Privacy Policy


Frank Paull Real Estate Pty Ltd Trading As Speechley Property

Privacy Policy

1.   Introduction & Purpose of this Policy
1.1  Frank Paull Real Estate Pty Ltd (ABN 61 001 478 262) T/as Speechley
       Property provides real estate services including but not limited to the sale,
       management. rental and leasing of residential, rural, commercial and industrial
       properties.
1.2  We are bound by the Privacy Act and the Australian Privacy Principles (APP)
       which regulate the collection, use and disclosure of personal information. This
       Privacy Policy explains;
  • The scope of our Privacy Policy; 
  • Why we collect personal information;
  • What personal information we collect;
  • How we collect and use your personal information;
  • How we disclose your personal information;
  • Your right to access your personal information;
  • Your right to correct your personal information;
  • How we protect the integrity of your personal information;
  • Your right to make a privacy complaint; and
  • How you can contact us regarding privacy concerns
       We reserve the right to review and if necessary, change this Privacy Policy. We will post changes to this
       privacy Policy on our website.

2.    Scope
       This Privacy Policy governs all personal information collected by and provided to us and must be adhered to
       by all persons who access, use, process, control or otherwise deal with personal information on our behalf.
       This policy applies to independent contractors and job applicants, as well as individuals who provide us with
       personal information.

3.    What is personal information?
       Personal information is any information that can be used to identify you. This includes any information or an
       opinion about you (including information or an opinion forming part of a database), whether true or not, and
       no matter how the information or opinions are recorded. The information may be collected from you directly
       or provided to us by another party.

4.    Why do we collect personal information?
4.1   We collect personal information from you for the following purposes:
  •  To allow us to lawfully carry out our real estate functions and activities;
  •  To enable us to deliver the products and services that you requested;
  •  To provide you with further information about the products and services you requested;
  •  To personalise and customise your experiences with us;
  •  To help us review, manage and enhance our services;
  •  To communicate more effectively with you;
  •  For administration purposes, including charging, billing and collecting debts;
  •  To promote and market our products and services which we consider may be of interest to you;
  •  When considering making offers to job applicants and prospective employees or for employment              purposes
  •  To receive services from you or the organisation which employs you.
4.2   We may also collect, hold, use and/or disclose personal information if you consent or if required or
        authorised under law.

5.     What personal information do we collect?
5.1   We collect personal information that is reasonably necessary for one or more of its functions or activities.
 
5.2   The type of information that we collect and hold may depend on your relationship with us. For example:

5.3   Candidate: if you are a candidate seeking employment with us, we may collect and hold information
        including your
        name, address, email address, contact telephone number, gender, age, employment history, references,
        resume, medical history, emergency contact, taxation details, qualifications, payment details and other
        relevant information
5.4   Customer: if you are a customer of the Company, the Company may collect and hold information including
        your name, address, email address, contact telephone number, gender, age, bank details and any other
        relevant information necessary for us to interact with you
5.5   Supplier: if you are a supplier of the Company, the Company may collect and hold information including
        your name, address, email address, contact telephone number, business records, billing information, bank
        details form payment and information about goods and services supplied by you. We may also collect other
        relevant information necessary for us to interact with you.
5.6   Sensitive information: we will only collect sensitive information where you consent to the collection of the
        information and the information is reasonably necessary for one or more of the Company’s functions or
        activities. Sensitive information includes, but is not limited to, information or an opinion about racial or
        ethnic origin, political opinions, religious beliefs, philosophical beliefs, membership of a trade union, sexual
        preferences, criminal record, health information or genetic information.
5.7   If you feel that the personal information that we are requesting at any point is not information that you
        wish to provide, please feel free to raise this with us.

6.     Employee records
6.1   This policy does not apply to the collection, holding, use or disclosure of personal information that is an
        employee  record.
6.2   An employee record is a record of personal information relating to the employment of an employee.
        Examples of personal information relating to the employment of the employee include, but are not limited
        to, health information and information about the engagement, training, disciplining, resignation,
        termination, terms and conditions of employment of the employee.

7.     How do we collect and hold personal information
7.1   We must collect personal information only by lawful and fair means. We will collect personal information
        directly from you if it is reasonable or practicable to do so.
7.2   We may collect personal information in a number of ways, including without limitation:
  •  through application forms;
  •  by email or other written mechanisms;
  •  over a telephone call;
  •  in person;
  •  through transactions;
  •  business cards;
  •  contracts;
  •  through our website;
  •  through surveillance cameras;
  •  by technology that is used to support communications between us;
  • from third parties, including through publically available information sources (which may include telephone  directories, the internet and social media sites).
7.3   When we collect personal information about you through publicly available information sources, such
        information will be managed in accordance with the APPs.
7.4   Unsolicited personal information is personal information that we receive which we did not solicit. Unless we
        determine that we could have collected the personal information in line with the APPs or the information is
        contained within a Commonwealth record, we must destroy the information to ensure it is de-identified.

8.     How do we use your personal information?
8.1   We will only use and disclose your personal information for purposes which are related to those identified
        under paragraph 4 of this policy or if we get your consent to do so and it is in accordance with  this Privacy
        Policy and the Privacy Act.
8.2   We will not use your personal information for any purpose for which you would not reasonably expect us to
        use it for. Additionally, we will not disclose your sensitive information without your consent, unless there is a
        need to disclose such information in accordance with the Privacy Act or to comply with any other regulatory
        requirement.

9.     Is personal information used for direct marketing?
9.1   We may use or disclose personal information (other than sensitive information) about you for the purpose
        of  direct marketing (for example, advising you of new goods and/or services being offered by us).
9.2   We may use or disclose sensitive information about you for the purpose of direct marketing if you have
        consented to the use or disclosure of the information for that purpose.
9.3   You can opt out of receiving direct marketing communications from the Company by contacting the Privacy
        Officer in writing (see contact details in Para 17 below) or, where available, accessing the Company’s
        website and unsubscribing appropriately.

10.   What happens if you do not provide your personal information?
10.1  You are not obliged to give us your personal information. If you would like to access any of our services on
         an anonymous basis or using a pseudonym, we will take reasonable steps to comply with your request.
         However, we will require you to identify yourself if:
  • We are required by law to deal with individuals who have identified themselves; or
  • It is impracticable for us to deal with you if you not identify yourself or elect to use a pseudonym. This might include ensuring the safety of others for whom we have responsibility.
10.2  Please be aware that your request to be anonymous or to use a pseudonym may affect our ability to
         provide you with the requested services. For example, your ability to bid for a property at auction.
 
11.    When do we disclose your personal information?
11.1   You acknowledge and agree that we may disclose your personal information for any of the purposes for
          which it was collected, as indicated under paragraph 4 of this policy, or where it is under a legal duty to do
          so.
11.2   Disclosure will usually be internally and to related entities or to third parties such as contracted service
          suppliers.
11.3   Before we disclose personal information about you to a third party, we will take steps as are reasonable
          in the circumstances to ensure that the third party does not breach the APPs in relation to the information.
        
12.    Do we send information overseas?
12.1   We are likely to disclose personal information to overseas recipients.
12.2   Before we disclose personal information about you to an overseas recipient, we will take steps as are
          reasonable in the circumstances to ensure that the overseas recipient does not breach the APPs in
          relation to the information.
12.3   Overseas recipients may include , but not limited to, our landlords, your previous landlords or agents or
          other persons, companies or organisations who/which may require information you have provided or we
          have legally collected for purposes of which you are aware.

13.     Access to your personal information
13.1    If we hold personal information about you, you may request access to that information by putting the
           request in writing and sending it to the Privacy Officer. We will respond to any request within a
           reasonable period, and a charge may apply for giving access to the personal information.
13.2    There are certain circumstances in which we may refuse to grant you access to the personal information.
           In such situations we will give you written notice that sets out:
  •   the reasons for the refusal; and
  •  the mechanisms available to you to make a complaint.  
14.     Correction of your personal information
14.1   If we hold personal information that is inaccurate, out-of-date, incomplete, irrelevant or misleading, we
          must take steps as are reasonable to correct the information.
14.2   If we hold personal information and you make a request in writing addressed to the Privacy Officer to
          correct the information, we must take steps as are reasonable to correct the information and we will
          respond to any request within a reasonable period.
14.3   There are certain circumstances in which we may refuse to correct the personal information. In such
          situations we will give you written notice that sets out:

            • the reasons for the refusal; and
            • the mechanisms available to you to make a complaint.

14.4    If we correct personal information that it has previously supplied to a third party and you request us to
           notify the third party of the correction, we will take such steps as are reasonable to give that notificatio
           unless impracticable or unlawful to do so.

15.     Integrity and security of your personal information
15.1    We will take such steps (if any) as are reasonable in the circumstances to ensure that the personal
           information that we:
            • collect is accurate, up-to-date and complete; and
            • uses or discloses is, having regard to the purpose of the use or disclosure, accurate, up-to-date and
           complete.
15.2    We will take steps as are reasonable in the circumstances to protect the personal information from
           misuse, interference, loss and from unauthorised access, modification or disclosure.
15.3    If we hold personal information, it no longer needs the information for any purpose for which the
           information may be used or disclosed, the information is not contained in any Commonwealth record and
           we are not required by law to retain the information, it will take such steps as are reasonable in the
           circumstances to destroy the information or to ensure it is de-identified.

16.     Complaints
16.1    You have a right to complain about our handling of your personal information if you believe we have
           breached the APPs.
16.2    If you wish to make such a complaint to us, you should first review our Complaints Handling Policy which
           may be found on our website under About Us/Complaints and then contact the Privacy Officer in writing.
           Your complaint will be dealt with in accordance with our complaints procedure and we will provide a
           response within a reasonable period.
16.3    If you are unhappy with our response to your complaint, you may refer your complaint to the Office of the
           Australian Information Commissioner.

17.      Privacy Officer contact details:
           Our Privacy Officer can be contacted in the following ways:
           a) Telephone number: 02 45 77 4699
           b) Email address: info@speechley.com.au
           c) Postal address: PO Box 5722, South Windsor, 2756

18.     Interpretation
           Personal pronouns: except where the context otherwise provides or requires:
              • The terms we, us or our refers to Frank Paull Real Estate Pty Ltd, Frank Paull Real Estate Pty Ltd T/As
                 Speechley Property and/or Speechley Property.
              • The terms you or your refers to any person who provides us with personal information in any form or
                 by any means.