Orchard Property Group and Orchard Developments Pty Ltd understands and appreciates that your privacy is very important to you and that you have a right to control your personal information. We know that providing personal information is an act of trust and we take that seriously. This Policy explains how we will deal with your personal information as you interact with us.

COLLECTING PERSONAL INFORMATION

Personal information is any information that can be used to personally identify you. We will collect personal information from you so we can provide you with products and services that you have requested or which you have enquired about, and any additional information necessary to deliver those products and services. We may also collect your personal information to respond to your enquiries and so we can let you know about other products, services, or opportunities you might be interested in.

WHAT PERSONAL INFORMATION DO WE COLLECT AND HOLD?

We may collect the following types of personal information:

• name;
• mailing or street address;
• email address;
• telephone number;
• age or birth date;
• profession, occupation or job title;
• any information relating to you that you provide to us directly through our websites or indirectly through use of our websites; and
• any other information we consider necessary to your situation.

If you have invested in a managed investment scheme, we are required to collect additional personal and sensitive information under the Income Tax Assessment Act and Anti Money Laundering and Counter Terrorism Financing (AML/CTF) Act.

HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

We collect your personal information directly from you unless it is unreasonable or impracticable to do so. When collecting personal information from you, we may collect in ways including:

• through your access and use of our websites;
• during conversations between you and our representatives;
• when you become a tenant or owner of one of our properties; or
• when you complete an application.

In some situations, we may collect information about you from third parties such as your legal or personal representative, your financial adviser, or publicly available sources of information. We will only collect your information from third parties when we reasonably believe that you have consented to these sources collecting and disclosing the information.

WHAT HAPPENS IF WE CAN’T COLLECT 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; or
• we may not be able to provide you with information about products and services that you may want;

For investment clients, failure to provide a tax file number may result in a higher rate of tax being applied and failure to provide information under the AML/CTF Act may result in us not being able to process your request.

USING AND DISCLOSING YOUR PERSONAL INFORMATION

In line with modern business practices and to assist you with your requirements we may disclose your personal information to the organisations/persons described below.

• Our employees, related bodies corporate, including those located in the USA and Canada, contractors or service providers for the purposes of operation of our business, fulfilling requests by you, and to otherwise provide products and services to you including, without limitation: companies involved in maintaining, reviewing and developing our business systems, and infrastructure; Organisations involved in providing, managing or administering your product or service such as third party suppliers; and contractors employed to provide building maintenance services;
• Your financial adviser.
• Those people who are your authorised legal or personal representatives.
• Government or regulatory bodies as required or authorised by law,
• Any other company or person with your express consent.

Your personal information will not be shared, sold, or disclosed other than as described in this Policy.

DIRECT MARKETING MATERIALS

We may send you direct marketing, communications and information about our products and services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS 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 opt-out of receiving marketing communications from us by contacting us (see the details below) and we will then ensure that your name is removed from our mailing list.

PROTECTING YOUR PERSONAL INFORMATION AND KEEPING IT ACCURATE AND UP-TO-DATE

We store information in different ways, including in paper and electronic form. The security of your personal information is important to us and we take reasonable steps to protect it from misuse and loss and unauthorised access, modification or disclosure.

We will also take reasonable steps to make sure that the personal information we collect, use or disclose is accurate, complete and up-to-date. If you believe your personal information is not accurate, complete, or up to date, please contact us.

If you believe that your personal information is incorrect or out of date you can request to have this amended. To request access to your personal information you can contact us using the information in the “Contacting Us” section below.

Please be aware that some information cannot be amended or deleted sue to legal reasons. If we deny your request, we will inform you of the reasons for this decision.

OUR WEBSITES

Our websites have electronic security systems in place, including firewalls. Depending on the Group organisation with which you deal, other security measures may also be in place to control access to your personal information.

LINKS TO OTHER SITES

You may be able to access external websites by clicking on links we have provided. Those other websites are not subject to our privacy standards, policies and procedures. You will need to contact or review those websites directly to determine what security measures they have in place.

When we have personal information about you we will make every reasonable effort to make sure that the information is secure and is used or disclosed consistently with the Privacy Principles.

USING GOVERNMENT IDENTIFIERS

We will not use or disclose a government identifier (such as a tax file number) other than when required or authorised by law.

YOUR SENSITIVE INFORMATION

We will not collect sensitive information about you unless we are required to do so by law; the information is required for an insurance claim; or the information is necessary for the establishment, exercise or defence of a legal claim.

NOTIFIABLE DATA BREACHES

A notifiable data breach (NDB) scheme commenced in Australia on 22 February 2018 and applies to eligible data breaches that occur on, or after, that date. The NDB scheme requires us to notify individuals and the Office of the Australian Information Commissioner if there is a data breach that is likely to result in serious harm to any individual to whom the information relates and occurs when personal information is lost or subjected to unauthorised access or disclosure. Exceptions to the NDB scheme apply for some data breaches.

CONTACTING US

If you have any questions about privacy, you can call our offices. Our staff will do their best to resolve your issue. If an investigation is required, the Privacy Officer will become involved in the process. We will keep you advised of progress of the investigation.

To request access to personal information held about you in Orchard Property Group’s records, to make a privacy related complaint, to obtain more information about this Privacy Policy or to enquire about privacy matters generally, please contact the Orchard Property Group as follows:

Mail:  PO Box 9094 G.C.M.C 9726
Email:  info@orchardpg.com
Telephone:  (07) 5655 0629

If you feel that we have not adequately dealt with any privacy complaint you have made, you may contact the Office of the Australian Information Commissioner (Australia)

MORE INFORMATION

For more information about privacy legislation, you can visit the web site of the Office of the Australian Information Commissioner at www.oaic.gov.au