NPA Projects Pty Ltd (ABN 62 605 946 987) trading as “First Release” and “NPA Projects” (or our or we) is in the business of lead generation for clients that provide goods/services in the real estate/property industry (Property Industry) (and providers of goods/services related to the Property Industry) (our Clients) including the creation, hosting and management on behalf of our Clients of their sales and marketing campaigns, customer acquisition/lead enquiry platforms, websites and applications, social media pages and other online systems and associated services (Services).
This Policy governs how First Release & NPA Projects will deal with your Personal Information collected in connection with the Services we provide to you and our Clients. For the avoidance of doubt, we collect information from you on our own behalf, and on behalf of our Clients as their agent.
This Policy also applies to Personal Information collected by First Release and NPA Projects in connection with our, and our Clients’, websites, social media accounts, applications, software and other technological means (Online Platforms), as well as in connection with any direct communication between you and First Release and NPA Projects (including where First Release and NPA Projects acts on behalf of its Client).
First Release and NPA Projects uses third parties located both locally and overseas in addition to its own resources to provide these Services.
We are committed to protecting the privacy of everyone who uses our Online Platforms and/or our Services, for them to understand what Personal Information we collect and store, and why we do so, how we receive and/or obtain that information, the rights an individual has with respect to their Personal Information in our possession, and with complying with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act) when they apply to us.
THE INFORMATION WE COLLECT
We may collect Personal Information that allows us to identify who an individual is and share Personal Information.
The type of information we may collect includes:
Personal Information – We may collect personal details such as an individual’s name, gender, occupation, location, date of birth and nationality allowing us to identify who the individual is;
Contact Information – We collect information such as an individual’s email address, telephone & fax number, third-party user names, residential, business and postal address and other information that allows us to contact the individual;
Personal Preferences – We may collect information about an individual’s personal preferences, interests, hobbies, lifestyle and other personal circumstantial information, including shopping preferences and expressed interest in goods/services offered by us and/or our Clients, related bodies corporate and Property Industry business partners;
Financial Information – We collect financial information such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our Services;
Statistical Information – We collect behavioural and statistical information about an individual and businesses in connection with the Services and/or the Online Platforms;
Third Party Sites/Social information – We collect information about you when you when you access our Services or engage with our Online Platforms through a social media site such as Facebook or another third party site, in which case we will collect information provided to us by that social media or third party site.
WHY WE COLLECT PERSONAL INFORMATION
We collect your Personal Information so that we can carry out the following actions:
to enable you to use our/our Clients’ Online Platforms;
to provide our Services to you and our Clients, including collection of your Personal Information for the purpose of on-supplying such Personal Information to our Clients, related bodies corporate, service providers and Property Industry business partners (where you have expressed an interest in learning more about the goods/services offered by our business partners);
to communicate with you, including about our Services and offers which might interest you including the goods/services offered by our Clients, related bodies corporate and Property Industry business partners as set out in Clause 12;
to provide you with information or advice;
to process payments by or to you in connection with our Services (including payments on behalf of our Clients);
to create accounts, tax invoices or receipts;
to contact you to conduct research, surveys and feedback;
to help carry out our obligations arising from any contracts entered into between you and us/our Clients;
to combine your Personal Information with information that our Clients, services providers, third parties, Property Industry business partners, cookies and web beacons have collected in order to create a profile and/or to provide you with a personalized or improved use of our Online Platforms/our Client’s Online Platforms, our Services and the goods/services of our Clients, services providers and Property Industry business partners;
to provide your Personal Information to third parties in order for them to supply the Services to you;
to consider and respond to complaints made by you.
We may disclose additional purposes for collection of your Personal Information in collection statements at the point of collection.
HOW INFORMATION IS COLLECTED
Information is collected via a variety of sources, including via our related bodies corporate, service providers, Clients and our Property Industry business partners.
Your Personal Information is collected in association with your use and/or our provision of the Services, an enquiry about First Release and NPA Projects/our Clients/our Property Industry business partners or generally dealing with us directly or via our Online Platforms or the Online Platforms of our Clients.
WHEN PERSONAL INFORMATION IS USED & DISCLOSED
We may disclose your Personal Information to our related bodies corporate, service providers and Clients.
Subject to Clause 12 we may also disclose your personal information to our Property Industry business partners who offer goods/services which are related or ancillary to the Services or the goods/services provided by our Clients, where you have expressed an interest in learning more about such goods/services provided by Property Industry business partners.
There are some circumstances in which we must disclose an individual’s information:where we reasonably believe that an individual may be engaged in fraudulent, deceptive or unlawful activity that a governmental authority should be made aware of;
as required by any law (including the Privacy Act); and/or
in order to sell our business (in that we may need to transfer Personal Information to a new owner).
Sensitive information is information about you that reveals your racial or ethnic origin, political opinions, religious or philosophical beliefs or affiliations, membership of a professional or trade association, membership of a trade union, details of health, disability, sexual orientation or criminal record.
It is our policy to only collect your sensitive information where it is reasonably necessary for our functions or activities and either you have consented or we are required or authorised under law to do so.
In addition to any other provision of this Policy, we may use your Personal Information in de-identified form (de-identification being a process by which a collection of data or information is altered to remove or obscure personal identifiers and Personal Information) to assist us in running our business.
We may also provide, including by way of sale, de-identified information in aggregated form, to third parties.When your Personal Information is included in de-identified, aggregated data, it is not possible to identify you or anything about you from that data.
We may use temporary (session) cookies or permanent cookies when you access our Online Platforms and/or Services.
This allows us to recognise your browser and track the web pages you have visited. You can switch off cookies by adjusting the settings on your web browser.
We, our Clients, service providers (including analytics and advertising providers) and business partners may also use web beacons and measurement software to record trends, target and record information about your visit to Online Platforms.
THE SAFETY & SECURITY OF PERSONAL INFORMATION
We may hold your Personal Information in either electronic or hard copy form.If you provide information to us electronically we retain this information in our computer systems and databases.
If you provide information to us in hard copy (paper) this information is normally retained in our files and a copy is made to our electronic files. We use industry standard security measures to safeguard and protect your information.
We may disclose your Personal Information to third parties and service providers located overseas in connection with any purpose, including to overseas cloud computing hosts.
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 are not responsible for the privacy or security practices of any third party (including third parties that we are permitted to disclose an individual’s Personal Information to in accordance with this policy or any applicable laws).
The collection and use of an individual’s information by such third parties may be subject to separate privacy and security policies.If an individual suspects any misuse or loss of, or unauthorised access to, their Personal Information, they should let us know immediately.
We are not liable for any loss, damage or claim arising out of another person’s use of the Personal Information where we were authorised to provide that person with the Personal Information.
HOW TO ACCESS AND/OR UPDATE INFORMATION
If you would like us to update or amend your Personal Information, please contact us and we will make the requested amendments.We may ask you to verify your identity to ensure that Personal Information we hold is not improperly accessed.
Third party services should have their own privacy and security policies which we encourage you to read before supplying any Personal Information to them.
We, our Clients, related bodies corporate and service providers may contact you with direct marketing communications and information about the Services or other products and services offered by us, our Clients, related bodies corporate and service providers.
We may also disclose your personal information to our business partners within the Property Industry who offer goods/services which are related or ancillary to the Services or the goods/services provided by our Clients, where you have expressed an interest in learning more about such goods/services via communications with us/our Clients.
Contact with you may occur via telephone, email, SMS, or regular mail, in accordance with your preferences as communicated from time to time.If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so.
You may opt out of receiving marketing communications at any time by responding via the channel in which you received the marketing communication, or by contacting us (see contact information below).
You can unsubscribe from emails by clicking the unsubscribe link on the footer of the email communication you have received.
COMPLAINTS AND DISPUTES
If an individual needs to contact us or has a complaint about our handling of their Personal Information, they should address their communication in writing to the details below:
Mail: Att Privacy Officer PO Box 143, Chirn Park QLD 4215
Email: Att Privacy Officer [email protected]
If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.
If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
ADDITIONS TO THIS POLICY