Now Living Realty’s commitment to our clients
Our management and staff are aware of the importance of protecting the privacy of individuals who come in contact with us.
We are committed to ensuring the privacy of the personal information we collect in the course of our business. We believe that respect for your privacy forms part of the ongoing trust we wish to develop with you.
We are bound by the 13 Australian Privacy Principles contained in the Privacy Act 1988 (Cth). The Australian Privacy Principles set out the way in which organisations can collect, use, keep secure and disclose personal and sensitive information. It also gives individuals the right to know what information an organisation holds about them and the right to correct that information if it is wrong. Further information on the Australian Privacy law is available from the Office of the Australian Information Commissioner (www.oaic.gov.au).
Caprice Bay Pty Ltd ACN 060 170 434 trading as Now Living Realty is a real estate agency based in Perth, Western Australia offering a variety of housing options.
‘Personal information’ is information or an opinion whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
What kinds of personal information does Now Living Realty collect and hold?
The personal information we may collect and hold varies and is dependent on the product requested or the service to be provided. Details can include but are not limited to:
- date of birth
- current and previous address (including postal address)
- contact details including telephone numbers
- E-mail address
- bank account details
- bank statements and statements for electricity / gas accounts
- credit references or reports from a third party
- drivers license details
- passport and visa details
- property ownership
- financial information including assets and liabilities, investment and loan accounts, insurance application details, consumer spending
- credit information
- consumer and commercial credit reports
- rental references and prior rental contacts; and
- consumption habits and preference information.
The above information is collected and recorded about individuals who interact with us such as:
- our customers, potential customers and their representatives
- our suppliers and their representatives
- contractors and their representatives providing goods and services to us
- our employees past and present, including applicants, and
- any other person who comes into contact with Now Living
In most cases, if we do not collect the information we require, then we may be unable to undertake certain activities, such as providing you with the requested information, or services.
The Privacy Act provides an exemption for employee records. That is information about an individual if that information directly relates to the act or practice of a current or former employment relationship between the employer and the individual. That exemption may apply to Now Living Realty in relation to the information held by Now Living Realty about its employees. Please contact the Privacy Officer for more details.
How does Now Living Realty collect personal information?
Generally, when providing goods and services to our clients or obtaining goods and services from our suppliers or contractors, we collect personal information directly from the individuals where reasonable and practical.
We may collect personal information directly from you when you:
- provide information to us in any way (including by completing a form, disclosing information over the phone or providing us a business card)
- visit our website
- use our services
- request information about us, our products or our services
- provide feedback
- fill in a form on our website, or when we phone you in response to a form you have submitted via our website; or
- where we are required or authorised by law to do so.
We may also collect information about you from other sources such as:
- nominated representatives of the individual (e.g. spouse, accountant, power of attorney, brokers and other professional advisors)
- other credit providers
- credit reporting bodies and mercantile reporting agencies
- publicly available sources of information
- lawyers, medical providers, investigators, insurers including (Work Cover in relation to insurance claims).
We will only collect your personal information from third parties if it is unreasonable or impractical to collect the necessary information directly from you or if we are otherwise permitted to do so.
How does Now Living Realty handle sensitive information?
The Privacy Act describes ‘sensitive information’ as information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual orientation, criminal record, and health information about an individual.
Occasionally it may be necessary for us to collect sensitive information about you (such as health information, racial origins and criminal records). If you or third parties provide us with sensitive information, we will as a matter of policy only use and disclose the information for the purpose for which it was provided or another directly related purpose, unless you agree otherwise, or where required by law.
Where practical and reasonable, we will only collect sensitive information with your consent.
Why does Now Living Realty collect personal information?
Now Living Realty is committed to providing quality customer service to our internal and external clients and to operate its businesses within statutory requirements and comply with its legal obligations.
We collect and hold personal information in order to operate our businesses efficiently as well as to provide and market our products and/or services for the benefit of our customers.
We collect, hold and use your personal Information:
- to identify and communicate with you
- to enable us to provide requested goods and services
- to assess any request you make for the supply of goods and services on credit by establishing your financial position and credit status
- assess your ability to repay a loan
- to collect payments
- to place insurance policies
- to process any job application submitted by you
- to manage and maintain credit accounts for the provision of goods and services on credit
- to help us to manage and enhance goods and services we provide to you
- to help us to manage and enhance goods and services we purchase from our suppliers
- notify and assess insurance claims, pay settlements and finalise claims, determine liability
- to develop and tell you about goods and services that we consider may be of interest, unless you advise us not to do so
- to protect you and us from fraud
- for business support purposes including maintenance, backup and audit
- to comply with our statutory and legal obligations
- to allow us to provide advertising material to you regarding us, our clients and other business partners,
- to respond to any queries or complaints you may have.
When does Now Living Realty disclose your personal information?
Depending on the product or service we are providing to you, we may disclose your personal information to our related entities, third parties where it is necessary to enable us to provide a product or service or to other third parties (such as your referee in connection with a job application you have submitted). We may disclose your personal information to third parties for the purposes set out above.
We may disclose your personal information to:
- your nominated representatives
- credit reporting bodies and mercantile reporting agencies
- financial planners
- other credit providers or trade suppliers
- mercantile agents
- banks, mortgage insurers, leaders, valuers, real estate agents (referees), insurers, finance brokers, settlement agents, auditors, business consultants and IT service providers
- other companies or individuals who assist us in providing products and services to you
- professional service providers and advisors who perform functions on our behalf, such as lawyers
- medical providers including medical and rehabilitation practitioners for assessing insurance claims; and
- Government, regulatory authorities and other organisations as required or authorised by law (such as Centrelink or the Police).
To manage and provide cost effective services, we outsource various administrative functions to third parties that provide mailing services, invoice and statement printing services, archiving functions, marketing services, and other services and functions as deemed necessary by management from time to time. We may also disclose your personal information to our website host or software application providers in certain limited circumstances, for example when our website experiences a technical problem or to ensure that it operates in an effective and secure manner.
Organisations providing professional services to us are required to keep those dealings and personal information provided by us as confidential unless required to disclose such information by statute or law.
In general we do not send your personal information to any overseas recipient. However, we, or one of our third party providers may disclose your personal information to overseas recipients including insurers, IT service providers, auditors and medical providers if:
- our related entities are overseas
- we outsource certain activities to an offshore entity, or
- transactions, services, or products have an overseas connection.
Now Living may disclose personal and sensitive information to Singapore due to their IT servers being located in that country.
We do not otherwise disclose your personal information without your permission, unless the disclosure is:
(b) required or authorised by law, including without limitation the Australian Privacy Principles, or
(c) made with your consent.
You consent to us using your personal information for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future. You also consent to us sending you such information by means of mail, email, SMS and MMS messages. You can contact us using the contact details specified in Enquiries if you do not want to receive marketing information from us.
The Company refers to Now Living Realty.
This Policy sets out the Company’s objectives and processes in seeking to moderate content posted on its social media sites, consistent with the guidelines published by the Australian Competition & Consumer’s.
The Company will, as far as possible, report and/or remove from the relevant social media pages or public review websites any posts or comments which:
- are abusive, threatening or harassing – including swear words or personal threats or attacks, i.e. negative comments which target particular staff by name or description;
- are intolerant – that is, vilify, or reflect intolerant comments about other people’s race, culture, beliefs, physical or mental conditions, gender, religion or age;
- are inappropriate or patently offensive – including posts depicting nudity, hate speech or violence;
- are fraudulent, false or misleading – including fake reviews (i.e. reviews by people who have not had any dealings with Now Living Realty, reviews which contain objectively incorrect or misleading factual assertions or which are written by people affiliated with employees of the Company where these affiliations are not disclosed in the same post;
- contain advertising – including viral advertising, links, promotions or similar advertisements, although product recommendations or comparisons with other products or brands are acceptable if relevant to the context of the post;
- are spam or otherwise irrelevant; or
The Company may block the social media accounts of those social media users (Users) that post comments of the above nature in a persistent or extreme manner, to avoid any future posts of a similar nature.
The Company may contact Users who have had negative experiences with the Company, as reflected in their comments and/or posts on social media, and attempt to take such reasonable steps it considers appropriate to resolve or address the concerns raised in the relevant posts. The Company may also respond to those Users who post positive reviews. This contact will either be through the relevant forum (e.g. Facebook) and/or directly by way of telephone or email.
In contacting any Users to discuss their experiences, the Company may either contact the User through the public forum of the host site, or where the discussion is of a sensitive nature (whether in relation to positive or negative reviews or other), including the request for personal contact details, the contact will be through private forums (such as Facebook’s private messaging tool) or phone or email.
The Company may remove or report clearly false, misleading or fraudulent reviews, and/or block the relevant User, even where the Company is continuing to discuss the relevant post with the User outside of the social media forum. The Company will only do so where it considers the content is objectively false and misleading or fraudulent (but it will not remove negative reviews where the reviews appear to reflect the genuine experiences of the poster).
The Company will use reasonable endeavors to respond to public posts and/or private messages as soon as practicable where they, in the Company’s assessment, include a legitimate request for a response and relate to matters that the Company has not otherwise already dealt with. The Company may also respond to posts which it considers otherwise warrant a response. The Company appreciates the patience of Users outside of the Company’s business hours (Mon-Fri 8:30am -5pm).
How does Now Living Realty manage data security?
We take reasonable steps to protect the security of your personal information by ensuring it is protected from misuse, loss, interference and from unauthorised access, modification or disclosure.
Our personnel are required to respect the confidentiality of your personal information and the privacy of individuals. We maintain strict standards and security procedures to prevent unauthorised access to the personal information whether it is in an electronic or paper format, and to ensure the correct use of this information. Personal information is stored in a central database that is password protected with access available only to authorised persons (such as Now Living Realty employees or our external database administrator) or otherwise your personal information is securely held within Now Living Realty’s offices and only available to authorised persons.
Where we no longer require your personal information we will take reasonable steps to delete, de-identify or destroy all record of the information held.
You can access and update your personal information
You are entitled to access the personal information that we hold about you. Upon written request, we will provide access to your personal information, except in circumstances where there are legal or administrative reasons to deny access. If we refuse your request to access your personal information, we will provide you with reasons for our refusal. For example, if the information requested relates to an insurance claim, we may refuse access if the information has been provided by third parties during an investigation.
We will require you to verify your identity and to specify what information you require. We may charge a reasonable fee depending on the complexity of the request to cover costs in retrieving, coping and supplying the information to you.
If you establish that the personal information we hold about you is not accurate, complete and up to date, we will take reasonable steps to correct the information so that it is accurate, complete and up to date. If we cannot take reasonable steps to correct the information due to such correction is not technically possible or would be impracticable for us to perform, we may be unable to continue to provide services to you. In these cases, we will provide reasons for denial of correction.
To request access or to correct your information, please contact our Privacy Officer.
How Now Living deals with complaints?
If you feel that we have not satisfactorily addressed your complaint, you may also make a complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au or by writing to GPO Box 5218 Sydney NSW 2001 or GPO Box 2999 Canberra ACT 2601.
All complaints should be made in writing detailing relevant information pertaining to the complaint and those parties involved in the alleged breach.
E-mail address: firstname.lastname@example.org
Mailing Address: The Privacy Officer
Now Living Realty
6 Bennett Street
East Perth 6004
This policy was last updated on 22 April 2014. If you have any general comments on this policy, please feel free to contact our Privacy Officer.