PRIVACY & CCTV POLICY
We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and we comply with all of the Act’s requirements in respect of the collection, management and disclosure of your personal information.
What is your personal information and sensitive information?
What personal information do we collect and hold?
We may collect the following types of personal information, depending on your interaction with us:
- name, date of birth, age and other identification details (including, where relevant, your passport details and drivers licence);
- contact details include mailing or street address, email address, telephone number;
- details of your employment;
- financial information about you, such as your income details, bank account and financial capacity (where relevant);
- any additional information that you chose to provide to us directly through our website or through our surveys, including customer portals or any Resident Portals that we operate, or will operate for and on behalf of the owners corporation in the properties developed by us (collectively website portals);
- passwords created for website portals;
- details of your interests in properties owned and/or developed by us (our “properties”), your purchase of properties from us, the services that you acquire from us, together with any additional information necessary to complete the purchase transactions and to respond to your enquiries; and
- - any additional information relating to you that you provide to us through use of our websites or online presence, or through our representatives or during your visits to our display show rooms or purchase centres.
We may collect some sensitive information about you such as any pre-existing medical conditions, but such information will only be collected where you choose to provide it to us through the website portals.
We are required, in certain circumstances such as where you wish to purchase a property, to collect your name, address, date of birth and other verification information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or the Foreign Acquisitions and Takeovers Act 1975 (Cth) to verify your identity and your residential status.
We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous or aggregated information using web tracking technologies about how users use our website.
How do we collect your personal information?
We collect your personal information generally directly from you unless it is unreasonable or impracticable to do so (for example, where you engage one of our agents).When collecting personal information from you, we may collect in ways including:
- through your access and use of our website, including the website portals;
- during conversations and correspondences between you and our representatives, including our agents based in Australia or overseas; or
- when you complete an application, a survey, a registration form or purchase contract.
To the extent permitted by, law, we may also collect personal information from third parties including from third party companies such as credit reporting agencies, law enforcement agencies and other government entities. Otherwise, we do not generally collect personal information from third parties, except that we may collect limited personal information about a person from users of our website portals (for example, where you are listed as an emergency contact of a residence in one of our properties).
Cookies and other tracking technologies
We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.
We and our advertising partners also use advertising cookies and other web-tracking technologies, such as pixel tags and web beacons to collect information about browsing habits, analyse trends, administer our websites, track users web movements, gather broad demographic information and other marketing purposes. These are also used to make advertising more relevant to you and your interests.
What happens if we can’t collect your personal information?
If you do not provide us with the personal information described above, some or all of the following may happen:
- we may not be able to provide the requested website portals to you, either to the same standard or at all, or some features may not function properly;
- we may not be able to provide you with information about our properties, opportunities and services that you may want, including information about new developments, sales or special promotions;
- we may not be able to complete a sale transaction with you; or
- we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.
You are never required to provide us with sensitive information to be able to use our website portals.
For what purposes do we collect, hold, use and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and to provide best possible quality of customer service.
We collect, hold, use and disclose your personal information for the following purposes:
- to provide the website portals and facilitate interaction between users of our websites and website portals, products and services to you and to send communications requested by you;
- to answer enquiries, provide customer services, and provide information or advice about our properties, opportunities and services;
- to complete property transactions with you, including to conduct background checks where necessary (for example if required in relation to a proposed purchase, lease and or licence);
- to assess the performance of the website and to improve the operation of the website;
- to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
- for the administrative, marketing (including direct marketing and advertising), planning, product or service development, quality control and research purposes of Time & Place, its related bodies corporate, contractors or service providers;
- to provide your updated personal information to our related bodies corporate, contractors or service providers;
- to update our records and keep your contact details up to date;
- to process and respond to any complaint made by you;
- to generate statistics and derive insights from our data; and
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.
We utilise the services of third parties for marketing purposes, including online platforms and social media platforms, and we will disclose personal information about you to the third-party service provider for our marketing purposes. While these third parties generally only use the personal information for our marketing purposes, some may retain certain personal information about you for their own purposes.
To whom may we disclose your information?
We may disclose your personal information to:
- our employees, contractors or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you or completing a property transaction with you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, data entry service providers, electronic network administrators, and professional advisors such as accountants, solicitors, business advisors and consultants;
- suppliers, joint venture partners and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and
- any organisation for any authorised purpose with your express consent or where required by law.
Our website portal may include functionality that permits you to post information (such as bulletin boards).Such information will be disclosed to other users of the website portal.
We may combine or share any information that we collect from you with information collected by any of our related bodies corporate or joint venture partners (within Australia).
Direct marketing materials
We (or our service providers and advertising partners) may send you direct marketing communications and information about our properties, opportunities, and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, targeted advertisements, SMS, fax, and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth).You consent to us sending you those direct marketing communications by any of those methods. 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 details below) or by using opt-out facilities provided in the marketing communications.
Please note that we also carry out digital advertising campaign from time to time that do not rely on your personal information. Your opt-out will not have effect on such advertising campaigns.
We do not use your sensitive information for the purposes of direct marketing.
How can you access and correct your personal information?
You may request access to any personal information we hold about you at any time by contacting us (see the details below).Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you).We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. We will not charge for simply making the request and will not charge for making any corrections to your personal information.
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.
What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.
We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Our Privacy Officer deals with privacy complaints and any complaints should be directed to our Privacy Officer using the contact details below. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.
After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.
If you are not satisfied with the way your privacy-related complaint is handled by us, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC). Details of how to lodge a complaint with the OAIC may be found at www.oaic.gov.au or by calling 1300 363 992.
Do we disclose your personal information to anyone outside Australia?
We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above. Our IT systems that hosts our data (which may include your personal information) may also reside outside Australia.
We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed.
Our security measures include:
- role based access control to our ICT systems;
- locked cabinets for storage of physical records containing personal information;
- regular security vulnerability and penetration reviews and tests;
- approach level of security training for technology staff and the broader business;
- identity and access management processes and controls to key systems and information.
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
PRIVACY & CCTV POLICY
Purpose of a video doorbell security system
We use video doorbell security systems (“Video Security Systems”) to record images to assist in the provision of a safe and secure environment for the benefit of those who work at and visit Time & Place's office and experience studios, and for the protection of our property. Monitoring of Video Security Systems helps us to:
- maintain public safety;
- maintain the security of our property;
- assist in the prevention of crime;
- reduce the fear of crime and offer reassurance to staff; and
- facilitate the apprehension and prosecution of offenders in relation to crime.
We consider the processing of personal data for these purposes to be in our legitimate interests so that we can have a safe workplace.
Control of access
Access to our Video Security Systems and any associated recorded images which contain personal information ("Recorded Materials") is strictly controlled and is limited to those who need to have access in accordance with this policy. Any such access will only be given with the approval of the privacy officers.
Disclosure of Recorded Materials will only be provided to third parties for the purposes outlined above and in compliance with applicable data privacy laws.
In order to meet the stated purposes it may be necessary for us to share Recorded Materials internally with our offices and related entities. For further information on the sharing of your data between our entities please see the section entitled “To whom may we disclose your information?” of this policy.
Recorded Materials may only be viewed for the following purposes:
- the investigation of an alleged crime; or
- the investigation of a security incident.
Any authorised viewings shall be registered in a log.
Recorded Materials may be used by us after an incident to assist in the identification and detection of offenders or in the investigation of a security incident.
Disclosure to Police
The police should not require or be provided with access to any of our Video Security Systems except under the following circumstances:
- emergencies or investigation of serious incidents;
- identification of offenders; or
- at our request (in accordance with this policy).
Recorded Materials will be supplied to the police for crime incidents on receipt of a formal request.
Any requests by police to remove video security recordings will be notified to our privacy officers and will only be met where the request complies with applicable data privacy laws. Any such requests will also be registered in a log.
Access by you
The privacy laws of some jurisdictions give individuals the right to access, amend or delete their personal information or, in some circumstances, to restrict the processing of their personal information.
If you would like to request a copy of your data or would like to change or erase all or any part of the information we hold about you, please contact us as set out below.
Video doorbell security locations
Video doorbell security cameras are located at strategic points throughout our offices and experience studios so as to provide coverage of entry and exit points to our office areas and experience studios. Where required by privacy laws, signage is displayed at appropriate points to alert employees and visitors that video security surveillance is in use and to provide our contact details for further information.
Any Recorded Materials shall be held securely and shall not be saved or placed in areas accessible by our employees (other than those with requisite access rights), the public or be otherwise distributed.
We will take all reasonable precautions necessary to protect Recorded Materials from:
- misuse, interference and loss; and
- unauthorised access, modification or disclosure.
Storage of video doorbell security footage
Recorded Materials shall not be retained for any longer than is required for the stated purpose. Ordinarily footage is only retained for as long as is necessary to fulfil the stated purpose. Recorded Materials will be deleted securely and promptly once the stated purpose has been fulfilled.
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
Please contact our Privacy Officer at: