Last updated November 2020
1. We respect your privacy
Ownit Homes Pty Ltd (ACN 009 873 581) and its related bodies corporate (Ownit Homes) (as defined by the provisions of the Corporations Act 2001 (Cth)), (Ownit Homes, we, us and our) respects your privacy and is committed to protecting it.
We comply with the Australian Privacy Principles and the Privacy Act 1988 (Cth) (Privacy Act), which govern the way private sector organisations collect, use, keep, secure and disclose personal information.
The Privacy Act defines “personal information” to mean any information or an opinion about an identified individual, or an individual who is reasonably identifiable whether the information or opinion is true or not; and whether the information or opinion is recorded in a material form.
2. The kinds of personal information collected, used and disclosed by Ownit Homes.
We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to by you. At or around the time we collect personal information from you, we will endeavour to provide you with a notice which details how we will use and disclose that specific information. We set out some common collection, use and disclosure instances as outlined below.
Purpose: Sales enquiries (online, telephone and in person)
Types of Information
- Contact information: Such as your name, email address, postal and residential addresses, phone numbers, country of residence, driver’s licence details.
- Product Information: Such as the products you are interested in or products that you have purchased from us or from third parties within the building industry, including but not limited to the styles of residential properties that you are interested in.
- Additional Information: Such as any additional information you provide us via our website.
- Customer services: Information collected in connection with you providing us with testimonials, including but not limited to any photographs we may take or you may provide to us.
- Security information: Such as CCTV footage at our premises or display homes, photographs or information used to secure ecommerce transactions.
The types of uses we will make of personal information collected for this type of purpose include:
- Products and services: the provision of our products and services to you including using your personal information in order to contact you regarding products, services or events we think would be of interest to you and to provide any customer service functions, such as responding to any enquiries for further information in relation to our products.
- After-sales services:
– To provide customer service functions, including handling customer enquiries and complaints.
– To provide you with product awareness information concerning the products purchased or other matters in relation to the residential property or area in which the property is located.
- Marketing and consumer analytics: using your personal information for the purposes set out in “Marketing Services” section below.
- General administrative and security use:
– To protect Ownit Homes premises and website from security threats, theft, fraud, burglary or other criminal activities.
– The use of your personal information collected in the administration and management of Ownit Homes.
– The maintenance and development of our products and services, business systems and infrastructure.
– In connection with the sale of any part of Ownit Homes’ business or a company owned by an Ownit Homes entity.
– To provide customer services to customers and other related enquiries.
The types of disclosures we will make of personal information collected for the type of purposes listed include, without limitation:
- Third party service providers utilised in connection with:
– any administrative matters;
– (including IT service providers, contractors and sales consultants) who assist Ownit Homes in providing our products and services to you;
– providing our products and services which are related to the building industry and the building and completion of residential properties;
– the sales and after sales process including ecommerce services, financial institutions, credit service providers who assist us in providing our products to you.
– the marketing process including messaging service providers or other third parties who assist us in providing our products to you.
- Medical practitioners and emergency service providers in the event of a medical emergency on our premises.
- Related bodies corporate of Ownit Homes (including related entities).
- Third parties in connection with the sale of any part of Ownit Homes’ business or a company owned by an Ownit Homes entity.
- As required or authorised by law.
Purpose: Marketing services (which include social media)
Types of Information
- Contact information: Such as your name, email address, current postal and residential addresses, phone numbers, country of residence (and, if applicable, age).
- Product interests: Such as the Products and styles of residential properties you are interested in and those that you have purchased.
– Social media activity: Including “likes”, comments or feedback, photos posted or uploaded and other information pertaining to your social media activities which concern, or relate, to Ownit Homes.
- Events: including your attendance at any event and participation in any competitions or promotions, photos taken or any reviews or product preferences provided by you.
General marketing: using your personal information to:
- Offer you updates on products, events or information that may be of interest to you.
- Improve our services (including contacting you about those improvements and asking you to participate in surveys or reviews about our products and services).
- Marketing and promotional activities by us (including by direct marketing by mail, telemarketing, email, SMS and MMS messages) such as newsletters and competitions.
- In connection with the sale of any part of Ownit Homes’ business or company.
Social media: If you attend an event facilitated by Ownit Homes (or its agents) or participate in our social media platforms (such as Facebook, Twitter, Google+, LinkedIn, Pinterest, Houzz, YouTube, Instagram) or participate in any competitions (whether online or otherwise) and you provide us your personal information, we will use it for:
- Drawing and contacting winners.
- Adding entrants to marketing database.
- Customer service related contact.
- Responding to social media messages.
- Fulfilling social media platform rules.
Identity verification: if required, the verification of your identity and age
We may disclose your personal information to:
- Our third party partners, such as magazines, media companies who assist us with a competition or promotion.
- Third parties in connection with the sale of any part of Ownit Homes’ business or a company owned by an Ownit Home entity.
- Service providers (including IT service providers), contractors and sales consultants that assists Ownit Homes with sales, marketing and promotions.
- Third parties connected with the marketing process including messaging service providers or other third parties who assist us in providing our products and services to you.
- As required or authorised by law.
Purpose: Human Resources
Types of Information
- Contact information: Such as your name, e-mail address, current postal and residential address, phone numbers, country of residence, next of kin contact details.
- Employee record information
- Identifying information: Such as your photo, passport and residency details, date of birth, licence.
- CV, resume or application related information: Such as the details provided in your resume or CV, your eligibility to work in Australia, visa details, your education, previous employment details, professional memberships or qualifications, parental consent to work forms.
- Tax, superannuation and payroll information: Such as your Tax File Number and ATO Declaration, Superannuation details and financial institution details.
- Background check information: Information obtained from you or third parties to perform background checks.
- Performance related information: Pre-employment testing and other information collected by Ownit Homes’ systems in the course of the employee or contractor’s engagement with Ownit Homes.
- Information collected from referees.
Pre-employment screening: Utilising the information collected for the purpose of assessing candidate suitability for a role, including by obtaining:
- Verification of your identity and age.
- Criminal history background checks including publicly available information including Facebook, Twitter, Instagram, YouTube.
- Confirmation of eligibility to work in Australia.
- Confirmation of education and qualifications.
- Confirmation of previous employment.
Administration and performance monitoring use: Utilising the information collected for the purpose of:
- Dealings related to the employer/employee relationship or the contractor/principal relationship (as the case may be).
- Use of such information whether or not the employment or contractor relationship is prospective, current or past.
- Use of such information to monitor systems, performance and time usage and internet usage.
- The use of your Personal Information collected in the administration and management of Ownit Homes.
- In connection with the sale of any part of Ownit Homes’ business or a company owned by a Ownit Homes entity.
We may disclose your Personal Information to:
- Relevant superannuation company.
- Government agencies, including but not limited to The Australian Taxation Office, Centrelink and Department of Human Services.
- Relevant Worker’s Compensation organisation (e.g. WorkCover, etc).
- Third party referees provided by you in connection with an application made to Ownit Homes.
- Service providers engaged to assist Ownit Homes in the administration of its business (including IT service providers, HR software provider and payroll providers), if any.
- Recruitment agents used in connection with your application with us.
- Third parties in connection with the sale of any part of Ownit Homes’ business or a company owned by a Ownit Homes entity.
- Third parties in connection with obtaining any background checks, pre-employment screening.
- Financial institutions for payroll purposes.
- As required or authorised by law.
3. How Ownit Homes collects and holds personal information
3.1 Collection generally
When you engage in certain activities, such as filling out a survey or sending us feedback, we may ask you to provide certain information. It is completely optional for you to engage in these activities.
Depending upon the reason for requiring the information, some of the information we ask you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory information or any other information we require in order for us to provide our products or services to you, we may be unable to provide our products or services to you in an effective manner, or at all.
3.2 Other collection types
We may also collect personal information about you from other sources, such as:
(a) when we collect personal information about you from third parties or competitions (including but not limited to our share registry provider); or
(b) when we collect personal information about you from publicly available sources including but not limited to, court judgments, directorship and bankruptcy searches, Australia Post, White Pages directory, and social media platforms (such as Facebook, Twitter, Google, Instagram etc).
3.3 Notification of collection
If we collect details about you from someone else, we will, whenever reasonably possible, make you aware that we have done this and why, unless special circumstances apply, including the following circumstances:
(a) where information is collected from any personal referee you have listed on any application form (including any employment application) with Ownit Homes;
(b) where information is collected from publicly available sources including but not limited to, court judgments, directorship and bankruptcy searches, social media platforms (such as Facebook, Twitter, Google, Instagram etc); or
(c) as otherwise required or authorised by law.
3.4 Unsolicited personal information
In the event we collect personal information from you, or a third party, in circumstances where we have not requested or solicited that information (known as unsolicited information), and it is determined by Ownit Homes (in its absolute discretion) that the personal information is not required, we will destroy the information or ensure that the information is de-identified. However, where unsolicited personal information is collected in relation to your future potential employment with Ownit Homes, we may retain this personal information.
3.5 How we hold your personal information
Once we collect your personal information, we will either hold it securely and store it on infrastructure owned or controlled by us or with a third party service provider who have taken reasonable steps to ensure they comply with the Privacy Act. Refer to Section 8 (Data security and quality) for more information.
3.6 Cookies and IP addresses
If you use our website, we may utilise “cookies” which enable us to monitor traffic patterns, trends and to serve you more efficiently if you revisit our website. In most cases, a cookie does not identify you personally but may identify your internet service provider or computer.
We may gather your IP address as part of our business activities and to assist with any operational difficulties or support issues with our services. This information does not identify you personally.
You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. However, if you disable cookies, you may not be able to access certain areas of our websites or take advantage of the improved web site experience that cookies offer.
4. Uses and discloses of personal information
4.1 Use and disclose details
We provide a detailed list at Section 2 of some common uses and disclosures we make regarding the personal information we collect. We may also use or disclose your personal information and in doing so we are not required to seek your additional consent:
(a) when it is disclosed or used for a purpose related to the primary purposes of collection detailed above and you would reasonably expect your personal information to be used or disclosed for such a purpose;
(b) if we reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
(c) if we have reason to suspect that unlawful activity has been, or is being, engaged in; or
(d) if it is required or authorised by law.
4.3 Use and disclosure procedures
4.4 Communications opt-out
5. Direct Marketing
5.1 Express informed consent
You give your express and informed consent to us using your personal information set out in:
(a) the “Sales and Enquiries (online, telephone and in-person)” section of the table at Section 2 of this document above;
(b) the “Marketing Services which includes social media” section of the table at Section 2 of this document above;
to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) which we consider may be of interest to you, whether by post, email, SMS, messaging applications and telephone (Direct Marketing Communications).
5.2 Inferred consent and reasonable expectations of direct marketing
Without limitation to paragraph 5.1, if you have provided inferred or implied consent (e.g. not opting out where an opt-out opportunity has been provided to you) or if it is within your reasonable expectation that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.
If at any time you do not wish to receive any further Direct Marketing Communications from us or others under this Section 5, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the Direct Marketing Communication or by contacting us via the details set out in Section 10.
6. Anonymity and pseudo-anonymity
Due to the nature of the goods and services we provide, it is only practicable or reasonable for Ownit Homes to transact and correspond with you on a named basis. Your personal information may be required in order to provide you with our goods and services, or to resolve any issue you may have.
7. Cross Border Disclosure
7.1 Cross border disclosures
Any personal information collected and held by Ownit Homes may be disclosed to, and held at, a destination outside Australia, including the United States, Germany and Japan, where we utilise third party service providers to assist Ownit Homes with providing our goods and services to you. Personal information may also be processed by staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.
As we use service providers, online applications and data storage facilities which can be accessed or disclosed in various countries, it is not always practicable to know where your information may be held. Where reasonably practicable, we will take reasonable steps to inform you as to where your personal information is held or disclosed.
7.2 Provision of informed consent
7.3 If you do not consent
If you do not agree to the disclosure of your personal information outside Australia by Ownit Homes, you should (after being informed of the cross border disclosure) tell Ownit Homes that you do not consent. To do this, either elect not to submit the personal information to Ownit Homes after being reasonably informed in a collection notification or please contact us via the details set out at the top of this document.
8. Data security and quality
8.1 Ownit Homes’ security generally
We have taken steps to help ensure your personal information is safe and protected from unauthorised access, use, disclosure, alteration, or destruction. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information, especially where the Internet is involved.
Notwithstanding the above, we will take reasonable steps to:
(a) make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
(b) protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
(c) destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.
The accuracy of personal information depends largely on the information you provide to us, so we recommend that you:
(a) let us know if there are any errors in your personal information; and
(b) keep us up-to-date with changes to your personal information (such as your name or address). We provide information about how you can access and correct your information in Section 9.
9. Access to and correction of your personal information
You are entitled to have access to any personal information relating to you which we hold, except in some limited circumstances provided by law (including the Privacy Act). You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.
If you would like access to or correct any records of personal information we have about you, you are able to access and update that information (subject to the above) by contacting us via the details set out at the top of this document.
10. Resolving Privacy Complaints
10.1 Complaints generally
We have put in place an effective mechanism and procedure to resolve privacy complaints. We will ensure that all complaints are dealt with in a reasonably appropriate timeframe so that any decision (if any decision is required to be made) is made expeditiously.
10.2 Contacting Ownit Homes regarding complaints
If you have any concerns or complaints about the manner in which we have collected, used or disclosed and stored your personal information, please contact us by:
– Telephone: 07 3343 4244
– Email: firstname.lastname@example.org
– Post: PO Box 6002 Upper Mt Gravatt Qld, 4122
Please mark your correspondence to the attention of the Privacy Officer.
10.3 Steps we take to resolve a complaint
In order to resolve a complaint, we:
(a) will liaise with you to identify and define the nature and cause of the complaint;
(b) may request that you provide the details of the complaint in writing;
(c) will keep you informed of the likely time within which we will respond to your complaint; and
(d) will inform you of the legislative basis (if any) of our decision in resolving such complaint.
10.4 Register of complaints
We will keep a record of the complaint and any action taken in a Register of Complaints.
11. Consent, modifications and updates
(a) certain sections or paragraphs in this policy are incorporated into that contract, but in such a way that they do not give rise to contractual obligations onto Ownit Homes, but do create contractual obligations on the other party to the contract; and
(b) the consents provided in this policy become contractual terms provided by the other party to the contract.