CBH Property Group and its related bodies corporate (CBHPG, we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This Privacy Policy sets out how we collect and manage personal information and the steps we take to protect it.

CBHPG respects your rights to privacy under the Privacy Act 1988 (Cth) (Act) to ensure we handle personal information in accordance with the Act and complies with all of the Act’s requirements in respect of the collection, management and disclosure of personal information, including the Australian Privacy Principles.

 

What is your personal information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

 

What personal information do we collect and hold?

Depending on the services which we provide to you, we may collect your name, mailing or street address, email address, telephone number, facsimile number, age or birth date, employment details such as profession, occupation or job title, employment status, employer, salary, length of employment, governmental identification details such as driver’s license number, passport and/or other forms of identification, tenancy agreements, personal and financial referees in relation to your application, desired property details, and any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise and information you provide to us through our service centre, customer surveys or visits by our representatives from time to time.

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 aggregated information about how users use our website and historical transaction details.

 

How do we collect your personal information?

CBHPG collects your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:

• through your access and us of our website
• by telephone, letter, fax or email
• during conversation between you and out representatives
• by contracting with us
• by entering competitions, promotions or requesting information or material from us
• completing surveys, providing feedback or complaining to us

CBHPG may also collect information about you from the following third-parties including:

• from third party companies such as law enforcement agencies, credit reporting agencies, and government entities
• your employer
• your representatives (lawyers, accountants and financial advisers)
• publicly available sources of information or any other organisations where you have given your consent

 

In some cases, we may also collect your information while you are accessing our website, through the use of cookies. “Cookie” is a small summary file containing a unique ID number to your computer. This enables us to recognise your computer and greet you each time you visit our website without bothering you with a request to register. It also enables us to keep track of products or services you view so that, if you consent, we can send you news about those products or services. We also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online products and services. Our cookies do not collect personal information. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.

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.

 

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 products or services to you, either to the same standard or at all
• we may not be able to provide you with information about products and services that you may want or
• we may not be able to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.

 

For what purposes do we collect, hold, use and disclose your personal information?

We collect personal information 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 products and services to you and to send communications requested by you
• to answer enquiries and provide information or advice about existing and new products or services
• to provide you with access to protected areas of our website
• to assess the performance of the website and to improve the operation of the website and our business
• 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), planning, product or service development, quality control, survey and research purposes of CBHPG, its related bodies corporate, contractors, franchisees, franchisees’ real estate agents or service providers
• for tenancy verification and identity purposes
• to provide your updated personal information to our related bodies corporate, owners corporation, 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, 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 (or political sub-division of a country).

Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

 

 

 

To whom do we disclose personal information?

We may disclose your Personal Information:

• to our employees, related bodies corporate, contractors, franchisees, franchisees’ real estate agents and employees or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide services to you. This includes, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, utilities providers, and professional advisors such as accountants, solicitors, business advisors and consultants;
• if you are a tenant of any property that we are managing, to the National Tenancy Database;
• to suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and
• to any organisation for any authorised purpose with your express consent.

There are some instances when CBHPG need to provide your Personal Information to third parties. CBHPG and its subsidiaries may be bound by law to provide your details to government-related bodies, including the Titles Office or the Residential Tenancies Bond Authority.

CBHPG does not sell your personal details to other organisations. We may however use the information about you to assist us with internal marketing and research.

 

Direct marketing materials

We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). 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 and we will then ensure that your name is removed from our mailing list.

 

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). CBHPG may charge you a reasonable fee to cover its administrative and other reasonable costs in providing the information to you. CBHPG will not charge for simply making the request and will not charge for making any corrections to your personal information.

 

CBHPG may not be able to provide access to information in some situations, including:

• where granting access would interfere with the privacy of others or if it would result in a breach of confidentiality.
• where your request for access is, in CBHPG’s opinion, frivolous or vexatious, or where providing access would be unlawful, may prejudice an investigation of possible unlawful activity, may prejudice enforcement of law, or denying access is specifically authorised by law.

 

To obtain access to your personal information:

You will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected, and

• CBHPG requests that you be reasonably specific about the information you require.
• 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 us using the contact information below and provide details of the incident so that we can investigate it. We will deal with the complaint in accordance with our then current Complaints Handling Procedure.

 

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. 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 may disclose your personal information to entities located outside of Australia, including the following:

• our related bodies corporate, located in foreign countries,
• our data hosting and other IT service providers, located in various countries; and
• other third parties located in various foreign countries.

We may disclose your personal information to entities with Australia who may store or process your data overseas, In the event that a disclosure is made in an overseas country (which we consider unlikely), the information will not be protected by the Australia Privacy Principles. In any event, by providing your details, you consent to your information being disclosed in this manner.

 

Security

CBHPG will take reasonable steps to ensure information CBHPG collects, uses or discloses is stored in a secure environment that is accessed only by persons authorised by CBHPG so as to prevent interference, misuse, loss, unauthorised access, modification or disclosure. However, as our website is linked to the internet, and 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.

 

Links

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.

 

Contacting us

If you have any questions about our privacy policy, any concerns or feedback regarding the treatment of your privacy, please contact our Privacy Officer using the details set out below.

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.

 

Privacy Officer

Email: contact@cbhpg.com.au

 

Changes to our Privacy Policy

We may change this Privacy Policy from time to time and any updates will be posted on our websites. This Privacy Policy was last updated on 31st May 2020.