We are a specialist land division project management consultancy, and provide services for residential developments, including assistance with land acquisitions, subdivision and sale. For this purpose, the policy references Urblox, a business of Drone Maps Pty Ltd.
1. Our Commitment
1.1 In our capacity as project managers, we act on behalf of investors and stakeholders in land.
1.3 We are committed to compliance with the Privacy Act 1988 (Cth), which incorporates the Australia Privacy Principles (APPs), when handling client information. We demonstrate this commitment by ensuring that all our practices reflect the requirements of the APPs.
2. Who does this Policy Apply to?
2.1 This policy applies to or any person for whom we currently hold, or may in the future collect, personal information.
3.1 This policy applies to personal information. In broad terms, ‘personal information’ is information or opinions relating to a particular individual who can be identified from that information.
3.2 Information is not personal information where the information cannot be used to identify an individual.
4. How do we manage your information?
4.1 In order to comply with the APPs, we manage the personal information we collect through:
4.1.1 the implementation of appropriate procedures for identifying and managing privacy risks;
4.1.2 use of information management systems for protecting personal information from misuse, interference and loss from unauthorised access, modification or disclosure;
4.1.3 provision of training to all employees on privacy processes;
4.1.4 procedures that will ensure any agents or contractors who deal with us are compliant with the APPs;
4.1.5 implementing procedures for identifying and reporting privacy breaches and for receiving and responding to complaints; and
4.1.6 appointment a privacy officer within the business to monitor privacy compliance.
4.2 We will take reasonable steps to destroy or permanently de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.
4.3 In limited circumstances, such as for prospective clients or investors, it may be possible for you to use a pseudonym or remain anonymous when initially dealing with us. If you wish to use a pseudonym or remain anonymous you should notify us when making first enquiries. We will use our best endeavours to deal with your request, subject to our ability to provide you with the requested services without using your name.
5. What kind of information will we collect and hold?
5.1 We will collect and hold personal information about you, which might include:
5.1.1 contact information;
5.1.2 property information;
5.1.3 financial information;
5.1.3 credit information;
5.1.4 banking details; and
5.1.5 any other personal information required to facilitate the relationship between you and us in connection with our work.
6. Do we collect any sensitive information?
6.1 We do not generally collect sensitive information about individuals.
7. How and when do we collect personal information?
7.1 Our usual approach to collecting personal information is to collect it directly from you.
7.2 We might also collect personal information in other ways, for example:
7.2.1 from electronic queries sent to us;
7.2.2 from expression of interest forms;
7.2.3 through transactions with us;
7.2.4 through questionnaires you complete;
7.2.5 from subscriptions to our database;
7.2.6 from our consultants;
7.2.7 from website cookies;
7.2.8 from interaction with Urblox social media sites;
7.2.9 from paid search providers;
7.2.10 through referrals from individuals or other entities;
7.2.11 through marketing and business development events; and
7.2.12 from other third party providers.
7.3 If you wish, you may elect not to accept cookies on your browser. This should not adversely affect your experience when visiting our website.
8. How do we hold personal information?
8.1 Our usual approach to holding personal information includes:
8.1.1 physically at our offices (securely); and
18.104.22.168 on secure online servers and software and our database; and
22.214.171.124 through third party software providers.
8.2 We secure the personal information we hold in numerous ways, including:
8.2.1 scanning all documents into our secure database and returning originals or destroying copies;
8.2.2 using secure archiving for some documents;
8.2.3 using secure cloud providers with servers located in Australia to store personal information; and
8.2.4 using unique usernames, passwords and other protections on systems that can access personal information.
9. Why do we collect, hold, use or disclose personal information?
9.1 We take reasonable steps to use and disclose personal information for the primary purpose for which we collect it. The primary purpose for which information is collected varies, depending on the particular service being provided, but is generally to provide any of the following services to you or your business (Services):
9.1.1 for project marketing purposes;
9.1.2 to assist in determining residential development and investment opportunities; and
9.1.3 delivering project management services, or any other service in connection with our business.
9.2 In the case of potential employees, the primary purpose the information is collected is to assess the individual’s suitability for employment.
9.3 In the case of land survey or legal partners, the primary purpose the information is collected is to assist us in creating partnerships to perform the Services.
9.4 Personal information may also be used or disclosed by us for secondary purposes which are within your reasonable expectations and which are related to the primary purpose of collection.
9.5 For example, we may also collect and use personal information:
9.5.1 to invite you to events;
9.5.2 in connection with tendering for building development projects;
9.5.3 to provide you with service and product updates that are relevant to you or your business;
9.5.4 to provide you with tailored market offers, products and incentives;
9.5.5 to assist in our customer profiling, so we can provide you with enhanced customer service; and
9.5.6 for research purposes.
9.6 We might disclose personal information to:
9.6.1 potential buyers, tenants, landlords and referees;
9.6.2 external auditors and professional advisers;
9.6.3 government bodies;
9.6.4 other service providers or referral partners in order to provide the Services to you, or to assist our functions or activities (such as law firms);
9.6.5 other third parties such as direct marketing agencies, and sales, rental and investment consultants and project managers;
9.6.6 third party technology providers; and
9.6.7 any other third parties incidental to us carrying out our functions in providing the Services.
9.8 Otherwise, we will only disclose personal information to third parties if permitted by the Privacy Act.
10. Will we disclose personal information outside Australia?
10.1 From time to time, we may disclose information to overseas recipients if it is necessary to providing the Services.
10.2 We take reasonable steps to ensure that the receiving party provides commitments to privacy and confidentiality which are at least equal to the APPs or the recipient is subject to privacy protection laws that offer at least the same level of protection as required under the Privacy Act in Australia.
11. How can a person access or correct personal information?
11.1 You should keep us informed about any and all changes to your personal information.
11.2 You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.
11.3 We will grant you access to your personal information as soon as possible, subject to and in accordance with the Privacy Act.
11.4 In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.
11.5 We may deny access to personal information if:
11.5.1 the request is unreasonable;
11.5.2 providing access would have an unreasonable impact on the privacy of another person;
11.5.3 providing access would pose a serious and imminent threat to the life or health of any person; or
11.5.4 there are other legal grounds to deny the request.
11.6 We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.
11.7 If the personal information that we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, where it is appropriate to do so.
12. How can a person complain about the collection or use of personal information?
12.1 If you believe there has been a breach of your privacy you may make a complaint using the following process:
12.1.1 The complaint must be firstly made to us in writing, using the contact details in this section. We will require a reasonable time to respond to the complaint.
12.1.2 In the unlikely event the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.
13. Who should I contact if I want to access or correct information, or make a complaint?
13.1 A person may make a complaint or request to access or correct personal information we have about them. We will take reasonable steps to ensure the personal information we hold is accurate and complete. Such a request must be made in writing to the following address or contact officer:
PO Box 510
North Adelaide 5006
Telephone number: 0433 572 677
14.2 This policy is effective from March 2019. If you have any comments on the policy, please contact the privacy officer with the contact details in section 13.1 of this policy.