Privacy Policy

General

Harlow Development Pty Ltd trading as Harlow is committed to respecting your right to privacy and protecting your personal information. We are bound by the Privacy Act 1988 (Cth) (Act) and the Australian Privacy Principles set out in the Act. We will ensure that all officers, employees and subcontractors are aware of and understand Harlow’s obligations as well as their own obligations under the Act. We will achieve this through the provision of training and through maintaining and implementing internal policies and procedures to prevent personal information from being collected, used, disclosed, retained, accessed or disposed of improperly. This Policy applies to all your dealings with us, whether in person, or via telephone, email, correspondence or our website.

Collection

Types of collected information

We may collect and hold personal information about you, that is, information that can identify you and is relevant to providing you with the services and products you are seeking. The kinds of information we typically collect include name, gender, address, phone number, email address, facsimile number, bank account details, tax file numbers or other information relevant to providing you with the services and products you are, or someone else you know, is seeking.

Method of collection

Personal information will generally be collected directly from you through the use of any of our standard forms, over the internet, via email, or through a telephone conversation with you. We may also collect personal information about you from third parties acting on your behalf (for instance, financial advisers).

There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impracticable to collect personal information directly from you. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.

Purpose of collection

The personal information that we collect and hold about you, depends on your interaction with us. Generally, we collect, use and hold your personal information if it is reasonably necessary for or directly related to the performance of our functions and activities and for the purposes of:

• providing services and products to you or someone else you know;
• providing you with marketing information, including newsletters and emails about other services and products we offer which may be of interest to you, including future investment opportunities;
• responding to your enquiries;
• facilitating our internal business operations, including the fulfilment of any legal requirements; and
• analysing our services and products with a view to improving those services and products

Except as otherwise permitted by law, we only collect sensitive information about you if you consent to the collection of the information and if the information is reasonably necessary for the performance of our functions, as set out above.

Failure to provide information

If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services and products you, or they, are seeking.

Internet users

If you access our website, we may collect additional personal information about you in the form of your IP address or domain name. Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and any linked websites are not subject to our privacy policies and procedures.

Our website uses cookies. The main purpose of cookies is to identify users and to prepare customised web pages for them. Cookies do not identify you personally, but they may link back to a database record about you. We use cookies to monitor usage of our website and to create a personal record of when you visit our website and what page you view so that we may serve you more effectively.

Our website uses analytics, provided by Google Inc. (Google) and other digital providers. Analytics uses cookies and JavaScript code that enables analysis on your usage of our website and data will be transmitted to and stored on Google or other servers. Your data may be used to compile reports on your usage of our website and provide services relating to website activity and internet usage. We will use the analytics data collected to improve the functionality of our website and services.

Use and disclosure

Generally, we only use or disclose personal information about you for the purposes for which it was collected (as set out above). We may disclose personal information about you to:

• our related entities to facilitate our and their internal business processes;
• third party service providers who assist us in operating our business, and providing services to you such as:
• third parties who assist with transactions, including financial institutions and payment service providers;
• third parties who assist with the business, including information technology and marketing service providers, and these third party service providers may not be required to comply with our privacy policy; and
• our related entities and other organisations with whom we have affiliations, so that those organisations may provide you with information about services, products, future investment offers, upcoming projects and various promotions.

In some circumstances, the law may permit or require us to use or disclose personal
information for other purposes (for instance, where you would reasonably expect us to and the purpose is related to the purpose of collection).

Disclosure of personal information overseas

We may have related bodies corporate, third party service providers or other recipients who are based overseas or may use infrastructure outside Australia, including the USA, the EEA, Asia and India. We take reasonable steps to ensure information disclosed overseas is handled with this policy and relevant law.

Security

We store your personal information in different ways, including in paper and electronic form. The security of your personal information is important to us. We take reasonable measures to ensure your personal information is stored safely to protect it from misuse, loss, unauthorised access, interference, modification or disclosure, including electronic and physical security measures.

Access and correction

You may request access to personal information we hold about you, by making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for processing your request (but not for making a request for access).

We may decline a request for access to personal information in circumstances prescribed by the Privacy Act and if we do, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).

If, upon receiving access to your personal information, or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.

If we refuse to correct your personal information, we will provide you with a written notice that sets out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint.

Complaints and feedback

If you wish to make a complaint about a breach of the Privacy Act, Australian Privacy Principles or a privacy code that applies to us, please contact us as set out below and we will take reasonable steps to investigate the complaint and respond to you. If you are not happy with our response, you may complain directly to the Australian Privacy Commissioner. To lodge a complaint, visit the ‘Complaints’ section of the Information Commissioner’s website, located at https://www.oaic.gov.au/privacy/privacy-complaints, to obtain the relevant complaint forms, or contact the Information Commissioner’s office.

If you have any questions or concerns about this privacy policy or the way we handle your personal information, please contact:

Street address: 23 Hurst Drive, Tarneit
Email: clientservices@rpmgrp.com.au

Telephone:(03) 9862 9555

More information

For more information about privacy in general, you can visit the Australian Privacy Commissioner’s website at www.oaic.gov.au.

Whenever you deal with RPM Real Estate Group, whether as a current or prospective seller, buyer, lessor or lessee, we will collect personal information in order to provide services to you. We do not collect personal information unless it is reasonably necessary for, or directly related to, one or more of the services we provide or functions we carry out.

The types of personal information we generally collect include but is not limited to:

• Name.
• Date of birth.
• Residential address.
• Postal address.
• Email address.
• Home telephone number.
• Work telephone number.
• Mobile telephone number.
• Your occupation and business address.
• Financial information including details of your employer, income, name of bank or financial institution.
• Details of your spouse, de facto, dependent children, and roommates.
• Details of properties owned by you.
• Details specifically pertaining to your requirements in relation to purchasing property (e.g. Lot size required, builder engaged, price range, FIRB status, etc.)

We will not ordinarily ask you to provide sensitive information. However, there may be circumstances where the information provided by you reveals sensitive information. For example:

• You may require a property with particular features, such as wheelchair ramps. This may reveal health information.
• In providing details of your spouse or de facto partner, this may reveal sensitive information regarding your sexual orientation.

We will only collect sensitive information in circumstances where:

• It is reasonably necessary for one or more of the services we provide or functions we carry out; and
  You consent to the collection of the information; or we are required or authorised by law to collect the sensitive information.
• We will, if it is reasonable or practicable to do so, collect your personal information directly from you. This may happen when you fill out a form or when you give us personal information in person, or via telephone, email, correspondence or our website.

Sometimes we will collect personal information from a third party or a publicly available source. For example, we may need to collect personal information from a credit reporting agency, your legal adviser, your past or current employers, your previous lessors or property managers, and tenancy information services or databases.

If we receive personal information that we did not solicit, we will determine as soon as reasonably practicable whether we could have lawfully collected that information as part of our functions or activities. If we are not satisfied that we could have lawfully collected the information, then we will (if it is lawful and reasonable) destroy the information or ensure that it is de-identified.

You may choose to deal with us anonymously or under a pseudonym where lawful and practical. Where anonymity or use of a pseudonym will render us unable to provide the relevant service or do business, we may request that you identify yourself.

For example, whenever documents are to be submitted to government agencies or financial institutions, it is essential that we record your name accurately.