(Including Credit Reporting Policy)
Golf Property Limited operates the website located at golfproperty.com (“the Website”).
For non-material changes we make that would not cause material detriment to a client, we will give clients and visitors who have registered a email address with us at least 7 days’ written notice via their email address provided to GPL before the modification is to take effect, but clients may not terminate as a result of this modification during this period. Media contacts will be advised via the Media Centre,
RESPECTING INFORMATION PRIVACY
We recognise the importance of protecting personal information. We do not collect sensitive information as defined under the Privacy Act 1988 (Cth) (“Privacy Act”), such as racial or ethnicity information, political opinions or associations, criminal records or health information.
In collecting and handling personal information, we are bound by the Privacy Act, including the Australian Privacy Principles (“APPs”), and applicable privacy regulations.
THE PERSONAL INFORMATION WE COLLECT ABOUT YOU
We may collect personal information about you including, but not limited to your name, address, phone number, email, gender, occupation, personal interests and any other information provided. For some services and products, we may also collect your personal information to enable verification of your identity, including information from your driver’s licence, passport, and health care and concession cards. If you access any of our services through a social network site such as Facebook, we will collect limited information provided to us by that social network site, such as user name, site ID and email address and IP address.
If you are a shareholder of GPL we may collect information about your shareholdings, banking details and tax file numbers for payment of dividends and other amounts. If you subscribe to any alert services on the Website, we may collect your name and email address.
If you submit personal information to us in relation to an employment opportunity, we may also collect information about your employment and academic history.
We may also collect non-personal information about you including, but not limited to, data relating to your activities on the Website (including IP addresses) via tracking technologies such as cookies, web beacons and measurement software or data relating to survey responses.
You acknowledge that the personal information you provide us and which we collect from you, is your own information or information which you have been authorised to provide to us.
HOW WE COLLECT YOUR PERSONAL INFORMATION
We may collect personal information about you from a variety of sources including, but not limited to:
(a) registering to use the Website or parts of it through an account;
(b) logging in to use our Website via your social networking site (“SNS”) account;
(c) visiting our Website
(d) subscribing to receive alerts/e-brochures, eBooks and filling in forms, applications, surveys or research, participating in promotions and competitions on the Website or websites of our service providers;
(e) contacting us or our service providers for any reason including, but not limited to, reporting a problem with the Website, requesting further services or seeking our assistance;
(f) posting or contributing material on our Website;
(g) using our services and any credit provided by us in connection with those services (see our Credit Reporting Policy below for more detail);
(h) applying for an employment opportunity with us directly, via an SNS site (eg. LinkedIn) or through your nominated referees; AND
(i) if you are a shareholder of GPL, from third parties (including, for example, collection of information from its share or share plan registrar); and if you subscribe to receive email alerts, ASX announcements, media releases and other news relating to GPL through the Website.
We may also collect your personal information through our related bodies corporate, our service providers and third parties so that we may provide a better or more relevant service or product to you.
If you apply to us for credit, we may also obtain personal information about you from credit reporting bodies (see our Credit Reporting Policy below for more details), other credit providers, existing or previous suppliers of goods or services, your bank and certain other businesses for the purposes of assessing your application.
HOW WE USE YOUR PERSONAL INFORMATION
More specifically, we may use personal information which it has collected to:
(a) ensure that content from the Website is presented in the most effective manner for you and for your computer;
(b) provide a better or more relevant service or product to you, for instance by automatically populating forms on the Website when you make enquiries of selected properties;
(d) personalise and customise your services, experience, advertising and content that you view and engage with on the Website or the websites of our service providers and business partners
(e) respond to or provide you with service, products, information and assistance that you request from us;
(f) contact you to conduct surveys, research and feedback about our products, services or the Website;
(g) verify your identity when you register or log into our Website via your SNS account and remind you of your password and username;
(h) allow you to participate in interactive features of our service, when you choose to do so;
(i) help carry out our obligations arising from any contracts entered into between you and us;
(j) to assess your application for credit as a business in connection with our services;
(k) by disclosing the information to debt collection agencies to recover any amounts you owe us; and
(l) notify you about changes to our products and services.
If all or part of this information is not provided, we may not be able to provide these services.
If you are a shareholder of GPL we may also use your personal information to:
(a) communicate with, and comply with our legal obligations to our shareholders, and to process payments to them; and
(b) enable our service providers to provide us with services relating to the GPL share register.
If you submit personal information to us in relation to an employment opportunity with us, we may also use your personal information to:
(a) consider you for the position for which you have submitted your personal information to us or any other positions that are or become available in the future;
(b) respond to you in relation to any future application you make for an employment opportunity with us; and
(c) contact your referees in order to collect the information you have consented to us collecting about you in order to consider you for employment opportunities with us.
USING AND DISCLOSING YOUR PERSONAL INFORMATION FOR MARKETING PURPOSES
(a) use your personal information to provide you with information about offers, promotions, goods or services, which we believe may be of interest to you; and
(b) share your information with our service providers and other third parties so that they can provide you with products or services on our behalf or help us to provide you with the requested products or services including contacting you in relation to the products or services.
If we do contact you by using your personal information in accordance with either of the above, we will give you the opportunity to request that your information not be used for further direct marketing in the future.
We may also, if you request us to by opting-in through your online registration, share your information with third parties so they may contact you directly about their offers, promotions, goods or services.
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose personal information to our related bodies corporate, service providers or business partners.
We may also disclose your personal information:
(a) to real estate agents or agencies, property developers, builders, retirement community operators and landlords that have listings or advertising on our Website and which you have requested information from by submitting an enquiry;
(b) to our service providers, so that they can provide you with products or services on our behalf or products or services that you have requested directly from them, or to help us to provide you with our products or services (including if you are a shareholder, to share registrar and share plan management service providers). If you have subscribed to a service through the operating system on your mobile device (including, but not limited to Google’s “Google Now” service), we will disclose information such as your search history to Google. You can opt out of us providing such information to Google through the operating system on your mobile device;
(c) to third parties where you have requested information, services or products from them;
(d) if you have submitted an application to the property portal from which you accessed service and property information businesses;
(e) in conjunction with a sale or similar transfer of a property;
(f) if you apply to us for credit, to:
(i) credit reporting bodies (for the purpose of obtaining credit reporting information about you and other permitted purposes – see our Credit Reporting Policy below for more details); and
(ii) other credit providers, existing or previous suppliers of goods or services, your bank and certain other businesses for the purposes of assessing your application;
(g) relevant public, government or regulatory authorities, our legal representatives or other concerned parties, in special situations where we have reason to believe that disclosing your personal information is necessary to help identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users or anyone else who could be harmed by such activities; and
(h) where we are otherwise authorised or required by law to do so.
DISCLOSURE AND STORAGE OF PERSONAL INFORMATION OUTSIDE AUSTRALIA
Personal information submitted by our customers and visitors to our Website may be held on servers located in Australia or in the data centres of our outsourced data processors with data centres in Australia, the United States of America, Europe and Asia. We may transfer data outside of Australia to our service providers in order to obtain secure storage, back-up and data retrieval services and to provide services. We have implemented policies and procedures to safeguard the secure storage and processing of data with our related companies and have verified the security arrangements of our outsourced data processors. When you provide us with your personal information you give us your consent to store your personal information outside of Australia for the purposes described above.
Where we have obtained your consent to do so, we may also share your personal information with our service providers and other third parties located outside Australia so that they can provide you with any products or services requested by you, including contacting you in relation to the products or services. As these entities are located outside of Australia, they are not required to comply with the Privacy Act and you will not be able to seek any redress under the Privacy Act in connection with the use of your information.
We strive to ensure the security, integrity and privacy of personal information we collect. We have established safeguards and use reasonable security measures to protect your personal information from unauthorised access, modification and disclosure. Our employees, contractors, agents and service providers who provide services related to our information systems, are obliged to respect the confidentiality of any personal information held by us. We review and update our security measures in light of current technologies. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure.
CORRECTION AND ACCESS
We will endeavour to take all reasonable steps to keep accurate and up to date, any information which we hold about you. If, at any time, you discover that information held about you is incorrect or you would like to review and confirm the accuracy of your personal information, you can contact us.
You can also gain access to the personal information we hold about you, subject to certain exceptions provided for by law. To request access to your personal information, please contact us.
We are committed to providing its customers with a fair and responsible system for the handling of complaints.
If at any time you have any concerns, complaints or questions in relation to your privacy or the operation of [GPL], please contact our Privacy Officer with “Attention Privacy Officer” in the Subject line at [email protected] so that we may resolve your concerns.
Our Privacy Officer will consider your query and endeavour to respond to you promptly.
For more information about privacy issues in Australia and protecting your privacy, visit the Office of the Australian Information Commissioner’s website.
OPTING OUT OF PERSONALISED ADS
We aim to give you a highly relevant experience on our site and apps. This involves us collecting and using information about the content you engage with, such as images, articles, calculators and ads, along with any information you provide to us via your property.com account (if you have one). We then show you ads that we believe will be engaging. You can opt out of us personalising your advertising experience by going to the opt out page.
COOKIES AND WEB BEACONS
We may combine our cookies, information collected through the cookies and web beacons on the Website with other information (including information collected by third parties using their own cookies and web beacons and providing our cookies and information to third parties) and use analytics services to provide better or more relevant services and advertising to you on the Website and third party websites. Our service providers and other third parties may do the same in order to provide more relevant services and advertising to you through other websites that you may visit.
APPLICATIONS, WIDGETS OR LINKS TO OTHER WEBSITES
CREDIT REPORTING POLICY
Credit applications by businesses for our services
We may provide ‘commercial credit’ for the purposes of the Privacy Act to businesses (such as real estate agents, developers and business brokers) who apply for credit in relation to our services. We do not provide any consumer credit.
References to “you” and “your” in this credit reporting policy are references to individuals in relation to whom we hold credit information or credit eligibility information for the purposes of the Privacy Act in connection with such credit. This policy provides details about our management of such information.
How we collect and hold ‘credit information’ and ‘credit eligibility information’ about you
“Credit information” relates mainly to your credit-related dealings with us and comprises various types of information that can be collected by credit reporting bodies (“CRBs”) that report on consumer credit worthiness. We may collect or generate various categories of ‘credit information’ about you.
We may also collect “credit eligibility information” about you, which is mostly information provided by CRBs relating to your dealings with other credit providers (for example, financial institutions that provide you with loans or other businesses that provide you with credit in connection with their products or services).
“Credit information” and “credit eligibility information” may include:
(a) identification information: such as your name, address, date of birth or employer;
(b) consumer credit liability information: being information about consumer credit accounts you hold with other credit providers;
(c) details about information requests made to CRBs: such as the fact that we or another credit provider have requested credit reporting information about you from a CRB to assess a credit application and various details about the credit you have applied for;
(d) default information: being information about overdue payments owed by you in connection with consumer credit which have been disclosed to a CRB by other credit providers;
(e) payment information: being information that an overdue payment has been repaid;
(f) information about consumer credit-related serious credit infringements;
(g) new arrangement information: being information about certain credit-related arrangements you may have entered with another credit provider in connection with a consumer credit default or serious credit infringement;
(h) court proceedings information: being information about certain credit-related judgments;
(i) personal insolvency information: being information recorded in the National Personal Insolvency Index about bankruptcy or various other insolvency-related matters;
(j) publicly available information about activities relating to credit worthiness.
Credit eligibility also includes credit worthiness information that we may derive from data we receive from a CRB, such as a credit risk score.
We may collect credit information about you in any of the circumstances described above under the heading “How we collect your personal information” above. We collect credit eligibility information from CRBs but may collect it from other third parties where permitted by the Privacy Act (such as from other credit providers with your consent).
We store and safeguard your credit information and credit eligibility information in the manner described under the headings “Disclosure and storage of personal information outside Australia” and “Security” above.
How we use and when we disclose your credit information and credit eligibility information
We may disclose your credit information to CRBs. Those CRBs may then include that information in credit reporting information that they provide to other credit providers to assist them to assess your credit worthiness. For example, we may disclose to a CRB the type of commercial credit, and the amount of credit, sought in your application for credit with us. We may also use and disclose your credit information for other purposes and in other circumstances as described under the headings “”How we use your personal information”” and “”How we disclose your personal information”” above when permitted to do so by the Privacy Act.
Our use and disclosure of credit eligibility information is regulated by provisions of Part IIIA of the Privacy Act and the Credit Reporting Privacy Code. We will only use or disclose such information for purposes permitted by these provisions, such as:
(a) to process an application for credit with us in relation to our services;
(b) to manage the commercial credit we provide and collect overdue payments; or
(c) where a disclosure is required or authorised under an Australian law or a court/tribunal order.
In some cases, the people to whom we may disclose your credit information or credit eligibility information may be based outside Australia – see the heading “Disclosure and storage of personal information outside Australia” above for more details.
Correction of and access to credit information and credit eligibility information
To request correction of, or access to, your credit eligibility information please see the heading “Correction and access” above
Complaints regarding our compliance with credit reporting requirements
If at any time you would like to make a complaint about whether we have complied with Part IIIA of the Privacy Act or with the Credit Reporting Privacy Code please contact our Privacy Officer via placing “Attention Privacy Officer” at [email protected] so that we may resolve your concerns.
If you make such a complaint, we will write to you within 7 days acknowledging that we have received your complaint and setting out how we will deal with it. We will aim to investigate and resolve your complaint within 30 days. We may need to consult with a CRB or another credit provider to do so. If we need more than 30 days to resolve your complaint, we will advise you of the reasons for the delay and ask for your consent to extend this day period.
If you are not satisfied with our handling of your complaint, you can refer your complaint to our external dispute resolution service provider, Credit Ombudsman Service Limited (COSL). Please only do this once you have complained directly to us as described above.
COSL offers consumers an accessible, independent and fair dispute resolution service. You can contact COSL at 1800 555 727, online at cosl.com.au or write to them at Credit Ombudsman Service Ltd, PO Box A252, South Sydney, NSW 1235.