Privacy Policy

Performance Property Advisory Group · Last updated 28 April 2021

Performance Property Advisory Group

Introduction

We respect your Personal Information and We are committed to protecting and maintaining privacy, accuracy and security of Personal Information in accordance with the Australian Privacy Principles and the Privacy Act. This Privacy Policy:

explains how We collect, use, disclose and otherwise handle your Personal Information; and
covers Your access to, and use of, Our Site and Our Services.

This Privacy Policy covers all entities in the Performance Property Advisory Group.

By using Our Services, You consent to be bound by this Privacy Policy.

Definitions

In this Privacy Policy:

Account means an account associated with a registered user who uses or has used Our Site.

Our Partners means persons with whom We have a commercial relationship from time to time.

Personal information is information or an opinion which identifies an individual or which could reasonably identify an individual, regardless of whether the information or opinion is in a material form or not.

Privacy Act means the Privacy Act 1988 (Cth).

Services means any of Our products and services (including, but not limited to, use of Our Site and any related content such as Our articles, seminars, reports, podcasts and videos, property management services and investment advisory services).

Site means any of Our websites, including https://performanceproperty.com.au/ and https://propertyfordoctors.com.au/.

Terms and Conditions means the terms and conditions applicable to Our Services and available at Our Site.

Third Party Services means products or services provided by third parties, including those made available through internet sites maintained by third party providers.

We, Our and Us means PPA IP Pty Ltd ACN 623 135 857 and its related bodies corporate and other related or associated entities.

You, Yourself, Your means all individuals including members, customers and other persons with whose Personal Information We deal, and any person, business, company or organisation accessing or using Our Site.

What personal information do we collect

We may collect information about You when You visit Our Site or use Our Services including, but not limited to, when You register or become a registered user on Our Site, or download Our reports, podcasts or videos or register for one of Our mailing lists.

The Personal Information that We collect may include, but is not limited to:

Your identity information, such as Your full name and Your date and place of birth, and Your gender;
Your contact information, such as Your email address, mail or street address, and phone number, and other information that may be used to contact You;
information in relation to Your professional advisers, including the names of Your accountant, financial planner, mortgage broker and lawyer (if any);
other information reasonably relevant to Our Services (including Your preferences, interests, enquiries and property portfolio);
any other Personal Information You provide to Us in relation to the Services (including as provided under any Privacy Collection Statement);
Your financial information, such as information in relation to Your annual income, Your expenses and Your assets, as well as information relating to Your bank account or credit card details (as required);
geolocation and computer-generated information, such as your device ID, device type, computer and connection information, statistics on page views, traffic to and from Our website, IP address and standard web log information;
details of the products and services that We have provided to You or which You have enquired about, including any additional information necessary to enable Us to deliver those products or services to You, and to respond to Your enquiries;
other information that We are required or authorised to collect in relation to assist Us to comply with Our legal requirements;
information that You provide to Us through customer surveys and through other means not expressly set out above; and
any other Personal Information You provide to Us in relation to the Services.

When visiting Our Site or accessing Our Services, We may also collect and store and following details:

an IP address from which You access Our Site or Services;
the date and time You access Our Site or Services;
any third party website from which You linked to Our Site or accessed Services;
statistics on page views, traffic to-and-from Our Site and Services; and
other transactional information about Your access to Our Site or Services.

Cookies and other tracking software

We may utilise 'cookies' and other tracking software which enable Us to monitor traffic patterns and to serve You more efficiently if You revisit Our Site as well as for Our general analytics purposes.

A cookie does not identify You personally but it does identify Your computer. You can set Your browser to notify You when You receive a cookie and this will provide You with an opportunity to either accept or reject it in each instance.

If You have registered with Us and have an Account on Our Site, Our software may identify You personally based on the information You have provided on Your Account. Otherwise, non-registered users will not be personally identified by Our software.

Can You deal with Us on an anonymous or pseudonymous basis?

In accordance with Australia's privacy laws, where it is lawful and reasonable to do so, You have the right to deal with Us on an anonymous or pseudonymous basis. This means that You do not need to provide Us with Personal Information if and when We request that information. Subject to the following, We will give You the option of not identifying Yourself to Us, or using a pseudonym, in dealing with Us.

However, if You choose to interact with Us on an anonymous or pseudonymous basis, or You do not submit Your Personal Information to Us when We request the information, We may not be able to provide You with the products or Services that You request.

Further, We reserve the right to request Your identity in certain circumstances, and to verify Your identity if We consider that it is appropriate or reasonable for Us to do so. For example, when You request that We give you access to or that We correct Personal Information that We hold about You, or when You inform us that You wish to make a complaint regarding the manner in which Your Personal Information has been handled, We reserve the right to request Your identity and contact details in order to deal with Your request and to respond to Your complaint.

How do We collect Personal Information?

We only collect Personal Information through lawful and fair means. Generally, We will collect Personal Information about You from You directly. However, there may be situations where We collect information about You from other sources or third parties, including other customers or clients.

We may collect Personal Information when You:

communicate with Us through correspondence, chats, emails or when You share information with Us from other social applications, services or websites;
directly contact Us in the course of Us providing Services to You or to any entity associated with You (such as Your employer);
interact with Us, acquire Services, or access content and advertising;
apply for a job with Us; or
invest in Our business or enquire as to a potential purchase in Our business.

We may also collect Personal Information about You from current and prospective suppliers of products or services to Us. We may collect Personal Information about You from referral partners (including, but not limited to, finance brokers, conveyancers, financial advisers, accountants and other professional advisers and service providers).

Additionally, We may collect Personal Information about You from publicly available databases and registers of information, including registers maintained by government agencies and authorities, such as the Australian Securities and Investments Commission as well as State or Territory land titles offices.

How do We handle Personal Information received on an unsolicited basis?

Generally, We only collect Personal Information when We specifically request the information or when We take active steps to collect that information. However, from time to time, Personal Information may be volunteered to Us without Us requesting the information or taking steps to collect the information. For example, We may receive Personal Information about an individual when We receive misdirected mail or emails or when someone applies for a job with Us on his or her initiative and not in response to an advertised vacancy.

When We receive information on an unsolicited basis, in accordance with Our statutory obligations, We will determine whether We could lawfully have collected the information if We had requested the information or otherwise taken active steps to collect the information. If We determine that We could not have lawfully collected the information had We requested the information or otherwise taken active steps to collect the information, then We will take reasonable steps to destroy or to de-identify that unsolicited information, unless We are required or authorised by law to retain the information.

How do We use Personal Information

We only use and disclose Personal Information for the primary purpose(s) for which We collected the information, any secondary purpose related to the primary purpose for which You would reasonably expect Us to use or disclose that information, and as otherwise permitted or required by law.

We will use Your Personal Information for the purpose of providing Services to You or Your organisation. This includes, without limitation, providing You with:

articles, seminars, reports, podcasts, videos and other content relating to property;
information in relation to property management services;
information in relation to investment advisory services; and related services.

In addition to using Your Personal Information to provide Services to You or Your organisation, Your Personal Information may be used:

to verify Your identity, respond to Your requests, and contact You when necessary;
to process transactions and to administer accounts (including by processing of invoices, bills, statements of account, payment collection and related financial matters necessary to enable Us to provide Our products and Services to You or to Your organisation under relevant contractual arrangements);
to address queries and to resolve complaints;
for quality assurance purposes in respect of Our products and Services;
to maintain a safe working environment for Our staff, contractors other personnel (and their personnel);
to provide You with news, information and material in relation to Our products and Services, including to notify You about new products or services, which We believe may be of interest to You;
to provide You with news, information and material in relation to the services of Our partners or business contacts, which We believe may be of interest to You;
to send news and information about Our products and Services and general promotional material which We believe may be of interest to You;
to monitor who is accessing Our Site or using Services including to profile the type of people using Our Site or Our products or Services;
to profile the type of people using Our Site or Our products and Services;
to perform other administrative and operational tasks (including staff training, risk management, systems development and testing);
to improve Our Site or products and Services;
to consider any concerns or complaints You may have raised;
to comply with Our legal and statutory obligations, resolve any disputes that We may have with any of Our customers, and to enforce Our contracts with third parties or with You or Your organisation;
to consider your application for employment with us; and
as otherwise permitted by law (such as to comply with obligations under the Privacy Act in relation to mandatory data breach notification).

Third Party Services

Our Site may contain links and pointers to Third Party Services. These links to Third Party Services are provided for Your convenience only.

Third Party Services are not under Our control and We are not responsible for Third Party Services (including the suitability for Your intended use of the Third Party Services). We do not endorse or recommend any Third Party Services or any associated provider organisation or their products or services. You should make Your own enquiries as to the suitability of any Third Party Service. Third Party Services may also utilise cookies. You are responsible for reading the privacy policies or statements associated with any Third Party Service.

To whom do We disclose Personal Information?

We may provide Your Personal Information, to:

our related or affiliated entities and related bodies corporate (as that term is defined in the Corporations Act 2001 (Cth);
parties to whom You authorise Us to disclose Your Personal Information;
third parties which provide Third Party Services;
our partners, affiliates, suppliers, contractors and consultants, assisting Us in the provision of Services to You, subject to them being required to protect Your Personal Information in a broadly similar manner that We commit to Your privacy protection under this Privacy Policy;
other third parties that may provide products or services to You or to any organisation associated with You, including property managers, financiers and conveyancers;
government and regulatory authorities, as required or authorised by law;
our professional advisors; and
other third parties as permitted by law.

As at the effective date of this Privacy Policy, We may disclose some or all of the Personal Information We have collected about You to our suppliers and contractors, including suppliers and contractors located in India and in The Philippines. When We disclose or make available such Personal Information to any of these recipients, We take all reasonable steps to ensure that the recipient maintains the privacy of such Personal Information, including by entering into enforceable and binding contracts that impose such obligations on the recipient.

You also acknowledge and agree that We may engage service providers to host Our information for Us and that these service providers may host Our information for Us in jurisdictions outside Australia. Where We enter into any contract with a service provider to host Our data or website, We will use reasonable endeavours to ensure that the contract reserves for Us the right to control access to the Personal Information hosted and to avoid the need for the service provider to access the information it hosts for Us.

If you communicate with Us via email or through a social network service such as Facebook or Twitter, the email or the message may be routed through servers that are located outside Australia and, in relation to a message sent through Facebook or Twitter, the social network provider and its partners could collect, hold and process Your Personal Information in jurisdiction(s) outside Australia.

We take all reasonable efforts to keep Personal Information which We collect and hold secure, however, We cannot, and We do not, guarantee the security of transmission of all such information over the internet.

Can You opt-out of providing Personal Information?

The provision of Your Personal Information is required in order to access, or use, Our Site, to enable Us to provide You with Services or to contact You for marketing or promotional purposes.

If You do not wish to have Your Personal Information used in this manner described in this Privacy Policy, You can contact Us. However, if You do so, You may not be able to access, or use, all or part of the Services.

In addition, We may still use or disclose Your Personal Information if:

We subsequently notify You of the intended use or disclosure and You do not object to that use or disclosure;
We believe that the use or disclosure is reasonably necessary to assist a law enforcement agency or an agency responsible for government or public security in the performance of its functions;
to protect Our rights including enforcing Terms and Conditions;
to protect the safety of members of the public and users of Our Site and Services; or
We are required by law to disclose the information.

Data security, storage and retention

We will take reasonable steps to protect Personal Information which We hold from misuse, loss and from unauthorised access, modification or disclosure.

You should be aware that, when using Our Site or Services, no data transmission over the Internet can be guaranteed as completely secure. We do not warrant the security of any information You transmit to Us over the internet and You do so at Your own risk.

We will continue to store and hold Your Personal Information indefinitely, until such time as We no longer need it for any purpose for which the information may be used or disclosed under this Privacy Policy or under applicable privacy or data protection laws or (if earlier, and subject to the next paragraph) a reasonable time after You ask Us to delete it. We typically retain data for as long as We are providing Services to You and for a period of up to 6 years after We stop providing products or Services to You (or longer if the legal limitation period is greater).

We will destroy, delete or de-identify Your Personal Information within a reasonable time after the end of the period mentioned in the previous paragraph, unless We are required to retain it by law.

While We hold Your information, it will be under the ultimate, direct or indirect control of PPA IP Pty Ltd, in its custody or the custody of one or more entities under the common control within it. It may be stored in Australia, or any other location contemplated in this Privacy Policy.

Access to, and correction of, Your Personal Information

You must update Us regularly with Your Personal Information to ensure We hold information about You that is up-to-date, accurate and complete. This is to ensure correspondence is not received by a person who takes over Your old email address or phone number. You may request access to, or correction of, any Personal Information about You that We hold. We may request You to verify Your identity before processing any such request.

A fee will not apply to making a request for access or to update Your Personal Information. A fee may apply and be charged for providing Personal Information to You. Any such fee covers the cost to Us in collating, copying and providing certain information to You. We will only charge this fee where it is lawful for Us to do so.

In some circumstances, We may refuse to provide You with access to or to correct Your Personal Information including, but not limited to, where:

giving access or correcting would have an unreasonable impact on the privacy of others;
the information relates to existing or anticipated legal proceedings and the information would not be discoverable in those proceedings;
giving access or correcting would be unlawful;
denying access or correcting is otherwise required or authorised by law; or
the request for access or correcting is frivolous or vexatious.

If We refuse to provide You with access to or correct Your Personal Information, We will provide You with an explanation in writing. In some circumstances where We correct information, We may still retain the original information.

Contact us

If You have any queries relating to this Privacy Policy, You wish to request access or to correct or make an inquiry regarding any Personal Information relating to You which may be in Our possession, if You have a query regarding Our privacy practices, if You have an complaint in relation to a breach of the Australian Privacy Principles, or You would like to request a printed copy of this Privacy Policy, please contact Our Privacy Officer at:

postal address: Level 10, 30 Collins St, Melbourne, Victoria 3000;
telephone: 1300 088 932; or
e-mail: privacy@performanceproperty.com.au.

We ask that any privacy-related complaint is made first in writing to Us. We will then respond to Your complaint in writing and in accordance with any timeframes required by law. We may request You to provide further information about Your complaint to properly and comprehensively assess it. If for any reason You do not wish to complain to Us initially or if We are unable to resolve Your complaint to Your satisfaction, a complaint may also be made to the Office of the Australian Information Commissioner.

Changes to this Privacy Policy

We can change, modify or update this Privacy Policy at any time, without liability to You, by publication on Our Site or through Services (as applicable). You will be bound by the changes immediately upon notification or publication, unless otherwise set out in this Privacy Policy or the notice.

This Privacy Policy was last updated on 28 April 2021.