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.
1.1 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.
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;
(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
2.2 If we contact you by using your personal information, we will give you the opportunity to request that your information not be used for direct marketing in the future by following the opt out instructions provided in the communication.
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.
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.
3.4 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.
4.1 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.
5.1 We aim to keep your personal information secure. Any personal information that is collected via the Compare Villages Platform or which is stored on our IT systems is protected by a range of safeguards and security measures including physical, technical and procedural methods.
7. Questions and complaints
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.