This version current as at: 4 November 2019
Propic Australia Pty Ltd (“Propic”, “We”, “Us”, “Our”) is committed to providing secure and trustworthy technology solutions for the property industry that ensure the privacy, accuracy and security of individuals’ personal information.
In this Policy:
- Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether or not recorded in a material form; and
- Sensitive information (a subset of personal information) means information or an opinion about an individual’s race or ethnic origins, political opinions and associations, religious beliefs or affiliations, philosophical beliefs, sexual preferences or practices, trade or professional associations and memberships, union membership, criminal record, health or genetic information or biometric information.
Third party websites and social media
Whose personal information do we collect?
We may collect personal information from a range of sources, including from you, business partners and clients, recruitment agencies, contractors and government agencies. For example, we may collect your personal information when you or a Propic client request or acquire a service or product from us, provide a service or product to us, apply for employment with us or communicate with us via our website, by email, telephone or in writing.
Type of personal information collected
The personal information we collect includes:
- names, addresses, date of birth, relationship status and next of kin, email addresses, phone numbers, and real estate buying, selling and leasing preferences;
- other details about customers of our real estate clients including potential and actual buyers and sellers, landlords and tenants, and lessors and lessees;
- details necessary to initiate, manage and complete real estate transactions;
- bank account details;
- information about staff and directors, as required in the normal course of human resource management and the operation of a business; and
- information about current and previous Propic suppliers and clients with whom we have dealings.
We will only collect your sensitive information if you have consented to us doing so – for example, as part of information collected about directors and employees for company and human resource management purposes, or where required or permitted by law.
How and why do we collect personal information?
We only collect personal information by lawful and fair means. We usually collect personal information from:
- our clients and business partners – for example, in order for us to supply services and goods;
- face-to-face meetings, interviews and telephone calls;
- applications (Mobile Applications) that clients or clients’ authorised individuals (Users) download to, and run on, their mobile devices (Devices). Mobile Applications provided by Propic may obtain information from, or access data stored on, Users’ Devices where this is necessary to provide services related to the relevant Mobile Application;
- electronic communications – for example, emails and attachments, instant chat messages, forms filled out by people, including as part of acquiring a product or service from us;
- third parties – for example, from recruitment agencies and your representatives or agents; and
- our website, including if you use it to contact us.
We collect the personal information necessary:
- for us to provide the products and services requested from us, including to help manage and complete real estate-related transactions;
- for marketing purposes and to provide information about products and services that may be of interest to you, our business partners and our clients;
- to improve the products and services we provide; and
- to enable us to conduct our business, including meeting our legal and regulatory obligations.
If personal information is not provided, we may not be able to supply the requested product or service, employ you or otherwise deal with you.
Dealing with unsolicited personal information
If we receive personal information that we have not requested, and we determine that we could not have lawfully collected that information under the APPs had we asked for it, we will destroy or de-identify the information if it is lawful and reasonable to do so.
Disclosing your identity
Where lawful and practicable, we allow individuals the option of interacting with us anonymously or using a pseudonym.
Use of information collected
Propic only uses personal information for the purpose for which it was provided to us, for related purposes, or as required or permitted by law. Such purposes include:
- in the ordinary course of conducting our business. For example, supplying or acquiring products and services, responding to enquiries and feedback, and providing information about our events, news, publications, products and services that may be of interest;
- market research and product and service development, so that we are able to better understand our clients’ needs and tailor our future products and services accordingly;
- performing general administration, reporting and management functions. For example, invoicing and account management, payment processing, risk management, training, quality assurance and managing suppliers;
- employment-related purposes, such as recruiting and providing services to staff;
- as part of a sale (or proposed sale) of all or part of our business; or
- other purposes related to or in connection with our business, including meeting our legal and contractual obligations to third parties and for internal corporate governance purposes.
Disclosure of personal information
We may disclose your personal information to third parties:
- engaged by us to provide products or services, or to undertake functions or activities, on our behalf. For example, processing payment information, providing and managing technology solutions and databases, marketing, research and advertising. These recipients are authorised to use your personal information only as necessary to provide products and services, or to undertake functions and activities for us;
- that are our business partners, clients, joint venturers or agents;
- as part of a sale (or proposed sale) of all or part of our business. For example, we may disclose information to our external advisers, to potential and actual bidders and to their external advisors;
- such as our external advisers, and government agencies. For example, where disclosure is reasonably required to obtain advice, prepare legal proceedings or investigate suspected unlawful activity or serious misconduct; or
- as required or authorised by law. For example, to comply with a subpoena, or similar legal process or where you consent to the disclosure.
We do not sell personal information to third parties.
Propic may post lists of customers and testimonials on propic.com.au that contain information such as customer names and titles. Where you provide a testimonial, you consent to your name and title being disclosed on our website. To request removal of your personal information from our blog or forum, or to have reference to you or your company removed, or to have your testimonials removed, please contact us.
We may use and disclose your personal information (other than sensitive information) to provide you with information about our products and services that we consider may be of interest to you. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails.
Customers cannot opt out of receiving transactional emails related to their use of Propic’s products and services.
Disclosure of information overseas
We may disclose your personal information to overseas recipients – for example, when storing personal information online or “in the cloud”. However, we will not send your personal information overseas without obtaining your consent (this may be implied) or otherwise in compliance with the APPs. Any overseas disclosure does not affect our commitment to safeguarding personal information. Where reasonable in the circumstances, our contracts with overseas recipients oblige them to comply with the APPs and the Act.
The security of personal information is important to us.
We take reasonable steps to protect personal information from misuse, interference and loss, and unauthorised access, modification and disclosure. Such steps include:
- encrypting the transmission of information using industry standard SSL or better encryption;
- physical security over paper-based and electronic data storage and premises;
- computer and network security measures, including use of firewalls, password access and secure servers;
- restricting access to personal information to employees and those acting on our behalf who are authorised and on a ‘need to know’ basis;
- retaining personal information for no longer than it is reasonably required, unless we are required by law to retain it for longer; and
- entering into confidentiality agreements with staff and third parties.
Where we no longer require personal information, and there are no legal obligations to keep records containing the personal information, we will ensure that the information is de-identified or destroyed.
Data quality and updating information
We take reasonable steps to ensure that personal information we hold is accurate, complete and up-to-date. However, we rely on you, and in some cases our clients, to advise us of any changes or corrections to the information we hold about individuals. If you consider that the information we hold about you is not accurate, complete or up-to-date, or if your information has changed, please let us know as soon as possible.
Where we hold personal information collected from one of our clients, individuals wishing to update that information should in the first instance seek to update it through that client.
You may request access to the personal information we hold about you by contacting us. We will respond to your request within a reasonable time. We will provide you with access to the information we hold about you unless otherwise permitted or required by law. If we deny access to the information, we will notify you of the basis for the denial unless an exception applies. Where reasonable and practicable, we will provide access to the information we hold about you in the manner you request. No fee applies for requesting access to information we hold about you. However, we reserve the right to charge a reasonable fee where we do provide access.
Where we hold personal information collected from one of our clients, individuals wishing to access that information should in the first instance seek access through that client.
If you believe that personal information we hold about you is incorrect, incomplete or not current, you may request that we update or correct your information by contacting us. We will deal with your request within a reasonable time. If we do not agree with the corrections you have requested (for example, because we consider that the information is already accurate, up-to-date, complete, relevant and not misleading), we are not required to make the corrections. However, where we refuse to do so, we will give you a written notice setting out the reasons.
Where we hold personal information collected from one of our clients, individuals wishing to correct that information should in the first instance seek correction through that client.
If you have a complaint in relation to the collection, storage, use or disclosure of your personal information, please contact our Privacy Officer using the details below. You will need to provide us with details of your complaint, as well as any supporting evidence and information. We will review all complaints received and our Privacy Officer will respond to you. If you are not satisfied with our response, you may discuss your concerns with or complain to the Australian Privacy Commissioner via www.oaic.gov.au.