This policy explains how Rose Property Group Pty Ltd, Rosecorp Marketing Pty Ltd, Rose Group Marketing Pty Ltd and Beaches CHB Pty Ltd (Rose Group) collect, store, use and disclose personal information (Policy). The purpose of this Policy is to assure anyone who interacts or does business with Rose Group that Rose Group will use its best endeavours to comply with both the letter and spirit of the Privacy Act 1988 (Cth) (the Act).
Compliance with Privacy Legislation
It is Rose Group’s policy to respect the confidentiality of information and the privacy of individuals. Rose Group complies with the Australian Privacy Principles (APPs) contained in the Act. The principles are designed to protect the privacy of individuals by regulating the way entities handle personal information. In summary, the Act defines ‘personal information’ as information or an opinion about an identified individual or an individual who is reasonably identifiable.
Collection of Personal Information
Rose Group collects personal information from you in a number of different ways. We may collect personal information directly from you or in the course of our dealings with you, for example when you provide personal information to us:
– In person
– By email
– Over the phone; or
– Through use of our website (for instances where you fill out an online enquiry form)
Rose Group may also collect personal information about you from publicly available sources of information and, if you consent, from third parties (including third party selling agents or references). The personal information we collect about you may include (but may not be limited to) your:
- Contact details (eg phone number, address, email address etc);
- Age and other demographic information;
- Internet Protocol address;
- Customer preferences in relation to our products and services; and
- For job applicants, education and employment history.
The purposes for which we collect your personal information will vary depending on your relationship with us, and may include:
- Verifying your identity;
- Contacting you;
- Responding to your queries;
- Providing you with information in relation to our developments and properties;
- Developing and improving our services and obtaining feedback;
- Providing you with marketing information and materials related to our developments and properties, including, where you have opted in, via email or other digital communications; and for job applicants, assessing your application for employment with us.
If Rose Group is not able to collect personal information about you we may not be able to provide you with services and assistance to the extent that they require us to collect, use or disclose personal information, or, in the case of job applicants, assess your application for employment.
Use and Disclosure of Personal Information
Rose Group operates a number of businesses, which handle personal information. Rose Group’s policy is to use or disclose personal information for the purpose for which it was collected. Rose Group may also use or disclose your personal information for any secondary purpose that is related to a purpose for which we collected it, where an individual would reasonably expect it to be used or disclosed for that purpose.
We may also use or disclose your personal information where the use or disclosure is authorised or required by law. If Rose Group wishes to use or disclose the personal information in other circumstances we will obtain the customer’s prior consent to do so.
Sharing Personal Information with Other Organizations
We may also disclose your personal information to third parties, including disclosure to:
– Our related companies;
– Contractors performing services for us (including third party selling agents); and
– Other third party service providers we use in conducting our business (such as information technology service providers and banks).
We require that third party organizations to whom we disclose your personal information (for example, a company which helps maintain Rose Group’s computer systems or sends out Rose Group mail) to acknowledge the confidentiality of this information, respect any individual’s right to privacy and comply with the APPs and this Policy. We also require that these organizations use this information only for the purposes for which we collected the information (or a secondary related purpose as described above) and otherwise follow our reasonable directions with respect to this information.
As mentioned above, Rose Group may send advertising mail to its customers, including, where they have opted in, via email or other digital communications. If a customer no longer wishes to receive such promotional information from Rose Group, the customer should advise the Rose Group Privacy Officer using the contact details in the ‘Contact Us’ section below.
Storage and Security of Personal Information
Rose Group will take reasonable steps to protect personal information that it collects and to ensure that the information is accurate and up-to-date.
The Rose Group electronic database is held on a secure server system domiciled in Australia with strict access controls monitored by our third party contractor. The Rose Group electronic database is password protected on encrypted hardware and can only be accessed by a limited number of senior employees and personnel of Rose Group and third party database contractors. All access events by personnel of Rose Group and the third party database contractor are digitally recorded by the database system. During the collection of your personal information some data is recorded on hardcopy forms. These forms are stored in secure facilities at the location of the data collection, such as a display centre.
Access to and Correction of Personal Information
Customers have a right to request access to personal information about them held by Rose Group. To obtain a copy of the personal information, please contact the Rose Group Privacy Officer using the contact details in the ‘Contact Us’ section below. As a security measure, Rose Group may require personal identification from you to verify your identity before providing this information to you.
If a customer wishes to change or update personal information that is inaccurate or out-of-date, they may contact the Rose Group Privacy Officer using the details given in the ‘Contact Us’ section below.
If you have any questions or concerns about our collection, use or disclosure of personal information, or if you believe we have not complied with this Policy or the Act, please contact us as set out below. Our Privacy Officer will investigate the complaint and determine whether a breach has occurred and what action, if any, to take.
Rose Group will take any privacy complaint seriously and will aim to resolve any such complaint in a timely and efficient manner, and our target response time is 30 days.
Rose Group expects our procedures will deal fairly and promptly with your complaint. However, if you remain dissatisfied, you can also make a formal complaint with the Officer of the Australian Information Commissioner (which is the regulator responsible for privacy in Australia):
Office of the Australian Information Commissioner (OAIC) Complaints must be made in writing:
Director of Compliance
Office of the Australian Information Commissioner (OAIC)
GPO Box 5218 Sydney NSW 2001
1300 363 992
If you have any questions or would like further information about how Rose Group handles personal information, please contact our Privacy Officer on (02) 8302 1400, at firstname.lastname@example.org or at 51 Riley Street Woolloomooloo NSW 2011.
Updates to this Policy
Rose Group reserves the right to change this Policy at any time. Rose Group will notify any changes by posting an updated version of the Policy on the website. Policy last updated: 3 June 2014