Savills (Aust) Pty Ltd ACN 056 426 834 and its related bodies corporate (we, our, us) recognise the importance of protecting the privacy and the rights of individuals in relation to their personal information.
This document is our Privacy Policy, and it tells you how we collect, use, store, disclose and manage your personal information. We respect personal data privacy and are committed to implement and comply with the data protection principles and provisions under the Privacy Act 1988 (Cth) (Act). We comply with all of the Act’s requirements in respect of the collection, management and disclosure of your personal information.
What is your personal information?
When used in this Privacy Policy, the term “personal information” has the meaning given to it in the Act.
"Personal information" is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual or an individual who is reasonably identifiable.
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.
Personal information may include sensitive information, and the term “sensitive information” has the meaning given to it in the Act. "Sensitive information" is personal information which is about your racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information and biometric information or templates.
What personal information do we collect and hold?
We may collect and hold the following types of personal information about you:
- identity information, for example, legal names, profession, job title, employer name, organisation, gender, age and date of birth contact information, for example, phone number, facsimile number, mailing or street address and email address.
- payment and transaction information including billing address details about payments to and from you and other details of products or services you have purchased from us, bank account details.
- details of the products and services you have purchased or enquired about from us or our clients, together with any additional information necessary to deliver those products and services and to respond to your enquiries and
- Employment-related records which include data on job applications, personal particulars, education and qualifications, employment history, salary and allowances, participation in Mandatory Provident Fund, terms and conditions of service, housing and medical benefits, leave records, training and development, appraisal reports, conduct and discipline, etc.
- General administrative records which include personal data collected in connection with the office administration functions, records containing information supplied by data subjects and collected in connection with the handling of enquiries and complaints made to Savills, etc.
- Customers records which include personal data collected in the course of handling customers’ membership applications, transactions, complaints and enquiries, etc and
- Other records which include administrative and programme records containing personal data.
We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.
How do we collect your personal information?
We collect your personal information in various ways, including directly from you, unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect it in ways including:
- through your access and use of our website
- when you contact us or correspond with us by telephone or post
- during conversations between you and our representatives
- through you giving us your business card
- when you become our customer
- when you enter into agreements that we are privy to
- when you submit payments to us; and
- when you request marketing materials to be sent to you, or if you respond to any marketing materials.
We may also collect personal information from third parties including from third party companies such as credit reporting agencies, law enforcement agencies and other government entities.
We may also collect personal information automatically when you interact with our website, communications or online advertisements using cookies and tracking technology.
Cookies
In some cases we may collect your personal information through the use of cookies. When you access one of our websites, 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 enables us to keep track of products or services you view so that, if you consent, we can send you news about those products or services. We may also use cookies to measure traffic patterns, to determine which areas of our websites 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 services.
As we may collect your personal information through the use of cookies, if you do not wish to receive cookies, then 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.
For what purposes do we collect, hold, use and disclose your personal information?
We collect personal information about you so that we can perform our business activities and functions and to provide the best possible quality of customer service.
We collect, hold, use and disclose your personal information for the following purposes:
- to provide products and services to you
- to send communications requested by you
- to update our records and keep your contact details up to date
- to answer enquiries and provide information or advice about existing and new products or services that we or our clients are offering
- to provide you with access to protected areas of our website
- to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties
- to comply with our statutory and regulatory reporting obligations
- to complete internal and/or external audits within our group
- to comply with our legal obligations and other compliance requirements
- to process and respond to any complaint made by you
- 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)
- for our administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes
- to provide your updated personal information to our related bodies corporate, contractors or service providers
- to process and respond to job applications; and
- for any other purpose notified to you at the time your personal information is collected, or for any other purpose that you have consented to.
If we wish to use your personal information in a manner other than as described in this Privacy Policy, we will not do so unless we have obtained your consent.
What happens if you don’t provide us with your personal information?
If you do not provide us 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; and/or
- we may not be able to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.
To whom may we disclose your information?
We may disclose your personal information to:
- our employees, related bodies corporate, clients, contractors or service providers for the purposes of marketing initiatives, operating our business, fulfilling requests by you, and to otherwise provide products and services to you
- clients, suppliers and other third parties with whom we have commercial relationships with, for example, for business, marketing, and related purposes
- professional advisers including lawyers, accountants, auditors and other advisers including financial institutions who may provide consultancy, legal or accounting services
- third parties who assist with improving and managing our business, including third party service providers such as payment system operators, IT suppliers, identity and fraud protection services, marketing (including direct marketing) and market research services, identifying and serving targeted advertisements services, mailing services, analytic services, or web hosting services
- courts, law enforcement, regulators and other government agencies so we may respond to their reasonable requests for information or comply with all applicable laws, regulations, rules and our legal obligations
- any other entities notified to you at the time of collection and
- any organisation for any authorised purpose with your express consent
We may disclose your personal information to our related companies and/or third party service providers based around the world who may use, hold or access your information from a place outside your place of residence, including in New Zealand.
We may combine or share any information that we collect from you with information collected by any of our related bodies corporate.
Direct marketing materials
We may send you direct marketing communications and information about our or our client’s products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, 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.
You may, at any time, opt-out of receiving marketing communications from us by contacting us (see the details below) or by using the opt-out facilities provided in the marketing communications.
We do not provide your personal information to other organisations for the purposes of direct marketing.
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).
There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
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 note that you disagree with our decision and keep a record of this.
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.
If you make a complaint, we will respond within 48 hours to let you know who is responsible for managing your complaint. We will use our best endeavours to try and resolve your complaint within 10 working days. If this is not possible, we will contact you within that time to let you know how long we think it will take.
We will investigate your complaint and where necessary, consult with third parties about your complaint. Once the matter has been fully investigated, we will write to you outlining our findings and the reasons why we have made them.
If you are still unsatisfied with our response then please contact us using the contact information below and we will explain to you how you can make a complaint to the Office of the Australian Information Commissioner.
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 New Zealand, China, Hong Kong, Japan, Malaysia, Taiwan, Philippines, South Korea, Vietnam, Thailand, India, Singapore and the United Kingdom
- our data hosting and other IT service providers, located in the United States
Security
We take reasonable steps to ensure your personal information is protected from misuse, and loss and from unauthorised access, modification or disclosure.
We may hold your information in either electronic or hard copy form. Personal information is destroyed or de-identified when no longer needed.
Retention of personal information
We retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements (which usually require data to be kept for at least 7 years).
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. We recommend that you review the privacy policies of any third parties to understand how these parties may collect and use your personal information.
Contacting us
If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please contact our General Counsel 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.
Our General Counsel’s contact details are as follows:
General Counsel
Savills
Post: Level 25, Governor Phillip Tower 1 Farrer Place, Sydney NSW 2000
Phone: +61 (0) 2 8215 8888
Email: [email protected]
Changes to our privacy policy
We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website.