Privacy Statement

1.         About this Policy

Capital Corporation Property Management Pty Limited (ABN 78 130 969 069) (Capital Corporation) ('we', 'us', 'our') understands the importance of, and is committed to, protecting your personal information. We comply with the Privacy Act 1988 (Privacy Act). We are bound by the Australian Privacy Principles (APPs) which regulate how we may collect, use, disclose and store personal information, and how our users, clients and suppliers ('you') may access and correct personal information we hold about you.

Purpose

The purpose of this privacy policy is to:

  • clearly communicate how we deal with personal information
  • enhance the transparency of Capital Corporation's operations
  • give a better and more complete understanding of the sort of personal information that Capital Corporation holds, and the way we handle that information.

Changes to this privacy policy

We may change this privacy policy from time-to-time. The updated privacy will be posted on our website, with the date of the update shown.

Who to contact

If you have any questions, concerns or complaints about this privacy policy, or our use of your personal information, please contact the Privacy Officer using the contact details provided below. You can also contact the privacy officer if you believe that the privacy of your personal information has been compromised or is not adequately protected.

Once a complaint has been lodged, the Privacy Officer will respond to you as soon as possible.

You may also lodge a complaint with the Office of the Australian Information Commissioner by telephone: 1300 363 992 or email: enquiries@oaic.gov.au

Capital Corporation Privacy Officer: Tel +61 2 8853 5000 Fax +612 8853 5099

Email:  privacy@capcorp.com.au

Mail: PO Box 6285, Baulkham Hills Business Centre, NSW 2153            

 2.         Information we collect about you

We collect personal information about you that we reasonably need for our activities and providing and promoting our products and services to you, and operating our website. Our business activities include:

  •  providing you with Capital Corporation's information, projects and services – these are described generally on our website, brochures, advertising, letters, emails and communications to users, suppliers and business partners
  • activities in support of those functions including administration, employment, management, marketing, contracting, online and mobile marketing, IT, legal, security, customer support, finance (including credit control) and human resources
  • activities we plan for the future including new ways of communicating, new products and services, new business models and new businesses
  • Generally the types of information we collect from you includes your name, your email address, telephone number, identification for verification of age including your date of birth (for example passport or driver’s licence), marital status, gender, credit card information (where necessary), your profession, occupation or job title, your employer, your computer’s IP address and billing information.
  • We may combine your personal information above with sensitive information and other information about you, for example:
  • if you login to our website we may collect details about your user name, site usage and projects and services you may be interested in;
  • if you request information from us (for example about a project or service) or register a complaint, we collect information about your request or complaint;
  • if you enter a promotion or competition, attend an event or enquire about Capital Corporation, we may collect your contact details so that we can follow up on your enquiry or interest by sending you marketing material.

We record this information (personal information) in our database whilst we deal with you. We will remove this information from out database when we have no further need to keep a record of it, except if we are required to keep it by law.
 

3.         How we collect information about you

How do we collect personal information?

Generally, we collect personal information directly from you. We may record your contact details when you call us, when you register and login to our website, when you send us an SMS/MMS, when you use an app, when you purchase a product or service, when you fill out an application form, when you participate in a transaction, when you provide your contact details via web, mobile or email or when you ask us for information or request something from us.

 Sometimes we collect personal information about you from another person or business, or from a publicly available source. For example:

  • personal information which we obtain from others (including our service providers, websites, social media sites, mobile and other technology based sources);
  • from a friend or someone who refers our projects, products and services to you;
  • we may get your details from a publicly released register;
  • if you enter a promotion or competition organised by us, we may be given your name and contact details by the promoter of the event.

We use lawful and fair means to collect your information. We will collect personal information about you from another person or from a publicly available source only if it is unreasonable or impracticable to collect it directly from you, and we will take reasonable steps to inform you that we have collected your personal information. Those reasonable steps may include informing you through this privacy policy.

Unsolicited information

If we receive personal information about you that we have not requested, and if we determine that we could not have lawfully collected that information under privacy law had we requested it, we will destroy or de-identify the information, if it is lawful and reasonable to do so. If we collect your personal information in an unsolicited manner, we take reasonable steps to inform you of such collection and also how we use, disclose and secure your personal information. Such reasonable steps may include referring you to this privacy policy. 

4.         Do you have to provide you with us with your personal information?

You can deal with us anonymously (without giving us your name and contact details) or by using a pseudonym (a name that does not include your real name, for example an email address or a user name that you use in an online forum (nickname)).

If you choose to deal with us anonymously or using a nickname, we can give you general information about our projects, products and services, but there are some things we cannot do, for example:

If you do not give us your personal information, we cannot give you information about your dealings with us, deal with a complaint you may have, provide you with a service or deliver a product or service to you at an address and you cannot enter into any competitions or promotions anonymously or using a nickname that we conduct.

You can deal with us using a nickname together with your real name and contact details. If you choose to deal with us in this way, we may collect your personal information together with your nickname. When you identify yourself to us using your nickname only, we can deal with you only as described above. We may ask you to provide proof of your identity if you use a nickname.

5.         Why we collect personal information about you (purpose of collection) 

We collect and record personal information about you so that we can carry out our functions and activities described above. The primary purposes for which we collect your personal information include:

  • to provide products and services to you;
  • to provide you with news, information or advice about our existing and new projects, products and services;
  • to communicate with you including by email, mail or telephone;
  • to manage and enhance our projects, products and services;
  • to personalise and customise your experience;
  • to provide you with access to any protected areas of our websites;
  • to conduct competitions or promotions and selected third parties;
  • to verify your identity;
  • to provide that information as part of business data to third parties if you have authorised us to do so;
  • to conduct business processing functions for operation of our website or our business;
  • for our administrative, marketing (including direct marketing), promotional, planning, project/product/service development, quality control and research purposes, or those of our contractors or external service providers;
  • to provide your updated personal information to us, our contractors or external service providers;
  • to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and/or
  • as required or permitted by any law (including the Privacy Act).

We also collect your personal information for certain secondary purposes that are related to the primary purposes outlined above. Secondary purposes may include so that we can run our business efficiently, for example, so that our advisors can provide us with customer research, or so that we can use technology to automate our business and to understand how our business is performing, to allow us to operate efficiently and to lower costs by outsourcing services (such as collecting or paying money) and making our processes more efficient. Other secondary purposes may include so that we can sell or transfer our business or merge with another business.

6.         Disclosure

Do we disclose your personal information?

We will not sell your personal information without your consent, unless we sell our business or website.

We may choose to disclose your personal information to our contractors, our bank, our agents, our related entities, government authorities, law enforcement and any other party who may assist us in providing products and services to you, or in promoting or marketing our projects and services to you, or any party who purchases or seeks to purchase our business (or any part of it including a website).

We may choose to disclose your personal information to law enforcement and government authorities (‘Authorities’) at our discretion. Disclosure is usually made where we suspect or become aware of criminal or unlawful conduct, or where a request is made by Authorities.

Disclosure overseas

We may disclose your personal information to an overseas service provider, a cloud data centre or a customer information call centre. Our overseas service providers may be located in Singapore, the United States of America or another country. You may contact us at any time to determine where the recipients of such personal information are located overseas via the above contact details. 

If it is not practicable or reasonable for us to gain your consent to disclose your personal information to an overseas service provider, we will take reasonable steps to notify you of the specific countries where we disclose your personal information. We will take reasonable steps to ensure that the overseas services provider is bound by privacy and confidentiality obligations. 

7.         Access to your personal information  

You may request access to the personal information that we hold about you by using the contact details provided above.

We will deal with your request for such access within a reasonable time. If we refuse access, we will provide you with a written notice which sets out the reasons for the refusal and the relevant provisions of the Privacy Act that we rely on to refuse access. 

We may recover reasonable costs in relation to a request for access to personal information.

Accuracy and correction

We take reasonable steps to make sure that the personal information we use and collect is accurate, up-to-date and complete. Where we believe that the personal information we hold is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information.

Where we believe that the information we hold is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take reasonable steps to correct that information and to notify that correction to third parties at your request. You may also request that we correct personal information that we hold about you, by using our contact details above.

We will take reasonable steps to correct the information within a reasonable time. However, if we do not agree with the corrections you have requested, we are not obliged to alter your personal information, but we will give you a written notice which sets out the reasons for our refusal, the mechanisms available to complain about the refusal and the relevant provisions of the Act that we rely on to refuse correction. You can also ask us to associate a statement with the relevant information that puts your view that it is inaccurate, out-of-date, incomplete, irrelevant or misleading. We will not charge you for making a correction request, for correcting your information or for associating a statement with your information.

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.).   If you make an access request, we will ask you to verify your identity. 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.  

8.         Security

We hold your personal information in paper-based and electronic files. We will take reasonable steps to ensure that your personal information which is kept in our files is protected from:
  • misuse, interference and loss
  • unauthorised access, modification or disclosure

This means that, in respect of our paper-based files, we maintain various security systems on our premises, and in respect of electronic files, we (or our service providers) maintain secure electronic network systems. 

When we no longer require your personal information (including when we are no longer required by law to keep records relating to you), we ensure that it is destroyed or de-identified.

Website 

This section explains how we handle personal information collected from our website (including mobile site if relevant). If you have any questions or concerns about transmitting your personal information via the internet, you may contact us using the contact details provided above, as there are other ways for you to provide us with your personal information. 

Visiting our website 

If you access an unsecured part of our websites, that is, a public page that does not require you to log on, we (or our service providers) will collect information about your visit, such as:

  • the time and date of the visit
  • any information or documentation that you download
  • your browser type
  • your IP address

Cookies 

A "cookie" is a small text file which is placed on your internet browser and which we access each time you visit our website. When you visit the secured pages of our website (i.e. pages that you have to provide login details to access) we use cookies for security and personalisation purposes. When you visit the unsecured pages of our website (i.e. public pages that you can access without providing login details) we use cookies to obtain information about how our website is being used. 

You may change the settings on your browser to reject cookies; however doing so will prevent you from access to the secured pages of our website. 

Email 

When we receive emails, we will retain the content of the email and our response to you where we consider it necessary to do so. 

Your email address will only be used or disclosed for the purpose for which is was provided. It will not be added to any mailing lists or used for any other purpose without your consent. 

Security 

We make reasonable efforts to ensure that the most up-to-date security measures are used on our website to protect your personal information. Any data containing personal information which we transmit via the internet is encrypted. However, we cannot guarantee that any information transmitted via the internet by us, or you, is entirely secure. You use our website at your own risk. 

Links on our website 

Our website may contain links to third party websites. We advise that the terms of this privacy policy do not apply to external websites. If you wish to find out how any third parties handle your personal information, you will need to obtain a copy of their privacy policy. 

9.         Marketing 

We may use your personal information, including your contact details, to provide you with information about products and services, including those of third parties, which we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS or email, in accordance with applicable marketing laws, such as the Spam Act 2004 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so.

You may opt-out of receiving marketing communications from us by contacting us or by using the opt-out facilities provided (e.g. an unsubscribe link, single word instruction or verbally during a direct marketing phone call). We will then ensure that your name is removed from our mailing list. We do not provide your personal information to other organisations for the purposes of direct marketing unless expressly authorised by you.

If you receive communications from us that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact us.


This Policy was last updated on 1 July 2014.