Updated 30 April 2020
Ever Bright Group Pty Ltd ACN 133 707 150 (EBG Developments, we, us, our) is committed to protecting your personal information, in accordance with the Spam Act, the Do Not Call Register Act, the Australian Privacy Principles in the Privacy Act and applicable health privacy laws.
This Policy explains how we collect, use, disclose and otherwise handle personal information. By ‘personal information’ we mean information or an opinion, whether true or not and whether recorded in a material form or not, about an individual who is identified or reasonably identifiable (for example, your name, email address and phone number).
2. What we collect
The type of personal information that we collect about you depends on the dealings you have with us. For example, if you:
enquire with us or submit an expression of interest in relation to the purchase of property, we will collect your name, email address, telephone number, address and the property address in respect of which you are enquiring
request the creation of a sale of land contract, we will collect your name, email address, telephone number, address and the property address for the property the subject of the sale of land contract
sign up for our newsletter, we will collect your name and email address
work for a supplier, we may collect details such as your name, job title, address, telephone number and email address
send us an enquiry or provide us with feedback, we may collect your name, contact details, details of your enquiry or feedback and information about our response
apply for a job with us, we will collect the information you include in your job application, including your cover letter, resume, contact details and referee details
2.2. Sensitive information
We only collect sensitive information (such as health information) where it is reasonably necessary for our functions or activities, and either you have consented, or we are required or authorised by law to do so.
2.3. Collection of information other than personal information through our website
When you visit the Site, some of the information that is collected about your visit is not personal information, as it does not reveal your identity.
For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.
We use and disclose this information in anonymous, aggregated form only, for purposes including statistical analysis and to help us identify the most effective areas of the Site and improve the less popular ones. You are not individually identified, however we reserve the right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with the Site, or where we are otherwise required or authorised by law to do so.
A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users, although they do identify the user’s internet browser.
Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website.
Online behavioural advertising
We use advertising programs that place cookies on your computer to collect information about your browsing history (including on external websites). This information, which does not identify you personally, is collected in order to improve your online experience by customising the advertising you see to your interests (including the display of more relevant ads on external websites). You can opt out of these programs at any time by clicking here.
2.4. What if you don’t provide us with your personal information?
We will provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to an individual’s actual name.
For example, you can access our website and make general phone queries without having to identify yourself.
In some cases however, if you don’t provide us with your personal information when requested, we may not be able to provide you with the product or service that you are seeking. For example, you must identify yourself to enter into a contract to purchase land from us.
3. How we collect personal information
3.1. Methods of collection
We collect personal information in a number of 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)
from third parties, including real estate agents that we have engaged to sell properties on our behalf
3.2. Collection statements
Where we collect personal information about you, we will take reasonable steps to provide you with certain details about that collection (such as why we are collecting the information and who we may share it with). We will generally include this information in a collection statement.
4.Why we collect personal information
The main purposes for which we collect, hold, use and disclose personal information are to:
process enquiries and expressions of interest, and give effect to transactions for the purchase of real estate,
operate loyalty programs
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 (see under heading 4.2 below)
procure products and services for our business
perform research and statistical analysis, including for marketing, customer satisfaction, product development and service improvement purposes
protect the security of our offices, staff, customers and merchandise (including fraud and loss prevention)
answer queries and resolve complaints
recruit staff and contractors
We may also collect, hold, use and disclose personal information for other purposes explained at the time of collection, or which are required or authorised by or under law, or for which you have provided your consent.
4.2. Direct marketing and opting out
We may use your personal information to let you know about us and our products and services (including new properties you may be interested in, promotions, special offers and events), either where we have your express or implied consent, or where we are otherwise permitted by law to do so. We may contact you for these purposes in a variety of ways, including by mail, email, SMS, telephone, social media, online advertising or facsimile.
Where you have consented to receiving marketing communications from us, your consent will remain current until you advise us otherwise. However, you can opt out at any time, by:
contacting us (details under heading 10 below)
advising us if you receive a marketing call that you no longer wish to receive these calls
using the unsubscribe facility that we include in our electronic messages (such as emails, SMSes and MMSes)
5. Who we may share your personal information with
We may share your personal information with third parties where appropriate for the purposes set out under heading 4, including:
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)
In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant products or services.
6. Cross border disclosure of personal information
7. Data quality and security
We hold personal information in a number of ways, including in electronic databases, email contact lists, and in paper documents held in drawers and cabinets. Paper files may also be archived in boxes and stored offsite in secure facilities. We take reasonable steps to:
make sure that the personal information that we collect, use and disclose is accurate, up to date and complete and (in the case of use and disclosure) relevant;
protect the personal information that we hold from misuse, interference and loss and from unauthorised access, modification or disclosure; and
destroy or permanently de-identify personal information that is no longer needed for any purpose permitted by the APPs.
You can help us keep your information up to date, by letting us know about any changes to your details, such as your address, email address or phone number.
The steps we take to secure the personal information we hold include website protection measures (such as firewalls and anti-virus software), security restrictions on access to our computer systems (such as login and password protection), controlled access to our corporate premises and restriction of access to personal information on our systems to staff who need the information to perform their roles.
While we endeavour to protect the personal information and privacy of users of our website, we cannot guarantee the security of any information that you disclose online and you disclose that information at your own risk. If you are concerned about sending your information over the internet, you can contact us by telephone or post (details under heading 10 below).
If you have an online account with us, you can also help to protect the privacy of your personal information by maintaining the confidentiality of your password and by ensuring that you log out of the website when you have finished using it. In addition, if you become aware of any security breach, please let us know as soon as possible.
Third party websites
8. Access and Correction
Please contact us (details under heading 10 below) if you would like to access or correct the personal information that we hold about you. We may require you to verify your identity before processing any access or correction requests, to make sure that the personal information we hold is properly protected.
We will generally provide you with access to your personal information, subject to some exceptions permitted by law. We will also generally provide access in the manner that you have requested (eg by providing photocopies or allowing a file to be viewed), provided it is reasonable and practicable for us to do so. We may charge a fee to cover our reasonable costs of locating the information and providing it to you.
If you have an online account with us, you can also access your account information by logging into your account through our website.
If you ask us to correct personal information that we hold about you, we will take reasonable steps to correct that information. If we refuse to correct personal information in the manner you have requested, you may ask us to associate your request with the information and we will take reasonable steps to do so.
Except in the case of more complicated requests, we will endeavour to respond to access and correction requests within 30 days.
If you have a complaint about how we have collected or handled your personal information, please contact us (details under heading 10 below).
We will endeavour in the first instance to deal with your complaint and take any steps necessary to resolve the matter within a week. If we are not able to do so, we will ask you to submit your complaint in writing. In most cases, we expect to investigate written complaints and provide a response within 30 days of receipt. If the matter is more complex and our investigation may take longer, we will contact you and tell you when we expect to provide our response.
If you are not satisfied with our response, you can refer your complaint to the Office of the Australian Information Commissioner (see here for further information).
10. Our contact details
Please contact us if you have any queries about the personal information that we hold about you or the way we handle that personal information. Our contact details are set out below.
Mail: Charsfield – 478 St. Kilda Road, Melbourne, Victoria 3004
Telephone: (03) 86256400
11. Changes to this Policy