Privacy Policy

Smart Property Manager Pty Ltd ACN 126 136 187 and its related bodies corporate (Smart Property Manager, SPM, VIP Consulting, we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information. The following Privacy Policy Statement details how we collect and manage any personal information we may recieve and the steps we take to protect it.

At SPM, we respect your right to privacy under the Privacy Act 1988 (Cth) (Act) to ensure we handle personal information in accordance with the Act and complies with all of the Act’s requirements in respect of the collection, management and disclosure of personal information, including the Australian Privacy Principles.

This Privacy Policy is intended to inform you about the following:

• what type of personal information SPM may collect;
• how and why SPM collects or discloses your personal information;
• how SPM maintains and keeps the information secure;
• how you may access, correct or update any personal information that SPM holds about you;
• the process for complaining about a breach of privacy.

What is your personal information?

When used in this privacy policy, the term “personal information” has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What personal information do we collect and hold on your behalf?

SPM may collect any or all of the following information about you if you are a current or prospective buyer, seller or landlord, or tenant:

• contact details (including, name, address, telephone number and email address);
• personal information (age or birth date, profession/occupation/job title)
• driver’s license number;
• property ownership details including details of properties sold or acquired, current holdings;
• desired property ownership details; and
• any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise and information you provide to us through our service centre, customer surveys or visits by our representatives from time to time.

If you are a current or prospective tenant for a rental property, SPM may collect some or all of the following additional information from you:

• contact details (including, name, address, telephone number and email address);
• personal information (age or birth date, profession/occupation/job title)
• driver’s license, passport and/or other forms of identification;
• employment details such as your employment status, employer, salary, length of employment;
• other sources of income; and
• personal and financial referees whom we may contact about your application.

We also may collect anonymous answers to questionnaires or accumulated information about how users use our website. This is not personal information because it does not identify you or anyone else.

How do SPM collect personal information?

SPM collects your personal information directly from you (unless it is unreasonable or unneccesary to do so). When we collect information from you, we may collect in various ways, including through written formats (emails, letters, etc.), through your use of our website and during conversations between you and our representatives, by contracting with us, when you enter competitions, promotions or requesting information or material from us, completing surveys or providing feedback. 

SPM may also collect information about you from the following third party sources:

• various databases in the public domain such as Telstra White Pages, Australia Post DPID database, Titles Office or other property databases;
• your representatives (lawyers, accountants and financial advisers);
• your employer;
• the National Tenancy Database (NTD) operated through Veda Advantage Information Services and Solutions Limited (Veda);
• law enforcement agencies and other government entities;
• referrals and recommendations from existing clients of SPM; and
• publically available sources of information or any other organisation where you have given your consent.

In some cases we may also use cookies to collect your information. When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our website without bothering you with a request to register. It also allows us to keep track of services or products you view so that, if you consent, we can send you news about those relevant services or products. We also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online products and services. Our cookies do not collect personal information. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them.

We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements, and gather broad demographic information.

Can you be anonymous when you deal with SPM?

To a degree, you may remain annonymous when you deal with SPM. You can browse our website without providing any personal information, you can access our real-estate advertising in various publications and in some instances whereby the auction is held on the street and you do not intend to bid, and you may not be requested to provide personal information.

What happens if SPM can’t collect your personal information?

If you don’t provide Smart Property Manager with the personal information described above, some or all of the following may happen:

• we may not be able to provide the requested products or services to you, either to the same standard or at all;
• we may not be able to provide you with information about products and services that you may want; or
• we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.

For what purposes do we collect, hold, use and disclose your personal information?

SPM gathers personal information so that we can perform our business tasks and roles and to give you the best possible level of customer service.  

We collect, hold, use and disclose your personal information for the following reasons:

• to provide products and services to you and to send communications requested by you;
• to answer enquiries and provide information or advice about existing and new products or services;
• to provide you with access to protected areas of our website;
• to assess the performance of the website and to improve the operation of the website;
• to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
• for the administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes of SPM, its related bodies corporate, contractors, franchisees, franchisees’ real estate agents or service providers;
• for tenancy verification and identity purposes;
• to provide your updated personal information to our related bodies corporate, contractors or service providers;
• to update our records and keep your contact details up to date;
• to process and respond to any complaint made by you; and
• to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political sub-division of a country).

SPM will not share, sell, rent or disclose any personal information other than as described in this Privacy Policy.

To whom do we disclose personal information?

We may release your personal information to:

• our staff, related bodies corporate, contractors, franchisees, franchisees’ real estate agents or service providers for the reasons of operation of our website or our business, tending to requests made by you, and to otherwise inform you of products and services including, without limitation, web hosting providers, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors and consultants;
• suppliers and other third parties with whom we have commercial relationships, for business, marketing, and related purposes.

If you are a current or prospective tenant for a rental property, SPM may also disclose your personal information to the NTD for tenancy verification and identity purposes.

SPM’s disclosures of your personal information to third parties are on a confidential basis or otherwise in accordance with the law.  SPM may also disclose your personal information with your consent or if disclosure is required or authorised by law.

The NTD can be contacted by writing to:

Veda Public Access
PO Box 964
NORTH SYDNEY NSW 2059
or at This email address is being protected from spambots. You need JavaScript enabled to view it.

Veda’s policy on its management of personal information through the NTD can be accessed through its website at: www.veda.com.au

If SPM wishes to use or disclose any of your personal information in any other ways than described above, SPM will not do so unless we:

• has your express consent to do so;
• has reasonable grounds to believe that the use or disclosure is necessary to prevent a threat to life or health; or
• has reasonable grounds to believe that the use or disclosure is required by law or to enforce the law.

We may combine or share any information that we collect from you with information collected by any of our related bodies corporate (within Australia).

Direct marketing materials

We may send you direct marketing communications and information about our services and products that we believe may be of interest to you. These communications may be sent in many forms, including mail, text, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing communications from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.

How can you access and correct your personal information?

You may request access to any personal information we hold about you at any time by contacting us (see the details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). SPM may charge you a reasonable fee to cover its administrative and other reasonable costs in providing the information to you. SPM will not charge for simply making the request and will not charge for making any corrections to your personal information.

SPM may not be able to provide access to information in some situations, including:

• where in SPM’s opinion providing your access may create a serious threat to the life or health of any individual or may be an unreasonable intrusion into the privacy of another individual;
• where your request for access is, in SPM’s opinion, frivolous or vexatious; or
• where providing access would be unlawful, may prejudice an investigation of possible unlawful activity, may prejudice enforcement of law, or denying access is specifically authorised by law.

To obtain access to your personal information:

• you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected; and
• SPM requests that you be reasonably specific about the information you require.

Alternatively, if you would like to access personal information held about you by the NTD, please contact the NTD on the contact details set out above.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.

SPM will endeavour to respond to your request to access or correct your personal information within 30 days from your request.  If SPM refuses your request to access or correct your personal information, SPM will provide you with written reasons for the refusal and details of complaint mechanisms. SPM will also take steps reasonable in the circumstance to provide you with access in a manner that meets your needs and the needs of SPM.

What is the process for complaining about a breach of privacy?

If you believe that your privacy has been breached, please contact us using the contact information below and provide details of the incident so that we can investigate it.  We will deal with the complaint in accordance with our then current Complaints Handling Procedure.

At all times, privacy complaints:

• will be treated seriously;
• will be dealt with promptly;
• will be dealt with in a confidential manner; and
• will not affect your existing obligations or affect the commercial arrangements between you and SPM.

Do we disclose your personal information to anyone outside Australia?

We may disclose personal information to our related bodies corporate and third party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

We may disclose your personal information to entities located outside of Australia, including the following:

• our related bodies corporate, located in foreign countries including the United States of America, New Zealand, Hong Kong, China and Singapore; and
• other third parties located in various foreign countries.

Security

SPM will take reasonable steps to ensure information SPM collects, uses or discloses is stored in a secure environment that is accessed only by persons authorised by SPM so as to prevent interference, misuse, loss, unauthorised access, modification or disclosure. If the personal information is no longer needed for any purpose, SPM will take reasonable steps to destroy or permanently de-identify the personal information. SPM endeavours to provide a secure environment and a reliable system but you should be aware that there are inherent risks associated with the electronic storage and transmission of information (particularly via the Internet) which cannot be guaranteed to be 100% secure.

Links

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

Contacting us

If you have any questions about our privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please contact our Privacy Officer using the details set out below.

We will treat your requests or complaints confidentially. Our representative will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in timely and appropriate manner.

VIP Consulting
1300 736 638
Level 1, 296a Carlisle Street,
Balaclava, VIC 3183
This email address is being protected from spambots. You need JavaScript enabled to view it.

Changes to our privacy policy

We may change this privacy policy from time to time and any updates will be posted on our websites. This privacy policy was last updated on 3 July 2016