1.1 The Proper Group Pty Ltd ACN 636 885 857 (Proper) is committed to excellence in property management.
1.2 Proper is governed by the Australian Privacy Principles (APPs) under the Privacy Act 1988 Cth (the Privacy Act). The APPs set out the way organisations and government agencies can collect and use, disclose and provide access to personal and sensitive information.
(a) Personal information is information that identifies or could identify a person, whether it is true or not. It includes, for example, your name, age, gender, contact details, bank account details and medical records.
(b) Sensitive information as defined by the Privacy Act 1988 (as amended) is also personal information but relates to your opinions, views, racial or ethnic origin, political options or affiliations, religious beliefs, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices or criminal record or health, genetic, biometric information or biometric templates.
1.4 For further information please contact us at firstname.lastname@example.org.
2. WHAT WE DO
Examples of Proper’s current services where Proper might collect your personal or sensitive information include:
(a) Processing your request/s services;
(b) Considering your eligibility for our services;
(c) Administering your account with us, including the provision of services;
(d) Providing reports on your service activities as requested by you;
(e) Communicating with you and the people associated with your property assets regarding the management of your property and affairs;
(f) Delivering services to you via the post or email where our employees and/or a related service provider will need to know at a minimum your name and address in order to deliver the services and products; and
(g) Letting you know of developments, special offers, events or news from Proper, the industry or our partner organisations.
3. WHY WE COLLECT AND USE PERSONAL INFORMATION
3.1 At Proper we take your personal privacy seriously. Proper may collect personal information about you:
(a) because you have provided it directly to Proper, for instance contact details, date of birth, title gender and credit card numbers or bank account details;
(b) to provide a service that you have requested such as providing details to another association or service provider for service provision, billing, etc.;
(c) to provide you with the most appropriate services for your needs;
(e) because you work for us;
(f) for purposes directly related to any of the above and any of Proper’s services;
(g) to provide follow-up on information regarding Proper including responding to comments or questions or providing our services to you;
(h) to meet any requirements of government funding for programs including receiving, collecting and collating de-identified statistical information; and
(i) to monitor and evaluate existing services and plan for future services. if we are required to share your information with government or regulatory bodies (such as the Australian Tax Office and ASIC) as required or authorised by law.
3.2 We only use your personal and sensitive information for purposes which are directly related to the reason we sourced your information in the first place and where you would reasonably expect us to use your information. This may include sharing your personal or sensitive information with our or other agents and service providers.
3.3 We may share your information with government or regulatory bodies (such as the ATO, Titles Office and ASIC) as required or authorised by law. These agencies may also share this information with organisations or agencies outside Australia.
4. HOW WE COLLECT INFORMATION
4.1 Whenever possible, we will collect personal information directly from you unless unreasonable or impractical for us to do so. Proper may also collect personal information in a variety of ways, including when you:
(a) use our website;
(b) phone us;
(c) write to us;
(d) email us;
(e) visit us in person or at events;
(f) provide feedback to us;
(g) through the use of our services;
(h) through interviews;
(i) forms and questionnaires; and
(j) other evaluations.
5. DISCLOSURE OF PERSONAL INFORMATION
5.1 Disclosure of personal information to third parties
We will not disclose your personal information to another person unless you have given consent or if one of the exceptions under the Privacy Act applies.
Where possible, the information that could reasonable identify you as an individual is first removed.
Except as set out above, Proper will not disclose your information to a third party unless one of the following applies:
(a) you have given your consent for Proper to do so;
(b) you would reasonably expect us to use or give that information for another purpose related to the purpose for which it was collected (or in the case of sensitive information – directly related to the purpose for which it was collected);
(c) it is otherwise required or authorised by law; or
(d) it will prevent or lessen a serious threat to somebody’s life, health or safety or to public health or safety; or
(e) it is reasonably necessary for us to take appropriate action in relation to suspected unlawful activity, or misconduct of a serious nature that relates to our functions or activities; or
(f) it is reasonably necessary for the enforcement of a law conducted by an enforcement body.
5.3 Example of disclosure
(a) Enforcing terms of contract
When we manage property, we must regulate and enforce terms of contract, including of leases and contracts for services, and this may necessitate credit checks, and sharing information with lawyers, other agents, and financiers.
(b) Online Payments for Services
In order to process payments, we may be required to disclose your name and credit card details to a third party merchant service provider.
6. DISCLOSURE OF INFORMATION OVERSEAS
6.1 It is possible, but not expected, that we may disclose personal information to overseas-based organisations or agencies in the provision and/or administration of our services. In any such cases, we will aim to protect your personal information by ensuring the country of the overseas based organisation or agency has similar protections in relation to privacy, or that we enter into contractual arrangements with the organisation or agency to impose protocols and restrictions on the storage and use of your personal information.
7. CAN I REMAIN ANONYMOUS?
7.1 Except when we access personal information from public sources (e.g. titles, ASIC and credit records), it is your choice to provide information to us. Wherever it is lawful and practicable, you have the option not to identify yourself or to use a fictional name when interacting with us. You can remain anonymous when using some parts of the Proper website, or sites administered by Proper.
7.2 It may be necessary for us to collect your personal or sensitive information if you would like certain materials or services. If you choose to withhold the information we require, we may not be able to provide you the services you have requested.
8. SECURITY AND STORAGE OF YOUR INFORMATION
8.1 Proper stores your information in a number of ways including physically (such as in paper form) or electronically with third party data storage providers. Your privacy and the security of your information is very important to us so where we store your information with third party providers, we will enter into contractual arrangements with those providers to ensure they take appropriate measures to protect your information.
8.2 We take appropriate steps to protect your personal and sensitive information held by us from misuse, interference, unauthorised access, modification, loss or disclosure. This includes during storage, collection, processing and transfer and destruction of the information. These steps include but are not limited to:
(a) ensuring our computer systems and websites have security systems in place such as up to date firewall and data encryption;
(b) maintaining security systems and monitoring of our premises;
(c) implementing confidentiality agreements with our employees and contractors, sub-contractors and service providers;
(e) maintaining document storage security policies and procedures; and
(f) implementing verification procedures for all inquiries/transactions to ensure only authorised people can access personal information.
8.3 Proper’s website may contain links to external websites. We recommend that you review the privacy policies of those external websites as we are not responsible for their privacy practices.
9. HOW TO ACCESS AND CORRECT YOUR INFORMATION
9.1 We will take reasonable steps to ensure that all personal information we collect, use or disclose is accurate, up-to-date, complete, relevant, and not misleading.
9.2 We will correct any personal information that we believe to be incorrect, out-of-date, incomplete, irrelevant or misleading. This may include taking reasonable steps to notify any organisation or government agency to which information was disclosed about the correction. You may request to access or correct your personal information at any time by contacting the Privacy Officer using the contact details below. We will give you access to your information unless one of the exceptions under the Privacy Act applies. For example, if providing access would be unlawful or denying access is authorised by law.
9.3 If you request to access or correct your information, we will respond within a reasonable time (usually within 30 days). If your request is refused, we will give you a written notice that sets out the reasons for refusal and how to complain about the decision.
10. DIRECT COMMUNICATIONS AND PROMOTIONAL MATERIALS
10.1 From time to time, we may send out promotional materials and informational materials from other government departments and third parties for Proper’s purposes.
10.2 If you do not wish to receive these communications, please contact Proper to unsubscribe from that mailing list.
10.3 Your information may also be used by us to provide you with details of other organisation’s services where permitted by the Privacy Act or where you have consented to the use or disclosure of your personal information for direct communications and promotional materials.
10.4 It is our policy that any direct communications or promotional material will include a statement advising that you can request to not receive further material from us by contacting us using the details provided. Please note that if you choose this option this will also prevent you receiving offers of discounts and notices of upcoming sales as well as all promotional and informational materials.
11.1 The Proper website and sites administered by Proper uses software known as ‘cookies’ to record your visit to the website and collect some statistical information. We use this information to help administer and improve our websites. We do not use this information to personally identify you. Information we may collect includes:
(a) your server address;
(b) your domain name;
(c) the date and time or access to the website;
(d) pages accessed and documents downloaded;
(e) the previous site visited;
(f) if you have visited the website before; and
(g) the type of browser software in use.
11.2 You may set your browser to disable cookies when visiting our websites. However, some website functions may be unavailable if you choose to do so.
12. COMPLAINTS AND ENQUIRIES
13. CONTACT PROPER
13.1 By Email email@example.com
13.2 By Post Attn: Privacy Officer
Proper Group Pty Ltd
1 Breakfast Creek Rd
NEWSTEAD QLD 4006