Simonds Group Limited (ACN 143 841 801) (we, us, our, or Simonds) is bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth) (Privacy Act) and related privacy codes.
Personal Information means any information about you where you are identified or reasonably identifiable.
COLLECTION OF PERSONAL INFORMATION
The types of Personal Information that Simonds collects will depend upon what dealings you may have with us. We may collect and hold personal information about you in the following ways, including when:
- you purchase, or express an interest to purchase, a Simonds home. For example, when entering into a sale and purchase agreement, or when seeking information about a Simonds home;
- you lease, or express an interest to lease, a display home. For example, when negotiating, entering into or applying to enter into a lease with Simonds;
- we supply goods and services to you. For example, when establishing records and systems to enable payment for goods and services;
- you enter a Simonds office or gallery or building site. For example, when maintaining visitor registrations for a Simonds display gallery, or capturing video or images through surveillance systems in a Simonds office or gallery;
- you register or subscribe to join our marketing programs, promotions, newsletters or competitions;
- you use our websites, social media and other online services;
- you logon to wireless facilities provided in our offices or galleries;
- you otherwise come into contact with us such as to resolve a complaint; or
- you are provided with credit services, loans or other financial accommodation by our preferred mortgage broker.
We only collect Personal Information which is reasonably necessary for our dealings with you. The types of Personal Information collected may include, but are not limited to:
- your name, gender, address and contact details;
- your date of birth;
- your photo or video images of you;
- information about your financial position;
- information about you that is required or authorised by law;
- your tax file number; and
- your opinion about our products, services or staff.
Whenever it is reasonable and practical to do so, we collect Personal Information directly from you. In some circumstances, Personal Information may be provided to Simonds by other parties such as a member of your family, your agent or our authorised agents and subcontractors.
You may provide us with other people’s Personal Information (eg information about related guarantors). In those cases, you should only provide that information to us if you have the consent of the individual to provide the information and for us to manage the information in accordance with this Policy. You should also provide a link to, or copy of, this Policy to that individual.
If you do not provide personal information that we request in connection with our business functions and activities, we may not be able to provide some or all of our products or services to you or be able to respond and assist in the manner required. We also may not be able to provide you with information about products
and services that you may want. If you are applying for employment or a contractor’s engagement with us, we may be unable to fully consider your application.
PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
In general, we may collect, hold and use your Personal Information for the following purposes:
- providing goods or services to you at your request;
- communicating with the you, including following up on any enquiries you make through our various channels;
- managing, improving and enhancing our goods and services, including analysing customer feedback and future customer needs;
- helping us to assess your financial position;
- providing ongoing information and marketing about goods and services we believe you may be interested in receiving, or where you have signed up to receive such information;
- managing security and safety requirements in our offices, galleries and building sites;
- any general administration and business purposes;
- complying with our regulatory and legal obligations;
- recruiting potential employees and contractors; or
- fulfilling our obligations to our employees.
DISCLOSING PERSONAL INFORMATION TO OTHER PARTIES
We may disclose your Personal Information to our related entities within the Simonds Group.
We may also disclose your Personal information to third parties in certain circumstances. These include, but are not limited to:
- our agents, contractors and service providers who assist in the operation of our business or who provide a customer service. For example, a third party which helps maintain our computer systems, sends out our mail on our behalf or delivers or products and services;
- third party lenders, mortgage brokers, financial service providers and insurers;
- the Australian Securities Exchange (ASX), the Australian Securities and Investments Commission (ASIC);
- other government agencies as agreed or required by law;
- any other party that you authorise us to disclose your Personal Information to; or
- relevant parties in situations when Simonds is required by law to provide the information.
We limit the Personal Information we disclose to external parties to only what is required for such third parties to perform their services for us or you, or what is required by law. We require these third parties to agree to strict conditions governing how your Personal Information may be used and stored.
From time to time, we may disclose Personal Information to external parties located outside Australia to allow the external parties to perform their services for us or our related companies. This is currently restricted to organisations located in United States, China, Philippines and Vietnam We will only disclose Personal Information overseas when it is necessary for the services provided by these external parties.
We do not sell Personal Information to third parties outside the Simonds Group.
JOB APPLICANTS AND CONTRACTORS
We will collect your Personal Information if you submit a job application or register an interest for employment with us or any of our related companies, or if you wish to become a contractor for us. In such cases, we may collect the following information from you and contractors:
- your name, contact details, email address;
- your CV and other related documentation or certification;
- your skills, experience and educational and trade qualifications;
- any references; and
- any other information you provide to us during the course of the recruitment or engagement process.
We may collect Personal Information from third parties such as recruitment agencies, your referees, former employers and educational institutions.
If you are applying for a job or a contractor role with us, we may collect and manage your Personal Information for the following purposes:
- assessing your application, including conducting background checks and interviews;
- to facilitate any communication between you and us; and
- our internal record keeping purposes.
You may provide other people’s Personal Information as part of your application such as information about your referees. You agree that you have obtained the necessary consents for us to collect that Personal Information, and to contact such individuals for any of the above purposes in connection with your application.
If your application is unsuccessful, we may retain any Personal Information you provide for a limited period in case another opportunity becomes available.
SHAREHOLDER’S OR POTENTIAL SHAREHOLDER’S PERSONAL INFORMATION
If you are a shareholder or potential shareholder of Simonds, we will collect your Personal Information when you go through the investment process. For example, if you request a prospectus to subscribe for any shares issued by Simonds.
We may collect the following Personal Information from you if you are a shareholder or potential shareholder of Simonds:
- your name, date of birth, address, contact details or photo;
- your bank account details;
- details of the shares you hold and your shareholder reference number; and
- any other information you provide to us.
If you are a shareholder or potential shareholder of Simonds, we may collect and manage your Personal Information for the following purposes:
- managing your shareholding in Simonds and keeping your records on the shareholder register up-to-date;
- facilitating any shareholder-related communications or provide you with any shareholder materials such as annual reports or notices of annual general meetings;
- paying dividends;
- responding to any queries you may have;
- complying with our legal obligations such as record keeping requirements; or
- fulfilling any contractual obligations or protecting our legitimate interests.
We may send you direct marketing communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws. 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 and we will then ensure that your name is removed from the mailing list.
SECURITY OF PERSONAL INFORMATION
We take steps to protect the Personal Information that we hold from unauthorised access, modification or disclosure, misuse, interference and loss. We have implemented technical and organisation security measures such as physical security measures over our physical premises, and a range of computer and network security measures (such as systems access, firewalls, data encryption) over our electronic systems. Our employees are required to maintain the confidentiality of any Personal Information held by us.
Third party service providers are required to keep secure any Personal Information to which they have access.
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.
ACCESS AND CORRECTION OF PERSONAL INFORMATION
You may request access to, or correction of, any Personal Information that we hold about you. To access or correct your Personal Information, you should write to our Privacy Officer using the contact details below. We must be satisfied that any request is made by you and will require evidence to verify your identity.
This service is free of charge unless the Personal Information requested requires preparation time. In this situation, we may seek to recover reasonable costs incurred for providing any of the Personal Information that we hold about you. We will provide an estimate of how much this service will cost and will request agreement from you to these costs before proceeding.
In normal circumstances, we will provide you with access to your Personal Information and will correct it. However, in some circumstances, there may be legal, regulatory or administrative reasons to deny the requested access or correction. If access or correction is denied, we will provide you with the reasons for doing so. If we deny your request to correct your Personal Information, you have the right to request that a notation be included with your Personal Information to indicate your disagreement with the Personal Information we hold about you.
In each case we will inform you of our decision within a reasonable period.
KEEPING PERSONAL INFORMATION UP-TO-DATE
It is important that you notify us of any changes to your Personal Information (such as a change of address) so that the record we hold about you can be kept up-to-date. Please contact us if any of your details change.
You may request further information about the way we manage your personal information, or lodge a complaint if you believe that we have breached your privacy, by contacting our Privacy Officer using the contact details below.
We will deal with any complaint by investigating it, and providing a response to you within a reasonable time, provided that we have all necessary information and have completed any investigation required. In some cases, we may need to ask you to put your complaint in writing so that we are sure that we understand it, and may also need to ask you for further information or to verify your identity. 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 treat your complaint confidentially and respond to you within a reasonable time, usually in writing.
If you are dissatisfied with the outcome, please contact us. Alternatively, you may take your complaint to the Privacy Commissioner at the Office of the Australian Information Commissioner (OAIC). The contact details for the OAIC are available from the OAIC’s website at www.oaic.gov.au.
COOKIES AND WI-FI SERVICES
We may also collect cookies from time to time. A cookie is a small data file that may be placed on the computer of a web user (usually in the browser software folder) during a visit to our websites. Cookies are necessary to allow our websites and the user’s computer to interact effectively and enhance security. Cookies can record information about the user’s visit to assist us in better understanding the needs of the user. For example, user traffic data may be collected and used to infer the website user’s demographic using various web analytic technologies.
We sometimes also use performance tracking technology (such as conversion tags) to help track user behaviour on our websites. Such user traffic and performance tracking data is non-personally identifying and is collected on an aggregate level to report statistics to assist us in improving the quality and relevancy of our services.
When you register to use Wi-Fi services provided by us, we will collect your Personal Information in relation to your use of our Wi-Fi services, and for any other purposes we notify you of at the time of collection.
Our websites may contain links to other websites operated by third parties. We make no representation 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 information you about their own privacy practices.
Our Privacy Officer can be contacted as follows:
The Privacy Officer Simonds Group Limited Locked Bag 4002 South Melbourne Victoria 3205
Email: firstname.lastname@example.org Tel: 1300 SIMONDS / 1300 746 663
Last updated October 2019