Compare Villages Pty Ltd ABN 59 618 426 574 (“Compare Villages”, “we”, “us” or “our”) has implemented this Privacy Policy to provide users of our website www.comparevillages.com.au across desktop, mobile, tablet and app (as applicable) (“Compare Villages Platform”) and our other products and services with information about how we collect, hold, use and disclose your personal information. We will only collect, hold, use or disclose personal information in accordance with the Privacy Act 1988 (Cth) (“Act”) and this Privacy Policy.
By
using the Compare Villages Platform or our other products and services, or
providing your personal information to us, you are taken to have read, and agreed
to the collection, handling, use and disclosure of your personal information in
accordance with this Privacy Policy. Your use of the Compare Villages Platform
is also subject to the Platform Terms.
You
acknowledge that the personal information you provide to us and which we
collect from you, is your own information or information which you have been
authorised to provide to us.
1.
Collection
1.1
We
collect your personal information to allow us to conduct our business, in order
for you to (amongst other things):
(a)
use the
Compare Villages Platform;
(b)
enquire
about a property;
(c)
contact
or correspond with us;
(d)
buy or
otherwise receive our products or services;
(e)
register
for or use an account or subscription package with us;
(f)
request
information about us, our products or our services or third party products or
services;
(g)
provide
feedback or lodge an enquiry with us;
(h)
post or
contribute material on the Compare Villages Platform;
(i)
or for your
employer to, provide that information to us in the course of conducting or
administering our relationship with you; and
(j)
submit
a job application to us.
1.2
We may
also collect personal information from third parties (such as governmental, law
enforcement and other public authorities and commercial information suppliers)
and other publicly available information about you.
1.3
If we
engage with you multiple times over a short period in relation to the same
matter we may not provide you with a separate notice
about privacy each time we engage with you.
1.4
We may
collect personal information such as (but not limited to):
(a)
your contact details such as name, postal and email address
and telephone number;
(b)
your date of birth (or age);
(c)
your gender; and
(d) any other information from your curriculum vitae or job application submitted to us.
1.5
Non-personal
information may also be collected by our third party service providers who
assist us in operating the Compare Villages Platform. This may include behavioural
data related to your activities on the Compare Villages Platform collected via:
(a)
tracking technologies such as Google Analytics, Hotjar and Laravel
Web Framework;
(b)
clickstream data, cookies, web beacons;
(c)
third party content providers such as social media sites and links;
and
(d)
call tracking software.
Cookies
may be used to collect information in an anonymous form, including information about
the number of visits, the pages you visit and the device and software you are
using. Your cookie preferences can be configured on your browser. We use the
information collected by these technologies to prepare reports and improve the
customer experience of the Compare Villages Platform.
1.6
The
Compare Villages Platform makes use of location-aware technologies in order to
present geographically appropriate content. Whilst using the Compare Villages
Platform, anonymous user location information is obtained (e.g. rough latitude
and longitude) through the user’s IP address in order to present more relevant
data. This information is not shared with any third party providers, although
they may collect similar information, governed by their own privacy policies.
1.7
The
Compare Villages Platform may contain links to sites or services operated by
third parties. We are not responsible for those third parties. Access or use of
third party sites and services is subject to the third party’s terms and
conditions, security processes and privacy policies e.g. if you use Google Maps
you must agree to Google’s terms
of service and privacy
policy.
2.
Purposes
2.1
We use
the personal information we collect about you to conduct our business, in
particular to provide your personal information to the retirement village owner
or operator (or their service providers) so they can contact you directly about
your property enquiry when you enquire about their property. Other purposes for
which we collect your information may include:
(a)
communicating
with you and providing you with information, products or services you have
requested;
(b)
responding
to your enquiries;
(c)
notifying
you about changes to the Compare Villages Platform, products or services;
(d)
managing
and administering any account you may hold with us;
(e)
promoting
and marketing our products and services to you or providing you with
information about products or services which we believe may be of interest to
you from us, our partners and selected third parties;
(f)
personalising
and customising your experience on the Compare Villages Platform;
(g)
providing
a better or more relevant product or service to you, for example by
automatically populating forms on the Compare Villages Platform when you make
enquiries of retirement village owners or operators;
(h)
combining
your personal information with information we have collected from our related
entities, partners, service providers, third parties and cookies or web beacons
to improve the quality of our products or services and the products or services
of third parties. For example, we may combine behavioural data we have
collected about you through cookies or web beacons and combine it with your
personal information from requests you send to third parties through the
Compare Villages Platform;
(i)
researching
the needs of our customers to help us improve;
(j)
processing
any job application submitted by you;
(k)
if you
are an employee or other representative of a customer to which we provide our
products and services or a provider of services to us, communicating with you
about your or your employer's engagement with us and otherwise as specified in
this Privacy Policy;
(l)
managing
our accounts and carrying out debt recovery functions;
(m)
sharing
your personal information with our related entities, partners and selected
third parties so that they can provide you with products or services on our
behalf or help us to provide you with the requested products or services
including contacting you in relation to the products or services; and
(n)
enforcing
this Privacy Policy and the Platform Terms.
2.3
Whereas
we use or disclose your personal information for the purpose for which it was
collected we may also use and disclose your personal information for a
secondary purpose that is related to the purpose for which it was collected,
where you would reasonably expect us to use or disclose your personal
information for that secondary purpose.
2.4
We do
not otherwise collect, use or disclose your personal information without your
permission, unless the collection, use or disclosure is required or permitted by law, in accordance
with this Privacy Policy or any other agreement you enter into with us.
2.5
If you
choose not to provide your personal information to us for the purposes set out
in this Privacy Policy, we
may not be able to provide you with requested information, products or services
to the extent that they require us to collect, use or disclose personal
information.
3.
Disclosure
3.1
We
may disclose, or provide access to, your personal information to third parties
in connection with the purposes described in this Privacy Policy. We may disclose your personal information to
our related entities, our partners and third parties that provide products and
services to us or through us, or to other third parties e.g. we disclose your personal information
to the Compare Villages Platform hosting, back-up and other software and service
providers.
3.2
We may
also disclose your personal information to relevant public, government or
regulatory authorities, our legal representatives or other concerned parties,
in special situations where we have reason to believe that disclosing your
personal information is necessary to help identify, contact or bring legal
action against anyone damaging, injuring, or interfering (intentionally or
unintentionally) with our rights or property, users or anyone else who could be
harmed by such activities, or where we are otherwise authorised or required to
do so by law.
3.3
If you make an enquiry
to or request information from any company through the Compare Villages
Platform, you will need to check their privacy policy to find out how they
handle your personal information. We are not responsible for the way these companies
collect, use, disclose or handle personal information you provide to them
through the Compare Villages Platform.
3.4
Some of
the third parties to whom we disclose your personal information may be located
outside Australia. Although the countries in which these third parties are
located depends on the circumstances, we commonly disclose personal information
to third parties, or IT systems, located in the United States. We disclose your
personal information to service providers outside of Australia to obtain Website
hosting, secure storage, back-up and data retrieval services and to provide
services. When you provide us with your personal information you give us your
consent to transfer your personal information and data outside of Australia for
these purposes.
3.5
Where
such third parties are located overseas, you may have rights to enforce such
parties' compliance with applicable privacy laws, but you may not have recourse
against those parties under the Act in relation to how those parties treat your
personal information.
3.6
We may
also disclose and transfer personal data in connection with a merger or sale
involving all or part of Compare Villages or as part of a corporate
reorganisation or share sale or other change in corporate control.
3.7
We may
disclose, use, aggregate, make anonymous, use a pseudonym or de-identify
information about users for marketing, advertising, research, compliance or
other purposes.
3.9
If we
do contact you, we will give you the opportunity to request that your
information not be used for further direct marketing in the future. You can
always unsubscribe. Please also contact us at our details below at any time you
decide you want to opt out of receiving any direct marketing.
4.
Access
4.1
You are
entitled to access, correct or update personal information we hold about
you. If you wish to access, correct or
update any personal information we hold about you, please contact us as set out
below. We may charge for providing access to this information and we may refuse
access to the extent that the law allows us to do so.
5.2
Along
with security measures offered by our service providers, we protect your
information in a number of ways. We always take reasonable steps to protect
personal information. All sensitive data sent or received to the Compare
Villages Platform carries a Cross Site Request Forgery token which ensures data
cannot be read, modified or otherwise tampered with between the user and the
Compare Villages Platform. Identifiable information such as user IDs, email
addresses and passwords are always encrypted when being sent to or from the
Compare Villages Platform. We also have an active and verified SSL certificate.
We keep your personal information for only as long as it is required in order
to fulfil the purposes for which it was collected and as described in this
Privacy Policy and to comply with our legal obligations.
We may, from time to time, review and update
this Privacy Policy. Any changes to this
Privacy Policy will be published on the Compare Villages Platform. All personal
information held by us will be governed by our most recent Privacy Policy.
By continuing to use the Compare Villages Platform, or otherwise continuing to
deal with us, you accept this Privacy Policy as it is updated from time to
time.
7.
Questions and complaints
7.1
If you
have any questions or concerns about our collection, use or disclosure of
personal information, or if you believe that we have not complied with this
Privacy Policy or the Act, or if you would like to access, correct or update your
personal information held by us or want to opt out of direct marketing please
contact us at [email protected].
7.2
Our
Privacy Officer will investigate your query or complaint and endeavour to
respond to you promptly. Please provide as much detail as possible in relation
to the query, issue or complaint.
7.3 If you don’t think your privacy concerns have been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, you can contact the Office of the Australian Information Commissioner on 1300 363 992 or visit their website at www.oaic.gov.au.
Last updated: 7 August 2017.