What Is Personal Information?
For the purposes of this policy, “personal information’ has the meaning given to it in the Privacy Act. In general terms, if the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be regarded as personal information.
What Are The Types Of Information Held?
Personal information collected by PRO PG includes names, email addresses, other contact details, residential and mail addresses, gender information, occupation or job titles, and governmental identification details. We may also collect personal information specific to our products and services such as photographic identification, financial information (including credit reference information and credit card/banking details) and data obtained from third parties (such as a leasing applicants’ rental histories).
Generally, we do not collect sensitive information such as your ethnic origin, memberships of a professional/trade association or trade union, or criminal record. We will only collect sensitive information which it is reasonably necessary for our functions, and you have consented to the collection of that information.
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.
How Do We Collect Personal Information?
We may collect personal information directly from you:
- In person, by fax, letter, email or telephone;
- When you complete forms or applications in person or through our website;
- During conversations between you and our team members;
- By entering competitions or promotions;
- By completing surveys, providing feedback or complaining to us;
- When you engage us, or register with us, to provide you with products or services;
- When you subscribe to receive our publications; and/or
- When you request sales, leasing and advertising information.
We may also collect personal information from third parties including from:
- Credit reporting agencies;
- Law enforcement agencies and government entities;
- Your representatives (such as settlement agents or financial advisers);
- Your current or former employer(s);
- Data bases kept by third parties (such as individual’s rental histories); and
- From other real estate agents (such as when the agency is involved in a conjunctional sale of land or when we act for a buyer in a transaction.
We may also collect personal information from publicly available sources such as Landgate, local councils, websites, or telephone white pages.
There are certain circumstances where we are required to collect personal information by virtue of legal or regulatory requirements including but not limited to the provisions of Western Australian legislation such as the Real Estate and Business Agents Act 1978 (WA) and the Strata Titles Act 1985 (WA)).
Generally, we will collect personal information directly from you, unless it is unreasonable or impracticable for us to do so.
When you access our website, we may send a “cookie” to your computer (which is, a small summary file containing a unique ID number that a website can transfer to a computer to track site usage) and/or log IP addresses (that is, the electronic addresses of computers connected to the internet). This enables us to recognise your computer and we use this to analyse trends, administer the website and track users movements. Our cookies do not collect personal information. If you do not wish to receive cookies, you can change your browser settings so that your computer does not accept them or refuse to accept them.
What Happens When Your Personal Information Is Not Provided?
If you do not provide us with the personal information requested from you or the information required is not available, we may not be able to provide the requested products or services, information related to our products or services, to you, either to the same standard or at all.
For What Purposes Do We Collect, Hold, Use And Disclose Your Personal Information?
We hold, use and disclose personal information for the purpose of enabling us to perform our business activities and functions, in particular:
- To provide products and services to you and to send related communications requested by you;
- To respond to your submissions, enquiries, feedback, comments or complaints;
- Communicating with you in relation to PRO PG’s publications, marketing information and special events;
- To provide you with access to protected areas of our website (such as Landlord Logins);
- To assess the performance of the website and to improve the operation of the website;
- We obtain information from Landgate and other public registers as well as directly from you, to assist us in the valuing, selling and/or leasing of properties and/or related businesses;
- To conduct administrative processing functions as well as property maintenance/improvement functions which involves providing personal information to our related bodies corporate, contractors, service providers or other third parties;
- We provide information to the Real Estate Institute of Western Australia (Inc) and other providers of real estate internet services to enable us to market properties, promote our services and conduct our business through the internet;
- For survey and research purposes of PRO PG and its service providers;
- To update our records and keep your contact details up to date; and
- To comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator or governmental authority, or in co-operation with any governmental authority.
To Whom May We Disclose Your Information?
We may disclose your personal information to:
- Our employees, related bodies corporate, contractors, and employees 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 including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, utilities providers, tradesmen 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 other purposes related to our business; and
- Any individual or organisation for any authorised purpose with your express consent.
We may combine or share any information that we collect from you with information collected by any of our related bodies corporate and associates.
When Do We Send Direct Marketing Materials?
We may send you direct marketing communications and information about our products and services in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). 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.
When May We Disclose Personal Information To Overseas Recipients?
We may disclose personal information to third party suppliers and service providers located overseas, including the Philippines, in connection with our business activities and functions as outlined above (for example in connection with our data hosting and other IT service providers and the preparation of marketing and advertising material).
We may also disclose your personal information to entities within Australia who may store or process your data overseas.
In the event that a disclosure is made in an overseas country, the information will not be required to be held in accordance with the APPS and Privacy Act and we will not be liable for breaches of those provisions by overseas recipients however, we will take reasonable steps to satisfy ourselves that the overseas recipients of your personal information are aware of these obligations in relation to your personal information. In any event, by providing your details, you are agreeing to your information being disclosed in this manner.
How Is Your Information Stored And Secured?
The information we collect is held in confidence, and PRO PG takes all reasonable precautions to safeguard your personal information from loss, misuse, or unauthorised access, modification or disclosure. The Information is securely stored and access is restricted to authorised PRO PG team members.
Where we no longer require the information for the purpose for which it was collected by PRO PG we will take reasonable steps to destroy or permanently de-identify personal information.
We note that information provided over the internet or information stored on servers accessible through the internet cannot be guaranteed to be fully secure as the internet is inherently insecure. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Third Parties And Links
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. Where we hold information that you are entitled to access in accordance with the APPS, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you) within a reasonable time. We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you and, if so, the fees will be disclosed to you directly or displayed on our website. 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 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.
We may ask you to provide your request to access and correct personal information in writing.
What Is The Process For Complaining About A Breach Of Privacy Or How We Have Dealt With Your Personal Information?
If you are dissatisfied with the manner in which we deal with your personal information or should you wish to make a complaint regarding our compliance with privacy laws, please contact our Privacy Officer in writing.
When Can You Deal With Us Anonymously And Pseudonymously?
There may be circumstances where you may have the option to deal with us anonymously and pseudonymously. We will advise you of this option when this option is available unless it is not allowed by or under Australian law, or a court/tribunal order or it would be impracticable for PRO PG to deal with you if you have not identified yourself. If you decide to deal with us anonymously and pseudonymously it may limit our ability to assist you with your enquiry.
Our Privacy Officer will contact you within a reasonable time after receipt of your communication to discuss how we can resolve your enquiry (including details of any applicable reasonable costs). We will aim to ensure that your enquiry is resolved in a timely and appropriate manner.
The contact details for our Privacy Officer are:
The Privacy Officer
PRO PG Pty Ltd
Suite 5, 250 Oxford St
LEEDERVILLE WA 6007
Phone: +61 8 94437088
Any changes to this policy will be posted on the relevant section of our website.