We respect your rights to privacy under the Privacy Act 1988 (Cth) (Privacy Act) and we comply with all of the Act’s requirements in respect of the collection, management and disclosure of your personal information.
What is your personal information and sensitive information?
What personal information do we collect and hold?
We may collect the following types of personal information, depending on your interaction with us:
- Name, date of birth and other identification details (including, where relevant, your passport details);
- contact details include mailing or street address, email address, telephone number;
- details of your employment;
- financial information about you, such as your income details and bank account;
- any additional information that you chose to provide to us directly through our website or through our surveys;
- details of your interests in our properties, your purchase of properties from us, the services that you acquire from us, together with any additional information necessary to complete the purchase transactions and to respond to your enquiries;
- any additional information relating to you that you provide to us through use of our websites or online presence, or through our representatives or during your visits to our land sales offices or display homes;
We may collect some sensitive information about you such as any pre-existing medical conditions, but such information will only be collected where you choose to provide it to us through the website portals.
We are required, in certain circumstances such as where you wish to purchase a property, to collect your name, address, date of birth and other verification information under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) or the Foreign Acquisitions and Takeovers Act 1975 (Cth) to verify your identity and your residential status.
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 or aggregated information using web tracking technologies about how users use our website.
How do we collect your personal information?
We collect your personal information generally directly from you unless it is unreasonable or impracticable to do so (for example, where you engage one of our agents). When collecting personal information from you, we may collect in ways including:
- in person (for example, if you attend our premises and provide this information to one of our sales team);
- through the Site (for example, if you sign up for our newsletter, make an enquiry or sign up to a purchase online);
- through our social media pages;
- over the telephone;
- through written correspondence (such as letters, faxes and emails);
- on hard copy forms (for example, sale of land contracts); and
- from third parties, including real estate agents that we have engaged to sell properties on our behalf.
To the extent permitted by, law, we may also collect personal information from third parties including from third party companies such as credit reporting agencies, law enforcement agencies and other government entities. Otherwise we do not generally collect personal information from third parties, except that we may collect limited personal information about a person from users of our website portals (for example, where you are listed as an emergency contact of a residence in one of our properties).
Cookies and other tracking technologies
We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.
We and our advertising partners also use advertising cookies and other web-tracking technologies, such as pixel tags and web beacons to collect information about browsing habits, analyse trends, administer our websites, track users web movements, gather broad demographic information and other marketing purposes. These are also used to make advertising more relevant to you and your interests.
What happens if we can’t collect your personal information?
If you do not provide us with the personal information described above, some or all of the following may happen:
- we may not be able to provide the requested website portals to you, either to the same standard or at all, or some features may not function properly;
- we may not be able to provide you with information about our properties, opportunities and services that you may want, including information about new developments, sales or special promotions;
- we may not be able to complete a sale transaction with you; or
- we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.
You are never required to provide us with sensitive information to be able to use our website portals.
For what purposes do we collect, hold, use and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and to provide best possible quality of customer service.
We collect, hold, use and disclose your personal information for the following purposes:
- to operate loyalty and referral programs;
- to promote ourselves and our products and services (including new properties that you may be interested in), including through direct marketing, events, competitions and social media;
- to procure products and services for our business;
- to protect the security of our offices, staff, customers and merchandise (including fraud and loss prevention);
- to answer queries and resolve complaints;to provide the website portals and facilitate interaction between users of our websites and website portals, products and services to you and to send communications requested by you;
- to answer enquiries, provide customer services, and provide information or advice about our properties, opportunities and services;
- to complete property transactions with you, including to conduct background checks where necessary (for example if required in relation to a proposed purchase);
- to assess the performance of the website and to improve the operation of the website;
- to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
- for the administrative, marketing (including direct marketing and advertising), planning, product or service development, quality control and research purposes of Welsh Group, its related bodies corporate, contractors or service providers;
- to provide your updated personal information to our related bodies corporate, contractors or service providers;
- to update our records and keep your contact details up to date;
- to process and respond to any complaint made by you;
- to generate statistics and derive insights from our data; and
- to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.
We utilise the services of third parties for marketing purposes, including online platforms and social media platforms, and we will disclose personal information about you to the third party service provider for our marketing purposes. While these third parties generally only use the personal information for our marketing purposes, some may retain certain personal information about you for their own purposes.
To whom may we disclose your information?
We may disclose your personal information to:
- our employees, related bodies corporate, contractors 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 or completing a property transaction with you including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, data entry service providers, electronic network administrators, 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 related purposes, including but not limited to:
- our solicitors and other professional advisors in the processing of sale of land contracts
- financial institutions for payment processing
- referees whose details are provided to us by job applicants
- prospective purchasers in the event of a proposed or actual sale of our business
- our contracted service providers, including:
– sales and marketing agencies
– information technology and data storage providers
– venues and event organisers
– research and statistical analysis providers
– call centres
– hard copy and electronic mail houses
– regulatory or government bodies to comply with laws
– external business advisers (such as recruitment advisors, accountants, auditors and lawyers)
- any organisation for any authorised purpose with your express consent or where required by law.
In each case, we may disclose personal information to the third party and the third party may in turn provide us with personal information collected from you in the course of providing the relevant products or services.
Our website portal may include functionality that permits you to post information (such as bulletin boards). Such information will be disclosed to other users of the website portal.
We may combine or share any information that we collect from you with information collected by any of our related bodies corporate (within Australia).
Direct marketing materials
We (or our service providers and advertising partners) may send you direct marketing communications and information about our properties, opportunities and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, targeted advertisements, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003(Cth). You consent to us sending you those direct marketing communications by any of those methods. 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.
Please note that we also carry out digital advertising campaign from time to time that do not rely on your personal information. Your opt-out will not have effect on such advertising campaigns.
We do not use your sensitive information for the purposes of direct marketing.
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 (see the details below). 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). We may charge you a fee to cover our administrative and other reasonable costs in providing the information to you. 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 written 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.
What is the process for complaining about a breach of privacy?
If you believe that your privacy has been breached, please contact our Privacy Officer using the contact information below and provide details of the incident so that we can investigate it.
We request that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Our Privacy Officer deals with privacy complaints and any complaints should be directed to our Privacy Officer using the contact details below. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.
After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.
If you are not satisfied with the way your privacy-related complaint is handled by us, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC). Details of how to lodge a complaint with the OAIC may be found at www.oaic.gov.au or by calling 1300 363 992.
Do we disclose your personal information to anyone outside Australia?
We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above. Our IT systems that hosts our data (which may include your personal information) may also reside outside Australia.
We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.
We may disclose your personal information to entities located outside of Australia, including the following:
- our related bodies corporate, located in the United States of America; and
- our data hosting and other IT service providers, located in the United States of America.
We take reasonable steps to ensure your personal information is protected from misuse and loss and from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed.
Our security measures include:
- role based access control to our ICT systems;
- locked cabinets for storage of physical records containing personal information;
- regular security vulnerability and penetration reviews and tests;
- approach level of security training for technology staff and the broader business;
- identity and access management processes and controls to key systems and information; and
- external penetration testing of all systems holding sensitive data.
As our website is linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. We also cannot guarantee that the information you supply will not be intercepted while being transmitted over the internet. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk.
Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.
We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.
Please contact our Privacy Officer at:
Schedule 1 Entities
This Policy is used by the following entities and any of their related body corporates and subsidiaries:
Avenger Group Pty Ltd, Rompin Group Pty Ltd, Tulloh Group Pty Ltd, 1351MCR SPV Pty Ltd, ACTC SPV 4 Pty Ltd, Armstrong Creek Town Centre Pty Ltd, Welsh Group Pty Ltd, Landopo Pty Ltd, Welsh Charters Pty Ltd, Welsh CHMP Pty Ltd, Welsh Developments ACTC Pty Ltd, Welsh Developments ACTC SPV 1 Pty Ltd, Welsh Developments ACTC SPV2 Pty Ltd, Welsh Developments ACTC SPV 3 Pty Ltd, Welsh Developments Armstrong Creek No.2 Pty Ltd, Welsh Developments Armstrong Creek Pty Ltd, Welsh Developments Boundary Rd Pty Ltd, Welsh Developments Pty Ltd, Welsh Group Asset Register Pty Ltd, Welsh Group Holdings Pty Ltd, WelCo IP Pty Ltd, A.P. WelCo Management Consulting Pty Ltd, A.P. WelCo Holdings Pty Ltd, WelCo Group Pty Ltd, WelCo Asset Holding Pty Ltd, WelCo Developments Pty Ltd, WelCo Operations Pty Ltd, Key West Group Pty Ltd, Key West T65 Pty Ltd, Key West T68 Pty Ltd