This privacy policy sets out how Altitude Property Pty Ltd and its subsidiaries, related companies, joint venture partners, representatives, projects and trusts (“Altitude Property“, “we”, “our” or “us”) collects, uses, stores, discloses and manages your personal information and how Altitude Property complies with the Privacy Act 1988 (Cth) (“Privacy Act“).

By providing personal information to us, you consent to our collection, use, storage, disclosure and management of your personal information in accordance with this privacy policy and any other arrangements that apply between us. We may change our privacy policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current privacy policy.
What is personal information?

When used in this privacy policy, the term ‘personal information’ has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include, but is not limited to, your name, address, telephone number, email address and occupation. If the information Altitude Property collects personally identifies you, or you are reasonably identifiable from it, the information will be considered to be personal information.

What personal information do we collect?
The information Altitude Property collects about you depends on the products, services or information that you ask us to provide to you and the dealings that you have with us. We may collect the following types of personal information:

• your name, date of birth, gender and contact details including your physical address, mailing address, email address and telephone number;
• bank account and credit card details;
• information to verify your identity such as your driver licence number;
• information relating to your income and credit-worthiness;
• your employment history, and other information you provide as part of the recruitment process, if you apply for a job with us;
• details of products and services that we have supplied to, or you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
• your preferences for particular products, services, facilities or lifestyle activities when you tell us what they are;
• information about you and your family and any characteristics, preferences or requirements that are relevant to the products and services that we may provide to you;
• any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites, Wi-Fi services, online presence or otherwise. That information may include information regarding what web pages you access;
• information you provide to us through our representatives or customer surveys from time to time;
• if you are involved in an incident, details about the involvement of you and other people in the incident, witness and incident statements, CCTV footage of the incident, medical information and information from medical consultants and other consultants and third parties;
• information including your image collected via our CCTV systems;
• if you use mobile applications developed by us or log-in to wireless facilities provided in a Altitude Property managed site, including sales centres and site offices, details relating to your use of the mobile application or wireless facility;
• your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information; or
• any other personal information that may be required in order to facilitate your dealings with us.

The Privacy Act contains restrictions on collecting sensitive personal information such as ethnicity, religious views and personal health information. Altitude Property generally does not collect sensitive personal information about an individual. In limited circumstances, with the express consent of the individual, Altitude Property may collect some sensitive personal information if it is reasonably necessary in its dealings with a particular individual.

How is personal information collected?
Altitude Property collects personal information in a number of ways including but not limited to:

• through your access and use of our websites, Wi-Fi services or mobile applications;
• through your enrolment and participation in surveys, questionnaires, customer VIP programs, competitions and promotions run by or on behalf of us;
• through your communications with us, including emails, letters, conversations or other correspondence between you and our representatives;
• when you make an enquiry, complete an application or purchase order;
• through our CCTV systems;
• through our referral partners, who have provided your information to us;
• other interactions with our websites, products, services, content or advertising; and
• in the case of incidents in which you are involved, from you, witnesses, CCTV footage of the incident, medical consultants and other consultants and third parties.

In addition, when you apply for a job or position with us we may collect information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This privacy policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act.

We may also collect personal information from third parties including but not limited to, marketing agencies, data collection agencies, credit reporting agencies, law enforcement agencies and other government entities.

What happens if Altitude Property cannot collect personal information?
If you decide not to provide Altitude Property with the personal information described above, some or all of the following may happen:

• we may not be able to provide the requested products or services to you, either to the same standard or at all;
• we may not be able to provide you with information about the products and services that you may want; or
• we may be unable to tailor the content of its websites or mobile applications to your preferences and your experience of the websites or mobile applications may not be as enjoyable or useful.

Why do we collect, store, use and disclose personal information?
Altitude Property operates a number of businesses that utilises personal information. Altitude Property businesses include but are not limited to the following:

• project marketing;
• sales and marketing of new house and land packages, land releases, apartments, townhouses or any new projects;
• seminars for first home buyers;
• seminars for investors;
• real estate agency services;
• property management;
• investment advisory services;
• new home building (project home construction;
• data and analytical services;
• property development and management services; and
• management of unlisted property funds.

Broadly, Altitude Property collects, stores, uses and discloses your personal information for the following purposes:

• to provide products and services to you and to send information and communications requested by you;
• to inform you of updates concerning us and our products and services;
• to provide you with access to protected areas of our websites;
• to assess the performance of our website and to improve, optimise and protect its operation;
• 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), planning, product or service development, quality control or research purposes of Altitude Property and its contractors and service providers;
• to provide your updated personal information to our contractors or service providers in order for us to provide and/or offer our products and services to you;
• to update our records and keep your contact details up to date;
• to process and respond to any enquiry or complaint made by you;
• for security and risk management purposes including incident investigation, loss prevention, claims management and litigation;
• to be provided to a partner or referral company;
• 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 (or political sub-division of a country); and
• to consider your employment application.

Your personal information will not be shared, sold, rented or disclosed other than as described in this privacy policy.

We may, from time to time, process your personal information so as to put it in a form from which your identity is not reasonably ascertainable (“de-identified information”). We use such de-identified information for analytic purposes, and may disclose that information to others for our business purposes. De-identified information falls outside of the scope of the Privacy Act.

Direct marketing communications
Altitude Property and/or third party service providers we engage may send you direct marketing communications and information about:

• products, services, discounts, competitions and special promotions that we consider may be of interest to you;
• offers or promotions based on how you use our products and services;
• third party products and services (including offers and discounts we may have negotiated for our customers) we think may interest you, if you’ve chosen to receive this information. For example, if we are selling residential land our packages, we may promote the services of a brokerage firm.

These communications may be sent in various forms, including by telephone, post, fax, email, SMS or any other form of electronic communication, in accordance with the Privacy Act and the Spam Act 2003 (Cth).

Under this policy you consent to Altitude Property and the third party service providers we engage sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will try to use that method whenever practicable to do so.

You may opt-out of receiving marketing communications from Altitude Property and/or our third party service providers at any time by contacting the sender using the details set out in the communication, or in the case of Altitude Property, using the details set out below) or by using the opt-out facilities provided in the marketing communication (eg an unsubscribe link). If you opt-out using the opt-out details provided in a marketing communication, we will ensure that you are removed from the distribution list for that particular communication. If you wish to opt-out of other (or all) marketing communications or mailing lists, please see below.

Opting-out of other or all marketing communications
If you no longer wish to receive certain or any direct marketing communications from us, you may opt-out at any time by contacting our administration team using the contact details below. If we are currently providing, and will continue to provide, you with services or products, we may still be required to make certain communications to you as required by law.

To whom does Altitude Property disclose personal information?
We may disclose personal information for the purposes described in this privacy policy to:

• affiliate partners or joint venture partners in property developments we are managing, developing, or marketing (for the purposes of marketing campaigns);
• consultants, agents or contractors acting on our behalf, including real estate and travel agents, marketing agencies, surveyors, conveyancers, builders and property developers;
• valuers where we are seeking to value a property or lease;
• credit reporting agencies or guarantors;
• regulatory authorities or government agencies or bodies where required by law;
• related parties, entities, partners and trusts of Altitude Property; and
• parties to whom Altitude Propertyhas outsourced various functions, including but not limited to providers of share registry services, catering and restaurant services, contractors or service providers for the purposes of operation of our website or our business, custodians, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, insurers, insurance brokers, real estate agents, marketing agents, travel agents, claims management services, injury management services, property management services and professional advisors such as accountants, lawyers and business advisors.

If any Altitude Property business, company or trust is sold to a third party, we may transfer any personal information we hold about you to that third party. We may also disclose personal information to prospective purchasers of such a business, company or trust on a confidential basis as part of their due diligence investigation of the business, company or trust.

Where we have disclosed personal information to a third party acting on our behalf, we request that those third parties do not use the personal information for their own purposes and that they comply with this privacy policy.

Do we disclose personal information outside Australia?
We may disclose personal information to persons outside Australia, including but not limited to the following:

• our related bodies corporate located overseas; and
• our data hosting and other service providers.

We will take reasonable steps to ensure that any overseas recipient will deal with such personal information in a manner that is consistent with the Privacy Act and this privacy policy.

Cookies
A cookie is a small text file that a website may write to your hard drive when you visit the website. A cookie file can contain information, such as a userID, that the website uses to track the pages you have visited. The only personal information a cookie can contain is information you personally supply. A cookie cannot read data on your hard disk or read cookie files created by other websites.

Altitude Property’s websites use cookies to track user traffic patterns and to better serve you when you revisit the website. You can set your browser to notify you when you receive a cookie, providing you with the opportunity to either accept or reject it. You can also refuse all cookies by turning them off in your browser. We handle personal information collected by cookies in the same way that we handle all other personal information as described in this privacy policy.

Security of Information
Altitude Property may hold your personal information in either electronic or hard copy form. We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure and we use a number of physical, administrative, personnel and technical measures to protect your personal information. For example, no employee should be able to access information that they do not require for their duties. There are passwords and security access IDs in place to restrict access to confidential and personal information to those who need it to perform their duties.

Third party links
Our websites and mobile applications may contain links to websites operated by third parties. Those links are provided for your convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. We note that the privacy policies that apply to those websites may differ from this privacy policy.

Access and correction of personal information
If you wish to seek access to the personal information we may hold about you, please contact our Privacy Officer using the contact details set out below. Where we hold information that you are entitled to access, we will try to provide you with a suitable means of accessing it (for example, by mailing or emailing it to you).

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 it would result in a breach of confidentiality. If that happens we will give you written reasons for the refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. If you wish to update the personal information that Altitude Property may hold, please contact [email protected]. In some unusual cases we may not agree that there are grounds for amending your personal information. If that happens, we will add a note to the personal information stating that you disagree with it.

We will not charge you for simply making the request and will not charge for making any corrections to your personal information. Depending on the nature of the request, we may ask you to provide us further information in order to verify your identity, put your request in writing and to complete an enquiry form, which will be sent to you.

What is the process for complaining about a breach of privacy?
If you think we have breached the Privacy Act, or you wish to make a complaint about the way we have handled your personal information, please contact our Privacy Officer. Please provide your name, email address and/or contact number and details of your complaint. Our Administration Team deals with privacy complaints and any complaints should be directed to the Administration Team using the contact details set out 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.

After Altitude Property has completed its investigation, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about your complaint. If we receive a response from you, we will assess it and advise if Altitude Property has changed its view. If you are unsatisfied with the outcome, we will provide you with information about the further steps you can take.

Changes to Altitude Property’s privacy policy
Altitude Property reserves the right to modify or amend this privacy policy at any time and will update the privacy policy on Altitude Property’s website if it has been changed. If you have any further questions about this privacy policy, please contact our Administration Team.

Contact us
For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact the Altitude Property Administration Team using the details set out below:

– Email: [email protected]
– Post: PO Box 898 Castle Hill NSW 1765

Effective: 4th June 2020