1.0 Introduction
At The Property Exchange (“the company”, “us”, “we”, “our”) we are committed to safeguarding your privacy by ensuring your information is protected in a way that observes our own corporate values, as well as complying with the requirements of the National Privacy Principles of the Privacy Act (Cth) 1988, as amended (the “Act”). This policy sets out the minimum procedures for safeguarding your privacy.

2.0 Scope of Statement
This statement applies to Alobeal Pty Ltd trading as The Property Exchange. Most organizations in Australia must comply with the 10 National Privacy Principles of the Act. The objective of the Privacy Act is to set a standard for protecting the privacy of all individuals. The National Privacy Principles and the requirements of them are explained in the detailed section of this statement, below.

3.0 Definitions
3.1 Personal Information
Your personal information includes details such as name, address, date of birth, contact details (such as telephone and facsimile numbers, email addresses).

3.2 Sensitive Information
Sensitive information is a subset of personal information and by its “sensitive” nature may have the potential to be used to discriminate against someone. Therefore the recording of it has stricter requirements than other types of personal information. Examples of sensitive information include but are not limited to personal information or opinions on your health, criminal records, sexual preferences, religion etc. Sensitive information can only be recorded if it is relevant to do so and with your consent.

4.0 The Property Exchange’s Privacy Principles
4.1.1 Collection of Personal Information (National Privacy Principle 1)
Where you have requested a service, The Property Exchange collects personal information where it is necessary primarily to identify you or your business entity and to assess and establish the service you have requested.

4.1.2 Your rights and the Disclosure of Personal Information
You need not give personal information about yourself that may be requested by us to supply you with our services. However, without that information, The Property Exchange may not be able to provide you with the services you requested.

4.1.3 Use of Information (National Privacy Principle 2)
The Property Exchange collects your personal information and uses the information to provide the services requested by you. The Property Exchange may use your personal information for related purposes, in accordance with the National Privacy Principles. Your personal information may also be used to complete internal business functions such as auditing, management reporting, research, development and planning.

4.1.4 Disclosure of Information (National Privacy Principle 2)
In providing services The Property Exchange may disclose your personal information to organizations that carry out functions on The Property Exchange’s behalf. This may include but not be limited to settlement agents, organizations or trades people carrying out maintenance and other service providers we may use in the provision of secondary services. This includes external auditors, computer and information technology service providers for computer, internet, network distribution and related functions.

Although The Property Exchange undertakes its best endeavours to ensure your personal information is safeguarded in a manner consistent with its privacy policy and only used to carry out functions on its behalf we cannot accept liability for any misuse of your personal information by those organizations or individuals.

The Property Exchange may also use and disclose your personal information to complete business functions within The Property Exchange such as internal auditing, performance reporting, research, development and planning

4.1.5 Data Quality (National Privacy Principle 3)
The Property Exchange must ensure your personal information collected, used or disclosed is, at all times, accurate, complete and up to date.

You should advise us immediately when you become aware that any information we hold about you is incorrect or out of date. The Property Exchange undertakes to amend its records as soon as practical after it is advised subject to the validity of the request being confirmed.


4.1.6 Data Security (National Privacy Principle 4)
The Property Exchange will take all reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access modification and disclosure. Your information may be stored in paper or electronic format.

Security measures implemented with respect to The Property Exchange IT systems will take account of internal and external recommendations, general industry practise and technological development in the provision of IT security services.

The Property Exchange IT security measures include firewall technology, encryption of internet services and provision of unique user identification and password codes to your account.

When using our internet services we may use “cookies” to ascertain service preferences and tailor future visits to the site to suit them. Most web browsers can be configured to not accept cookies, however the site functionality may be restricted as a result. Other than statistical information we do not collect information about you through our website other than where you provide it.

4.1.7 Openness to The Property Exchange’s Practices (National Privacy Principle 5)
The Property Exchange has developed a policy that outlines information handling practices. Information in this statement gives you some insight into how we manage your personal information and your rights.

4.1.8 Access (National Privacy Principle 6)
You are entitled to access personal information we may hold about you. The type of information that you may request is your personal information as well as any comments, opinions and file notes that The Property Exchange holds about you.

The Property Exchange will process your request within a reasonable time, generally 14 days for a straight forward request. However additional time may be needed depending on the nature of the request.

There is no fee for lodging a request for personal information. However, The Property Exchange reserves the right to recover reasonable costs associated with processing the request. You will be advised the cost, if any, before we proceed.

The Property Exchange is not required to provide you with access to your information in some cases ie: where the law allows The Property Exchange to deny access. If The Property Exchange denies you access to your information you will be advised the reason why.

A request to access your personal information must be directed in writing to: rental@palmhills-golf.com

4.1.9 Correction
You may ask The Property Exchange at anytime to correct personal information it holds about you. The company undertakes to correct the information within a reasonable time provided it is satisfied as to the validity of the request being confirmed. If the validity of your request cannot be confirmed by The Property Exchange you will be advised that The Property Exchange has not acted on it and the reason why. If The Property Exchange disagrees with your request to correct information it holds, you have the right to request a statement be held with that information noting your disagreement.

4.1.10 Identifiers (National Privacy Principle 7)
Identifiers are unique numbers that a Commonwealth Government agency has assigned to you. These include tax file numbers and Medicare numbers.

4.1.11 Anonymity (National Privacy Principle 8)
In complying with the National Privacy Principles The Property Exchange will allow its customers to interact anonymously wherever it is lawful and practical to do so.

4.1.12 Trans Border (overseas) Data Flows (National Privacy Principle 9)
Should you request a transaction or service where your personal information may be transferred to another country, your information may be transferred to a country that does not have the same privacy laws as Australia. This may occur in instances where you request an international telegraphic transfer where your name and account details may be divulged.

4.2.1 Sensitive Information (National Privacy Principle 10)
If it is necessary to record sensitive information (such as health related information), we must obtain your specific consent to collect that information. Sensitive information is generally not required for most of The Property Exchange’s services. You are entitled to access any information that we record.

5.0 Information required for Statutory Compliance Purposes
In addition to questions that The Property Exchange may ask to ensure general statutory compliance there may be special circumstances where the company or its agents are required to seek additional information about you.

6.0 Further Information or questions
The company has a Privacy Officer appointed to manage, investigate, coordinate and respond to your inquiries, disputes lodged, information access and correction requests in accordance with The Property Exchange’s procedures and the National Privacy Principles.

All inquiries will be managed consistent with the National Privacy Principles and The Property Exchange’s general procedures.

The Privacy Officer will also provide you with contact details for the Privacy Commissioner if required where the company is unable to resolve a dispute to your satisfaction.

The company’s Privacy Officer can be contacted between 9:00am and 5:00pm Monday to Friday (excluding public holidays )