Date of Last Revision: 1 March 2019
Jinding Pty Ltd (ACN 610 924 822) is a proprietary company limited by shares. References to ‘Jinding’, ‘we’, ‘us’ or ‘our’ are references to Jinding Pty Ltd (ACN 610 924 822) and its related bodies corporate (as defined in the Corporations Act 2001 (Cth)).
1.2 What is personal information?
1.3 Our obligations
We comply with the Australian Privacy Principles (APPs) in the Privacy Act. The APPs regulate the manner in which personal information is handled throughout its life cycle, from collection to use and disclosure, security, accessibility and disposal.
The Privacy Act also includes a data breach notification regime, which requires Jinding to address data breaches involving personal information held by Jinding.
We also comply with more specific privacy legislation in some circumstances, such as the Spam Act and the Do Not Call Register Act.
1.4 Employee records
The type of personal information that we collect about you depends on the type of dealings you have with us. For example, if you:
In addition to the above, if you interact with Jinding generally, Jinding will collect your details (e.g. name, telephone number, email address), details of the properties you are interested in, how you heard about us or the relevant property development and details of your dealings with us. Other information may be collected from other sources but those sources should provide you with details of what personal information is being collected and why.
The personal information collected may vary depending on your particular interaction with Jinding but will be limited to that information necessary to record and manage our interaction with you (e.g. your name, relevant contact details and information about the interaction) and to that information required to enable you to participate in our services and other products being offered on Jinding’s website.
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 answers to surveys or aggregated information about how users use our website.
2.2 Sensitive information
Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection, such as health information. We only collect sensitive information where it is reasonably necessary for our functions or activities and either:
2.3 Collection of information other than personal information through our website
When you visit our website, some of the information that is collected about your visit is not personal information, as it does not reveal your identity.
Site visit information
For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.
We use and disclose this information in anonymous, aggregated form only, for purposes including statistical analysis and to assist us to improve the functionality and usability of our website. You are not individually identified, however we reserve the right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.
A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users, although they do identify the user’s internet browser.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website.
Online Behavioural Advertising
We use advertising programs that place cookies on your computer to collect information about your browsing history (including on external websites). This information, which does not identify you personally, is collected in order to improve your online experience by customising the advertising you see to your interests (including the display of more relevant ads on external websites). You can opt out of these programs by turning off the cookie setting in your own internet browser.
2.4 What if you don’t provide us with your personal information?
We will provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to an individual’s actual name. For example, you can access our website and make general phone queries without having to identify yourself.
In some cases however, if you don’t provide us with your personal information when requested, we may not be able to provide you with the product or service that you are seeking. For example, you must identify yourself to register your interest or purchase a property at any Jinding development.
3.1 Methods of collection
We collect personal information in a number of ways, including:
3.2 Collection notices
Where we collect personal information about you, we will take reasonable steps to provide you with certain details about that collection (such as why we are collecting the information and who we may share it with). We will generally include this information in a collection notice.
3.3 Unsolicited information
Unsolicited personal information is personal information we receive that we have taken no active steps to collect (such as an employment application sent to us by an individual on their own initiative, rather than in response to a job advertisement).
We may keep records of unsolicited personal information if the Privacy Act permits it (for example, if the information is reasonably necessary for one or more of our functions or activities). If not, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.
If you do not provide us with the personal information described above, some or all of the following may happen:
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.
The main purposes for which we collect, hold, use and disclose personal information are set out below:
We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection or:
5.1 Direct marketing
You consent (until such time as you opt out, as described below) that we may use your personal information to let you know about us and our products and services (including promotions, special offers and events) and our third party products and services, either where we have your express or implied consent, or where we are otherwise permitted by law to do so. We may contact you for these purposes in a variety of ways, including by mail, email, SMS, telephone and online advertising.
Where you have consented to receiving marketing communications from us, your consent will remain current until you advise us otherwise. However, you can opt out at any time, by:
Once you do this, we will update your profile to ensure that you don’t receive further marketing messages. Stopping marketing messages will not stop service communications (such as contract updates).
We will get your express opt-in consent before we share your personal data with any company outside the Jinding entities for marketing purposes.
Notification of source
If we have collected the personal information that we use to send you marketing communications from a third party (for example a direct mail database provider), you can ask us to notify you of our source of information, and we will do so, unless this would be unreasonable or impracticable.
Jinding may disclose your personal information, and you consent to Jinding disclosing your personal information, to Jinding’ related bodies corporate and associated entities (as those terms are defined in the Corporations Act 2001 (Cth)).
Jinding may also disclose your personal information, and you consent to Jinding disclosing your personal information, to the following third parties:
In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant services.
We may also disclose information to provide our products and services, to respond to legal requirements, enforce our policies, and protect our rights and property.
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. 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:
We will not:
unless this is permitted by the Privacy Act (for example, use of an identifier to verify an individual’s identity or uses or disclosures required or authorised by or under an Australian law).
Jinding is committed to keeping your personal information secure and confidential. All reasonable precautions will be taken to protect personal information from loss, misuse, unauthorised access or alteration. Paper documents are held in locked drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. Additionally, we also take reasonable steps to:
You can help us keep your information up to date, by letting us know about any changes to your details, such as your address, email address or phone number.
You acknowledge that the security of online transactions you conduct using the website cannot be guaranteed. To the fullest extent permitted at law, Jinding does not accept responsibility for misuse of or loss of, or unauthorised access to, your personal information where the security of that information is not within Jinding’s control.
The steps we take to secure the personal information we hold include website protection measures (such as firewalls and anti-virus software), security restrictions on access to our computer systems (such as login and password protection), controlled access to our corporate premises, policies on document storage and security, personnel security (including restricting access to personal information on our systems to staff who need that access to carry out their duties), staff training and workplace policies.
Online credit card payment security
We process payments using EFTPOS and online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.
While we strive to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online, and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone or post (details under heading 14 below).
If you are a registered user of our website, you can also help to protect the privacy of your personal information by maintaining the confidentiality of your username and password and by ensuring that you log out of the website when you have finished using it. In addition, if you become aware of any security breach, please let us know as soon as possible.
An IP (internet protocol) address is a number that is automatically assigned to your computer by your internet service provider when you log on. Your IP address is not linked to your personal information, but we do preserve the right to use IP addresses to identify individuals who may threaten our site, services or clients. IP addresses may also be used to help diagnose problems with our website and to gather broad demographic information.
Third party websites
If there is any breach of your personal information, Jinding will deal with such breach and notify you in accordance with its obligations under the Privacy Act.
We will only keep the information we collect about you for as long as required for the purposes set out above or as required to comply with any legal obligations to which we are subject. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.
If you close an account you have with us or you decide not to go ahead with purchasing a property for which you have registered, we may still keep your information.
If you wish to stop receiving any e-mails or other communications from Jinding which may be sent to you in the future, or if you have submitted personal information through the website and would like to have that information deleted from our records, please unsubscribe through the link at the bottom of any email or notify us at firstname.lastname@example.org
Jinding will preserve the contents of any e-mail message that you send if we believe that we have a legal requirement to do so. E-mails sent to or from Jinding are routinely monitored for quality control, systems administration and legal compliance purposes.
Please contact our Privacy Officer (details under heading 14 below) if you would like to access or correct the personal information that we hold about you. We may require you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.
We will generally provide you with access to your personal information, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (eg by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may however charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you ask us to correct personal information that we hold about you, or if we are satisfied that the personal information we hold is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
If we correct personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, we will take reasonable steps to do so, unless this would be impracticable or unlawful.
12.4 Timeframe for access and correction requests
Except in the case of more complicated requests, we will endeavour to respond to access and correction requests within 30 days.
12.5 What if we do not agree to your request for access or correction?
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.
In addition, if we refuse to correct personal information in the manner you have requested, you may ask us to associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, and we will take reasonable steps to do this in such a way that will make the statement apparent to users of the information.
If you have a complaint about how we have collected or handled your personal information, please contact our Privacy Officer (details under heading 14 below).
We will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week. If your complaint can’t be resolved at the first instance, we will ask you to submit your complaint in writing.
In most cases, we expect to investigate written complaints will be investigated and a response provided within 30 days of receipt. If the matter is more complex and our investigation may take longer, we will write and let you know, and tell you when we expect to provide our response.
If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner (see here for further information).
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, Jinding, Level 53, 525 Collins Street, Melbourne VIC 3000 or email@example.com or 03 9457 8588.
Further general information about privacy is available on the website of the Office of the Australian Information Commissioner at www.oaic.gov.au or by calling the OAIC’s enquiry line at 1300 363 992.