Privacy and Data Protection Policy 

The Privacy and Data Protection Policy Statement sets out the policy of AA Realty ABN 75 858 841 003 (“we”, “us”. “our”) with respect to the way in which we obtain, use, protect and disclose information about you, including through our website www.aa-realty.com.au.  We adopt and are bound by the Australian Privacy Principles (“APPs”) contained in the Privacy Act 1988 (Cth) (“the Act”). 

We understand and appreciate that you are concerned about privacy, particularly in relation to the use and disclosure of Personal Information. We are committed to providing a high level of privacy in relation to all Personal Information that is collected by us. If you would like more information, please don’t hesitate to contact us. 

Your Consent 

You consent to your Personal Information being used in accordance with this Privacy Policy Statement by any one or more of the following: 

• by communicating with us or by continuing to request our services, including but not limited to: by attending to our office, making enquiries via internet, email or phone; 

• providing us with your contact details and consenting in writing for such details to be conveyed to a mortgage broker or financier; 

• by visiting our website or participating in an online enquiry; 

• by visiting any website or social media site established by us, including but not limited to Facebook, Twitter, Instagram, Google+, Youtube and Linked In (“Social Media Sites”); and 

• by participating in any activity on a Social Media Site including but not limited to entering competitions, subscribing to our blog, posting, pinning or uploading any material on any Social Media Site, following, liking and/or commenting on us or anything on any Social Media Site (“Social Media Activity”). 

What personal information we collect about you 

The type of personal information that we collect from you will depend on how you use our website. You can be certain that the information we receive about you will be treated as strictly confidential. 

Personal information is any information or opinion about you that may identify you or that may make you reasonably identifiable. The personal information we collect may include general information about you such as your name, contact details (e.g., your postal and email address, or mobile phone number) identity verification information, including copies of government-issued identification documents, date of birth, and any other information that you otherwise share with us, or that we reasonably need to collect from time to time in connection with our services. 

Some of the personal information we collect as part of our identity verification process, is ‘sensitive information’ under the Privacy Act. We will only collect sensitive information, with your consent, except where the law otherwise permits or requires us to do so. 

How we may collect your personal information 

We only collect personal information that is necessary for us to conduct our business and provide services to you. 

Where you provide your mobile number and consent to receiving SMS communications, we may use it to send you SMS text messages relating to your enquiry, including follow-ups, appointment reminders, and marketing communications about our products, services and events. Message and data rates may apply and message frequency varies. You can opt out of marketing SMS at any time by replying “STOP” to any message, or by contacting us using the details below. 

If you log onto website and read or download information, our Internet Service Provider/Hosting Provider, will record your server address, domain name, the date and time of your visit to our site, the pages viewed and the information downloaded. This information is used for statistical and web site development purposes only and does not identify you. 

If you complete a survey or questionnaire provided by us, we will collect the personal information you use in your responses, or when you provide us with feedback and participate in promotions.  

The names of persons who subscribe to our newsletter are added to our database and will be sent regular property updates by email. We will also inform you of upcoming events. You can always unsubscribe if you wish. 

We may be able to obtain other information about you via Social Media Sites, which may itself constitute Personal Information or which, when combined with other information, is capable of identifying you, including photos, videos and any other information that you include on our Social Media Sites or sites linked to our Social Media Sites (“Other Sites”). The level of information to which we have access may depend on your privacy settings on such Other Sites. 

Tracking technologies such as cookies may be used on our website to recognise a user’s browser each time that user visits our site and to track which pages the user visits whilst on our site and also to push advertisements to your internet protocol address.  Cookies are pieces of information that a website transfers to a computer’s hard drive for record keeping purposes.  Most web browsers are set to accept tracking technologies such as cookies.  These tracking technologies do not personally identify the user.  If you do not wish to receive any cookies, you may set your browser to refuse them.  However, your use of our websites may be affected. 

This website uses remarketing to advertise services you may be interested in. We may use third party vendors, such as Google and Facebook, to store your information once you visit our site. We may then remarket to you when you visit other websites that are part of the third party vendors’ advertising network. We use cookies to store this information in your web browser. You can opt out of Google’s use of cookies by visiting Google’s Ads Settings. 

How we may use your personal information 

AA Realty and its representatives will never unnecessarily exchange your personal or business information with any third party for any reason, unless compelled by force of law. 

Your personal information may be used in order to: 

• verify your identity and comply with our obligations under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML/CTF Act), including customer due diligence, screening against sanctions and politically exposed persons lists, ongoing monitoring, and reporting to AUSTRAC; 

• process any purchases of services that you may make through this site, including charging, billing and collecting debts; 

• respond to any queries or feedback that you may have; 

• contact you with information that might be of interest to you, including information about products, services and events of ours and of others; 

• ask for your opinion or preference about our products or the products of others; 

• prevent and detect any misuse of, or fraudulent activities involving, this site; 

• conduct research and development in respect of our services; 

• gain an understanding of your information and communication needs or obtain your feedback or views about our services in order for us to improve them; and/or 

• maintain and develop our business systems and infrastructure, including testing and upgrading of these systems, and 

• for any other purpose reasonably necessary in connection with the products and services we provide to you, or as otherwise permitted or required by law. 

When you become a client, you consent to AA Realty using your personal information for direct marketing purposes (for an indefinite period) by post, email, phone or SMS, unless you contact us to withdraw your consent. 

You acknowledge that where we reasonably determine it to be appropriate, we may add some of your Personal Information including your name and email address to our database. The database will be used for ongoing marketing and related purposes or to advise you of the other services we or our business partners or affiliates can offer. 

The type of marketing and sales activities that we undertake includes sending material to you so that you are kept updated in relation to various property related issues or other services that we can offer you. 

In each direct marketing communication that you receive from us we will attach prominent and simple instructions on how you can immediately unsubscribe from our mailing list.  

When we may disclose your personal information 

In order to deliver the services you require, we provide, or for the purposes set out in this Privacy Policy, we may share your personal information to organisations outside AA Realty. We take reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information. These organisations may be hired by us to deliver the services you require from us or may carry out or provide: 

• client enquiries; 
• mailing systems; 
• billing and debt-recovery functions; 
• information technology services; 
• marketing, telemarketing and sales services; 
• market research; and 
• website usage analysis. 

In addition, we may disclose your personal information to: 

• your authorised representatives or legal advisers (when requested by you to do so); 
• our professional advisers, including our accountants, auditors and lawyers; 
• government and regulatory authorities and other organisations, as required or authorised by law, including AUSTRAC (the Australian Transaction Reports and Analysis Centre) under the AML/CTF Act; 
• organisations who manage our business strategies, including those involved in a transfer/sale of all or part of our assets or business (including accounts and trade receivables) and those involved in managing our business risk and funding functions; and 
• the police or other appropriate persons where your communication suggests possible illegal activity or harm to others. 

Contacting us about privacy 

If you would like more information about the way we manage your personal information, or are concerned that we may have breached your privacy, please contact us by email to rob@aa-realty.com.au. 

We will acknowledge your complaint promptly and aim to respond within 30 days. If you are not satisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC) at https://www.oaic.gov.au/. 

Access to your personal information 

In most cases, you may have access to personal information that we hold about you. We will handle requests for access to your personal information in accordance with the Australian Privacy Principles. All requests for access to your personal information must be directed to us, in writing, via the email address or by writing to us at the postal address stated above.  

We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information that is not currently in use, may require further time before a response can be given. We may charge you a fee for access if a cost is incurred to us, to retrieve your information. In no case will we charge you a fee for your application for access. 

In some cases, we may refuse to give you access to personal information that we hold about you. This may include circumstances where giving you access would: 

• be unlawful (e.g., where a record that contains personal information about you is subject to a claim for legal professional privilege by one of our contractual counterparties); 
• have an unreasonable impact on another person’s privacy; or 
• prejudice an investigation of unlawful activity. 

We may also refuse access where the personal information relates to existing or anticipated legal proceedings, and the information would not be accessible by the process of discovery in those proceedings. If we refuse to give you access, we will provide you with reasons for our refusal. 
 

AML/CTF Confidentiality (“Tipping-Off”) 

The AML/CTF Act prohibits us from disclosing that we have made, or are considering making, a report to AUSTRAC about you or your dealings with us, or from disclosing certain other information about our AML/CTF compliance activities. If we are unable to respond to a request for information, this may be because we are subject to these confidentiality obligations. This does not affect your other rights under this Privacy Policy or under the Privacy Act. 

Security 

We are committed to ensuring the security of your Personal Information and we will take all reasonable steps to protect this Information from misuse, interference, loss, unauthorised access, modification or disclosure, including: 

• ensuring the physical security of our premises and databases/records; 

• restricting access to personnel who need that information in order for us to be able to provide our products and services; and 

• industry standard technological measures, such as computer passwords, data back-up, anti-virus software and firewalls. 

We will take all reasonable steps to ensure the Information is accurate and up-to-date and relevant for the purposes for which it may be used pursuant to this Privacy Policy. 

Please note that our website does not provide systems for secure transmission of Personal Information across the internet, except where otherwise indicated.  When emailing or providing Personal Information to us via our website, please be aware that there are risks involved in transmitting such information across the Internet. 

Our websites contains links to other websites. We have no control over the privacy practices employed at other websites and we accept no responsibility for Personal Information provided via unsecured websites. 

We cannot provide any guarantee with respect to the security of your Personal Information and we will not be liable for any breach of security or unintended loss or disclosure of information due to the website being linked to the Internet. 

How we handle emails 

We will preserve the contents of any e-mail message that you send us if we believe that we have a legal requirement to do so. 

What to do if you believe the information we hold about you is inaccurate 

If you believe that any information that we hold about you is inaccurate or out of date, please contact us and we will review the relevant information. 

Changes To The Statement 

From time to time, it may be necessary for us to revise this Privacy Policy. Any changes will be in accordance with any applicable requirements under the Privacy Act and the Australian Privacy Principles. We will notify you about changes to this Privacy Policy by posting an updated version on our websites.