Personal Information and Sensitive Information
- Personal Information means information that identifies you or can be used to identify you, or from which you are reasonably identifiable such as your name, date of birth, contact details such as telephone number and email address, financial information such as bank details and credit card details, employment status, identification on your driver’s licence or passport and details of your property, property ownership and lease-holding interests.
- Sensitive Information is a sub-category of Personal Information which is likely to be particularly private for you such as your political opinions, your membership of a political association or trade union and whether you have a criminal record.
Sensitive Information generally receives greater protection under the Privacy Laws than other forms of Personal Information and our physical and technical systems are in place to protect Personal Information and Sensitive Information in accordance with the Privacy Laws.
- current, former or prospective directors, employees, contractors and agents of landlords of properties, their real estate agents and tenants of properties;
- individuals who have a commercial relationship with our business associates and suppliers; and
- other individuals who come into contact with Smarthouse in relation to our business.
We generally collect your Personal Information to enable us and our third party suppliers and affiliates, partners, agents and professional advisors to provide you with our products and services either directly or indirectly, to promote and market our services to you through promotional material and otherwise and to provide you with ongoing information about Smarthouse services.
We may collect your Personal Information for other legitimate, ancillary purposes including our compliance with the Privacy Laws.
We may also collect Personal Information of individuals to whom we market our services (including via our website, apps and tele messages).
How we collect your Personal Information
We will only collect Personal Information about you by lawful and fair means. We may collect Personal Information from you at various times throughout our interaction with you. We collect Personal Information from you in a variety of circumstances including when meeting you and interacting with you (via our website or otherwise).
How we hold your Personal Information
We will hold your Personal Information in physical or electronic records and we will take all reasonable steps to store your Personal Information securely to avoid misuse, interference, loss, unauthorised access, modification or disclosure.
We will comply with applicable security obligations under the Privacy Laws in relation to any Personal Information that we handle, hold and store including ensuring only relevant and authorised Smarthouse employees, contractors and agents deal with your Personal Information.
Smarthouse has a range of security controls in place (including physical, technical and procedural safeguards) designed to protect your Personal Information. These are upgraded from time to time.
Disclosure of your Personal Information
On occasions we may be required to disclose your Personal Information in accordance with applicable Privacy Laws.
We may disclose your Personal Information overseas
From time to time, in the ordinary course of our business, we may need to hold your Personal Information on servers which are located outside of Australia.
It is possible that our service providers located overseas may be subject to foreign laws that do not provide the same level of protection of Personal Information as in Australia. In this case we will use reasonable endeavours to ensure that such overseas service providers are obliged to protect the privacy and security of your Personal Information and use it only for the purpose for which it is disclosed.
You consent to the collection, use, storage, and processing of your Personal Information outside of Australia.
Accuracy and Access to Personal Information
We take reasonable steps to ensure that the Personal Information about you that we collect, use and disclose is accurate, complete, up-to-date and relevant.
You may request to update your Personal Information at any time in which case we will do so in a timely manner and in any event in accordance with the Privacy Laws.
If you request to access your Personal Information, we will grant your request within a reasonable period of time unless providing you with access would unreasonably impact upon the privacy of others or be otherwise prohibited by relevant laws including the Privacy Laws.
In the case of requests to update or access your Personal Information, we may require you to substantiate your identity to protect you from fraud and privacy breaches perpetrated by third parties pretending to be you.
Where access to Personal Information is legitimately denied, Smarthouse will provide you with written reasons for the refusal of access.
When and how we dispose of your Personal Information
We seek to keep your Personal Information for only as long as it is required in order to:
- provide you with after-service support including customer care services and the fulfilment of contractual warranties and guarantees;
- allow us to legitimately perform our business functions and activities after our dealings with you have concluded;
- allow us to legitimately comply with our legal obligations including those imposed on us by the Privacy Laws.
When your Personal Information is no longer needed for these purposes, we will take reasonable steps to destroy or permanently de-identify your Personal Information.
If your Personal Information is hacked or inadvertently disclosed
If we become aware that we have inappropriately used or disclosed your Personal Information, or that the security of your Personal Information has been compromised, including by way of third party data hacking (a data breach), and we are unable to rectify the data breach without any potential adverse effect on your privacy, we may contact you to inform you, and to work with you to minimise or mitigate the consequences of the data breach. In the case of a data breach, we may also be required to notify the Office of the Australian Information Commissioner and other relevant third party organisations in accordance with the Privacy Laws. Where we are legally entitled to do so we will notify you of such disclosure.
How to contact us and more information
Write to: Campbell Brown
You can find out more information about the Privacy Laws including the Privacy Act 1988 and the Australian Privacy Principles from the Australian Information Commissioner. The Information Commissioner may be contacted at www.oaic.gov.au (email – firstname.lastname@example.org).