Privacy

Hatt Pty Ltd, Mararch Dev Richmond Pty Ltd, Redbank Unit Trust and Wengor Dev Richmond Pty Ltd have formed Redbank Communities to conduct the business of developing, marketing and selling properties in the Redbank North Richmond development (our activities). A reference in this privacy policy to 'we', 'us or 'our' is a reference to each of us individually and all of us together.

We aim to protect the privacy of the personal information that we collect and hold whilst carrying out our activities. Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

We are bound by the Privacy Act 1988 (Cth) (Act). This policy has been developed to comply with our obligations under that legislation and our compliance with the Australian Privacy Principles (APPs) contained in the Act.

This policy applies to personal information collected by us, our staff and agents from and about any individual making enquiries about any property, our customers, our staff, our suppliers and any other individual whose personal information we may collect from time to time.

This policy explains:

• what types of personal information we might collect;
• how we collect personal information;
• how we use personal information;
• when we will disclose personal information to others;
• how we manage and secure personal information;
• how you can access and seek to correct personal information that we hold about you; and
• how you may make a complaint if you think that we have breached the APPs.

From time to time, we may review and update this policy – for example, to reflect changes to the law, technology, our activities or company. You should check this policy, which is available on our website at http://www.redbankrichmond.com.au to read about any changes, modifications, or revisions to this policy.

All personal information held by us will be governed by our most recent privacy policy. If you are unsure whether you are reading the most current version of our privacy policy, please contact us by using the contact details at the end of this policy.

What types of personal information do we collect?

We collect 'personal information' (as defined under the Act) that is reasonably necessary for our activities. The types of personal information that we collect will depend on the nature of the interaction between you and us, and where and how we collect the information.

The personal information we collect includes:

• information about individuals that express an interest in any of our properties, including names, addresses, email addresses, telephone and fax numbers and other contact details and also information about their use of our services;
• information about any individual that purchases or rents any property and any related guarantors, including information about their financial position and credit-worthiness;
• information about job applicants, staff members, volunteers and contractors;
• details about any person that enters into any of our buildings or properties; and
• details of other individuals who come into contact with us such as real estate agents or suppliers.

The Act imposes restrictions on us collecting 'sensitive information' (as defined under the Act). This can include information about your racial or ethnic origin, religious beliefs or affiliation, or health. We will only collect sensitive information from you if you consent to that collection and it is reasonably necessary for our activities, or if the collection is required by law or a court or tribunal order. We will only share personal information, including sensitive information, in limited circumstances. We do not generally collect sensitive information, but may do so if it is necessary to allow us to deal with you and provided you give us your consent to do so.

How do we collect your personal information?

We usually collect personal information directly from you. This can be when you make an enquiry through our website, visit our display centres or sales offices, send us correspondence by e-mail or in writing, deal with us over the telephone or in person, or otherwise contact us.

Sometimes, someone else may give us personal information about you, with or without your direct involvement. For example, we might get your personal information from:

• a representative, such as a buyer's agent; or
• publicly available sources of information (such as telephone directories).

How do we use the personal information we collect?

We collect personal information from you to allow us to conduct our business. We may use the personal information we collect from you to:

• respond to your queries and provide you with information about any property that we sell or rent;
• negotiate and enter into agreements with you for the sale or rental of any of our properties;
• assess your credit worthiness;
• communicate with you;
• provide you with information about our other products or services that we consider would interest you (which you can tell us not to do at any time);
• help us run our business, for example to improve our products or services or for our security, to train staff or to undertake marketing activities; and
• comply with our legal obligations.

If we collect your personal information for any other purpose, we will generally let you know that purpose at the time we collect the information.

Information of job applicants, staff members and contractors

We collect personal information from job applicants, staff members and contractors for the primary purpose of assessing and (if successful) engaging the applicant, staff member or contractor, as the case may be.

We use the personal information collected from job applicants, staff members and contractors:

• to recruit staff and contractors;
• to manage an individual's employment or engagement;
• for insurance purposes;
• to ensure that we hold relevant contact information; and
• to satisfy our legal obligations.

When will we disclose your personal information to others?

We will only disclose your personal information for the primary purpose for which it was collected. This means that we will usually only disclose personal information in connection with our business and administrative functions. This could be when disclosure is necessary to provide you with a product or service that you have requested, to help us with the running of our organisation, or for security reasons.

Sometimes we may also disclose your personal information outside our joint venture for the purpose for which the information was collected, or for a related purpose – for example when disclosure is necessary to assess your creditworthiness for rental of any of our properties, to complete a sale transaction with you or on your behalf, to provide you with a product, service or to undertake an activity that you have requested we perform, to help us with the running of our organisation or for security reasons.

We may provide your personal information to:

• our related parties, associates and affiliates who assist us in carrying out our activities;
• outsourced service providers who perform functions on our behalf, such as organisations providing security services, conducting market research, providing email and mail handling services;
• service providers that manage our information technology systems, some of whom are located in the United States of America;
• our authorised agents and representatives who sell products or provide services on our behalf;
• anyone authorised by you to receive your personal information (your consent may be express or implied and can be withdrawn at any time);
• an actual or prospective purchaser in the event we sell part of our business; and
• anyone to whom we are required by law to disclose personal information.

We generally require third parties to only use your personal information for the specific purpose for which it was given to us and to protect the privacy of your personal information. We will only disclose your personal information to third parties on the basis that such parties agree with us to keep your information confidential.

Consent

You consent to our disclosure of your personal information to the third parties listed above for all the purposes listed above, and to similar organisations. You can ask not to receive communications from us at any time by contacting us by using the contact details at the end of this policy.

If you do not permit the disclosure of some personal information as we request, we then may not be able to meet our legal obligations and may not be able to do business with you. If this is the case, we will let you know.

Sending information overseas

There may be circumstances in which we will disclose personal information that we hold about you to a third party overseas. This may occur, for example, where we have a database or server hosted outside Australia or where you are interacting with an application which is based overseas.

Before we disclose your personal information to an overseas recipient, we have an obligation to take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to your personal information.

Our current service providers have databases and servers located in the United States of America and the personal information we collected from you will be sent overseas to the United States of America and stored on and accessed from these databases and servers.

Our website

When you visit the public pages of our website, our website server makes a record of your visit and logs the following information;

• your IP ('Internet Protocol') address (which, in general terms, is a unique identifier assigned to your computer when it is connected to the Internet);
• search terms used;
• the operating system and Internet browser software you are currently using; and
• the data that you download (such as web pages or other document files or software), and the time that you download it.

This information cannot be used to identify you and is only used for statistical purposes to help us identify what parts of our website our users visit the most, which in turn assists us to determine how to improve our services.

If you contact us through our website or email us, we will only use your personal information to respond to your request or answer your queries. We will not add your email address to our mailing list without your consent.

We uses 'cookies' in the secure section of our website, which are a mechanism to keep track of certain information between visits to the site by the same user. Our website uses cookies to make the browsing experience more responsive when accessing some services on the website. This information is not linked to any personal information and cannot be used to identify the user. This means that our obligations in relation to personal information do not apply to the information that wet collect via cookies.

You can adjust your web browser's settings to detect or disable cookies if you prefer.

Other websites

To the extent that our website contains links to sites operated by third parties, including other organisations, those linked websites are not controlled by us and we are not responsible for the privacy practices of the site operators. Before you disclose your personal information to any linked websites, we advise you to examine their privacy policies and terms and conditions of use.

How we manage and secure personal information

We require our staff to respect the confidentiality of all personal information and the privacy of individuals, and we have directed our staff that personal information must be dealt with in accordance with this policy.

We have security systems in place which are intended to protect your personal information from misuse, loss, unauthorised access, modification or disclosure by the use of various methods including locked storage of paper records and passworded access rights to computerised records.

If we receive personal information about you which we did not request and which we do not reasonably require, we may destroy or de-identify this information where appropriate.

If you reasonably believe that there has been an unauthorised use or disclosure of your personal information, please let us know by contacting us using the details at the end of this policy.

Updating personal information that we hold about you

We aim to have all personal information that we hold to be accurate, complete and up-to-date. We encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact us using the details at the end of this policy.

We are required by law to keep some types of information for certain periods of time. If we no longer require your personal information, we will generally destroy or de-identify that information. We may retain information for a period longer than that for which it is required to retain the information if we consider that it is necessary, and as long as it is in accordance with the APPs.

How you can access personal information that we hold about you

Under the Act, an individual generally has the right to obtain access to any personal information that we hold about them and to advise us of any perceived inaccuracy in that information. There are some exceptions to this right.

In some circumstances, the Act entitles us to deny access, for example if providing access would impact unreasonably on the privacy of others or prejudice negotiations in which we are involved. If we do refuse access, we will generally let you know the reasons for our refusal, except where it is unreasonable to do so.

If you make a request for access to your personal information, we may ask you to verify your identity and specify what information you require. We may charge a fee to cover our costs of locating, retrieving, reviewing and copying any material requested. If the information sought is extensive, we will generally advise the likely cost in advance.

To make a request to access any information that we hold about you, please contact us using the details at the end of this policy.

Requests, questions or complaints

If you have any requests, questions or would like to make a complaint about our compliance with the Act, please contact The Privacy Officer, Redbank Communities, PO Box 1918 Penrith NSW 2750, Ph: (02) 4760 1400, email: privacy@redbankcommunities.com.au.

If your personal information has not been handled in an appropriate way, we will do our best to remedy your concerns quickly, including by acknowledging receipt of your complaint in a timely manner and trying to resolve the complaint within a reasonable period. If this is not possible, we will contact you to let you know an anticipated time frame for dealing with your complaint.

If your complaint is not satisfactorily resolved, you may approach an external dispute resolution service or apply to the Office of the Australian Information Commissioner (OAIC) who may investigate your complaint further.