Last updated 22 July 2021
1. About this policy
1.2 We are committed to protecting your privacy and understand the importance of protecting your personal information. This Policy outlines the types of personal information that we usually collect, the purposes for which we collect it, to whom we disclose it, how we hold and keep it secure and your rights in relation to your personal information, including how to complain and how we deal with complaints.
1.3 We will handle your personal information in accordance with this Policy and all applicable laws, including the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
2. What is personal information?
2.1 In this Policy, personal information means any information or opinion about an identified individual or an individual who is reasonably identifiable, whether true or not. It does not include information that is de-identified.
2.2 This Policy does not apply to the personal information of our employees.
3. Types of personal information we collect
The types of personal information we collect about you depends on the dealings you have with us, and may include:
- your name, date of birth, address, email address, phone number and other information available from the provision of identification documents to us by you (including copies of said documents);
- bank account details and tax file numbers;
- information placed on public and private forms between residents and building managers;
- information related to building use, such as details regarding use of facilities, CCTV footage, access records, front door codes and wi-fi passwords;
- information obtained from publicly available sources, such as social media;
- correspondence and actions taken by you in connection with the use of our website (https://www.norupwilson.com/) (Website) or applications (including, in the case of our applications, text, photos, user credentials, video calls and record of call time, duration and date, messages sent, and calendar usage); and
- the internet protocol (IP) address of any device and type of browser you are using when accessing our Website;
- your geographical location and type of device that you are using when accessing our Website; and
- records of our communications with you, including any complaints, requests or queries.
4. Dealing with us anonymously or using a pseudonym
4.1 Where possible and lawful, you may interact with us anonymously or using a pseudonym. For example, if you contact us with a general question we will not record your name unless we need it to adequately handle your question.
4.2 However, for many of our functions and activities we usually need your name, contact information and other details to enable us to provide our services to you.
5. Ways we collect your personal information
We may collect personal information from or about you in different ways, including:
- from you directly when you interact with us (eg, by telephone, email, or through our Website or applications, including when you submit an online form);
- through third parties with whom we interact in order to provide our services, including data analytics service providers and third party websites (such as https://www.realestate.com.au/); and
- from publicly available sources, such as social media sites and Google.
6. Collection of information via our website
6.1 Our Website uses ‘cookies’ or other similar tracking technologies that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can modify your browser to reject cookies; however, this may affect certain Website features and functionality.
6.2 Whilst we do not use browsing information to identify you personally, we may record certain information about your use of our Website, such as which pages you visit, the time and date of your visit, search engine referrals, and the IP address assigned to your computer.
6.4 We have enabled Google Analytics Demographics and Interest Reporting features on our Website to allow us to review information about users of the Website, including identifiers such as users’ age, gender, interests, and other categories based on acquisition, behaviour, and conversions metrics. We may use this information to enable us to make decisions about what information to include on our Website and how to present it. We have also enabled Google Display Network Impression Reporting on our Website to allow us to track how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to site visits to our Website. We and our third-party suppliers, including Google, use first-party Google Analytics cookies and third-party DoubleClick cookies together to collect the data for the Google Display Network Impression Reporting functionality.
7. Purposes for which we collect, use and disclose personal information
We collect your personal information for the purposes of undertaking our functions and activities, including:
- providing our services;
- managing and conducting our business, including through sending relevant details to selling agents, and undertaking research and analysis;
- direct and indirect marketing activities;
- obtaining feedback;
- helping us manage, develop and enhance our services, such as our Website and applications;
- maintaining our relationships with clients and partners through correspondence and the sending of updates; and
- complying with our legal obligations, resolving any disputes, and enforcing our agreements and rights with third parties.
8. Disclosing your personal information
8.1 We will not use or disclose your personal information for purposes other than the purpose for which it was collected (or a related purpose), unless you have consented to that other purpose, or we are required or permitted to do so by law.
8.2 In the course of providing our products and services to you, we may disclose your personal information to the following:
- our related companies;
- third parties in order to provide our services, for example real estate agents, marketing companies, contractors, consultants, and outsourced IT providers;
- anyone to whom part or all of our assets or businesses are transferred or sold;
- our professional advisers, including lawyers, accountants and auditors;
- government agencies, regulatory bodies and law enforcement agencies, or other similar entities; and
- other parties as permitted by law.
8.3 We may disclose your personal information to the following overseas recipients:
- to organisations or individuals who assist us in providing services or who perform functions on our behalf (such as third party service providers), including those located in Singapore, Europe and the USA;
- to anyone else to whom you authorise us to disclose it; and
- to anyone else where we are required or authorised by law to do so.
8.4 If we disclose your personal information to any recipient located outside of Australia, we will take reasonable steps to ensure that the recipient also treats that information in accordance with the Privacy Act.
9. Direct Marketing
We may use your personal information to identify a product or service that you may be interested in or to contact you about an enquiry you have made. We may, with your consent, use the personal information we have collected about you to contact you from time to time whether by electronic direct mail, text message, email, phone or SMS to tell you about new products or services and special offers that we believe may be of interest to you. We will always give you the opportunity to opt out of receiving any future direct marketing communications.
10. Security and storage
10.1 We will take reasonable steps to ensure that the personal information we collect and hold about you is accurate, up-to-date, and complete. To assist us, please ensure that the information you provide to us is correct, and advise us of any updates.
10.2 We may store your personal information in hard copy and in electronic form. Electronic information may be stored by a third party storage provider. We will take reasonable and appropriate steps to protect the personal information we collect and hold from misuse, interference and loss, as well as unauthorised access, modification or disclosure.
10.3 We only keep your personal information for as long as it is required for the purpose for which it was collected or as otherwise required by applicable laws. If we no longer need to hold your personal information for any reason or we are no longer required by law to keep it, we will take reasonable steps to de-identify or destroy that information. These steps may vary depending on the nature of the information, the way it was collected and how it was stored.
11. Access to correction of your information
11.1 We will endeavour to ensure that the personal information collected from you is up to date, accurate and complete.
11.2 You may request access to, or correction of, the personal information we hold about you at any time by contacting our Office Administrator via the contact details below. We will need to verify your identity before responding to your request. Subject to any applicable legal exceptions or requirements, we will process your request within a reasonable timeframe. We may recover from you our reasonable costs of supplying you with access to your information. However, we will not charge you to make a request or to correct or update your personal information.
11.3 If we decide not to provide you with access to or correct your personal information, we will advise you of the reasons for our decision.
12.1 If you have any concerns about the way we have handled your personal information, you can make a complaint in writing addressed to ‘The Directors’ via our contact details below. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.
12.2 If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner (OAIC) via the OAIC website (oaic.gov.au) or by calling 1300 363 992.
13. Other organisations’ websites
14. Changes to this policy
We may amend this Policy, in whole or part, in our sole discretion at any time.
15. Contact us
If you have any questions about this Policy or if you wish to request access to your personal information, correct or update your details or raise any privacy concerns you may have, please contact us at:
Norup & Wilson Group
Address: Level 1, 19 Ogilvie Road, Mount Pleasant WA 6153
Phone: +61 (8) 9315 1513