Ridgelea Privacy Policy

Index

1. Background

1.1 General

Parklea Pty Limited (ACN 005 736 256) and its related bodies corporate (together we, us, our) specialise in undertaking and managing property developments.
We are committed to protecting your privacy, in accordance with applicable Australian privacy laws.

This Policy is designed to give you a greater understanding of how we collect, use, disclose and otherwise handle personal information.

A copy of this Privacy Policy is available on each of our websites, including at www.parkleadevelopments.com.au. You can also request a copy by contacting our Privacy Officer (details under heading 11 below).

1.2 What is personal information?

Personal information means information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable.

1.3 Our obligations

We are required to comply with the Australian Privacy Principles (APPs) in the Privacy Act 1988 (Cth) (Privacy Act). The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, security, accessibility and disposal.

We are also required to comply with more specific privacy legislation in some circumstances, such as:

• applicable State and Territory health privacy legislation (including the Victorian Health Records Act ) when we collect and handle health information in the relevant jurisdiction; and
• the Spam Act and the Do Not Call Register Act.

1.4 Employee records

We are generally exempt from the Privacy Act when we collect and handle employee records and this Privacy Policy does not apply to that information. However, where State or Territory health privacy legislation applies, we are still required to protect the privacy of employee health information. This Privacy Policy will apply in those circumstances.

2. What we collect

2.1 General

The type of personal information that we collect about you depends on the type of dealings you have with us. For example, if you:

• are a purchaser or prospective purchaser of land or a house and land package – we will collect your name, address, contact details, details of the land or house and land package that you are interested in or have agreed to purchase (such as the location and size of the land and the design and specifications of the house), and, if you are purchasing from us, the terms of your contract (including price), payment details, information relating to your financing arrangements (such as your bank details and how much money you are borrowing) and contact details for your authorised representatives (such as your lawyer)
• are a residential or commercial tenant, we will collect your name, address, contact details and information relevant to the management of the tenancy
• are a supplier to us – we will collect your name and contact details, details about the goods or services you supply and payment details
• fill in a contact form at one of our display homes / villages – we will collect your name, age, address, contact details, details of the properties you are interested in (including price ranges), whether you are an investor or an owner/occupier, demographic information (such as the number of children you have), your country of origin and how your heard about us or the relevant property development
• ask us to send you information about our products and services – we will collect your name, address, contact details, details of the properties you are interested in and how you heard about us or the relevant property development
• join one of our residents groups – we may collect your name, address and contact details
• enter a competition run by us – we will collect your name, address, contact details and information relevant to the competition
• send us an enquiry or provide us with feedback – we will collect your name, contact details, details of your enquiry or feedback, details of the properties you are interested in (including price ranges) and information about our response
• apply for a job with us – we will collect the information you include in your job application, including your cover letter, resume, contact details and referee reports

2.2 Sensitive Information

Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection, such as health information, information about racial or ethnic origin and criminal record information.

We do not usually collect sensitive information. If we do, it will only be where that information is reasonably necessary for our functions or activities and either:

• the individual has consented; or
• we are required or authorised by or under law (including applicable privacy legislation) to do so.

2.3 Collection of information other than personal information through our website

When you visit our website, some of the information that is collected about your visit is not personal information, as it does not reveal your identity.

Site visit information

For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.

We use and disclose this information in anonymous, aggregated form only, for purposes including statistical analysis and to assist us to improve the functionality and usability of our website. You are not individually identified; however, we reserve the right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.

Cookies

A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users, although they do identify the user’s internet browser.

We use cookies to hold anonymous session information. This information is used to personalise your current visit to the website, for example to allow the website to remember who you are by keeping server variables linked to your session.

We only use non-persistent cookies. That is, they are held on your browser’s memory only for the duration of your session.

Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website.

Online Behavioural Advertising

We use advertising programs that place cookies on your computer to collect information about your browsing history (including on external websites). This information, which does not identify you personally, is collected in order to improve your online experience by customising the advertising you see to your interests (including the display of more relevant ads on external websites). You can opt out of these programs at any time.

2.4 What if you don’t provide us with your personal information?

We will provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to an individual’s actual name.

In some cases; however, if you don’t provide us with your personal information when requested, we may not be able to provide you with the product or service that you are seeking. For example, you must identify yourself to enter into a contract to purchase land or a house and land package or to apply for a job with us.

3. How we collect personal information

3.1 Methods of collection

We collect personal information in a number of ways, including:

• in person (for example, at a sales office at one of our display villages)
• through our website (for example, if you complete and submit a “contact us” form)
• over the telephone
• through written correspondence (such as letters, faxes and emails)
• on hard copy forms and contracts (for example, competition entry forms and contracts of sale)
• through surveillance cameras
• from third parties, including:
  • builders and their housing consultants
  • your representatives, such as your lawyers, builders, real estate agents and other authorised agents
  • finance companies and financial consultants
  • the Land Titles Office
  • relevant State and Territory Valuers General
  • the Australian Securities and Investment Commission
  • mortgage brokers and/or financial service providers
  • through publicly available sources of information, such as social media

3.2 Collection notices

Where we collect personal information about you, we will take reasonable steps to provide you with certain details about that collection (such as why we are collecting the information and who we may share it with). We will generally include this information in a collection notice.

Collection notices provide more specific information than this Privacy Policy. The terms of this Privacy Policy are subject to any specific provisions contained in collection notices and in the terms and conditions of particular offers, products and services. We encourage you to read those provisions carefully.

3.3 Unsolicited information

Unsolicited personal information is personal information we receive that we have taken no active steps to collect (such as an employment application sent to us by an individual on their own initiative, rather than in response to a job advertisement).

We may keep records of unsolicited personal information if the Privacy Act permits it (for example, if the information is reasonably necessary for one or more of our functions or activities). If not, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.

4. Why we collect personal information

The main purposes for which we collect, hold, use and disclose personal information are to:

• process transactions for the sale of land or house and land packages
• design, engineer, construct and deliver our developments
• obtain finance for our developments
• provide you with information that you have requested
• process any applicable payments
• promote ourselves and our products and services, including through direct marketing, events and competitions
• perform research and statistical analysis, including for customer satisfaction and service improvement purposes
• comply with our legal and regulatory obligations
• protect the security of our offices, staff, customers and property
• answer queries, provide customer support and resolve complaints
• recruit staff and contractors

We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or:

• which are required or authorised by or under law (including, without limitation, privacy legislation); or
• for which you have provided your consent.

4.1 Direct marketing

We may use or disclose your personal information to let you know about us, our products and services and the products and services of third parties (including promotions, special offers and events) either where we have your express or implied consent, or where we are otherwise permitted by law to do so. We may contact you for these purposes in a variety of ways, including by mail, email, SMS, telephone or online advertising.

Opting out

Where you have consented to receiving marketing communications from us, your consent will remain current until you advise us otherwise. However, you can opt out at any time, by:

• contacting us (details under heading 11 below)
• advising us if you receive a marketing call that you no longer wish to receive these calls
• using the unsubscribe facility that we include in our commercial electronic messages (such as emails and SMSes)

5. Who we may share your personal information with

We may share your personal information with third parties where appropriate for the purposes set out under heading 4, including:

• our related bodies corporate
• responsible authorities, such as local councils and water authorities
• land vendors
• the Land Titles Office
• relevant State and Territory Valuers General
• real estate agents
• the Australian Securities and Investment Commission
• financiers and prospective financiers
• financial institutions for payment processing
• mortgage brokers and financial planners
• owners corporation managers and managing / letting agents
• your representatives, such as your lawyers, builders, estate agents, and other authorised agents
• referees whose details are provided to us by job applicants
• our contracted service providers, including:
  • engineers, builders, sub-contractors ,architects and other consultants
  • suppliers of building materials and fittings
  • information technology and data storage providers
  • function and event organisers
  • marketing and communications agencies
  • research and statistical analysis providers
  • call centres
  • mail houses, delivery and shipping providers
  • external business advisers (such as consultants, recruitment advisors, accountants, auditors and lawyers)

In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services.

6. Cross border disclosure of personal information

We do not currently disclose personal information to third parties located overseas. If this changes at some time in the future, we will comply with the requirements of the Privacy Act that apply to cross border disclosures of personal information and this Privacy Policy will be amended accordingly.

7. Use of government related identifiers

We will not:

• use a government related identifier of an individual (such as a Medicare number or driver’s license number) as our own identifier of individuals; or
• otherwise use or disclose such a government related identifier, unless this is permitted by the Privacy Act (for example, use of an identifier to verify an individual’s identity or uses or disclosures required or authorised by or under an Australian law).

8. Data quality and security

8.1 General

We hold personal information in a number of ways, including in hard copy documents, electronic databases, email contact lists, and in paper documents held in drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. We take reasonable steps to:

• make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
• protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and
• destroy or permanently de-identify personal information that is no longer needed for any purpose permitted by the APPs.

You can help us keep your information up to date, by letting us know about any changes to your details, such as your address, email address or phone number.

8.2 Security

The steps we take to secure the personal information we hold include website protection measures (such as firewalls and anti-virus software), security restrictions on access to our computer systems (such as login and password protection), controlled access to our corporate premises, policies on document storage and security, personnel security (including restricting access to personal information on our systems to staff who need that access to carry out their duties ), staff training and workplace policies .

Online credit card payment security

We process payments using EFTPOS and online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.

Website security

While we endeavour to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online, and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone or post (details under heading 11 below).

Third party websites

Links to third party websites that are not operated or controlled by us are provided for your convenience. We are not responsible for the privacy or security practices of those websites, which are not covered by this Privacy Policy. Third party websites should have their own privacy and security policies, which we encourage you to read before supplying any personal information to them.

9. Access and Correction

Please contact our Privacy Officer (details under heading 11 below) if you would like to access or correct the personal information that we hold about you. We may require you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.

10. Complaints

If you have a complaint about how we have collected or handled your personal information, please contact our Privacy Officer (details under heading 11 below).

Our Privacy Officer will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week. If your complaint can’t be resolved at the first instance, we will ask you to submit your complaint in writing.

Complaints process

We will endeavour to acknowledge receipt of your written complaint within 5 business days of receiving it and to complete our investigation into your complaint in a timely manner. This may include, for example, gathering the relevant facts, locating and reviewing relevant documents and speaking to relevant individuals.

In most cases, we expect that complaints will be investigated, and a response provided within 30 days of receipt of your written complaint. If the matter is more complex and our investigation may take longer, we will write and let you know, and tell you when we expect to provide our response.

Our response will set out:

• whether in the Privacy Officer’s view there has been a breach of this Privacy Policy or any applicable privacy legislation; and
• what action, if any, we will take to rectify the situation.

If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner or, in some instances, other regulatory bodies, such as the Victorian Health Services Commissioner or the Australian Communications and Media Authority.

11. Our contact details

Please contact us if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details are set out below.

• Mail: Parklea Privacy Officer, PO Box 388, Officer, Victoria, Australia, 3809
• Email: contactus@parklea.com
• Telephone: +61 3 5940 0050

Further general information about privacy is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au or by calling the OAIC’s enquiry line at 1300 363 992.

12. Changes to this Policy

We may amend this Privacy Policy from time to time. The current version will be posted on our website and a copy may be obtained by contacting our Privacy Officer (details above).