Privacy Policy

Caydon Group Holdings Pty Ltd (ACN 156 445 984) and its related bodies corporate including JESC Holdings Pty Ltd (ACN 611 079 344) and its related bodies corporate and CP IP Holdings Pty Ltd (ACN 622 221 729) and its related bodies corporate (together Caydon, we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. This document is our privacy policy and it tells you how we collect and manage your personal information, including when you use our website at (www.caydon.com.au).

We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and we comply with all of the Act’s requirements in respect of the collection, management and disclosure of your personal information.

What is your personal information and sensitive information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Privacy 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 sometimes sensitive information (defined below). If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

When used in this privacy policy, the term “sensitive information” has the meaning given to it in the Privacy Act. This may include information about your racial or ethnic origin, political opinions, political associations, memberships of any professional or trade associations, membership of trade unions, criminal records or health information.

What personal information do we collect and hold?

We may collect the following types of personal information, depending on your interaction with us:

- Name, date of birth and other identification details (including, where relevant, your passport details);
- contact details include mailing or street address, email address, telephone number;
- details of your employment;
- financial information about you, such as your income details and bank account;
- any additional information that you chose to provide to us directly through our website or through our surveys, including our Customer Portal and any Resident Portals that we operate for and on behalf of the owners corporation in the properties developed by us (collectively website portals);
- passwords created for website portals;
- details of your interests in our properties, your purchase of properties from us, the services that you acquire from us, together with any additional information necessary to complete the purchase transactions and to respond to your enquiries;
- any additional information relating to you that you provide to us through use of our websites or online presence, or through our representatives or during your visits to our display show rooms or purchase centres;

We may collect some sensitive information about you such as any pre-existing medical conditions, but such information will only be collected where you choose to provide it to us through the website portals.

We are required, in certain circumstances such as where you wish to purchase a property, to collect your name, address, date of birth and other verification information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or the Foreign Acquisitions and Takeovers Act 1975 (Cth) to verify your identity and your residential status.

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 anonymous or aggregated information using web tracking technologies about how users use our website.

How do we collect your personal information?

We collect your personal information generally directly from you unless it is unreasonable or impracticable to do so (for example, where you engage one of our agents). When collecting personal information from you, we may collect in ways including:

- through your access and use of our website, including the website portals;
- during conversations and correspondences between you and our representatives, including our agents based in Australia or overseas; or
- when you complete an application, a survey, a registration form or purchase contract.

To the extent permitted by, law, we may also collect personal information from third parties including from third party companies such as credit reporting agencies, law enforcement agencies and other government entities. Otherwise we do not generally collect personal information from third parties, except that we may collect limited personal information about a person from users of our website portals (for example, where you are listed as an emergency contact of a residence in one of our properties).

Cookies and other tracking technologies

In some cases we may also collect your personal information through the use of cookies. When you access our website, we may send a “cookie” (which 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 or login to website portals. Cookies also enable us to keep track of web pages and our properties, opportunities and services that you view so that, if you consent, we can send you news and updates relating to your interests. We also use cookies to measure and analyse 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. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them. Please note that some services or features of our website will not function so well if cookies are disabled.

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.

We and our advertising partners also use advertising cookies and other web-tracking technologies, such as pixel tags and web beacons to collect information about browsing habits, analyse trends, administer our websites, track users web movements, gather broad demographic information and other marketing purposes. These are also used to make advertising more relevant to you and your interests.

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 website portals to you, either to the same standard or at all, or some features may not function properly;
- we may not be able to provide you with information about our properties, opportunities and services that you may want, including information about new developments, sales or special promotions;
- we may not be able to complete a sale transaction with you; or
- we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.

You are never required to provide us with sensitive information to be able to use our website portals.

For what purposes do we collect, 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 for the following purposes:

- to provide the website portals and facilitate interaction between users of our websites and website portals, products and services to you and to send communications requested by you;
- to answer enquiries, provide customer services, and provide information or advice about our properties, opportunities and services;
- to complete property transactions with you, including to conduct background checks where necessary (for example if required in relation to a proposed purchase);
- 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 and advertising), planning, product or service development, quality control and research purposes of Caydon, its related bodies corporate, contractors or service providers;
- to provide your updated personal information to our 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;
- to generate statistics and derive insights from our data; 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.

Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy. We will never share or sell your sensitive information.

We utilise the services of third parties for marketing purposes, including online platforms and social media platforms, and we will disclose personal information about you to the third party service provider for our marketing purposes. While these third parties generally only use the personal information for our marketing purposes, some may retain certain personal information about you for their own purposes.

Where we collect personal information from a user of our website that relates to someone who is not the user, we will only use that personal information for the purpose for which it was collected (for example, to contact them in the event of an emergency). You must only submit the personal information of another person if that person has read and understood this privacy policy, and agrees to you providing that person’s personal information to us.

To whom may we disclose your information?

We may disclose your personal information to:

- 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 or completing a property transaction with you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, data entry service providers, electronic network administrators, and professional advisors such as accountants, solicitors, business advisors and consultants;
- suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes; and
- any organisation for any authorised purpose with your express consent or where required by law.

Our website portal may include functionality that permits you to post information (such as bulletin boards). Such information will be disclosed to other users of the website portal.

We may combine or share any information that we collect from you with information collected by any of our related bodies corporate (within Australia).

Direct marketing materials

We (or our service providers and advertising partners) may send you direct marketing communications and information about our properties, opportunities and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, targeted advertisements, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). You consent to us sending you those direct marketing communications by any of those methods. 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.

Please note that we also carry out digital advertising campaign from time to time that do not rely on your personal information. Your opt-out will not have effect on such advertising campaigns.

We do not use your sensitive information for the purposes of direct marketing.

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

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.

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 our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.

We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Our Privacy Officer deals with privacy complaints and any complaints should be directed to our Privacy Officer using the contact details below. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.

If you are not satisfied with the way your privacy-related complaint is handled by us, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC). Details of how to lodge a complaint with the OAIC may be found at www.oaic.gov.au or by calling 1300 363 992.

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. Our IT systems that hosts our data (which may include your personal information) may also reside outside Australia.

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 the United States of America; and
- our data hosting and other IT service providers, located in the United States of America.

Security

We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed.

Our security measures include:

- role based access control to our ICT systems;
- locked cabinets for storage of physical records containing personal information;
- regular security vulnerability and penetration reviews and tests;
- approach level of security training for technology staff and the broader business;
- identity and access management processes and controls to key systems and information; and
- external penetration testing of all systems holding sensitive data.

As our website is linked to the internet, and the 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 this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or 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.

Please contact our Privacy Officer at:

Privacy Officer
Caydon Group Holdings Pty Ltd
Post: Level 2, 436 Johnston Street, Abbotsford, VIC, 3067, Australia
Tel: +61 (3) 9416 3400
Email: privacyofficer@caydon.com.au

Changes to our privacy policy

We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website. Please review it regularly.

This privacy policy was last updated on 12 June 2018.