Honeycombes Property Group Pty Ltd and its related bodies corporate (we, our, us), understand and respect your right to privacy and the protection of your personal information. We are bound by the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles (APPs) contained within this Act. This document sets out how we collect, use, disclose, retain and manage your personal information.
Scope and Responsibilities
This policy applies to our board members, managers, employees and volunteers and describes the type of information we collect, how the information is handled, how and to whom the information is disclosed and how the information may be accessed.
We will take steps to ensure that all those responsible are aware of and understand our obligations as well as their own obligations under the Act. We will achieve this through the provision of training and through maintaining and implementing internal procedures to prevent personal information from being collected, used, disclosed, retained, accessed or disposed of other than in accordance with this policy.
For the purpose of this policy, the following terms will have the following meanings:
Personal Information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not.
Sensitive Information means:
(a) Information or an opinion about an individual's:
1. radical or ethnic origin; or
2. political opinions; or
3. membership of a political association; or
4. religious beliefs or affiliations; or
5. philosophical beliefs; or
6. membership of a professional or trade association; or
7. membership of a trade union; or
8. sexual orientation or practices; or
9. criminal record;
That is also personal information; or
(b) Health information about an individual; or
(c) Genetic information about an individual that is not otherwise health information; or
(d) Biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or
(e) Biometric templates.
Types of personal and sensitive information collected and held
The types of personal information we collect and hold includes (but is not limited to):
Mailing or Street addresses
Bankruptcy and credit reporting information
Bank account information and credit card details
Insurance related information
Copies of photo identification (e.g. drivers licence & passport)
Other personal information you provide to us directly in relation to the products and services we are providing to you
We do not collect personal and sensitive information unless it is reasonably necessary for, or directly related to, one or more of the services we provide or functions we carry out. We will not collect any sensitive information unless we first obtain your consent to the collection of that information, or if we are required or authorised by law to collect the information.
How do we collect your personal information?
We will if it is reasonable or practicable to do so, collect your personal information directly from you. We may collect personal information in various ways, including:
through your access and use of our websites; or
by telephone, email, fax, SMS or letter; or
during conversations between you and us; or
by entering competitions, promotions or requesting information from us; or
by contracting with us; or
by completing surveys or providing feedback.
Sometimes we may collect personal information from a third party such as credit reporting agencies and government bodies or from representatives such as lawyers and accountants. If you provide personal information to us about someone else, you must ensure that you have their consent to disclose their information to us. You should also ensure that you take reasonable steps such that the individual concerned is aware of the various matters dealt with in this policy. We endeavour to contact and notify the individual of the circumstances of such collection where it is reasonable to do so.
If we receive personal information that we did not solicit, we will determine as soon as reasonably practicable whether we could have legitimately collected that information as part of our functions or activities. If we determine the unsolicited information could not have been legitimately collected by us, then provided it is lawful and reasonable to do so, we will destroy or de-identify that information as soon as practical.
During your website visit we may automatically collect certain aggregate information related to your website visit. Aggregate information is non-personally identifiable or anonymous information about you, including the date and time of your visit, your IP address, your computer browser information, the internet address that you visited prior to and after reaching the website, the name of the domain and host you used to access the internet, and the features of our website which you accessed. We may, from time to time, use the information we collect to improve the quality of our website, enhance or tailor the information we offer, and make your experience on our website as valuable and efficient as possible.
Links to other websites
You may choose to interact with us anonymously or under a pseudonym where lawful and practical. If you do not provide us with the personal information as described above, some or all of the following may happen:
• we may not be able to provide the requested products or services to you, either to the same standard or at all; or
• we may not be able to provide you with information about products and services that you may want; or
• we may be unable to tailor the content of our websites to your preferences, thus your experience of our websites may not be as enjoyable or useful.
Use and disclosure of personal information.
We collect personal information to enable us to provide our products and services. This includes (but is not limited to):
Processing of payments;
Processing of forms;
For the administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes of us and our related bodies corporate, sales associates or service providers;
Communicating with you (including direct marketing);
Facilitating potential buyers and investors in connecting with us (lead generation);
Facilitating the public display of property listings on various portals;
Complying with our legal obligations;
Providing financial advice and services;
Assisting with processing applications;
Assisting with recognition/acknowledgment;
Facilitating the application &/or registration for various documents, licences, names etc as required by law;
Maintaining and updating our records of your contact details;
Processing and responding to any complaints; and
To enable us to provide our products and services, we may disclose your personal information to third parties in certain circumstances including (but not limited to):
where disclosure is required or authorised by law;
when we use it for the purpose for which it was collected, e.g. as part of an application form for a business name;
to our related bodies corporate;
to suppliers and other third parties with whom we have commercial relationships, for business, marketing and related purposes;
in circumstances where you would reasonably expect information of that kind being passed to a third party;
if it is reasonably necessary for enforcement related activities conducted by, or on behalf of, an enforcement body (e.g. Police); and
if you expressly agree to any use or disclosure not covered above.
We may transfer your personal information to overseas countries including but not limited to India in order to perform one or more of our functions or activities. It may also be transferred between any of the countries in which our service providers operate.
The Act and corresponding APPs require us to ensure that, before disclosing personal information overseas, reasonable steps are taken to ensure that overseas recipients do not breach the Act or the APPs (APP 8.1). Whilst we take reasonable steps to ensure this, it is not always possible to ensure that overseas recipients will comply. We do not take any responsibility for the actions of overseas third party recipients of personal information.
Like many other businesses in Australia, we may rely on third party suppliers to provide specialised services such as web hosting, cloud computing technology and data storage services. These suppliers may store data on servers located outside Australia. It is not practicable to list every country in which such overseas recipients may be located. If personal information is provided to these suppliers in order for them to perform the agreed tasks, we will make every effort to ensure that these suppliers handle the personal information in accordance with the Act and the APPs.
We may sell, transfer, or otherwise disclose our database of personal information to an actual or potential successor entity, purchaser, or investor in connection with a corporate merger, consolidation, sale of our assets or substantially all our assets, share sale, investment transaction or other corporate rearrangement.
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 Contacting Us section for more information) or by using opt-out facilities provided in the marketing communications. If you opt-out, we will ensure that your name is removed from our mailing list(s).
Accuracy of personal information
We will take reasonable steps to ensure that all personal information we collect, use or disclose is accurate, complete and up-to-date.
If you believe your personal information is not accurate, complete or up-to-date, please contact us (see the Contacting Us section for more information).
Security of personal information
Your personal information may be stored in hard copy documents or electronically. We and our related bodies corporate are committed to keeping your personal information secure and safe. Some of the ways we do this are:
Requiring employees and service providers to enter into confidentiality agreements;
Secure hard copy document storage, e.g. storing hard copy documents in locked filing cabinets;
Security measures for access to our computer systems;
Access control for our building after hours;
Use of password protection;
Access privileges for our websites and data servers;
Anti-spam, anti-virus and anti-malware software;
Secure server room with access limited to authorised personnel.
We will review and update our security measures from time to time.
In addition, we will review the personal information held by us from time to time, in order to ensure that information which is no longer needed for a purpose for which it was initially collected is destroyed or de-identified.
Access to personal information
You may request access to any personal information we hold about you at any time by contacting us (see the Contacting Us section for more information). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it. 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 to you prior to the request being actioned. No charges will apply for simply making a request and for us to make any corrections to your personal information.
If we do not agree to provide access to your personal information or to correct your personal information, we will provide written reasons for the refusal and outline the mechanisms available to complain about the refusal (see the Complaints section for more information).
You may contact us by mail, email or telephone as follows: Mail: Honeycombes Property Group, PO Box 1223, Brisbane, QLD, 4001 Email: Phone: 07 3231 8300
If you consider that there has been a breach of the Act of the APPs, you are entitled to complain to us (see the Contacting Us section for more information).
We will acknowledge receipt of a complaint within 2 business days. We will investigate the complaint and attempt to resolve it within 20 business days after the complaint was received. Where it is anticipated that this timeframe is not achievable, we will contact you to provide an estimate of how long it will take to investigate and respond to the complaint.
If you consider that we have not adequately dealt with a complaint, you may complain to the Office of the Australian Information Commissioner on the below details:
Officer of the Australian Information Commissioner (OAIC)
GPO Box 5218 SYDNEY NSW 2001 Email: Phone: 1300 363 992
This policy will be reviewed as follows:
At least every two years;
Following an information security incident;
Following significant changes to our systems;
Following changes to government legislation.