More information about privacy and the operation of the Privacy Act can be found on the website of the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
COMPLIANCE WITH THE PRIVACY ACT
COLLECTION OF PERSONAL INFORMATION
To enable Bensons to deliver the best possible service to you (its clients, prospective, past and current customers, investors, contractors, partners and suppliers) it is necessary for Bensons to collect personal information. The type of personal information that is collected will be determined by the nature of the relationship between you and Bensons. At the time personal information is collected, Bensons will take reasonable steps to inform you about the purpose for which the information is collected, your rights to access the information and other matters contemplated in the Australian Privacy Principles.
Generally, Bensons will only collect personal information directly from you unless it is not reasonable or practical or you otherwise consent to the information being collected from a third party.
WHAT TYPE OF PERSONAL INFORMATION DOES BENSONS COLLECT?
The type of personal information that we collect from you will depend on how you engage with us. Generally, Bensons will collect the following personal information:
your postal and email address, contact number, job title and employer name;
in relation to financial products issued by Bensons, bank account details and tax file number details;
transaction information; and
any other personal information that you submit to us, via our websites, including bensonspropertygroup.com.au and other sites owned or operated by us (Site).
We will only collect your personal information from third parties if you give the third party your consent to provide the information to us or it would be reasonably expected.
If someone other than you provides us with personal information about you that we did not ask for, or you provide us with unsolicited personal information, we will only hold, use or disclose this information if we determine that we could have collected this information from you had we asked for it. In this circumstance we will take all reasonable steps to notify you of the collection of that information. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.
USE OF PERSONAL INFORMATION
We will only use your personal information for the purposes for which it was given to us, or for purposes which are related to the provision of our services.
Your personal information may be used by us in a number of ways, including:
to facilitate the running of and participation in loyalty programs, memberships and subscription services;
to notify you about Bensons’ activities and campaigns, including direct marketing of Bensons products or services;
to notify you about new developments Bensons believes may be of interest to you;
to notify you about promotions, competitions or special offers about products or services offered by Bensons, as well as products or services offered by carefully selected third parties;
to facilitate the running of promotions, competitions or special offers about products or services offered by Bensons, as well as products or services offered by carefully selected third parties;
collecting payment from you;
Where practicable, the purpose for which Bensons collects personal information will be made clear at the time of collection.
DISCLOSURE OF PERSONAL INFORMATION
In certain circumstances, it may be necessary for us to disclose your personal information to third parties in order to assist us in providing our services, or where disclosure is required by us to meet our legal and regulatory obligations. Third parties may include:
digital marketing and other service providers and social media platforms;
parties making enquiries via our Sites;
technology support service providers where applicable to the service provided to you;
data storage providers;
government and law enforcement agencies and regulators; and
entities established to help identify illegal activities and prevent fraud where authorised by law.
We may also disclose your personal information to anyone authorised by you, or to whom you have provided your consent (either expressly or impliedly) or where another permitted general situation applies (as defined in Section 16A of the Privacy Act).
If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its or their assets, your personal information may be among the assets transferred.
We use personal information about you for the primary purpose of providing you with our services. We may also use it for other purposes for which you might reasonably expect us to use that information. You authorise us to use any email address or other contact information you provide to use at any time for such above purposes.
You can opt out of receiving electronic communication at any time. You agree and acknowledge that even if you opt out of receiving information about future events or marketing material, we will still send you essential information that we are required to send you relating to the services we provide.
QUALITY OF PERSONAL INFORMATION
Bensons will take such steps as are reasonable in the circumstances to ensure that the personal information it collects is accurate, complete and up-to-date and, having regard to the purposes of the use or disclosure of the personal information that is collected, relevant.
SECURITY OF PERSONAL INFORMATION
Bensons will take such steps as are reasonable in the circumstances to protect the personal information it holds from misuse, interference (which may include measures to protect against computer attacks) and loss and from unauthorised access, modification or disclosure.
If you reasonably believe that there has been unauthorised use or disclosure of your personal information please contact us using the details below.
We keep records of the personal information we gather from you. You warrant that you will not act in a manner that results in us collecting, using or storing information that is in breach of our obligations at law.
If we no longer need your personal information, unless we are required under Australian law or a court or tribunal order to retain it, we will take reasonable steps to destroy or permanently de-identify your personal information.
OPEN AND TRANSPARENT MANAGEMENT
ACCESSING AND UPDATING INFORMATION
You can request access to your personal information that Bensons holds by contacting Bensons’ Privacy Officer. Bensons will provide you with access to your personal information within a reasonable period after the request is received, unless Bensons is legally authorised to refuse your request. Where Bensons withholds personal information, Bensons may instead choose to give you a summary of that information. Bensons may charge a reasonable amount for providing access.
If you wish to change personal information that is out of date, inaccurate, incomplete, irrelevant or misleading at any time please contact Bensons’ Privacy Officer. After receiving notice from you, Bensons will take such steps as are reasonable in the circumstances to correct that information, including notifying any third party to whom the information has previously been disclosed. Bensons will not charge you for correcting your personal information. If you wish to have your personal information deleted please let Bensons know and Bensons will delete that information wherever practicable.
Where Bensons refuses your request to access, amend or delete your personal information, Bensons will provide you with reasons for its decision. Bensons’ notification of the refusal will include details of the mechanisms available to you to complain.
ANONYMITY AND PSEUDONYMITY
Wherever it is not unlawful or impracticable, you will have the option of not identifying yourself, or of using a pseudonym, when dealing with Bensons.
CROSS-BORDER DATA FLOWS
It is not usual for Bensons to transfer personal information overseas. If personal information is transferred overseas, then Bensons will wherever practical obtain your written consent before doing so. If obtaining your consent is not practical, then the information may still be transferred if Bensons has taken reasonable steps to ensure that the information will not be held, used or disclosed by the recipient in a manner that is inconsistent with the Privacy Act.
Our Sites may record information collected if you visit the Site. The information recorded may include the date and time of your visit to the Site, the pages accessed, any information downloaded, and any information and details entered by you for the purpose of contacting Bensons for any reason. Bensons may use information collected via its website for statistical, reporting and website administration and maintenance purpose.
Bensons website may use “cookies” to help personalise your online experience. You have the ability to accept or decline cookies. If you choose to decline cookies, you may not be able to fully experience the features of Bensons’ website.
When transmitting personal information from a computer to Bensons’ website, you must keep in mind that the transmission of information over the Internet is not completely secure or error-free. In particular, e-mails sent to or from the site may not be secure, and you should take special care in deciding what information to send to Bensons via e-mail. Other than liability that cannot lawfully be excluded, Bensons will not be liable in any way in relation to any breach of security or any unintended loss or disclosure of that information.
Our Sites may provide links to other websites directly or indirectly to users of the website. Linked sites are not under Bensons control and Bensons does not accept any responsibility or liability that may stem from any linked website.
If you wish to make a complaint about a breach of the Privacy Act by us, you may do so by contacting us using the details listed below. We will seek to respond to any complaint within a reasonable period of time. We may seek further information from you in order to provide a comprehensive and complete response.
If you are dissatisfied with our response, you may refer your complaint to the Office of the Australian Information Commissioner (OAIC). You may contact the Australian Information Commissioner via telephone on 1300 363 992, by submitting a complaint or inquiry online at www.oaic.gov.au or by writing to the OAIC at GPO Box 5218 Sydney NSW 2001.
Bensons Property Group Pty Ltd
Level 3, 367 Collins Street
Melbourne Victoria 3000
Telephone: 03 8602 0800
Facsimile: 03 8602 0888