PRIVACY POLICY
Apelbaum & Co (Estate Agents) Pty Ltd (ABN 74 576 086 133) trading as Healthcare Property Group (“HPG“, “we“, “our” or “us“) is in the business of providing commercial property consultancy services, particularly in the healthcare property sector. HPG operates its principal website at www.healthcarepropertygroup.com.au (“Website“).
We recognise the importance of maintaining the privacy of the personal information of the individuals we deal with in conducting our business.
This Privacy Policy applies to the collection, use and disclosure of personal information by HPG, and is made in accordance with the Australian Privacy Principles pursuant to the Privacy Act 1988 (Cth) (“Privacy Act“).
In the event of inconsistency between this Privacy Policy and the Privacy Act, the Privacy Act will prevail.
What is personal information?
The term “personal information” has the meaning it has in the Privacy Act 1988 (Cth) and under that legislation includes information about an identifiable individual, including names, addresses, telephone and fax numbers, email addresses, dates of birth, driver’s licence details, credit information and history, banking details, income details, other financial details, passport numbers, employment details and history, rental history, information about properties you currently own or desire, and if and where applicable, includes information that constitutes “sensitive information”. Personal information also includes opinions about individuals.
How is personal information collected by HPG?
HPG generally collects personal information from you directly, for example when you:
- Contact us to enquire about our services, whether by phone or email, via an on-line enquiry, or in person;
- Engage us to provide you with our services (including when you are a landlord or vendor);
- Interact or negotiate with us in respect of selling, purchasing or leasing or renting a property;
- When you enter into a contract for a property sale or purchase, or tenancy agreement;
- Ask to be included on our marketing distribution list; or
- Provide your details to us at an auction or a property inspection.
We sometimes also collect personal information from other sources such as:
- Credit reporting agencies; and
- Publicly available sources of information, such as the Titles Office.
We will take reasonable steps to notify you about our collection of your personal information, and will provide all relevant information prescribed under the Privacy Act.
We will only collect personal information by lawful and fair means.
What kinds of personal information are collected by HPG?
The personal information we may collect includes:
- Your name and date of birth;
- General contact information such as address, telephone, fax and email;
- Information about the property you are interested in selling, purchasing or leasing;
- Any queries you have, and our response to those queries; and
Where relevant, financial information including bank account and credit card details, profit and loss statements, balance sheets, your employer and occupation details and title and mortgage details of any relevant property.
Cookies
We may use ‘cookies’ to collect data (typically not personal information) relating to your general internet usage. This data may include IP-addresses, browser versions, number of visits and similar such data relating to your navigation of the internet and our Website. A cookie is a small text file that is placed on your computer’s hard drive. Cookies help us to improve our Website and to deliver a better and more tailored service, for instance by storing information about your preferences and allowing us to recognise you when you return to our Website.
You may refuse to accept cookies by activating settings on your internet browser. However, please note that if your select such settings you may be unable to access certain parts of our Website.
We hold personal information in our own secure databases and in secure hard copy files on our premises.
If you do not provide us with the personal information we request or require, we may not be able to provide our services to you or may not be able to do so to the same standards.
Anonymity/pseudonymity
Where practicable, customers and others have the right to interact with us anonymously or using a pseudonym. Circumstances where it is not practicable, however, include where personal information is required to complete a credit card or account transaction.
How is personal information used by HPG?
We will use the personal information we collect from you to provide you with the services that you have requested or otherwise to enable us to carry out our business as a commercial property consultancy service provider. This includes:
- To facilitate the purposes set out above, such as to complete transactions involving real estate;
- Supplying our products and services to you;
- Responding to your queries;
- Assessing tenancy applications and suitability of prospective tenants;
- Performing authorised financial transactions with you;
- Communicating with you and providing you with information (whether by email, post or other means) about our products or services, where you have requested or consented to receiving this from us or where this provision is otherwise permitted under the Australian Privacy Principles and other applicable legislation;
- Enforcing the terms and conditions of our engagement with you;
- Notifying you of changes to our goods and services or contractual arrangements;
- Ensuring compliance with our statutory obligations, and protecting our legal interests (if and to the extent necessary);
- Conducting credit checks; and
- Providing quality assurance for our services and monitoring the performance of our business.
When we collect personal information about you, we will not use that information for any purpose other than the primary purpose for which it is collected, except as otherwise set out in this Privacy Policy or as permitted or required by the Privacy Act.
All our customers and others with whom we interact have the option to opt-out of receiving marketing communications from us. If you do not wish to continue to receive electronic marketing communications from us and/or selected third parties you should opt-out by clicking on the “unsubscribe” link in any email communications that we might send you.
How is personal information disclosed by HPG?
We may disclose your personal information in the following ways:
- To our related companies, such as Health & Education Pty Ltd (ACN 622 731 702) t/a Healthcare Property Consultants, for the purposes of performing our obligations and exercising our rights under this policy;
- in a limited way, to potential buyers or to existing or potential clients, to property inspection consultants, property valuers, business valuers, to owners corporations, to government and statutory bodies, financial institutions or financial products and services providers;
- To the vendor of a property where you are a purchaser or a prospective purchaser;
- To other real estate agents or other third parties if required by a landlord or a landlord’s financier or legal representative, for the purpose of appraising or valuing a property;
- To actual or prospective tenants, to tradespeople and to other persons to whom we outsource functions of or incidental to acting for a landlord;
- To the landlord, referees, the relevant Bond Authority, other agents and third party operators of tenancy reference databases including where a tenant has failed to comply with any contractual obligations specified in the relevant tenancy agreement and to other sources necessary to identify and evaluate a potential tenant, to the extent permitted at law;
- To third party consultants who may from time to time manage our database or computer system for the purposes only of them providing those services;
- if we were to sell all or part of our business operations or the shares in our company, to that purchaser;
- If permitted or required to disclose your personal information in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions, to protect our rights, property, or safety, or that of our clients and customers; and
- Other disclosures incidental to our carrying out our business as commercial property consultancy service provider.
We limit the information we provide to third parties to the information they need to help us provide or facilitate the provision of goods and services to us or you. We deal with third parties that are required to meet the privacy standards required by law in handling your personal information and use your personal information only for the purposes that we gave it to them.
We do not disclose personal information to a business located outside Australia.
HPG will not otherwise use or disclose any information about you without your consent, except as otherwise required or permitted under the Privacy Act.
Does HPG use personal information for direct marketing communications?
We may contact you using the contact details which you provide to us in order to provide you with direct marketing communications about our services and business to the extent set out in this policy.
We will comply with our obligations under Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth) in relation to such direct marketing communications.
You may opt out of receiving direct marketing communications from us at any time.
How does HPG store personal information?
We will take all reasonable steps to protect personal information from misuse, interference, and loss, and from unauthorised access, modification or disclosure.
We store personal information we collect on secure servers and/or in hardcopy records stored in secure access facilities. We require our employees and contractors to protect the confidentiality of the personal information we hold.
Where we no longer require your personal information we will take reasonable steps to delete or destroy it.
How can I access, change or delete HPG’s records of my personal information?
You may request access to our records of your personal information by contacting us using the details set out below. We will generally make your information available to you within 14 days of receiving your request. However, we may require you to pay a reasonable charge for access. We also reserve the right to refuse you access to your information in certain circumstances permitted by the Privacy Act.
We may not be able to provide you with access to information in some situations including where doing so may create a serious threat to life or the health of any individual, where it may constitute an unreasonable intrusion into the privacy of another, where your request is in our opinion frivolous or vexatious or where otherwise permitted at law.
HPG will use its best endeavours to ensure that the personal information it holds is accurate, complete and up-to-date.
If you wish to update your personal information, please contact HPG using the details set out below to request an amendment to your record. Where it is established that personal information we hold about you is not accurate or up-to-date, we will take all steps necessary to amend it.
Changes to the HPG Policy
We reserve the right to change this Privacy Policy at any time. We will publish an updated version of the policy on our Website when it comes into effect. We encourage you to review this policy from time to time.
How can I make a query or complaint about privacy?
If you have any enquiries about this Privacy Policy or wish to make a complaint about a matter relating to privacy, please contact us using the details set out below.
To contact HPG about this Privacy Policy, you may:
- Write to us at:
Privacy Officer
Healthcare Property Group
Suite 1.01 / 354 Tooronga Road
GLEN IRIS VIC 3146
- Telephone us on +613 9811 5111; or
- Email us at enquiries@healthcarepropertygroup.com.au
HPG takes complaints seriously, and upon receipt will examine the complaint in accordance with the Privacy Act.