When does this policy apply?

This policy sets out the principles that Mulpha Australia Limited and its subsidiaries (Mulpha/we/us/our) adopt in the conduct of our business in order to protect your personal information. A number of our subsidiaries engage in activities under other brands. You can contact the Mulpha Group Privacy Officer to verify the details of the corporate group entity that this policy applies to. You can obtain a copy of this policy from our website at mulpha.com.my or by contacting our Privacy Officer whose details are set out below.

 

Protecting Your Privacy
Mulpha are committed to providing you with exceptional service, and this includes protecting your privacy and being open and transparent about what we do with your personal information. We aim to maintain a safe and secure system of handling your personal information, whilst still providing access to your personal information when required. For this reason, we aim to ensure that your personal information is handled in strict compliance with the Australian Privacy Principles (APPs) which are part of the Commonwealth Privacy Act 1988.

 

This Policy

This policy explains what kind of information we collect and hold; how and why we collect, hold and use it; and how and to whom we disclose that information. It also provides details about how you may access and seek correction of the personal information that we hold about you, and what you can do if you are not satisfied with how we have dealt with your personal information.

 

What is Personal Information and how do we collect it?

Personal information is information or an opinion (whether true or not and whether recorded in a material form or not) about an individual from which they can be reasonably identified. Depending on the circumstances, we may collect personal information from an individual in their capacity as a client, customer, contractor, stakeholder, job applicant or in some other capacity.

 

In the course of our business and providing products and services we collect and hold:

As part of our recruitment processes for employees and contractors, we may collect and hold:

Generally, we will seek consent from you in writing before we collect your sensitive information.

 

We only collect personal information about you that is necessary for us to carry on our business functions. The information we collect about you depends upon the nature of our dealings with you. Generally we only collect personal information from you, unless it is not reasonable or practical to do so in which case we may also collect personal information about you from third parties.

 

Information we collect from you
We collect personal information from you during your interactions with us, for example if you:

We may collect information based on how you use our website. We use ‘’cookies’’ and other data collection methods to collect information on website activity such as the number of visitors, the number of pages viewed and the internet advertisements which bring visitors to our website. This information is collected to analyse and improve our website, marketing campaigns and to record statistics on web traffic.

 

If you access your account with us online through a secure area of our website, we will collect your personal information using cookies. This is designed to track the use of our website and to allow our customers to effectively access their account information. This information is collected for security purposes and to protect the integrity of account details.

 

 

 

Information we collect from others

We collect personal information about you from third parties such as:

 

Sensitive information

We only collect sensitive information if it is:

 

Customer rights
Wherever it is lawful and practicable, we will give you the option of not providing information when dealing with us.  However, in most cases, if you do not provide the full and complete information requested we will be unable to provide our products or services to you.

 

Using your information
We only use your personal information for:

 

We use your personal information so we can, amongst others:

We may also collect, use and exchange your information in other ways where required by law or permitted by Privacy Act 1988.

Direct marketing
If you don’t want to receive direct marketing, you can tell us by emailing us and telling us which list you would like to be removed from at marketing@mulpha.com.au or write to us at Level 5, 99 Macquarie Street Sydney, NSW 2000 Australia. If we undertake direct marketing we acknowledge that we are bound by the Spam Act 2003 and the Do Not Call Register Act 2006.

Using government identifiers

If we collect government identifiers, such as your tax file number, we do not use or disclose this information other than required by law. We will never use a government identifier in order to identify you.

Disclosing your information
The reasons for disclosing your personal information and the parties to whom we might disclose it will be reasonably apparent to you when we collect your information. Our disclosure of your personal information will only be in connection with our business activities or where you have given consent. Where personal information is disclosed to any third party we will take reasonable steps to ensure that the person receiving your personal information keeps it confidential and does not misuse it or improperly disclose it to any other person.

Personal information may be shared between different entities within the Mulpha Group but where this occurs the principles contained in this policy will continue to apply to it.

We may disclosure your personal information to following parties:

 

We will not sell your personal information to other organisations.

 

Disclosure of your personal information to overseas recipients
We may disclose your personal information to an overseas organisation in the course of providing our goods or services to you, for example if any of the above named parties are located overseas, or directly to our own offices or agents in an overseas location, or when storing information with a “cloud service provider” which stores data outside of Australia. Where we do this, we make sure as far as reasonably possible that:

Please note that some of these overseas recipients may not operate in countries which have a similar privacy regime to Australia.

 

Storage and Security of Personal Information
We store personal information in a variety of formats including, but not limited to:

 

We take all reasonable steps to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. These steps include, but are not limited to:

 

Our public website may contain links to other third-party websites outside of the Mulpha Group. We are not responsible for the information stored, accessed, used or disclosed on such websites and we cannot comment on their privacy policies.

 

Responding to data breaches

We will take appropriate, prompt action if we have reasonable grounds to believe that a data breach may have, or is suspected to have occurred. Depending on the type of data breach, this may include a review of our internal security procedures, taking remedial internal action, notifying affected individuals and the Office of the Australian Information Commissioner (OAIC).

If we are unable to notify individuals, we will publish a statement on our website and take reasonable steps to publicise the contents of this statement.

 

The Quality of Personal Information

We take all reasonable steps to ensure the Personal Information we hold, use and disclose is accurate, complete and up-to-date, including at the time of using or disclosing the information.

If we become aware that the Personal Information is incorrect or out of date, we will take reasonable steps to rectify the incorrect or out of date information.

 

How do you access your information?
You may ask us what personal information we hold about you, and you may make a request to access to this information at any time. You may make a request by us by contacting our PRIVACY OFFICER (see below contact details). We may ask you to complete a PERSONAL INFORMATION REQUEST FORM and will process your request within a reasonable time and try to make this information available within 30 days of your request. Before we give you the requested information we will need to confirm your identity.

We generally will not charge you a fee in respect of such access but reasonable administrative costs may be charged in some circumstances. If there is an access charge, we will give you an estimate first and ask you to confirm that you would like us to proceed, if you would like us to we do require payment up front. Generally, the access charge is based on an hourly rate plus any other reasonable costs incurred by us such photocopying and postage. We do not need to provide access to your information in several circumstances; for example, the information is commercially sensitive, the request is frivolous or would unreasonably interfere with another person’s privacy or be in breach of the law, or, where to provide access would pose a threat to health or public safety. If we refuse you access we will advise you of our reasons for doing so.

 

How do you Correct or update your information?
You may ask us at any time to correct the information we hold about you or that we have provided to others us by contacting our PRIVACY OFFICER (see below contact details). We will process your request within a reasonable time and try to correct the information within 30 days. If it looks like it will take longer, we will let you know the reason for the delay and try to agree to an extended timeframe with you.

If we are able to correct your information because it is indeed inaccurate we will inform you when it is so corrected.

If we disagree with you that the information is inaccurate and should be corrected, we will inform you in writing of our reasons. You may request that we attach a statement to that relevant information noting that you consider it is inaccurate misleading, incomplete, irrelevant or out-of-date. We will take reasonable steps to comply with such a request.

 

What can you do if you have a complaint?
If you are not happy in respect of how we have dealt with your personal information or in gaining access to it, please contact our PRIVACY OFFICER to discuss your concerns (see below contact details). We will respond to the complaint within a reasonable time (usually no longer than 30 days) and we may seek further information in order to provide a full and complete response. If we do not resolve your complaint to your satisfaction or we are unable to resolve your complaint you have the right to refer the matter the Office of the Federal Privacy Commissioner – Privacy Hotline on 1300 363 992 or visit their website at www.oaic.gov.au  or writing to GPO Box 5218 Sydney NSW 2001. A referral to OAIC should be a last resort once all other avenues of resolution have been exhausted.

 

How to contact us:

PRIVACY OFFICER
Address: Mulpha Group Level 5, 99 Macquarie Street Sydney, NSW 2000 Australia
Phone: +61 2 9270 6186 Email: company.secretary@mulpha.com.au

 

Changes to our privacy and information handling practices

This Privacy Policy is subject to change at any time. Please check our Privacy Policy on our website mulpha.com.my regularly for any changes.

 

This Privacy Policy was approved by the Board on 28 February 2018.

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AUSTRALIA PRIVACY STATEMENT

Last updated: May 2016

INTRODUCTION

St Trinity Property Group and its affiliated entities, representatives, agents and related companies (collectively referred to as ST TRINITY PROPERTY GROUP) respect the privacy and security of your Personal Information, as defined below, and comply with the requirements of the Australian Privacy Principles under the Privacy Act 1988 (Cth).

This Privacy Policy explains in general terms how St Trinity Property Group handles your Personal Information. However, it does not apply to St Trinity Property Group’s employee records to the extent they are handled by any of our companies that is or was the employer of that employee in relation to the employee’s current or former employment. Such employee records are generally exempt from the Act and will be dealt with as permitted by law.

You may be able to deal with us without identifying yourself (i.e. anonymously or by using a pseudonym) in certain circumstances. If you wish to do so, please contact us to find out if this is practicable in your circumstances. However, if you do not provide us with the Personal Information we have requested, we may not be able to complete or fulfil the purpose for which we collect the information, including providing our services. By visiting our websites, using any of our services or otherwise providing us with your Personal Information (or authorising it to be provided to us by someone else), you agree to your Personal Information being collected and handled as set out in this Privacy Policy.

WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?

Under the Act Personal Information is defined as information or an opinion about an identified individual, or an individual that is reasonably identifiable, in whatever form and regardless of whether it is true or not (Personal Information). The Act also defines a subset of Personal Information as sensitive information (for example health records, racial or ethnic origin, religious beliefs, criminal records).

The types of Personal Information we collect and hold will depend on the circumstances of collection and on the type of service we are providing. For example, when we are engaged to sell a property, we may collect and hold Personal Information from both the seller and potential buyers such as name, address, email address, telephone numbers, employment details and details about their business.

We may also collect and hold certain sensitive information that is reasonably necessary for the provision of our services, including health and criminal records. If you provide us with any sensitive information, you consent to us collecting that information and handling it in accordance with this Privacy Policy.

HOW WE COLLECT PERSONAL INFORMATION

We may collect Personal Information about you directly when you deal with us over the telephone, send us correspondence (whether by letter, fax or email), have contact with us in person, visit our websites or complete hard copy or online forms.

There are also circumstances where we may collect Personal Information about you from someone else. For example, from:
• Market research companies contracted by us to obtain information so that we may improve and market our services;
• Your employer;
• Other agents and valuers who may be involved in the services we provide;
• Property developers who contract us to market properties;
• Publicly available information and databases;
• Any of the companies within the St Trinity Property Group (both local and overseas);
• and Anyone you have authorised to deal with us on your behalf.

We also automatically collect certain information when you visit our websites or our subscribers receive promotional emails from us via cookies and other tracking technology (such as web beacons), some of which may be capable of personally identifying you. Such information includes the type of browser and operating system you are using, your IP address and how you use our websites. Depending on the type of service you or our customers have requested, we may also seek to collect information about someone else from you (for example, contact details of your solicitor, emergency contact person or tenant). However, you must not provide us with Personal Information about another person unless you have clear consent from that person to do so, told them that their Personal Information will be handled in accordance with this Privacy Policy and directed them to where they can find it. Regardless of how it is collected, we handle Personal Information in accordance with this Privacy Policy.

WHY WE COLLECT, HOLD AND USE PERSONAL INFORMATION

We generally collect, hold and use your Personal Information for the purposes for which it is provided to us (which will usually be obvious at the time of collection), related purposes or as permitted or required by law. Such purposes may include:
• Acting as agent for vendors or purchasers in relation to the sale of a property;
• Acting as agent for owners or tenants in relation to the leasing and or valuation of a property;
• Project management services;
• Structured advisory services;
• Town planning services;
• Capital allowances services and other consulting services in relation to the property market;
• Administration of our business, such as collection of overdue commissions or outstanding fees;
• Responding to client enquiries and communicating with you from time to time to maintain contact and keep you updated on the services you have requested;
• Forecasting future needs of our services and general quality assurance and training purposes;
• Engaging in legal proceedings and/or enforcing judgments and/or orders;
• Complying with the applicable legal or regulatory requirements and/or orders of competent authorities;
• Providing you with promotional and marketing information, including market research reports, newsletters, event invitations and/or property market information relating to our products and services which we think may be of interest to you; and Any other purpose identified at the time of collecting your Personal Information.

We generally use information automatically collected by cookies and other tracking technology to identify you as a valid user, ensure that no one else can sign on simultaneously with your account from another computer and help us serve you better based on your registration preferences. We may also use cookies to help us facilitate any promotions or surveys that we provide. Third parties whose products or services are accessible on our websites may also use cookies, and we advise you to check their privacy policies for information about their cookies and other privacy practices.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose your Personal Information to third parties as may be necessary for any of the purposes stated in the above section. Such third parties generally include:
Our third party providers, contractors, consultants, agents and/or representatives (such as law firms, banks, financial institutions, insurers, IT providers, mortgage referral services providers and/or wealth management services providers) who provide services to us or on our behalf, including to:
• Conduct valuations;
• Assist with obtaining payment from creditors;
• Operate data centres;
• Conduct market research;
• Provide advice;
• Potential buyers, tenants, conjunctional real estate agents and brokers for the purpose for which the information was collected or for related purposes (for example to complete a transaction on your behalf or provide you with a service that you requested); Anyone you have authorised to deal with us on your behalf;
• Any of the companies within the St Trinity Property Group and their related companies; Government authorities, regulatory bodies, law enforcement agencies, courts, tribunals and/or parties to the legal proceedings where you have consented to this or we are required or authorised to do so by law;
• Debt collection agencies; and/or Any other third parties identified at the time of collection of your Personal Information.

DISCLOSURE OF PERSONAL INFORMATION OVERSEAS

Some of the third parties listed above to whom we may disclose your Personal Information are located overseas. For example: Our information technology and business process service providers that are located in countries including (but not limited to) the Indonesia, India and Philippines; and Our overseas clients that are located in the same countries as the companies within the St Trinity Property Group. Our contracts with these parties generally include an obligation for them to comply with Australian privacy law and this Privacy Policy. However you acknowledge that, by agreeing to the disclosure of your Personal Information to these entities outside of Australia, we will no longer be required to take reasonable steps to ensure the overseas recipient’s compliance with the Australian privacy law in relation to your Personal Information and we will not be liable to you for any breach of the Australian privacy law by these overseas recipients. On this basis, you consent to such disclosure.

ACCESS, UPDATE AND CORRECTION OF PERSONAL INFORMATION

We take reasonable steps to ensure that the Personal Information we hold about you is accurate, complete and up-to-date. However, we also rely on you to advise us of any changes to your Personal Information. If you are able to access your Personal Information by logging on to an account you have with us, it is your responsibility to ensure your information is accurate, complete, relevant and up-to-date. On request we will provide you with access to the Personal Information we hold about you, including for the purpose of correcting or updating that information, unless otherwise required or permitted by law. There is no charge for making the request or giving the access to your Personal Information. We will deal with your request within a reasonable period after the request is made. If we refuse to provide you with access we will provide you with a written notice that, at a minimum, outlines reasons for the refusal and the complaints mechanisms available to you. If you wish to access the Personal Information we hold about you or to update or correct it, you can either do so by logging on to your account (if you have one) or contact us using the contact details provided below. We will require you to verify your identity and specify what information you require.

SECURITY OF PERSONAL INFORMATION

We take reasonable steps to protect any Personal Information that we hold from misuse, interference and loss and from unauthorised access, alteration and disclosure. For example, we implement IT security procedures including password protection, firewalls and site monitoring and we store your Personal Information on a secure server.we store your Personal Information on a secure server. However, data protection measures are never completely secure and, despite the measures we have put in place, we cannot guarantee the security of your Personal Information. You must take care to protect your Personal Information (for example, by protecting any usernames and passwords). You should notify us as soon as possible if you become aware of any security breaches.

DIRECT MARKETING

When you register as a member on our websites, you will be given a choice as to whether you want to receive e-mail messages from us, including newsletters, announcements and e-mail communications about our latest news, products or services. To the extent the relevant local law requires us to seek your consent, we will only send such messages to you if you opt-in. If you do not wish to receive direct marketing calls or materials, you may use the unsubscribe facility in the marketing communication or contact our Chief Privacy Officer using the channels prescribed below. Further, as a registered member with us, you can modify your choice at any time by accessing your registered account with us. We will stop using your Personal Information for direct marketing if you so request.

PRIVACY ON OUR WEBSITES

Our websites may contain links to the websites of other entities. If you click on such links, you will be transferred to the websites of these entities. We have no control over, and are not responsible for, the privacy practices of these entities. You should read the privacy policy of these entities to find out how they handle your Personal Information when you visit their websites.

WHAT IF YOU HAVE A COMPLAINT?

If you wish to make a complaint about a breach of this Privacy Policy or the Australian Privacy Principles of the Act you can contact us using the contact details below. You will need to provide us with sufficient details regarding your complaint together with any supporting evidence. Our Chief Privacy Officer will investigate the issue and determine the steps that we will undertake to resolve your complaint. We will contact you if we require any additional information from you and will notify you in writing of the outcome of the investigation. If you are not satisfied with our determination, you can contact us to discuss your concerns or contact the Australian Privacy Commissioner via www.oaic.gov.au.

PRIVACY & SITE CHANGES

St Trinity Property Group may update this Privacy Policy from time to time so please review it periodically for changes. If the changes are significant or substantive, they will either be advised to you in writing or posted on our websites at www.sttrinity.com.au. Your continued use of our websites or services, requesting our assistance or the provision of further Personal Information to us (directly or via an authorised person) after this Privacy Policy has been revised, indicates your acceptance of the revised Privacy Policy.

OUR CONTACT DETAILS

If you have a query relating to this Privacy Policy or wish to make a complaint, please contact us using the following contact details:
• St Trinity Property Group
• Chief Privacy Officer
• PO Box 1235
• Menai NSW 2234
• privacy@sttrinity.com.au

MORE INFORMATION

For more information about the Privacy Act in Australia and protecting your privacy, visit the (external link) website below:
www.privacy.gov.au