Privacy Policy
1. Introduction – purpose of this Privacy Policy
Podia Management Pty Ltd (ABN 51 613 210 478) and the Podia group (we, us or our) are committed to protecting the privacy of your personal information in accordance with the Privacy Act 1988 (Cth) including the Australian Privacy Principles, and the New Zealand Privacy Act 2020 (together, the Privacy Laws).
This Privacy Policy is intended to provide a general overview of how we handle any personal information we collect from you. "Personal information" is essentially information or an opinion about an identified or reasonably identifiable individual. By providing your personal information to us you consent to us handling your personal information in accordance with this Privacy Policy.
If you have any queries about our handling of your personal information, please contact us for further information using the details below.
2. Collection of personal information – what we collect
We may collect personal information about you in the course of your dealings with us. The type of personal information we collect will depend on your dealings with us.
For example, where you contact us for business purposes in relation to our developments (e.g. as an actual or potential investor, purchaser or lessee, or as a real estate agent or other service provider such as an architect or builder), or for other business purposes, we may collect personal information from you including, without limitation:
- personal details – such as your name, date of birth, address and other contact details (e.g. your telephone number and email address); and
- business details – such as an ABN, business name and your position within your business or organisation (if applicable).
Where we interact with you as our employee, or if you submit an employment application to work with us, we may collect personal information from you including, without limitation:
- personal details – such as your name, title, gender, date of birth, address and other contact details (e.g. your telephone number and email address) and photographic images;
- personal details – such as your name, title, gender, date of birth, address and other contact details (e.g. your telephone number and email address) and photographic images;
- information needed to verify your identity – such as your passport, drivers licence or Medicare details;
- your tax file number and superannuation information;
- information that may be required to complete background checks to determine your suitability for a particular role; and
- any other personal information that we require or that you volunteer to us – such as your resume, details of your qualifications, skills, education provider, work history, references and residency status when you apply to work with us.
3. Sensitive information
"Sensitive information" includes your race, ethnic origin, political opinions and associations, religious or philosophical beliefs, trade union memberships or details of health or disability. We may collect sensitive information such as health information and criminal record checks where you are applying to work with us as an employee or contractor, however we otherwise generally do not collect sensitive information.
If we do collect sensitive information from you, we will only do so with your consent and if the information is reasonably necessary for one of our functions or activities. We will assume you have consented to us collecting, using and disclosing (in accordance with this Privacy Policy) all information that you provide to us, including any sensitive information, unless you tell us otherwise at the time of collection.
4. How we may collect your personal information
We may collect personal information about you in the course of your dealings with us, including when you call or email us. We may also receive personal information when you contact us via enquiry forms on our related websites, or via social media, including via our Instagram and LinkedIn accounts.We may collect personal information about you in the course of your dealings with us, including when you call or email us. We may also receive personal information when you contact us via enquiry forms on our related websites, or via social media, including via our Instagram and LinkedIn accounts.
We may also collect/receive personal information about you from third parties, such as from:
- recruiters, human resource consulting companies, referees you have nominated, publicly accessible online profiles and our existing employees (e.g. if you are a potential employee);
- real estate agents, our appointed selling agent and conjunction selling agents (if applicable); or
- any of our other authorised agents, service providers and subcontractors.
Where you provide us with any personal information relating to a third party, we receive that information on the understanding that we have the relevant individual's consent for us to collect and handle their personal information in accordance with this Privacy Policy.
5. Why we collect your personal information and how we use it
We will generally only use your personal information for the purpose for which we collected it, or for related purposes we consider would be within your reasonable expectations.
We will generally only use your personal information for the purpose for which we collected it, or for related purposes we consider would be within your reasonable expectations. Generally, we may use your personal information for purposes that include, for example:
- if you are a real estate agent, liaising with you in connection with the marketing, sale and/or leasing of a property and providing you with information regarding additional properties;
- if you are an actual or potential investor, purchaser, lessee or service provider, for the purposes of (as relevant):
- verifing your identity;
- facilitating the provision of products and services;
- addressing or responding to requests;
- informing you of existing products and services; and
- sharing your information with our selling agents so they may assist us with the marketing and sales of our properties, and with our property managers and other agents so they may provide us with services in connection with our properties and developments; and - if you are a potential employee or wish to work with us as a contractor, for recruitment purposes or to assess a potential contracting relationship.
We may also use your personal information:
- for general purposes connected with our business operations and strategy – such as seeking feedback, better understanding customer needs and developing and improving the quality and scope of our products and services;
- to provide other products or services to you;
- to manage any complaints or to otherwise achieve the purpose for which you have contacted us;
- for direct marketing / sending marketing and promotional communications, for marketing research and other marketing purposes;
- for selling the information to a third party, however in this case we will seek your consent to disclosure of your personal information and will not otherwise disclose it without your consent; and
- for our general business operations – such as maintenance of our business records, compliance with our legal, regulatory and insurance obligations, and for statistical purposes.
By providing us with your personal information, you consent to us using your personal information for these purposes. Where we propose to use or disclose your information for a purpose other than as outlined above, we will seek your permission (unless we are required or permitted by law to do so without seeking consent).
If you fail to provide personal information requested by us, or if the personal information you supply is incorrect or incomplete, there may be a range of consequences, for example we may be unable to provide you with our services.
6. Disclosure of your personal information
We will generally only disclose your personal information to third parties for the purpose for which we collected it – that is for those purposes listed above. We may also use it for related purposes we consider would be within your reasonable expectations.
We will generally only disclose your personal information to third parties for the purpose for which we collected it – that is for those purposes listed above. We may also use it for related purposes we consider would be within your reasonable expectations.The third parties we may disclose your personal information to include, without limitation:
- sales agents, property managers, lawyers, professional advisors, and other agents, consultants, contractors and service providers who assist us, or may assist us, in connection with the operation of our business (including, for example, our property development, marketing, sales and leasing activities, and the management of our properties, developments and clients);
- certain contracted third party suppliers that provide services to us (including, for example, cloud data storage providers such as Microsoft, invoice processing providers such as Lightyear, and other service providers);
- actual or potential providers of debt or equity finance;
- advisory and investment committees;
- any joint venture or other business partner; and
- anyone authorised by you.When making any such disclosures we will take reasonable steps to ensure that the recipient is bound by privacy obligations.
If Podia proposes to sell its business or part of its business, we may need to disclose certain information to prospective buyers as part of any due diligence process to allow the prospective buyer to consider the sale. In this case we will take reasonable steps to de-identify or aggregate your personal information so that it is not disclosed to the potential buyer as part of the relevant process. If this is not possible, we will seek your consent to disclosure of your personal information, and will not otherwise disclose it as part of the relevant process without your consent.
We may also share your information in response to subpoenas, court orders, or other legal process or as otherwise required or permitted by law (including to law enforcement and national security agencies, and other government and regulatory authorities).
7. Disclosure of information overseas
In some cases, the organisations to whom we may disclose your personal information may be based outside Australia. For example, we may disclose your personal information to contracted third party suppliers that provide services to us – for example, cloud data storage providers such as Microsoft or invoice processing service providers such as Lightyear, whose servers may be located in various countries around the world.
8. Storage and security of your personal information
We may hold your personal information in hard copy and electronic formats. This may include storage at our premises and on servers belonging to third party cloud data storage providers.
We take reasonable steps to securely store your personal information to ensure it is protected from unauthorised use, access, modification and disclosure, and from other types of misuse, interference and loss. We will take reasonable steps to destroy or permanently de-identify your personal information when we no longer require it for any purpose for which it was collected. We may retain your personal information for as long as necessary to comply with any applicable law, for insurance and corporate governance purposes, for the prevention of fraud, to resolve disputes and for any bona fide internal compliance or audit policies or procedures. Your personal information may also be retained in our information technology system back-up records.
If you provide any personal information to us via our online forms or via email, the privacy, security and integrity of this information cannot be guaranteed during its transmission unless we have indicated beforehand that a particular transaction or transmission of information will be protected (for example, by encryption).
9. Access and correction of your personal information
Please notify us if your personal details change so that we may keep our records current.
You may lodge a request to access your personal information or to correct personal information that we hold about you if you believe it is inaccurate, incomplete, out-of-date, irrelevant or misleading, in which case please contact us using the contact details below.
Generally, we will provide you with that access, except in limited circumstances where the law permits us to deny access. In those circumstances, we will provide you with written responses for refusal (unless it is unreasonable to do so).
Any such requests must be made in writing to us. We will respond to the request for access within a reasonable period and we will give access to the relevant information in the manner requested if it is reasonable and practicable to do so. We may require you to comply with certain procedures before we allow access to or amendment of your personal information in order to ensure the integrity and security of information that we hold (e.g. providing information needed to verify your identity).
10. Data breach
If a data breach or suspected data breach occurs, we will undertake a prompt investigation, which will include an assessment of whether the incident is likely to result in serious harm to any individuals.
In such a situation we will comply with the requirements of the Privacy Laws which may require notification to the privacy regulator and affected individuals. Please contact us if you have reason to believe or suspect that a data breach may have occurred, so that we can investigate and, if necessary, undertake appropriate containment, risk mitigation and notification activities as required.
11. Complaints
If you have a complaint about the way in which we handle your personal information, or you believe that a breach of your privacy has occurred, please contact us using the details below.
Your complaint will be considered and dealt with by our nominated representative, who may escalate the complaint internally within our organisation if the matter is serious or if necessary to resolve it.
Please allow us a reasonable time to respond to your complaint. If you are not satisfied with our resolution, you may make a complaint to the OAIC whose contact details can be found at: http://www.oaic.gov.au/.
12. Changes to our Privacy Policy
We may, from time to time, amend, modify or replace this Privacy Policy. You may obtain a copy of the current version of this Privacy Policy by contacting us. You should review our Privacy Policy each time you provide us with personal information.
13. Contact us
If you would like further information about the way we manage your personal information or if you have a complaint, please contact our Privacy Officer at privacy@podia.com.au.