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Publication Date: June 2018
Leakes Road Rockbank Pty Ltd ABN 93 122 773 924 (Woodlea, we, us, our) is a property development company based in Melbourne, Australia. We are committed to protecting your privacy, in accordance with applicable Australian privacy laws.
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. Examples include your name, address, date of birth and email address.
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.
The Privacy Act also includes a data breach notification regime, which requires Woodlea to address data breaches involving personal information held by Woodlea.
We are also required to comply with more specific privacy legislation in some circumstances, such as:
1.4 Employee records
2. What we collect
The type of personal information that we collect about you depends on the type of dealings you have with us. For example, if you:
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. We only collect sensitive information where it is reasonably necessary for our functions or activities and either:
For example, if you purchase a property from us, we may collect information about your residency status which may indicate your racial or ethnic origin.
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.
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 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 by clicking here.
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.
For example, you can access our website and make general phone queries without having to identify yourself.
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 from us.
3. How we collect personal information
3.1 Methods of collection
We may collect personal information in a number of ways, including:
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 the purpose for which we are collecting the information and the type of third parties to which it is usually disclosed). We will generally include this information in a collection notice.
4. Why we collect personal information
The main purposes for which we collect, hold, use and disclose personal information are set out below:
We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or:
4.2 Direct marketing
We may use or disclose your personal information to let you know about us and our products and services (including promotions, special offers and events) and the products and services of third parties (for example, in relation to house and land packages), 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 and facsimile.
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:
5. Who we may share your personal information with
Woodlea may disclose your personal information, and you consent to Woodlea disclosing your personal information, to Woodlea’s related bodies corporate and associated entities (as those terms are defined in the Corporations Act 2001 (Cth)).
Woodlea may also disclose your personal information, and you consent to Woodlea disclosing your personal information, with third parties where appropriate for the purposes set out under heading 4, including:
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.
We may also disclose information to provide our products and services, to respond to legal requirements, enforce our policies, and protect our rights and property.
6. Cross border disclosure of personal information
7. Use of government related identifiers
We will not:
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
Woodlea is committed to keeping your personal information secure and confidential. All reasonable precautions will be taken to protect personal information from loss, misuse, unauthorised access or alteration.
We hold personal information in a number of ways, including in electronic databases, email contact lists, and in hard copy 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:
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.
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.
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).
An IP (internet protocol) address is a number that is automatically assigned to your computer by your internet service provider when you log on. Your IP address is not linked to your personal information but we do preserve the right to use IP addresses to identify individuals who may threaten our site, services or clients. IP addresses may also be used to help diagnose problems with our website and to gather broad demographic information.
Third party websites
If there is any breach of your personal information, Woodlea will deal with such breach and notify you in accordance with its obligations under the Privacy Act.
9. How long we keep your information
We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
If you close an account you have with us or you decide not to go ahead with purchasing the property for which you have registered, we may still keep your information.
10. 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.
We will generally provide you with access to your personal information, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (eg by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask us to correct personal information that we hold about you, we will take reasonable steps to correct that information.
If we correct personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, we will take reasonable steps to do so, unless this would be impracticable or unlawful.
10.4 Timeframe for access and correction requests
Except in the case of more complicated requests, we will endeavour to respond to access and correction requests within 30 days.
10.5 What if we do not agree to your request for access or correction?
If we do not agree to your access or correction request, or if we do not agree to give you access in the manner you requested, we will provide you with a written notice setting out:
In addition, if we refuse to correct personal information in the manner you have requested, you may ask us to associate your request with the information and we will take reasonable steps to do so.
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).
We will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week. If we are not able to do so, we will ask you to submit your complaint in writing.
In most cases, we expect to investigate written complaints and provide a response within 30 days of receipt. If the matter is more complex and our investigation may take longer, we will contact you and tell you when we expect to provide our response.
If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner (see here for further information).
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: Privacy Officer, Woodlea, Suite 4.01, Level 4, 99 Queen Street, Melbourne VIC 3000
Telephone: +61 3 9912 0600
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
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