JMO Property Group Privacy Policy

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JMO Property Group Pty Ltd recognises the importance of protecting the privacy and the rights of individuals in relation to their personal information. We are bound by the Privacy Act 1988 (Cth) (Act) and the principles set out in the Act.Ā  This document is our privacy policy and it tells you how we collect and manage your personal information.

We will ensure that all officers, employees and subcontractors are aware of and understand these obligations as well as their own obligations under the Act.Ā  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.

The purpose of this Policy is to:

  • Give you a better and more complete understanding of the kinds of personal information we collect and hold;
  • Clearly and concisely communicate how and when we collect, disclose, use, store and otherwise handle personal information;
  • Inform you about the purposes for which we collect, hold, use and disclose personal information;
  • Provide you with information about how you may access your personal information and seek correction of your personal information;
  • Provide you with information about how you may make a complaint, and how we will deal with any such complaint;
  • Advise you of the circumstances in which we are likely to disclose personal information to overseas recipients; and
  • Enhance the transparency of our operations.

For the purpose of this Policy, the following terms will have the following meanings, as attributed to them by Section 6 of the Act:

Personal information means:

Information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.

Sensitive information means:

  1. Information or an opinion about an individualā€™s:
    1. Racial or ethnic origin;
    2. Political opinions;
    3. Membership of a political association;
    4. Religious beliefs or affiliations;
    5. Philosophical beliefs;
    6. Membership of a professional or trade association;
    7. Membership of a trade union;
    8. Sexual orientation or practices; or
    9. Criminal record.
Collection of Personal Information

Whenever you deal with JMO Property Group, we will collect personal information in order to provide or prospectively provide, services and products to you.Ā  Such services and products include:

  • Our professional services;
  • Complaint resolution services;
  • Advisory services;
  • Updates about event, products and services which may be of interest to you; and
  • Other products and services you may wish to purchase or obtain.

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 includes but is not limited to:

  • Name;
  • Date of birth;
  • Residential address;
  • Business address;
  • Postal address;
  • Email address;
  • Home telephone number;
  • Work telephone number;
  • Mobile telephone number;
  • Names of your employers or employees;
  • Your occupation and business address;
  • Financial information including names of banks or financial institutions;
  • Credit reporting information;
  • Bank account information and credit card details;
  • Insurance related information;
  • Whether or not you are a smoker; and
  • Whether or not you own a pet.

Apart from the above, 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;
  • 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 practical to do so, collect your personal information directly from you.Ā  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 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.

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

What happens if we canā€™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, including information about discounts, sales or special promotions; or
  • We may be unable to tailor the content of our websites to your preferences and your experience of our website may not be as enjoyable or useful.
For what purposes, do we hold, use and disclose your personal information?

We collect personal information about you 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 ordinarily 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;
  • 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, related bodies corporate, contractors or service providers;
  • To provide your updated personal information to related bodies corporate, 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).
To whom may we disclose your information?

In order to achieve the purposes described above, we may disclose your personal information to the persons/organisations described below:

  • Any mediators or tribunal representatives if you utilise our dispute resolution processes;
  • Our employees, related bodies corporate, contractors or service providers for the purposes of operation of our website or our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
  • Your financial institution;
  • Persons or organisations involved in maintaining, reviewing and developing our business systems;
  • Suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes;
  • Organisations involved in payments systems including financial institutions, merchants and payment organisations; and
  • Any organisation for any authorised purpose with your express consent.

We will only use and disclose personal information for the primary purpose for which it was initially collected, or for purposes which are directly related to one of our functions or activities.

We will not disclose your personal information to government agencies, private sector organisations or any third parties unless one of the following applies:

  • You have consented;
  • You would reasonably expect, or have been told, that information of that kind is usually passed to those individuals, bodies or agencies;
  • It is otherwise authorised by law; and
  • It is reasonably necessary for enforcement related activities conducted by, or on behalf of, and enforcement body (e.g. the police).

Personal information provided to JMO Property Group may be shared with its related companies.Ā  We will take all reasonable and practical measures to keep such information strictly confidential.

JMO Property Group may transfer personal information to overseas countries in order to perform one or more of our functions and activities.Ā  In these circumstances, we will take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to the information.

Like many businesses in Australia, JMO Property Group may rely on third party suppliers or contractors to provide specialised services such as web hosting, cloud computing technology and data storage services.Ā  If personal information is provided to these suppliers and contractors in order to enable them to perform the agreed tasks we will make every effort to ensure the supplier or contractor handles the personal information in accordance with the act and the Australian Privacy Principles.

There may be circumstances in which it is necessary for us to collect a government related identifier such as your tax file number or Centrelink reference number.Ā  We will not use or disclose your government related identifiers unless we are required or authorised to do so by law or by a court or tribunal order, or in order to fulfil our obligations to a State or Territory authority.

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 theĀ Spam ActĀ 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.

Accuracy of Personal Information

JMO Property Group will take reasonable steps to ensure that all personal information it collects, uses or discloses is accurate, complete and up-to-date.

If you believe your personal information is not accurate, complete, or up-to-date, please contact us (see the Contacting Us section for more information).

How can you access your personal information?

You may request access to any personal information we hold about you at any time by contacting us (see the Contacting Us section or more details). Ā Ā We will acknowledge your request within 14 days of the request being made.Ā  Access will usually be given with 14 days of our acknowledgement or, if the request involves complex considerations or voluminous copying or scanning, we will contact you to provide you an alternative timeframe based on the circumstances and anticipated work involved.

You will be required to verify your identify before access to your personal information is granted.

While we cannot and do not charge an ā€œapplication feeā€ for you applying to access your personal information, we may charge a fee for actually giving you access to your personal information in your preferred format (where reasonable and possible), which will cover our costs involved in locating and collating information as well as reproduction costs.

Once your request has been received by JMO Property Group, you may be forwarded the information by mail or email or you may personally inspect it at the location where the information is held or another appropriate location. Ā Whenever possible, we will endeavour to make the information available to you in the manner requested by you unless it is unreasonable for us to do so (e.g. if you have asked for the information to be emailed to you, we will endeavour to email the information to you.Ā  If the file size would be too large, we may send you the information by hard copy instead of email).

If you are aware that we hold personal information about you that is no longer accurate, complete or up-to-date, please contact us (see the Contacting Us section for more information).

If you request access to your personal information, or if you request that we correct your personal information, we will allow access or make the correction unless we consider that there is a sound reason to withhold the information, or not make the correction.

Under the Act, we may refuse to grant access to personal information if:

  • We believe that granting access would pose a serious threat to life, health or safety of any individual, or to public health or public safety;
  • Granting access would have an unreasonable impact on the privacy of other individuals;
  • Denial of access is required or authorised by law or by a Court or Tribunal order;
  • Giving access would be unlawful;
  • The request for access is frivolous or vexatious;
  • Legal proceedings are underway or anticipated and the information would not be accessible by way of the discovery process of those proceedings;
  • Giving access would reveal our intentions in relation to negotiations between us and you in such a way as to prejudice those negotiations;
  • Giving access is likely to prejudice enforcement related activities conducted by, or on behalf of, an enforcement body;
  • Giving access is likely to prejudice action being taken or to be taken with respect to suspected unlawful activity or serious misconduct relating to our functions or activities; and
  • Giving access would reveal information in connection with a commercially sensitive decision making process.

If we do not agree to make a correction to your personal information, you may provide a statement about the requested corrections, and we will ensure that the statement is apparent to any users of the relevant personal information.

If we do not agree to provide access to your personal information or to correct your personal information, we will provide written reasons for the refusal and mechanisms available to complain about the refusal (see the Complaints section for more information).

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, you are entitled to complain to JMO Property Group (see the Contacting Us section for more information).

We will acknowledge receipt of a complaint within 2 business days.

We will investigate the complaint and attempt to resolve it with 20 business day after the compliant was received.Ā  Where it is anticipated that this timeframe is not achievable, we will contact you to provide an estimate of how long it will take to investigate and respond to the complaint.

If you consider we have not adequately dealt with a complaint, you may complain to the office of the Australian Information Commissioner on the details below:

Mail:

Officer of the Australian Information Commissioner (OAIC)

GPO Box 5218

Sydney NSW 2001

Email:

enquiries@oaic.gov.au

Phone:

1300 363 992

Security

Your personal information may be stored in hard copy documents or electronically.Ā  JMO Property Group is committed to keeping your personal information secure and safe.Ā  Some of the ways we do this are:

  • Requiring employees and contractors to enter into confidentiality agreements;
  • Secure hard copy document storage (i.e. storing hard copy documents in locked filing cabinets);
  • Security measures for access to our computer systems;
  • Providing a discreet environment for confidential discussions;
  • Security measures for our websites;
  • Anti-spam, anti-virus and anti-malware software; and
  • Secure premises.

We will review and update our security measures from time to time.Ā  In addition, we will review the personal information and sensitive information held by us from time to time, ensuring that information that is no longer needed for a purpose for which it was initially collected is destroyed or de-identified.

Your Privacy on the Internet

JMO Property Group takes care to ensure that the information you provide to us via our website is protected.Ā  For example, our website has electronic security systems in place, including the use of firewalls and data encryption.Ā  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.

Changes to our privacy policy

This policy is to be reviewed as follows:

  • Annually as a minimum;
  • Following an information security incident;
  • Following significant changes to our systems; and
  • Following changes to the relevant State and Commonwealth legislation.

Reviews are to examine the appropriateness of the policy taking into consideration corporate, system and compliance requirement changes since the last review was undertaken.

JMO Property Group reserves the right to change this Policy at any time and any amended Policy is effective upon posting to our website.Ā  JMO Property Group will make every effort to communicate any significant changes to you by email.Ā  Your continued use of our services will be deemed acceptance of any amended Policy.

Contacting us

If you have any questions about this privacy policy, any concerns or feedback regarding the treatment of your privacy, you may contact us by mail, email or telephone as follows:

Mail:

PO Box 570

ORMEAU Q 4208

Email:

enquiries@jmoproperty.com.au

Phone:

(07) 5517 5282