates, profession or occupation, and job title.
- 2.3.2 properties and or services you have viewed and purchased;
- 2.3.3 your payment details including credit card information and optional account information such as the username and password you created when using the Property Focus Group AU Pty Ltd website, online presence, and client access to any of our CRM (Customer Relationship Management) software portals.
- 2.3.4 we may also collect information that is not considered to be personal information as it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how you use our website.
3. How do we collect your personal information?
3.1 We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:
- 3.1.1 through your access and use of our website;
- 3.1.2 by telephone, letter, fax or email;
- 3.1.3 during conversations between you and our representatives;
- 3.1.4 by contracting with us;
- 3.1.5 by entering competitions, promotions or requesting information or material from us;
- 3.1.6 completing surveys, providing feedback or complaining to us.
3.2 We may also collect personal information from third parties including:
- 3.2.1 from third party companies such as credit reporting agencies, law enforcement agencies and government entities;
- 3.2.2 your representatives (lawyers, accountants and financial advisers);
- 3.2.3 your employer;
- 3.2.4 publicly available sources of information or any other organisations where you have given your consent.
3.4We will not collect personal information secretly or in an underhanded way and will not sell your personal information to any third party.
3.5We may collect personal information from individuals who are not customers of our business but whose personal information is given to us by those individuals via our website or in the course of a transaction.
3.6 Where reasonably practicable, we attempt to collect information directly from individuals. When we collect information, we will generally explain to the individual why we are collecting it, who we give it to and how we will use or disclose it or, alternatively, those matters will be obvious from the circumstances such examples are;
- 3.6.1 Responding to your requests (including but not limited to enquiries and or complaints);
- 3.6.2 Processing of payments and the prevention of fraud;
- 3.6.3 Setting up your account for the purpose of providing services to you;
- 3.6.4 Complying with any legal obligations required including but not limited to the calculation of taxation;
- 3.6.5 Improving our services by reviewing and keeping your comments and reviews (if you choose to leave them);
- 3.6.6 Sending you notifications of new property releases and or information relating to property and Real Estate services in Victoria and Australia (if you have chosen to subscribe to our emailing list).
3.7We will collect personal information from you by lawful and fair means and not in an unreasonably intrusive way.
3.8Property Focus Group AU Pty Ltd team members have access to this information to help provide services and support to you.
3.9Property Focus Group AU Pty Ltd are required by law to store information for the purposes of taxation and accounting for a minimum period of seven years, such information required to be stored for this purpose is your name, your address, billing address and other information relevant to the services you have received from us.
- 3.10.1your computer’s operating system;
- 3.10.2your computer’s browser type and capabilities;
- 3.10.3your computer’s Internet Protocol (IP) address and geo-location;
- 3.10.4web pages visited, including how you were referred to each web page; and
- 3.10.5web page usage statistics, including the time spent on each web page.
3.11 Cookies can be managed by accessing the individual settings in your browser.
3.12 We will not identify users or their browsing activities, except where required by law.
4. Using and Disclosing Your Personal Information
4.1 We will generally use or disclose your personal information only for the primary purpose for which it was collected; or for a related secondary purpose where you would reasonably expect us to use or disclose the personal information for that secondary purpose. We may otherwise use and disclose your personal information if you have given us consent for the use or disclosure or it is required or authorised by law.
4.2 Generally, we use and disclose your personal information for the purpose of providing you with the services that you have requested, or otherwise to enable us to carry out our business.
4.3 If those purposes for which we have collected the information involve providing personal information about an individual to any third party, we will take appropriate and reasonable steps to ensure any personal information is protected.
4.4 We will only use personal information for marketing if you have given express or implied consent (e.g. subscribed to our emailing list).
4.5 We may also provide your information to third parties that provide services to us, including third parties that provide our payment gateway and technology support services. This may include providing your information to third parties that are located outside of Australia. Where your personal information is transferred outside Australia (including the USA, UK, Hong Kong, the Philippines and the EU), we will do so in accordance with APP 8.
In addition, we may also disclose your information to third parties in order for them to provide services to you.
5. To whom may we disclose your information?
5.1 We may disclose your personal information to:
- 5.1.1 Our employees, related bodies corporate, contractors, franchisees, franchisees’ real estate agents and employees or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, utilities providers, and professional advisors such as accountants, solicitors, business advisors and consultants;
- 5.1.2 Suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and
- 5.1.3 Any organisation for any authorised purpose with your express consent.
5.2 We may combine or share any information that we collect from you with information collected by any of our related bodies corporate (within Australia).
6. Do we disclose your personal information to anyone outside Australia?
6.1 We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
6.2 We may disclose your personal information to entities located outside of Australia, including the following:
- 6.2.1 our related bodies corporate, located in foreign countries including the United States of America, New Zealand, Hong Kong, China, India, Indonesia, Singapore, South Korea, and Philippines.
- 6.2.2 our data hosting and other IT service providers, located in various countries; and
- 6.2.3 other third parties located in various foreign countries.
6.3 We may disclose your personal information to entities within Australia who may store or process your data overseas. In the event that a disclosure is made in an overseas country (which we consider unlikely), the information will not be protected by the Australian Privacy Principles. In any event, by providing your details, you consent to your information being disclosed in this manner.
7. Direct marketing materials
7.1 We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below in Section 11) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.
8. Security of Your Personal Information
8.1 We take steps to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure and against other misuse. When no longer required, personal information is destroyed in a secure manner or deleted.
8.2 As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
9. Links to external websites
9.1 Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
10. Access to Your Personal Information and Complaints Procedure
10.1 Under the Privacy Act 1988 (Cth), you have certain rights to access the personal information we collect and hold about you.
10.2Generally, we will allow an individual access to the personal information we hold about them within a reasonable time after it is requested. When requesting such access please identify the precise type/s of information requested. You may make a request by contacting us at [email protected]
10.3We take those steps reasonable in the circumstances to ensure that the personal information that we collect, use and disclose is accurate, up to date and complete. Where an individual requests to correct information, we will take reasonable steps to correct the information, having regard to the purpose for which it is held. You may lodge a request to correct personal information in the manner outlined in clause 10.2 above.
11. Contacting us
11.2We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
12.1 To make a complaint about a breach of the Australian Privacy Principles, which includes how we handle your personal information, you may write to us by email [email protected] We will endeavour to respond to your complaint within a reasonable time after it is received. If you are not satisfied by our response, you may acquire further information regarding privacy from the Office of the Australian Information Commissioner. We may charge you a fee to cover our administrative and other reasonable costs in providing the information.