When collecting, using and handling personal information, Street Ninety Nine is required to comply with the Privacy Act 1988 (Cth) (Act) and is bound by the Australian Privacy Principles set out in that Act.
In this policy, ‘personal information’ means information or an opinion about an identified individual or an individual who is reasonably identifiable (whether the information is true or not or recorded in any form or not).
‘Personal information’ when used in this policy also includes sensitive information and health information. ‘Sensitive information’ is personal information about an individual’s health, racial or ethnic origin, political opinions or memberships, religious beliefs or affiliations, philosophical beliefs, professional or trade association/union memberships, sexual preferences and practices or criminal record. ‘Health information’ includes information about an individual’s physical or psychological health, health services provided to the individual or an individual’s expressed wishes about the future provision of health services.
This Policy applies to all your dealings with us, whether in person, or via telephone, email correspondence or our website.
Why we collect, hold, use and disclose your personal information
We collect personal information about you so that we can perform our business activities and functions and provide the best possible quality of customer service.
We collect, hold, use and disclose your personal information for the following purposes:
- to provide products and services to you and to send communications requested by you;
- to answer enquiries and provide information or advice about existing and new products or services;
- to provide you with access to protected areas of our website;
- to assess the performance of the website and to improve the operation of the website;
- to conduct business processing functions including providing personal information to contractors, service providers or other third parties;
- for the administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes of Street Ninety Nine, contractors or service providers;
- to provide your updated personal information to contractors or service providers;
- to update our records and keep your contact details up to date;
- to process and respond to any complaint made by you; and
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in cooperation with any governmental authority of any country (or political subdivision of a country).
The personal information we collect
The types of personal information Street Ninety Nine collects depends on the type of service sought or provided. To provide any of our real estate services, whether to a tenant or owner, we at least need to collect names and contact information. The types of personal information we generally collect include but are not limited to:
- Date of birth
- Residential address
- Postal address
- Email address
- Home telephone number
- Work telephone number
- Mobile telephone number
- Your occupation and business address
- Financial information including details of your employer, income, name of bank or financial institution
- Details of your spouse, de facto, dependent children, and roommates
- Details of properties owned by you
We will only collect sensitive information in circumstances where:
- It is reasonably necessary for one or more of the services we provide or functions we carry out; and
- You consent to the collection of the information; or
- We are required or authorised by law to collect the sensitive information.
Where it is practicable to do so, we will allow individuals to deal with us anonymously or using a pseudonym. However, this will ordinarily only be possible in the case of very general or preliminary enquiries.
How we collect personal information
- We aim to collect personal information directly from you.
- We also collect personal information:
- from your representatives (e.g. solicitor, accountant or financial adviser);
- through our Website and by other electronic communication channels;
- when sent to us by email or other communication from third parties;
- from publicly available sources of information including social media;
- when we are required to do so by law;
- from Strata or Bodies Corporate, Strata or Body Corporate Managers and On-Site Managers;
- when you enter into a competition or promotion with us or participate in a survey; and
- from our own records;
- from our employees;
- from our suppliers or partners; and
- from private vendors.
- If you supply personal information to us about another person, you represent and we accept it on the basis that you are authorised to do so and that the relevant person has consented to the disclosure to us.
A Cookie is a piece of information that our web server may send to your machine when you visit our Website. The Cookie is stored on your machine, but does not identify you or give us any information about your computer. A Cookie helps us to recognise you when you revisit the Website and to coordinate your access to different pages on the Website. With most Internet Browsers, you can erase Cookies from your computer hard drive, block all Cookies, or receive a warning before a Cookie is stored. If you want to do this, refer to your Browser instructions or help screen. Any information we seek to collect via cookies etc is used to better understand our customer needs and the services they are seeking from us. Cookies assist us in providing better and faster services.
Links on our Website may take you outside our network. These links are provided in good faith, however, we are not responsible for third party sites and accept no responsibility for the content, accuracy, security or function of third party sites.
Who we disclose your information to
We may disclose your personal information to:
- our employees, contractors 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;
- suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and
- any organisation for any authorised purpose with your express consent.
Street Ninety Nine may disclose personal information to other persons or organisations if required to do so by order of a court or tribunal or if the disclosure is otherwise authorised or required by law. For example, disclosure may be authorised or required where it is necessary to:
- eliminate or minimise a risk to public health or safety
- investigate or deal with unlawful activity or serious misconduct;
- locate missing persons; or
- establish or defend a legal claim.
Apart from the circumstances outlined above, your information will only be seen or used by persons working in or for Street Ninety Nine.
Direct marketing materials
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) 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.
However, if the law requires us to provide you with information about our products or services, we will provide that information to you even if you have elected not to receive information about those products or services generally.
How we hold and manage personal information we collect
Street Ninety Nine holds personal information in hard copy files and in electronic databases. Our information systems and files are protected from misuse, interference and loss and from unauthorised access, modification and disclosure by a range of security measures. Some of the ways we protect personal information include:
- securing premises both externally and internally;
- password protected electronic systems and technology products to prevent unauthorised computer access or damage to electronically stored information, such as requiring identifiers and passwords, firewalls and antivirus software;
- having internal policies which provide that staff and service providers have access to areas of our network only to the extent necessary for them to perform their role;
- determining levels of access to electronic systems at senior management level;
- maintaining physical security over hard-copy records; and
- providing Street Ninety Nine staff with training in relation to privacy obligations and requiring them to comply with this policy.
Street Ninety Nine relies on the personal information it holds in conducting its business. Therefore, we make every effort to ensure that the personal information we hold remains up-to-date and is used and disclosed appropriately. We provide tenants and owners with the opportunity to update personal details. We periodically review our databases to ensure that this information remains accurate, complete and up-to-date. To do this, we will ask you to inform us if there are any changes to your personal information.
If any of the information we are holding is inaccurate, incomplete or out-of-date, we will take reasonable steps to correct, complete or update it. Staff are required to delete or archive material that is no longer required for ongoing provision of products or services. Information that is not required for operational purposes is archived. Personal information that is not required by law to be retained will be deleted.
How you can access and correct your personal information
You may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you and, if so, the fees will be disclosed on our website. We will not charge for simply making the request and will not charge for making any corrections to your personal information.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.
How to make a complaint about a breach of privacy
If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it. We will deal with the complaint in accordance with our Complaints Handling Procedure.
We will treat your requests or complaints confidentially. We 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 a timely and appropriate manner.
You may contact us by mail, email or telephone as follows:
Address: 2/1 Achilles Drive, Springwood Qld 4127
Email: [email protected]
Phone: (07) 3053 9050
Office of the Australian Information Commissioner
More information about your rights and our obligations in connection with your personal information are available from the Office of the Australian Information Commissioner at www.oaic.gov.au.