1. Privacy Statement
We may use your personal information within LS PROPERTIES and disclose it to our authorised representatives and service providers who act on our behalf, to fulfil the purpose for collecting your information. Our service providers may have servers located inside Australia or overseas such as in USA, Europe, Philippines and Japan, and you consent to these overseas disclosures. Without your information, we may not be able to provide you with services and you may miss out on receiving valuable information from us. We do not collect sensitive information about you unless you provide it to us voluntarily. You have a right to access your personal information that we hold and may ask us to correct this
LS PROPERTIES ACN 166 730 883 (CORPORATION LICENSE 10019305) (“LS PROPERTIES” or “we”, “our” or “us”) including its franchisee’s, agents and/or brokers respect the importance respect the importance of protecting your privacy. We comply with our obligations under the Privacy Act 1998 (Cth) (Privacy Act), including the Australian Privacy Principles (APPs) as well as the Privacy (Credit Reporting) Code 2014 (CR Code).
b) Our Functions and Activities
We collect, hold, use and disclose your personal information so that we can perform our functions and activities and provide best possible customer service. Our collection, use and disclosure of your personal information will depend on our relationship with you, the circumstances of collection and the type of products and service you request from us. We may collect, hold, use and disclose your personal information for the following purposes:
- To provide and administer our products and services, including market properties for vendors and landlords, facilitate transactions for sales and leasing, assess and originate your application for finance or mortgage insurance and manage that finance, property concierge services, verify your identity, conduct credit checks and process payments if applicable;
- To respond to your submissions and enquiries about our products and services and property listings;
- To provide customer support, including conducting, investigating and responding to enquiries, surveys, feedback, comments and complaints;
- To distribute our newsletters and other communications either alone or with the assistance of service providers on information about us, our conferences, training and events, our property listings and our related products and services;
- To plan, market, host and facilitate our conferences, training sessions and events;
- To inform and conduct marketing activities including to promote our products and services;
- To conduct research about your interests and attitudes towards our products and services to improve our products and services, marketing activities and customer experience;
- To assess the performance of our websites and improve the operation of the websites;
- To perform data analyses and generate customer insights which may include combining personal information received from reputable data sources and public sources of information;
- To manage and carry out our business and operational functions, including HR management, business decisions and assessing your suitability for appointment as a franchisee or contractor agent or broker; and
- To maintain records and comply with our legal obligations
c) Types of Personal Information We Collect And Hold.
Personal Identifiable Information
Personal information is any information about you, from which you can be identified. We may ask you for, or you may voluntarily submit, personally identifiable information when you are using the Products and Services of LS PROPERTIES. The personally identifiable information which you may provide to us could include, but is not limited to:
i) Your name
ii) Your contact information (including, without limitation, address and email address);
iii) Proof of Identity;
iv) Your IP address;
v) Payment information (such as credit card or bank details);
vi) Other personal information required to provide our services in specific cases, for example, certain information to complete police checks and property transactions;
vii) Details of your use of our products or services; and
viii) Any other personal information.
Personal information we collect about you may also include credit-related personal information. Credit-related information is information used and disclosed to assess your creditworthiness, assess your application for finance and manage that finance. The types of credit-related personal information that we collect about you may include your credit liability information, repayment history information, the type and amount of finance you are applying for, court proceedings, insolvency actions and credit worthiness.
You are not obliged to provide personal information to us. However, in many cases, if you do not provide your personal information to us, we may not be able to supply the best or relevant product or service that you have requested from us.
If it is necessary to provide specific services to you, we may collect sensitive information about you. Under the Privacy Act, “sensitive information” includes but is not limited to information or an opinion about an individual’s racial or ethnic origin, religious belief, or criminal record and also includes health information about an individual. However, we will only collect sensitive information from you if you agree to provide it to us, you authorise us to obtain it from a third party or where the collection of the information is required or authorised by or under an Australian law or a Court/Tribunal order or otherwise where the collection is not prohibited under the Privacy Act. We will only use sensitive information in accordance with the Privacy Act and for the purpose for which it is provided.
Non-Personal or Aggregate Information
When you access our Service, we may automatically collect non-personally identifiable information from you, such as IP host address, web pages viewed, browser type, operating system, referring service, search information, device type, page views, usage and browsing habits on the Service and similar data. We may also aggregate demographic information collected from our users (such as the number of users in a particular geographical location) in a manner which does not identify any one individual. We may also aggregate information collected offline in connection with the Service, obtain non-personally identifiable information from third party sources and develop aggregate information by anonymizing previously collected personally identifiable information.
It is possible at times when collecting non-personally identifiable information through automatic means that we may unintentionally collect or receive personally identifiable information that is mixed in with the non-personally identifiable information. While we will make reasonable efforts to prevent such incidental data collection, the possibility still exists. If you believe that we have inadvertently collected your personal information, please notify us at firstname.lastname@example.org.
d) Collection of Information Methods
We collect personal information in the following ways:
- when you fill in and return to us a client information form;
- when you submit personal information through our website (such as when you send us a message or fill out an online form) and/or Contact us to make an enquiry about our listed properties or our products;
- Subscribe to communications from us such as updates, publications or newsletters
- Contact us to provide feedback, comments or suggestions on our functions and activities or complete one of our surveys
- in person, for example, when you engage with our employee’s, agents brokers and other representatives;
- when you connect to a third party or connect to our services via a third party; and
- in the course of providing products and/or services to you.
- Interact or engage with us through our websites or social media platforms;
- Register, attend or present at one of our conferences, training sessions and events;
- Attend property inspections or visit our offices, including via manual sign-in and security surveillance of our offices;
- Apply for a job with us or become an employee, or become a supplier or contractor that provide a product or service to LS PROPERTIES
We may also collect information about you from third party suppliers and government database services. We may combine this information with information we already have about you to help us understand trends, attributes, behaviour and preferences. Where we receive information about you indirectly from service providers, we require that the service provider has collected and disclosed that information in accordance with the Privacy Act.
LS PROPERTIES may collect information about you from:
- Credit reporting bodies and providers, law enforcement agencies and government agencies to verify your identity or assess your credit worthiness;
- Reputable data sources and publicly available sources of information;
- Your representatives (lawyers, mortgage broker, accountants and financial advisors);
- Your nominated referee or employer when you apply to rent a property or for finance;
- Service Providers that provide marketing leads, marketing and data analysis services to us;
- Service Providers that conduct our surveys for us;
- Speaker management companies if you present at one of our conferences, training sessions or events; and
- If you are a prospective employee, your nominated referee, law enforcement agencies for police checks or intermediaries such as recruitment agents and personnel providers.
We store personal information in computer storage facilities and paper-based files. We take steps to protect your personal information against loss, unauthorised access, use modification or disclosure. Some examples of the steps we take to protect your personal information include:
- ensuring there are suitable password protection measures and access privileges in place to monitor and control access to our IT systems;
- imposing restrictions on physical access to paper files;
- requiring any third parties engaged by LS PROPERTIES to provide appropriate assurances to handle your personal information in a manner consistent with the Privacy Act; and
- taking reasonable steps to destroy or de-identify personal information after we no longer need it for our business or to comply with the law.
f) Cookies and Similar Technologies
LS PROPERTIES may use and combine this information to maintain, secure and improve our websites, enhance your experience when using our websites, display and deliver relevant content, services and advertising and understand the effectiveness of our marketing and advertising (including direct marketing and online ads on external websites).
If you want to prevent cookies being used, you can change your browser settings to disable cookies. However, this might mean that your access to parts of our website is limited, or you may experience reduced functionality when accessing certain website functions.
g) Analytics and Anonymisation
We use Analytics providers (web analytics services) to help us analyse how users use our site and our products. Although the Analytics providers record data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you with us.
The information generated by the cookie about your use of the website and products will be transmitted to and stored by the Analytics provider on servers in your country of residence. The Analytics provider will use the information on behalf of LS PROPERTIES for the purpose of evaluating your use of the website and products, compiling reports on activity for us and providing us with other services relating to activity and internet usage. The IP address that your browser conveys within the scope of the Analytics provider, will not be associated with any other data held by the Analytics provider. You may refuse the use of these cookies via the settings in your browser as explained above.
h) Automatically Collected Information
When you access the Service or open one of our HTML emails, we may automatically record certain information from your system by using cookies and other types of tracking technologies. This “automatically collected” information may include Internet Protocol address (“IP Address”), a unique user ID, device type, device identifiers, browser types and language, referring and exit pages, platform type, version of software installed, system type, the content and pages that you access on the Service, the number of clicks, the amount of time spent on pages, the dates and times that you visit the Service, and other similar information. Depending on the law of your country of residence, your IP address may legally be considered personally identifiable information. In Australia you are protected by IP legislation and intellectual property laws.
i) The purposes for which we collect, hold, use and disclose personal information
LS PROPERTIES may disclose your personal information and credit-related information within LS PROPERTIES including to our officers, employees, agents, brokers and contractors.
We may disclose your personal information and credit-related information as part of our functions and activities, including:
- To the other parties in any real estate transaction including developers, vendors, landlords, purchasers and tenants, and their authorised representative;
- To guarantors, other mortgage intermediaries, lenders, financial institutions, insurers, valuers and credit reporting bodies and providers;
- To your authorised representatives (lawyers, mortgage brokers, accountants and financial advisors);
- To regulatory bodies, government agencies and law enforcement bodies in any jurisdiction;
- To the relevant government agency for verification of attendance at conferences and training sessions for continuing professional development requirements;
- To debt collectors and utility companies;
- If you are an employee or contractor to LS PROPERTIES sales consultants when on secondment or to hotels, airlines and other providers when you travel;
- If you are a shareholder, our share register is available for inspection by the public as required under the Corporations Act 2001 (Cth). The information collected in connection with your shareholding may also be disclosed to regulatory bodies such as the Australian Taxation Office;
- To our suppliers and service providers that provide products and services to assist us to perform our functions and activities such as marketing, events, recruitment, HR and share registry management; and
- When we may be required by law from time to time.
LS PROPERTIES collects information from various on-line platforms and services, such as Facebook and Google. Users of these platforms and services may elect to send information to LS PROPERTIES from the platform. LS PROPERTIES uses this information strictly in accordance with the terms imposed by that platform; this Policy; and the purposes for which the information was collected.
Some of the service providers we disclose your personal information to may have servers located overseas in various countries.
j) Direct Marketing
We also collect, hold, use and disclose your personal information to:
- send direct marketing communications you about the details of new services and products offered by us our property listings and other material that we consider you would find interesting or useful;
- notify you of the details of meetings, events and seminars that may be of interest to LS PROPERTIES customers and clients;
- send you our newsletters and other marketing publications;
- administer our databases for client service, marketing and financial accounting purposes; and
- to comply with our legal requirements regarding the collection and retention of information concerning the products and services that we provide.
If you do not wish to disclose your personal information for the purpose of direct marketing or you would like to opt-out of receiving direct marketing communications, you can do so by contacting LS PROPERTIES or by following the instructions to unsubscribe which are contained in a communication that you receive from us.
If you choose to opt out of all direct marketing communications, please note that LS PROPERTIES may still contact you for other reasonable purposes, including information that LS PROPERTIES is legally required to send, notifications of changes to LS PROPERTIES products and services or policies and information regarding the use, rights, benefits or obligations of customers of our products and services.
k) Access and Correction to Personal Information
You have a right to request access to your personal information which we hold about you and to request its correction. You can make such a request by contacting LS PROPERTIES using the contact details set out in this policy.
We will respond to any such request for access as soon as reasonably practicable. Where access is to be given, we will provide you with a copy or details of your personal information in the manner requested by you where it is reasonable and practicable to do so.
We will not charge you a fee for making a request to access your personal information. However, we may charge you a reasonable fee for giving you access to your personal information.
In some cases, we may refuse to give you access to the information you have requested or only give you access to certain information. If we do this, we will provide you with a written statement setting out our reasons for refusal, except where it would be unreasonable to do so.
We will acknowledge and investigate any complaint about the way we manage personal information as soon as practicable. We will take reasonable steps to remedy any failure to comply with our privacy obligations. If you are unhappy with our handling of the complaint, you may contact the Office of the Australian Information Commissioner at https://www.oaic.gov.au/.
m) Governing Law
Last update: 24 June 2020