Guardian Group Realty (GGR) needs a wide range of “personal information” in order to carry out its business. “Personal information” is defined in the Privacy Act (Cth) 1988 and is essentially information or an opinion about an identified individual, or an individual who is reasonably identifiable.
GGR is bound by the Australian Privacy Principles contained in the Privacy Act 1988.
1. What personal information does GGR collect?
GGR collects personal information from users of the site and the GGR service, and from merchants, partners, contractors, employees, and other people we do business with. The personal information we collect about users of the site and GGR service includes:
- Identification information: This includes each site user’s name, address, contact details (including telephone numbers and email address), bank account details, credit card details, date of birth and driver’s licence number; and
- Property information: This includes the records and related information that you create during your listing and marketing of any of your properties for sale or rent on the GGR website.
We may collect this information from you directly (when you communicate with us including by email, telephone or by your use of the GGR website), or from our site user profile creation process, on the GGR website, or when you participate in a survey, offer or other activity that we may conduct. In some cases, we may be provided with information from other site users including our Merchant partners and other users and suppliers, from our own records of how you use the GGR website, or from other publicly available sources. We may also engage third parties (such as web hosts or developers) to collect personal information on our behalf.
We also collect:
- Business Contact Information from and about our suppliers and other people we do business with (e.g. our merchants, our suppliers, our legal advisors, our insurers). This information is needed so that we can manage our business;
- Website activity about what our site users are doing on our site and related websites. This helps us determine how best to provide useful information to our site users and to understand which parts of our site, products and other services are of most interest and use to them.
2. How does GGR use personal information?
GGR is a web-based portal for property, mortgage finance and related services.
GGR uses personal information for the following purposes:
- to provide the GGR service and the site, including to administer the correct communications between us, our Merchants and other partners, suppliers and affiliates and our site users, administer our site user’s accounts, verify the identity of site users, process site use applications, assist you to subscribe or purchase products or services made available as part of the GGR service, charge fees, debit your bank account or credit card for payment of any goods or services purchased from GGR or any of our Merchants and for any other GGR activity you may choose, and to provide you with the best possible service;
- to communicate generally with our site users and business contacts including answering any enquiries and for customer support purposes;
- to send you information and updates in relation to the site and the GGR service, and goods and services offered by our Merchants and other suppliers and to contact you for your views on our services;
- ongoing research, development and refinement of the different types of products, services and features that we manage, create and/or market to our site users from time to time;
- to exchange information (which you consent to) with any partners we partner with from time to time to enable any of the transactions or other business we manage, create and/or market to occur; and
- to extract and analyse information generated by our site users in the course of using the GGR service and site, so that we can manage and improve the site and the GGR service, market to our site users, and develop new products and services.
We use certain aggregated, non-personal information (from sources which may include your personal information) to provide various property market and mortgage finance related data services for use by our site users, to manage and administer use of the GGR website and to operate our business generally.
Unless you tell us otherwise, we may also use your personal information to market to your special promotions, newsletters and other marketing material. For instance, GGR may email its site users information about its own promotions, or those offered by our business partners.
If you don’t want us to do this, we give you an opportunity to “opt out” from receiving certain materials through our ‘unsubscribe’ facilities.
3. Does GGR share my personal information with anyone else?
Like most businesses, sometimes we outsource or “contract out” specific support services from time to time including for instance, we may engage IT contractors to maintain our databases. All our contractors are subject to strict confidentiality obligations, which means they are authorised only to use personal information to provide the services or to perform the functions required by us.
We will disclose personal information if we are legally permitted to do so or under a legal requirement to do so (e.g. under a court order, or if required under legislation), or if an authorised request is made from a law enforcement agency.
Otherwise, we will only disclose personal information with the consent of the relevant individuals.
At times we may be required by law or litigation to disclose your personal information. We may also disclose information about you if we determine that for national security, law enforcement or other issues of public importance, disclosure is necessary.
Overseas disclosure of personal information:
We will generally not disclose your personal information to recipients outside of Australia, however it may be necessary from time to time to disclose personal information to service providers for processing on our behalf, or partners, some of which may be located outside of Australia. Unless otherwise advised, in the case that we do disclose personal information overseas, we will use reasonable steps to ensure that these overseas entities comply with the Australian Privacy Principles.
4. How can I access my Personal Information?
Privacy laws give you rights to seek access to the personal information we hold about you.
In limited circumstances, we may refuse your request to access, in which case, we will give you a reason for that refusal, information as to the complaint mechanisms available and other information required by law. We are not required to provide access where denying access is required or authorised by law or providing access would be unlawful.
Generally, much of the information that we have collected about you will be visible to you by accessing your site user profile on the GGR site. If you believe that there is any other personal information that we may have about you which is clearly identifiable as your information, then you can seek access by completing an access request form on our site. Generally, we should be able to provide you with access within a month of your request, although we may need more time if your request is complicated. Ordinarily, GGR will not charge you for the cost of providing access to your personal information. However, if we do propose to charge you, we will advise you of the relevant charge before we provide you with access.
We try to ensure that all the personal information that we hold about you is accurate, complete and up-to-date.
However, we rely on you to help us with this by ensuring that the details you create in your site user profile are accurate and up to date. In order to ensure that your personal information is accurate, complete and up-to-date we rely on you to contact our Privacy Officer to inform us of any changes that may need to be made. We will contact you if there is any issue about amending the record of personal information we hold about you.
If you wish to discuss our method of providing access or correction to personal information, please contact our Privacy Officer with your query, by emailing email@example.com.
5. Is my Personal Information kept secure?
GGR takes reasonable steps to ensure that the personal information we hold is stored in a secure environment and protected from misuse, interference, loss, and unauthorised access, modification or disclosure,
Where your personal information is no longer required by GGR it will be destroyed or de-identified.
GGR offers on-line services only to our site users. It is not permitted to become a site user of GGR without completing the site user profile creation process that is accessed from our site. A part of this process involves providing GGR with the minimum amount of personal information that is requested as part of this web-based process.
6. Cookies and Email/SMS marketing
Cookies: When you visit our site, we may collect certain data that does not identify you personally (sometimes called “web log information”) when you visit certain pages, such as the type of browser and operating system you have. We may also use “cookies” which are small files that are stored on your computer and that manage the security and navigation process of the site. You can choose to block these cookies, but some portions of the site may not function correctly if you do. This type of data is collected for statistical purposes only, and while cookies will identify your computer, they are unlikely to identify you personally.
Email/SMS marketing: We will not email or SMS you marketing material unless you have consented to this. This is a requirement of the Spam Act 2003. Further, you can unsubscribe from our e-newsletter or other bulletins by using the “unsubscribe” facility contained in each electronic publication we send.
If you are concerned that there may have been a breach of your rights or any rights under the Privacy Act 1988 (Cth) or any other applicable privacy law or code in Australia, please contact us by email at firstname.lastname@example.org. We take such matters very seriously and, we shall review your complaint and respond to any concerns promptly, usually within fourteen (14) working days. Further information about the Privacy Act and your privacy rights is available from the Office of the Australian Information Commissioner (see: http://www.oaic.gov.au/privacy/privacy-complaints).
8. Contact details and other information