Arden Vale Homes Pty Ltd ACN 082 471 449, its subsidiaries and affiliates in Australia (together as “Arden Vale Homes”, “we” or “us”) are committed to protecting and managing your personal information in accordance with the Australian Privacy Principles (APPs) established under the Privacy Act 1988 (Cth) (Privacy Act). This document is referred to as our Privacy Policy, and it outlines our ongoing obligations to you in respect of how we manage your Personal Information, including how we collect, use, hold, store and disclose your information.

This Privacy Policy applies to your personal information and sensitive information regardless of how we collect it from you. Through submitting information to us or accessing and using our websites or social media platforms, you are providing your consent to Arden Vale Homes using and disclosing your personal information in the ways set out in this Privacy Policy.

What Personal Information will we collect?

We may collect the following information:

• contact information and personal data including your name, email address and phone number
• demographic information such as postcode, preferences and interests
• cookies and other device information - your session cookies and persistent cookies when you visit our website, your device type, browser type, Internet Protocol (IP) address, your URL information, the date and time (including time zone) of your visit, the pages you have accessed on our websites and third party websites, your software and hardware information concerning your mobile device or computer. You can choose to accept or decline cookies. Most web browsers automatically accept cookies but you can usually modify your browser setting to decline cookies if you prefer. This may, however, prevent you from taking full advantage of the Website.
• any other administrative and additional information that you provide to us or authorise us to collect.

Why do we collect Personal Information?

We only collect personal information (and sensitive information) that is necessary for, or related to, conducting our business, assessing and managing our customers and business needs or for one or more of our functions or activities. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. The purposes for which we collect and use your personal information depends on the nature of your interaction with us and include the following circumstances:

• responding to requests for information, feedback and other general enquiries;
• communicating with you and confirming your identity;
• providing you with our services or the purpose requested;
• administering or managing the services and products provided to you;
• informing you about our business and service offerings, news, updates, direct marketing material and event invitations (including though our social media platforms for our convenience):
• for data and marketing research and developing and improving our product and service offering;
• for any other purposes (including secondary purposes) that you would reasonably expect; and
• to enable us to comply with our obligations under the law.

We collect personal information (and sensitive information) in many ways, including by correspondence, telephone, email, via our website www.ardenvale.com.au, from your website, from media and publications, from other publicly available sources, and from third parties.

When we collect personal information we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it. However, all personal information collected is used in accordance with this Privacy Policy.

You can always decline to give us your personal information, but that may mean that we cannot provide you with some or all of the products and services that you have requested. Consequently, this may expose you to higher risks and may affect the adequacy or appropriateness of our products and services.

Third Parties

Where reasonable and practicable to do so, we will collect your personal information only from you. However, in some circumstances we may be provided with information by third parties or other sources. In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

Disclosure of Personal Information

During the conduct of our business, we may disclose your personal information in a variety of circumstances, including to the following parties:

• our affiliates, subsidiaries and related entities;
• our engaged contractors, agents, suppliers who provide or perform different services for us;
• commercial partners under an agreed information sharing arrangement;
• our marketing research service providers and digital marketing agents;
• third party website service providers and website plugin or widget service providers;
• our professional advisors, such as our lawyers, accountants and financial advisers;
• the relevant courts, tribunals or regulatory authorities and law enforcement bodies;
• anyone else to whom you authorise us to disclose your information or that would be reasonably expected;
• any other company or individual that it is necessary to disclose your personal information to enable us to provide you with the products or services that you have requested; and
• potential purchasers of our business for their due diligence investigations.

We take reasonable steps to ensure that the third parties we engage take reasonable steps to protect your personal information following the APPs and in a similar manner with this Privacy Policy. Our third-party service providers are required only to use the personal information disclosed to them by us for the purpose that it was provided to them. Additionally, the third parties who we have disclosed your personal information to may contact you directly to let you know they have collected your personal information and to give you information about their privacy policies.

We also use Google Analytics to help us understand how our customers use our platforms, products and services. You can read more about how Google uses your Personal Information here. You may also opt-out of Google Analytics here.

We disclose information to overseas recipients

Your personal information may be transferred abroad or stored overseas for a variety of reasons. It is not possible to identify each country to which your personal information may be sent. If your personal information is sent to a recipient in a country with data protection laws which are at least substantially similar to the APPs, and where there are mechanisms available to you to enforce protection of your personal information under that overseas law, we will not be liable for a breach of the APPs if your personal information is mishandled in that jurisdiction. If your personal information is transferred to a jurisdiction which does not have data protection laws as comprehensive as Australia's, we will take reasonable steps to secure a contractual commitment from the recipient to handle your information following the APPs.

Security of Personal Information

Arden Vale Homes takes reasonable steps to protect your personal information from unauthorised access, use, or disclosure.

With that in mind, there is no method of transmission over the internet or through electronic storage through our engaged providers that is fully secure. We cannot guarantee the security of your personal information. If we are required by law to inform you of any unauthorised access, use, or disclosure of your personal information, then we will notify you electronically, in writing or by telephone (if required and permitted to do so by law).

Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Anyone using our website is encouraged to exercise care in sending Personal Information via the internet.

We hold and store your personal information in any of the following ways:

• electronic record keeping methods; and
• trusted third party storage providers based in Australia and overseas, including cloud-based storage providers.

Electronic Storage

Your personal information is generally collected in electronic form for use or storage with the third-party storage provider that we engage.

Third-Party Storage

Your personal information is generally usually collected in electronic form for use or storage with the third-party storage provider that we engage.

We cannot ensure that your Personal Information is or will remain secure. This is due to us not having control over the third-party provider’s policies and procedures concerning the handling and storage of your Personal Information. We take reasonable steps to ensure that the third parties we engage take reasonable steps to protect your personal information following the APPs and a similar manner with this Privacy Policy.

The choices that you can make about your Personal Information

You can request your Personal Information to:

• be destroyed; or
• be de-identified; or
• be accessed; or
• be provided to you as a copy,

at any time by request to our Privacy Officer using the contact details provided below. We may not be able to entertain your request if it is unlawful to do so or is otherwise impractical or unreasonable to do so.

Deleting your personal information

When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. However, most of the Personal Information is or will be stored in customer files which will be kept by us for a minimum of seven (7) years.

Remaining Anonymous & De-Identification

We require you to provide specific details and information to provide our products and services to you. We provide everyone with the opportunity of staying anonymous or using a pseudonym in their dealings with us where it is lawful and practicable (for example, when making a general enquiry). Generally, it is not possible for us to deal with you anonymously or pseudonymously on an ongoing basis. If we do not collect your personal information, you may not be able to utilise the products or services, participate in our events, programs or activities we manage or deliver.

Accessing, correcting and updating your personal information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. You are responsible for ensuring that your Personal Information with us is accurate and updated regularly. We will take reasonable steps to ensure that the Personal Information we collect, use or disclose is accurate, complete and up to date. You can help us to do this by letting us know if you notice errors, inaccuracies or discrepancies in the information we hold about you and letting us know if your details change.

If you wish to access your Personal Information, please contact us in writing.

Arden Vale Homes will not charge any fee for your access request but may charge an administrative fee for providing a copy of your Personal Information and the reasonable time and expense incurred in compiling information in response to your request.

In order to protect your Personal Information, we may require identification from you before releasing the requested information.

Direct Marketing Material - You Can Opt-Out

We may use or disclose your personal information to inform you about our services, upcoming promotions and events, or other opportunities that may interest you. If you do not want to receive direct marketing communications, you can opt-out at any time by contacting us in writing using the contact details below. We will process your request as soon as practicable.

If you opt-out of receiving marketing material from us, then we may still contact you concerning our ongoing relationship with you.

Website Usage

Third party links

Our website may include links to websites operated by third parties. We have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our website and welcome any comment about linked websites.

Your consent by using our website

By using our website, you consent to this privacy policy.

Policy Updates

We may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website regularly to keep up to date with any changes. If there are any material changes to our Privacy Policy, then we will take reasonable steps to notify you of any changes by either sending you an email to your last known email address that we hold.

General Data Protection Regulation - GDPR Compliance

GDPR stands for the General Data Protection Regulation and is effective as of 25 May 2018. GDPR replaces national privacy and security laws that previously existed within the European Union (the EU) with a single, comprehensive EU-wide law that governs the use, sharing, transferring and processing of any personal data that originates from the EU.

In some circumstances, the European Union General Data Protection Regulation (GDPR) provides additional protection to individuals located in Europe. The fact that you may be located in Europe does not, however, on its own entitle you to protection under the GDPR. Our website does not explicitly target customers located in the European Union, and we do not monitor the behaviour of individuals in the European Union, and accordingly, the GDPR does not apply.

Privacy Policy Complaints and Enquiries

You may contact us at any time if you have any questions or concerns about this Privacy Policy or about how your Personal Information has been handled. You may make a complaint to the Privacy Officer using the contact details set out below.

Complaint handling process:

The Privacy Officer will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will contact you within thirty (30) days of the date we receive the written details of your complaint to acknowledge that we have received it. We may ask you to provide further information about your complaint and the outcome you are seeking.

Our Privacy Officer will review of the way we dealt with your Personal Information, conduct an internal investigation (if necessary) into the complaint and will respond to you within thirty (30) days of the date we acknowledged receipt of your complaint. If the matter is complicated or our investigation may take longer, we will let you know.

If you are not satisfied with the outcome of your complaint, you may refer the matter to the Office of the Australian Information Commissioner (OAIC).

Telephone: 1300 363 992
OAIC email address: enquiries@oaic.gov.au
OAIC complaints page: https://www.oaic.gov.au/privacy/privacy-complaints

Contact Information

We welcome your comments and questions about our Privacy Policy. Please contact our Privacy Officer at the following:
Attention: Tim Waring
Email: tim@ardenvale.com.au

This Privacy Policy was last updated on 29 July 2020.