Lacey & Co Property Group Pty Ltd ACN 645 117 308, its subsidiaries and affiliates in Australia (collectively referred to as Lacey & Co) are committed to managing your personal information in accordance with the Australian Privacy Principles (APPs) established under the Privacy Act 1988 (Cth) (Privacy Act) and in accordance with other applicable privacy laws.
Broadly speaking, when we are referring to personal information, we are referring to information or an opinion about you, or information that is reasonably recognisable as you. This may include information or an opinion about you that may or may not be accurate, and whether the information or opinion is recorded in a hardcopy form or not.
If you wanted to find out more about ‘personal information’ and ‘sensitive information’, then we recommend that you visit the Office of the Australian Information Commissioner (the OAIC).
Lacey & Co is Australian based and offers a complete range of services in property management, project management and property development. Lacey & Co offers services such as letting and property management, construction management, design and development and contract and project management.
TYPES OF INFORMATION THAT WE COLLECT & WHY
We may collect, use, hold, store and disclose your personal information. This allows us to conduct our business which includes providing our service offerings to you.
The type of personal information that we collect will vary depending on the circumstances of collection and the kind of service that you request from us. We list the types of information that we collect from you in further detail below.
We collect personal information that is reasonably necessary to carry out our business, to assess and manage our business and client/customer needs, and provide services, including providing advice regarding construction and development projects. We may also collect information to fulfil administrative functions associated with these services, for example billing, entering into contracts with you or third parties and managing client/customer relationships.
We generally collect personal information directly from you. We may collect and update your personal information over the phone, by email, by our website, over the internet or social media, or in person. We may also collect personal information about you from other sources such as our affiliated and related companies and third-party suppliers and contractors who assist us to operate our business.
We also collect and use personal information for market research purposes and to innovate our delivery of products and services.
Why do we collect your information?
The purposes for which we usually collect and use your personal information depends on the nature of your interaction with us but may include the following circumstances:
• providing you with the best service experience possible, including on our website;
• responding to requests and general inquiries, including communicating with you and confirming your identity;
• processing and fulfilling any orders, transactions or sales in relation to the delivery of the services (including processing your payment information, and providing you with invoices or order confirmations);
• informing you about our business, service offerings, news, updates, marketing material and event invitations (including through third-party platforms for our convenience);
• recruitment processes (including for volunteers, internships and work experience);
• researching, developing and expanding our facilities and services;
• communicating and dealing with third-party suppliers and contractors who assist us to operate our business; and
• for any administrative or other purposes necessary to conduct our business or innovate the delivery of our products and services.
What Information do we collect about you?
The types of personal information that we collect from you will vary depending on the circumstances, but may include the following:
• Contact Information & Personal Data: your name, age, gender, residential and postal address, mobile phone or other phone numbers, email address, and date of birth;
• Photographs & Videos: pictures, videos, sound recordings and other audio-visual recordings of you or your project;
• Payment Information: your purchase information, billing information, your credit card or other bank account details for payment processing, and additional contact information over and above what we already hold about you;
• Cookies & Other Device Information: we collect session cookies and persistent cookies when you visit our website, your device type, browser type, Internet Protocol (IP) address, your URL information, the date and time (including time zone) of your visit, the pages you have accessed on our websites and third party websites, your software and hardware information concerning your mobile device or computer;
• Interaction & Behavioural Information: your interactions, use, habits, behaviours when dealing with us, our website and other applications; and
• Administrative & Ancillary Information: any administrative and additional information that is necessary to conduct our business or innovate the delivery of our products and services, or that you provide to us, or authorise us to collect.
Not our client? We may still collect your information
Lacey & Co may collect personal information about other individuals who are not our clients or customers. This includes customers and members of the public who participate in events we are involved with, individual service providers and contractors to us, and other individuals who interact with us on a commercial basis or through our website and other platforms.
The kinds of personal information we collect will depend on the capacity in which you are dealing with us. Generally, it would include the types of personal information listed above.
If you are participating in an event we are managing or delivering, then we may take images or audio-visual recordings which identify you.
In limited circumstances, we may collect information which is considered sensitive information. For example, if you are injured at an event promoted or delivered by us, we may collect health information about you in an emergency or otherwise with your consent.
We may collect personal information about children (for example, when children participate in events we are involved with). Where children do not have sufficient maturity and understanding to make decisions about their personal information, we will require their parents or guardians to make decisions on their behalf.
You can always decline to give us any personal information we request, but that may mean we cannot provide you with some or all of the services you have asked for. If you have any concerns about the personal information we have requested, please let us know.
INTERACTING WITH US
Online & Our Website
Our websites may contain links to third-party websites. We are not responsible for the content or privacy practices of websites that are linked to our website.
We will provide you with the opportunity of remaining anonymous or using a pseudonym in your dealings with us where it is lawful and practicable (for example, when making a general enquiry). However, it is sometimes not possible for us to deal with you anonymously or pseudonymously on an ongoing basis. If we do not collect personal information about you, then you may be unable to utilise our services or participate in our events, programs or activities we manage or deliver.
HOW WE HOLD AND STORE YOUR INFORMATION
Holding your information – paper, electronic and our storage methods
We store information in many ways, including by means of:
• paper-based files;
• cloud or web-based servers (including trusted third-party storage providers based in Australia and overseas); and
• other electronic record-keeping methods in secure databases.
Your personal information may be collected in the paper-based form and then converted to electronic form for use or storage (with the original paper-based documents either archived or securely destroyed). We will take reasonable steps to protect your personal information from misuse, interference and loss and from unauthorised access, modification or disclosure.
If we hold your personal information in paper-based form, we will maintain physical security over paper and electronic data stores, such as through locks and security systems at our premises. We also maintain computer and network security, for example, the use of firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
Our cloud or web-based servers are operated by trusted third-party storage providers based in Australia and overseas. As a result of this, your personal information will be disclosed to these storage providers. We discuss this further below. We cannot ensure that your personal information is or will remain, secure concerning any third-party storage provider that we engage. This is due to our inability to have management and control over that third party provider’s policies and procedures concerning the handling and storage of your personal information.
Our websites do not necessarily use encryption or other technologies to ensure the secure transmission of information via the internet. Users of our websites are encouraged to exercise care in sending personal information via the internet.
We take steps to destroy or de-identify information that we no longer require.
DISCLOSING YOUR INFORMATION & OVERSEAS RECIPIENTS
Your personal information may be transferred overseas or stored overseas for a variety of reasons, but primarily for the purpose of storing your personal information which is facilitated by our third-party storage providers. It is not possible to identify each and every country to which your personal information may be sent.
If your personal information is sent to a recipient in a country with data protection laws which are at least substantially similar to the Australian Privacy Principles, and where there are mechanisms available to you to enforce protection of your personal information under that overseas law, we will not be liable for a breach of the Australian Privacy Principles if your personal information is mishandled in that jurisdiction.
If your personal information is transferred to a jurisdiction which does not have data protection laws as comprehensive as Australia’s, we will take reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the Australian Privacy Principles and we disclaim all responsibility and note that you may not have any remedy under Australian law.
In some circumstances, the European Union General Data Protection Regulation (GDPR) provides additional protection to individuals located in Europe. The fact that you may be located in Europe does not, however, on its own entitle you to protection under the GDPR. Our website does not explicitly target customers located in the European Union, and we do not monitor the behaviour of individuals in the European Union, and accordingly, the GDPR does not apply.
WHAT ELSE DO YOU NEED TO KNOW?
By using our website and interacting with us, you consent to the receipt of direct marketing material information for the purpose of informing you about our services, upcoming promotions and events, or other opportunities that may interest you.
We will only use your personal information for this purpose if we have collected such information directly from you or you have provided information to us, and if it is material of a type which you would reasonably expect to receive from us. We do not use sensitive personal information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature.
If you opt-out of receiving marketing material from us, we may still contact you in relation to its ongoing relationship with you.
Need to access or correct your information with us?
You are entitled to access your personal information held by us on request. You will not be charged for making a request to access your personal information, but you may be charged for the reasonable time and expense incurred in compiling information in response to your request.
We will take reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date. You can help us to do this by letting us know if you notice errors or discrepancies in the information we hold about you and letting us know if your personal details change. Otherwise, you can correct any inaccurate personal information (subject to certain exceptions).
If, at any point in time, you wish for your Personal Information to:
• be destroyed; or
• be de-identified; or
• be accessed; or
• be provided to you as a copy,
unless we are legally allowed or required to maintain your (or part of) your personal information, then you can submit a request to Manage My Information by contacting the Privacy Officer using the contact details set out below.
If you have complaints or concerns with the manner in which we maintain the privacy of your personal information, please contact our Privacy Officer as set out below.
All complaints will be considered by our Privacy Officer, and we may seek further information from you to clarify your concerns. If we agree that your complaint is well-founded, we will, in consultation with you, take appropriate steps to rectify the problem. Our investigations may take some time, but we will endeavour to complete our investigation into your complaint promptly.
If you are not satisfied with our response to your complaint, or you consider that we may have breached the APPs or the Privacy Act, then you can contact the OAIC by telephone on 1300 363 992 or by using the contact details on the OAIC website.
CONTACT US ABOUT PRIVACY
If you have any queries, or if you seek access to your personal information, or if you have a complaint about our privacy practices, you can contact us using the following details:
Attention: Privacy Officer