About this policy:
Our commitment to protecting your privacy:
We are committed to protecting your personal information, and ensuring its privacy, accuracy and security. We handle your personal information in a responsible manner in accordance with the Privacy Act 1988 (Act) and the Australian Privacy Principles (APPs).
'Personal information' means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether true or not, and whether or not recorded in a material form.
'Sensitive information' (a type of personal information), means information or an opinion about an individual’s race or ethnic origins, political opinions and associations, religious beliefs or affiliations, philosophical beliefs, sexual preferences or practices, trade or professional associations and memberships, union membership, criminal record, health or genetic information or biometric information.
Whose personal and other information do we collect?
We may collect your personal and other information from a range of sources, including from you, recruitment agencies, contractors, business partners and government agencies. For example, we may collect your personal and other information when you request or acquire a product or service from us, provide a service or product to us, apply for employment with us or communicate with us via our website, by e-mail, telephone or in writing.
What types of personal and other information do we collect and hold?
Allhomes collects personal and other information including:
- information about the sale, lease, and share of residential properties, and the sale and lease of commercial properties;
- names, addresses, e-mail addresses, phone numbers, payment details, occupation and other information to assist us in conducting our business, providing and marketing our products and services;
- information about staff and directors, as required in the normal course of human resource management and the operation of a business; and
- information about current and previous allhomes suppliers and clients with whom allhomes has dealings.
In particular, allhomes collects the following types of personal and other information from the following sources:
From listing agents: For the purpose of displaying listings for sale, lease, or share, allhomes collects the street address and listing price for the property, and a description, and commentary regarding the features, of the property. Allhomes also collects the listing agent’s name, telephone number, address, picture, and agency and email address. Allhomes also collects information concerning the property such as the asking price, property type, floor area, block size, unimproved land value, number and type of rooms, floors, car parking, and energy efficiency.
Allhomes collects information about the transfer of properties agents list. After a transfer, listing agents provide to allhomes information including the addresses of properties, sale dates, proposed settlement date, and sale prices, or in the case of a lease the address of a leased property and the amount payable. Agents may provide information relating to commission.
If listing agents or agencies wish to open accounts with allhomes, allhomes collects the agency name, contact details, the names of the real estate agent licence holder and principal, a street address, an email address, and a website address.
From State and Territory Governments: Allhomes has licence agreements with the Australian Capital Territory and the states of New South Wales and Tasmania under which allhomes is provided information.
- ACT: allhomes collects data regarding transferred properties, including division names, block and section numbers, street addresses, volume and folio identifiers, lease purpose codes, dates of transfer, sale prices, sale dates, and block areas. The ACT also provides valuation data to allhomes including rateable values and unit entitlements / aggregates.
- NSW: allhomes collects information published in the 'Spatial Information eXchange' ('SIX') database, including cadastral, topographic, addressing, vegetation, boundaries, and survey control data, satellite imagery, and current and historical aerial photography. Allhomes also receives property sales information, including (where applicable) record type, district code, submitter’s user ID, a property ID, sale counter, property name, unit number, house number, street name, locality, post code, area, area type, contract date, settlement date, purchase price, zoning, nature of property, primary purpose, strata lot number, percent interests of sale, dealing number, property legal description, purchaser-vendor information, owner type, owner interest, owner surname and first initial, owner title, and total records.
- Tasmania: allhomes collects data regarding transferred properties, including property IDs municipality codes, unit numbers, street numbers, streets, street types, localities, states, postcodes, sale dates, sale prices, capital values, land areas, land use codes, room counts, building areas, construction years, wall construction codes, and roof construction codes (where available).
From private customers: Where allhomes accepts a private listing (from the owner or lessor of property ('Customer')), allhomes collects the Customer’s first name and last name, email address, telephone numbers, credit card details, and the address of the property, and may also collect a description of the relevant property and its features, photographs of the property, documents concerning the property (like EER reports). Allhomes also collects information about the property including asking price, property type, floor area, block size, unimproved land value, number and type of rooms, floors, car parking, and energy efficiency.
From site users generally: Users of our website may choose to create a user account to take advantage of the website’s features (including property alerts, watch lists, etc.) In order to create an account allhomes collects a first and last name, State or Territory of residence, and an email address. Users also have the option of providing telephone contact details.
Users are able to submit online enquiries to allhomes. In this case, allhomes collects a contact name, contact email, a description of the user as being a member of the public, real estate agent, advertiser, or "other", and the nature of the enquiry. Users may also choose to provide a work or mobile phone number. When you submit an online enquiry it generates an email which is forwarded to our customer support email address. We keep a record of enquiries and details you submitted.
From job applicants: Allhomes advertises job vacancies on its website. Allhomes will ordinarily collect from an applicant (whether pursuant to an advertisement or unsolicited) a name and street address, contact details, details of current and former employment and education, referee details, and other kinds of information commonly included in curricula vitae. We keep a record of your job enquiry and all details you submitted with it.
Other: We may collect personal information from you, including your name, address and/or other contact information, gender, occupation, email address and any other information that is relevant to our functions and activities that you choose to give us when you use our website, services, or products.
In addition to those matters expressly set out above, we may also collect personal information from service providers and other third parties. In particular, allhomes uses the Google Analytics Demographics and Interest Reporting feature. That enables Google to collect data about visitors to the allhomes website via Google advertising cookies and anonymous identifiers. That information includes your age group, interests (based on web history), and location, information about your use of the allhomes website (including pages visited, pageviews, and session duration), and information about the software and hardware that the visitor is using to visit the website (“the Google information”). The Google Information is anonymised and allhomes does not merge it with any personally-identifiable information. You can opt out of the Google Analytics Demographics and Interest Reporting feature by clicking this link: opt out
We will only collect your sensitive information if you have consented to us doing so – for example, as part of information collected about directors and employees for company and human resource management purposes; or where required or permitted by law.
How do we collect personal and other information?
We only collect personal and other information by lawful and fair means. We usually collect personal and other information from:
- face-to-face meetings, interviews and telephone calls;
- business cards;
- electronic communications – for example, e-mails and attachments; forms filled out by people, including as part of acquiring a product or service from us;
- third parties – for example, from listing agents, State and Territory Governments, recruitment agencies and your representatives or agents, and, in the case of the Google Information, from Google (see above under ' What types of personal and other information do we collect and hold?'); and
- our website, including if you use it to contact us.
Why do we collect personal and other information?
We collect the personal and other information (including the Google Information): to enable us to publish residential and commercial property listings information via our website and mobile apps; necessary for us to provide you with the products and services you have requested from us; for marketing purposes and to provide you with information about products and services that may be of interest to you; to improve the products and services we provide; and to enable us to conduct our business, including meeting our legal and regulatory obligations. If you do not provide your personal information, we may not be able to supply the requested product or service, employ you or otherwise deal with you.
How we deal with unsolicited personal information?
If we receive personal information about you that we have not requested, and we determine that we could not have lawfully collected that information under the APPs had we asked for it, we will destroy or de-identify the information if it is lawful and reasonable to do so.
Do you have to disclose your identity when dealing with us?
Where lawful and practicable, we will give you the option of interacting with us anonymously or using a pseudonym.
Use of personal and other information:
We only use your personal and other information for the purpose for which it was provided to us, for related purposes or as required or permitted by law. Such purposes include:
- in the ordinary course of conducting our business. For example, publishing residential and commercial property listings information via our website and mobile apps, supplying or acquiring products and services, responding to your enquiries and feedback, and providing information about our events, news, publications and products and services that may be of interest to you;
- market research and product and service development, so that we are able to better understand our customers’ needs and tailor our future products and services accordingly;
- performing general administration, reporting and management functions. For example, invoicing and account management, payment processing, risk management, training, quality assurance and managing suppliers;
- employment-related purposes, such as recruiting and providing services to staff;
- as part of a sale (or proposed sale) of all or part of our business, or a sale (or proposed sale) of shares in allhomes; and
- other purposes related to or in connection with our business, including meeting our legal and contractual obligations to third parties and for internal corporate governance purposes.
Disclosure of personal and other information:
We may disclose, and you consent to us disclosing, your personal and other information to third parties:
- to the extent that a website user collects residential and commercial property listings information from our website;
- engaged by us to provide products or services, or to undertake functions or activities, on our behalf. For example, processing payment information, managing databases, marketing, research and advertising;
- that are authorised by you to receive information we hold;
- that are our business partners, joint venturers, partners or agents;
- as part of a sale (or proposed sale) of all or part of our business, or a sale (or proposed sale) of shares in allhomes. For example, we may disclose information to our external advisers, to potential and actual bidders and to their external advisors;
- such as our external advisers, and government agencies. For example, where disclosure is reasonably required to obtain advice, prepare legal proceedings or investigate suspected unlawful activity or serious misconduct; or
- as required or permitted by law.
Marketing use and disclosure:
We may use and disclose your personal and other information (other than sensitive information) to provide you with information about our products and services that we consider may be of interest to you. You may opt out at any time if you do not, or no longer, wish to receive marketing and promotional material. You may do this by: contacting us via e-mail or in writing at the address below and requesting that we no longer send you marketing or promotional material; or where applicable, clicking the "Unsubscribe" button.
Use or disclosure of sensitive information:
We will only use or disclose your sensitive information for the purpose for which it was initially collected or for a directly related purpose, as required or permitted by law, or where you consent to the use or disclosure.
Disclosure of personal and other information overseas:
From May 2014, allhomes will have disaster recovery support including use of servers physically located in a data centre in Hong Kong. Information that allhomes collects is backed up to, stored on, and retrieved from, those servers.
Also, allhomes’ electronic mail capability is provided by Google, and email is stored on Google’s servers. Google has data centres in the United States, Finland, Belgium, Taiwan, Singapore, and Ireland. Any personal or other information contained in email will be stored in a data centre in one or more of those countries.
Any overseas disclosure does not affect our commitment to safeguarding your personal or other information. Where reasonable in the circumstances, our contracts with overseas recipients oblige them to comply with the APPs and the Act. However, you acknowledge that, in agreeing to the disclosure of your information to overseas recipients, we will no longer be required to take reasonable steps to ensure overseas recipients’ compliance with the APPs in relation to your information and we will not be liable to you for any breach of the APPs by those overseas recipients. On this basis, you consent to such disclosure.
How is my personal and other information kept secure?
We take reasonable steps to protect your personal information from misuse, interference, loss and unauthorised access, modification and disclosure. Such steps include: physical security over paper-based and electronic data storage and premises; computer and network security measures, including use of firewalls, password access and secure servers; restricting access to your personal information to employees and those acting on our behalf who are authorised and on a 'need to know' basis; retaining your personal information for no longer than it is reasonably required, unless we are required by law to retain it for longer; and entering into confidentiality agreements with staff and third parties.
Allhomes uses a hosting provider for the storage of its information. The hosting provider uses a primary server room in Canberra and a secondary server room in Sydney. From May 2014, allhomes’ hosting provider’s primary server room will be in Sydney and its secondary server room will be in Hong Kong. Secure access to physical servers is controlled by allhomes’ hosting provider. Access to the information stored on the servers is protected by username/password authentication authorisation schemes.
Data transmissions between allhomes’ servers and its hosting provider’s servers is encrypted using Secure Sockets Layer ("SSL") security mechanisms.
Allhomes uses network vulnerability testers to ensure the security of its data. Allhomes also uses monitoring devices within its network infrastructure to notify of incursion or attempted incursion.
Where we no longer require your personal information, including where we are no longer required by law to keep records relating to you, we will ensure that it is de-identified or destroyed.
We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date. However, we rely on you to advise us of any changes or corrections to the information we hold about you. If you consider that the information we hold about you is not accurate, complete or up-to-date, or if your information has changed, please let us know as soon as possible.
You may request access to the personal information we hold about you by contacting us. We will respond to your request within a reasonable time. We will provide you with access to the information we hold about you unless otherwise permitted or required by law. If we deny you access to the information, we will notify you of the basis for the denial unless an exception applies. Where reasonable and practicable, we will provide access to the information we hold about you in the manner you request. No fee applies for requesting access to information we hold about you. However, we reserve the right to charge a reasonable fee where we do provide access.
Information we hold about current residential and commercial property listings is freely available via our website and mobile apps.
If you believe that personal information we hold about you is incorrect, incomplete or not current, you may request that we update or correct your information by contacting us. We will deal with your request within a reasonable time. If we do not agree with the corrections you have requested (for example, because we consider that the information is already accurate, up‑to‑date, complete, relevant and not misleading), we are not required to make the corrections. However, where we refuse to do so, we will give you a written notice setting out the reasons.
We do not adopt, use or disclose government related identifiers except as required or permitted by law.
If you have a complaint in relation to the collection, storage, use or disclosure of your personal information, please contact our Privacy Officer using the details below. You will need to provide us with details of your complaint, as well as any supporting evidence and information. We will review all complaints received and our Privacy Officer will respond to you. If you are not satisfied with our response, you may discuss your concerns with or complain to the Australian Privacy Commissioner via www.oaic.gov.au.
How to contact us:
- by email to firstname.lastname@example.org
- by writing to:
- Privacy Officer
- All Homes
- PO Box 4930
- Kingston ACT 2604
- by telephone: 02 6296 4814
- by fax: 02 6296 4818
Effective date: 26 June 2014