Privacy Policy

Privacy Policy

This Privacy Policy sets out how we manage personal information.  We comply with the Privacy Act 1988(Cth) ("Privacy Act") and the applicable Australian Privacy Principles under that Act in Australia, and any other applicable privacy laws when handling personal information.  We take the protection of your personal information seriously. 

In this Privacy Policy:

"we", "us" and "our" means The Commercial Portal Australia Pty Ltd ACN 630 414 738, and any associated entities of that company, and each of them severally, and their related bodies corporate, associates, third parties and affiliates.

"website" means any website operated by us.

Consent

By accessing any of our websites, signing up to any of our accounts or services (including memberships, promotions, digital data rooms and data alerts), subscribing to any of our newsletters, providing any advertisements, contacting us through any of our websites, or accepting any terms and conditions that incorporate this Privacy Policy, you agree to your personal information being handled in accordance with this Privacy Policy.  

You are not required to provide personal information to us.  However, if you do not provide us with all the information we request, the services we provide to you may be affected.  For example, by not providing your email address or any other personal information requested, we may not be able to communicate with you or deliver publications to you, or provide you with other updates and offers.

 

What is personal information?

Personal informationmeans any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not,and whether the information or opinion is recorded in a material form or not.

 

Sensitive information is a subset of personal information. It includes information about your racial or ethnic origin, political opinions, membership of political, professional or trade associations or trade unions, religious beliefs, sexual orientation or practices and criminal record.    

 

What types of personal information do we collect?

Examples of personal information we may collect include individuals’ names, occupation, company, their source of inquiry, contact details (e.g. telephone number, email address and address), and the publications and topics of interest to individuals.  For those who blog with us, personal information may also include photographs, location, profile and languages spoken.

We may collect the following personal information from job applicants, and contractors:  name, employment history and experience, qualifications, date of birth, contact details, referee details, and emergency contact details.

Names and contact details may also be collected from individuals representing industry related contacts.

We do not usually collect sensitive information.  We will only ever collect sensitive information in circumstances where you have consented to the collection, or we are required or authorised by law to collect the sensitive information.  If sensitive information is ever collected by us, it will only ever be used for the purpose it was collected.  We never use or disclose sensitive information for direct marketing purposes.

How do we collect and hold personal information?

We generally collect personal information from:

• individuals who deal with us in person (e.g. face to face or telephone);
• individuals who use our online subscription, listings or contact facilities, register for accounts online, or who email us about newsletters, advertising, products or services offered on or via our websites
• Associates (as defined above); 
• our overseas affiliates and media partners;
• co-publishers;
• our agents, service providers and contractors;
• our employees, related bodies corporate, partnerships, joint venture entities, contractors or external service providers for the operation of our network or our business, fulfilling requests by you, and otherwise provide products and services to you, including without limitation, web hosting providers, IT systems administrators, mailing houses, newsagents, couriers, payment processors, photographic analysers, data entry service providers, electronic network administrators, debt collectors, and professional advisers such as accountants, solicitors, business advisors and consultants;
• our existing or potential agents and/or business partners;
• specific third parties authorised by you to receive information held by us;
• property owners, property developers, real estate agents, brokers, valuers, researchers and other industry related contacts; and
• referees and former employers in the case of job applicants (including through the jobs portal), suppliers and contractors.

If you visit one of our websites, our internet service provider may record certain information about your visit, including:

• internet address;
• domain name; 
• internet service provider;
• the date and time of the visit to the website;
• any information or documentation and or data downloaded;
• your feedback, comments and conversations;
• the length of the session;
• the pages accessed;
• the website that referred to our website;
• the type and version of the browser; and
• the operating system used.

We are also able to collect information about email recipients including geographical location and viewing and interaction activity (such as views, bounces, clicks, replies, forwards, opt outs and links).  This information is aggregated for analysis as de-identified data.

We use pixels, or transparent GIF files, on our websites to help manage online advertising and email marketing.  These files enable our service providers to recognise a unique cookie in your web browser, which in turn enables us and our service providers to learn which advertisements and emails brought you to any of our websites, and how you use our websites.  GIF files are used to:

• track responses to advertisements, emails and site content (including social media engagements);
• determine your ability to receive HTML based emails;
• record how many users open an email;
• compile aggregated statistics;
• better target interactive advertising;
• enhance customer support and site usability; and
• provide offers and promotions that we believe would be of interest to you.

 

Cookies and Other Technologies

Cookies and other technologies may be used by us or by third parties when you visit any of our websites or use any of our applications or related digital properties (individually and collectively, “Services”).  In some cases, we may collect personal information from the cookies.  ‘Cookies’ contain some information with a unique ID number pertaining to your computer. We may use this information to determine your usage of our website and Services, and the performance of the websites and Services.

We may also collect information about your browsing behaviour, such as but not limited to, the number of times you have visited, the date you visited and the amount of time you spent using our Services.  We may also collect anonymous data (which is not personal information) about performance and errors that occur while you use our Services.

The information collected from cookies and other technologies is used solely for our internal purposes in managing our Services and improving their functionality and reliability, as well as to assist us in better targeting advertising, report statistics, analyse trends, administer our services, diagnose any errors and thereby enhancing customer support, site usability and quality.

Disclosure of personal information

In the course of our business, we may disclose personal information to:

• users of our websites;
• potential purchasers of businesses, advertisers, data and real estate and their professional advisers;
• our Associates (as defined above);
• our overseas affiliates;  
• property developers, property owners, real estate agents, brokers, valuers and other real estate industry contacts;
• third parties where you have requested information, goods or services from them (e.g. Ratesonline.com.au Pty Ltd if you use the online loan search or application tools powered by ratesonline.com.au that are accessible from our website/s, moneyQuest Australia Pty Ltd if you use its online forms to enquire about financial advice or car loans and moneyQuest Insurance Services Pty Ltd if you use the online insurance quote forms accessible from our website/s) and others from time to time;
• lenders and mortgage brokers;
• insurers and insurance brokers;
• referees and former employers (in the case of job applicants and contractors);
• external organisations that are our agents, suppliers, service providers or contractors;
• advertisers for marketing material;
• syndicated listing sites;
• our shareholders;
• our sponsors;
• media partners;
• third party IT suppliers;
• our professional advisers, such as accountants, lawyers and auditors; and
• if required or authorised by law, regulatory bodies, government agencies and authorities, law enforcement bodies and courts.

 

Use of personal information

The purposes for which we collect, hold, use and disclose personal information include:

• providing you with information from our websites, affiliates, partners and associated entities;
• sending you newsletters, publications, communications and advertising material (including third party publications, communications and advertising material);
• providing our overseas affiliates, co-publishers and media partners with your email address and other contact details so that they can contact and or send you local and or relevant versions of our publications;
• advertising or marketing products, opportunities and services (including third party products and services);
• responding to enquiries or providing a relevant product or service as requested;
• providing you with information in relation to real estate or the real estate industry;
• compiling, analysing and sharing statistics, sold data and or case studies;
• to customise our services or advertising;
• administration, business planning and other internal management functions and operations related to the provision or management of our and our Associates' products or services, including research and development;
• debt collection;
• surveys and customer feedback;
• complying with our legal obligations;
• audit;
• assessment of employment applications; and
• other purposes for which it was collected.

 

Direct marketing

You consent to us using your personal information to send direct marketing material in relation to our products or services, Associates’ products or services, or the products or services of third parties.

You also consent to us disclosing your personal information to Associates, our overseas affiliates, our partners, co-publishers, our sponsors and other third parties, in order to facilitate direct marketing by those parties. 

Where we have collected your personal information from one of our overseas affiliates, partners, co-publishers, contributors or bloggers, that entity has advised us that you have provided your consent to the use of your personal information for the purpose of receiving email publications, text messages and other electronic communications including for direct marketing purposes.

If you do not wish to receive marketing information from us, you may at any time opt-out of receipt of further marketing communications by contacting our Privacy Officer (contact details below).  If direct marketing is by email, you may also use the unsubscribe function.

You may contact our Privacy Officer if you do not wish us to disclose your personal information to third parties for direct marketing purposes.

 

Government related identifiers

We do not use any government related identifiers, such as driver’s licence numbers, as its own internal identifier of any individual.  We will not use or disclose any government related identifiers other than in accordance with the Privacy Act, or as otherwise required or authorised by law.

 

Data integrity and security

We endeavour to ensure that all personal information we hold is accurate, complete and up-to-date.  To assist us with this, individuals should contact us if any of their personal information changes, or if they believe that the personal information we have is not accurate or complete.

We take reasonable steps to protect the personal information that we hold from misuse, interference or loss, or from unauthorised access, modification or disclosure.  

If we no longer require personal information that we hold (including when we are no longer required by law to keep records relating to you), we will take such steps as are reasonable in the circumstances to destroy the information or ensure that the information is de-identified. 

 

Disclosure overseas

We may disclose your personal information to overseas recipients, including recipients in locations such as New Zealand, Japan, Indonesia, Singapore, Malaysia, China, Mongolia, Thailand, other Asian countries, United Arab Emirates, other countries in the Middle East and North Africa, and the United States of America.

By accessing any of our websites or Services, you consent to disclosure of your personal information anywhere in the world on the basis that we will not take any steps to ensure that overseas recipients do not breach the Australian Privacy Principles in relation to your personal information.  Overseas recipients may not be subject to any privacy obligations that are similar to the Australian Privacy Principles, and may be subject to a foreign law that could compel the disclosure of personal information to a third party such as an overseas authority.  We will not be accountable under the Privacy Act 1988 (Cth) or equivalent overseas laws, and you will not be able to seek redress under the Privacy Act 1988 and may not be able to seek redress under overseas laws, if the overseas recipient handles your information in a way that is inconsistent with the Privacy Act 1988 (Cth).

 

Access and correction

Individuals can ask us for access to their personal information by sending a written request to our Privacy Officer at the address below. 

We do not impose a charge for making a request for access, however, we may charge for reasonable administrative costs incurred in providing access.

You can ask us to correct or update your personal information.  We do not impose any charge with respect to requests for correction or updates.

Before correcting or providing access to personal information in response to a request, we will require your identity to be confirmed.  

Requests for access or correction may be refused upon the grounds contained in the Privacy Act.  If we refuse to provide access, or to correct personal information, we will provide you with reasons for the refusal.

 

Links

Our websites and our email communications may contain links to third party sites.  We do not control these sites or any of their content and if you visit these sites, they will be governed by their own terms of use (including privacy policies).

 

Complaints

Privacy related complaints should be directed to our Privacy Officer in writing at the email or postal address shown below. No charge will be imposed for the making of a complaint, or for dealing with the complaint.

Once a complaint has been lodged, our Privacy Officer will acknowledge its receipt to you as soon as possible.

We will endeavour to respond to your complaint as soon as possible.

We will do our best to ensure that our investigation is completed, and a decision on your complaint is communicated to you, within 30 days of our receipt of the written complaint. We will inform you if we need more time.  

If we are not able to resolve your complaint to your satisfaction you may also contact the Australian Information Commissioner.

 

Office of the Australian Information Commissioner

GPO Box 5218

SYDNEY NSW  2001

Telephone: 1300 363 992

Website:  www.oaic.gov.au 

 

Contact us

If you have any questions about this Privacy Policy or if you wish to request access to your personal information, correct or update your details or raise any privacy concerns you may have, please contact us at:

Address: Privacy Officer

Rialto Towers, Level 17, 

525 Collins street, Melbourne VIC 3000

Telephone: 1300 377 037 or 1300 223 554 (within Australia)

Email: [email protected]

 

Changes to this policy

We may amend this Privacy Policy, in whole or part, in our sole discretion at any time.

This Privacy Policy was last updated on 25 March 2019.