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PPD PRIVACY POLICY

Who this policy covers

This policy explains how PPD Real Estate and PPD Property Management collect, hold, use and disclose personal information when you use our website or deal with our real estate teams. It covers enquiries, appraisals, listings, inspections, auctions, sales, rental applications, tenancy management and associated communications.

The businesses covered are PPD Real Estate, operated by Phillips Pantzer Donnelley Partnership, ABN 75 780 367 883, and PPD Property Management, ABN 72 465 434 588. In this policy, “we”, “us” and “our” refer to the business providing the relevant service. Your agency agreement, application or transaction documents identify the business you are dealing with.

We handle personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and other applicable laws. Short collection notices explain particular activities and should be read with this policy. This policy does not replace a separate privacy policy issued by an independent finance provider or other third party.

Personal information we collect

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable. Depending on your dealings with us, we may collect contact details, addresses, property preferences, communications, inspection attendance and marketing choices.

For clients and transactions, relevant information may include identity and authority documents, property ownership, agency agreements, offers, auction registration, contracts, payment and trust account details, and records required by law. For rental applicants and tenancies, it may include permitted identity, income, employment, rental history and referee information, rent and bond records, maintenance requests and tenancy communications.

We collect only information reasonably necessary for our functions or activities or otherwise permitted or required by law. We do not require sensitive information for routine property enquiries. Where necessary, we generally collect sensitive information with your consent unless an exception applies. Please avoid sending health information, full identity documents or financial records unless we have requested them through an appropriate channel.

How we collect and use information

Collection from you and other sources

We usually collect information directly from you through enquiries, forms, inspections, meetings, telephone calls, email, our website, property portals, agency agreements and transaction or tenancy documents. We may also receive information from your authorised representative, other parties to a transaction, previous agents, referees, employers, public property registers, valuers, insurers and service providers where lawful and reasonably necessary.

We take reasonable steps to notify you about relevant collection circumstances, purposes, usual disclosures and your privacy choices at or before collection, or as soon as practicable afterwards. If you give us someone else’s details, tell them why you are doing so, direct them to this policy and obtain any consent or authority needed. We do not treat your disclosure as automatic consent from that person.

Sales and agency services

We use relevant information to respond to enquiries, provide appraisals, verify ownership and authority, prepare agency agreements, advertise properties, arrange inspections, record interest, communicate offers, register bidders, conduct auctions and assist with sales and settlement. We also use it to protect clients, occupiers and property, manage payments and trust accounts, and comply with recordkeeping and other legal obligations.

Property management and rentals

We use permitted information to register inspections, assess and communicate about rental applications, verify relevant details, prepare leases, administer rent and bonds, arrange repairs and inspections, communicate with landlords and tenants, manage disputes and comply with tenancy and agency requirements. Rental application and tenancy information is collected, disclosed and retained subject to applicable NSW restrictions. A tenancy database check, if used, is subject to the notices and safeguards required by law.

Required transaction checks

Where our services are covered by anti-money laundering and counter-terrorism financing laws, we collect and verify information about relevant customers, their representatives and beneficial owners. This may include identity, ownership and control, the purpose of a transaction, and source of funds or wealth where required. We may use verification providers, retain required records and make legally required reports. These obligations do not mean every inspection attendee must supply transaction-level identity documents.

Other business purposes

We use information to maintain accurate records, deliver customer support, administer our business, resolve complaints, improve services and comply with lawful requests. A new use or disclosure must be permitted by law; publishing this policy does not by itself authorise unrelated uses.

Sharing and marketing

Who receives personal information

We disclose information only where relevant to the service, reasonably expected and permitted by law, with your consent, or where otherwise authorised or required. Recipients may include vendors, purchasers, landlords, tenants, their authorised representatives, co-listing or conjunction agents, buyers’ agents, auctioneers, solicitors, conveyancers, valuers, insurers, financial institutions and settlement providers.

For property management, relevant recipients may include rental application referees and employers, tradespeople and maintenance contractors, bond authorities, tenancy database operators where lawful, debt recovery providers and dispute resolution bodies. We limit information given to a recipient to what is appropriate for the purpose.

We use providers for property and customer management, inspections, applications, identity verification, website hosting, electronic communications, document signing, payment administration and IT support. These providers may handle information on our behalf. Regulators, courts and law enforcement bodies may also receive information where the law permits or requires it, including AUSTRAC for covered transactions.

Information may be shared between the two businesses identified in this policy where this is necessary for a service, reasonably expected and lawful, or agreed by you. Common branding does not give unrestricted permission to share information. A proposed business sale or restructure may involve limited disclosure to a purchaser and professional advisers under appropriate confidentiality and legal safeguards.

Property updates and direct marketing

We may send relevant property alerts, market updates or service information where permitted by privacy, spam and telemarketing laws. Marketing emails and SMS require consent, which may be express or inferred where the law allows. Attendance at an inspection or acceptance of this policy is not, by itself, consent to unrelated marketing.

You can unsubscribe using the mechanism in a message or contact the Privacy Officer. Opting out is free. We honour unsubscribe requests within the applicable legal timeframe and maintain the information needed to respect your choice. Necessary service or transaction messages may still be sent. You can also ask us to stop disclosing your information to facilitate another organisation’s marketing and, where applicable, ask where we obtained your information.

Website and technology

Website information and cookies

Our website may collect technical information such as browser and device details, IP address, referring pages, visit times and pages accessed. We use website logs and cookies for website functions, remembering settings, security and understanding website use. Information submitted in a form or email is handled under this policy.

You can manage cookies through your browser settings. Disabling them may affect some website functions. Links to external websites and property portals lead to services with their own privacy policies.
Website analytics and advertising

We may use website analytics and advertising technologies, including cookies, pixels and similar tracking tools to understand how visitors use our website, measure the effectiveness of our advertising and improve our marketing. These technologies may collect information such as IP address, browser and device details, pages visited, referring websites and interactions with our website. Where enabled, third-party providers may use this information in accordance with their own privacy policies. You can manage cookies through your browser settings and adjust advertising preferences through the relevant third-party platforms. Disabling cookies may affect some website functions.

Overseas storage access and disclosure

Some technology, cloud and support providers may store or access personal information outside Australia. Before disclosing information overseas, we take reasonable steps required by law to ensure that the recipient does not breach the Australian Privacy Principles, unless a lawful exception applies. Overseas handling does not automatically remove our obligations or your rights. We take reasonable steps required by applicable privacy laws to ensure that overseas recipients handle personal information appropriately and in accordance with applicable privacy requirements.

Computer assisted decisions

We do not currently use computer programs to make decisions, or perform decision-making steps, that are substantially and directly related to decisions that could significantly affect an individual’s rights or interests without appropriate human involvement. Our staff may use software to organise, verify or assess information when providing our services. Where a decision may significantly affect an individual, they may contact our Privacy Officer to ask questions about how their information has been used.

Security

We take reasonable technical and organisational steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. Safeguards are selected for the information and risk and may include access restrictions, staff training, secure storage and transmission, and provider controls. No system is completely risk free. Please contact us promptly if you believe information has been compromised.

Data breaches

We assess suspected data breaches and take steps to contain and address them. Where an eligible data breach requires notification under the Notifiable Data Breaches scheme, we notify the OAIC and affected individuals as required, including recommended protective steps.

Your choices and contact details

If you do not provide information

You may make general enquiries anonymously or use a pseudonym where lawful and practical. We may need to identify you to arrange access, verify property ownership, assess an application, register an auction bidder or complete a transaction. Without necessary information, we may be unable to provide the requested service. We explain any relevant requirement when collecting the information.

Retention and deletion

We retain information for as long as needed for a lawful purpose, including agency, tenancy, financial, anti-money laundering and dispute requirements. Retention periods depend on the record and applicable law. When information is no longer needed and no law or court or tribunal order requires retention, we take reasonable steps to destroy or de-identify it, including information held by providers on our behalf.

You can ask us to delete information. We assess your request against our legal obligations and any continuing lawful need to retain it, and explain our response. Withdrawing consent or unsubscribing does not necessarily require deletion of transaction or statutory records.

Access and correction

Contact the Privacy Officer to request access to, or correction of, your information. We may verify your identity and authority. We respond within a reasonable period. There is no charge to make an access request or request a correction; a reasonable, non-excessive charge may apply to providing access, which we explain beforehand. If access or correction is refused, we give reasons where required and explain how to complain.

You may ask us to associate a statement with disputed information where applicable.

Complaints

Tell the Privacy Officer what happened and the outcome you are seeking. We will acknowledge the complaint, investigate and aim to respond within 30 days. If more time is needed, we explain why and keep you informed. If you are dissatisfied with our response or have not received one within 30 days, you can complain to the Office of the Australian Information Commissioner at www.oaic.gov.au/privacy/privacy-complaints or on 1300 363 992. Other complaint avenues may apply to particular services or health information.

Privacy Officer

PPD Real Estate and PPD Property Management
156 Edgecliff Road, Woollahra NSW 2025
Telephone 02 8355 1111
Email office@ppdre.com.au

Updates and copies

We review this policy when our services, systems or obligations change. The current version and effective date are published at www.ppdre.com.au/privacy-policy/. You can request a free copy from the Privacy Officer, including assistance accessing the policy. A revised policy does not itself supply consent where consent is required.