Privacy Policy

INTRODUCTION

SPG Brookville Pty Ltd (SPG, we, us) are committed to protecting your privacy. SPG takes all reasonable steps to comply with the Australian Privacy Principles set down by the Privacy Act 1988 (Cth) (“Privacy Act”) with respect to the collection, use, disclosure and security of, and access to, personal information.

COLLECTION

Type of collection

We may collect and hold personal information that can identify you that is necessary in order to conduct our business or communicate with you. The personal information collected by SPG depends on your interaction with SPG.

The kinds of information we typically collect include name, address, contact details (like phone numbers and email addresses) as well as electronic information from your use of our website (see further below).

Purpose of Collection

Generally, we will collect, use and hold personal information if it is reasonably necessary for or directly related to the performance of our functions and for the purposes of:

Marketing and promotion of our projects;
Facilitating Sun Property’s internal business operations;
Monitoring, auditing, evaluating and analysing SPG’s products and services and customer needs in order to develop its business;
Fulfilling any legal or regulatory requirements; and
Dealing with complaints or queries.

Method of collection

Personal information will generally be collected by us directly through use of any of our standard forms, websites, telephone conversations or other forms of communication with us. There may, however be some instances where personal information about you may be collected indirectly. SPG will usually notify you about these instances in advance or where that it is not possible, as soon as reasonably practicable after the personal information has been collected.

Failure to provide information

If the personal information you provide to us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the services you, or they, are seeking.

Internet users

If you access our website, we may collect additional personal information about you in the form of your IP address and domain name.

SPG may use technology to track the patterns of behaviour of visitors to our websites. This can include using a “cookie” which would be stored on an individual’s browser. An individual can usually modify their browser to prevent this occurring. The information collected in this way can be used to identify an individual unless browser settings are modified.

The main purpose of cookies is to identify users and to prepare customized web pages for them. Cookies do not identify you personally, but they may link back to a database record about you. We use cookies to monitor usage of our website and to create a personal record of when you visit our website and what pages you view so that we may serve you more effectively.

Our website may contain links to other websites. We are not responsible for the privacy practices of linked websites and linked websites are not subject to our privacy policies and procedures.

USE AND DISCLOSURE

Generally, we only use or disclose personal information about individuals for the purposes for which it was collected (as set out above). We may disclose personal information about you to:

our related entities to facilitate our and their internal business processes;
third party service providers, who assist us in operating our business (including professional advisors, financial advisers and technology service providers), and these service providers may not be required to comply with our privacy policy; and
our related entities and other organizations with whom we have affiliations so that those organizations may provide you with information about services and various promotions.

In some circumstances, the law may permit or require us to use or disclose personal information for other purposes (for instance where you would reasonably expect us to and the purpose is related to the purpose of collection).

SECURITY

Precautions are taken to safeguard personal information from loss, misuse, unauthorised access, modification or disclosure. Personal information which is no longer required for business purposes or by law will be de-identified, hard copies will be securely destroyed and soft copies will be permanently deleted from SPG’s computer systems.

We store your personal information in different ways, including in paper and in electronic form. The security of your personal information is important to us. We take all reasonable measures to ensure that your personal information is stored safely to protect it from misuse, loss, unauthorised access, modification or disclosure, including electronic and physical security measures.

ACCESS

You may access the personal information held about you by making a written request and on verification of your identity. We will try to acknowledge the request within 14 days of its receipt, and to provide access to the personal information within 30 days. SPG may charge a reasonable fee for providing access to your personal information (but not for making a request for access).

We may decline a request for access to personal information in circumstances prescribed by the Privacy Act, and if we do, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).

If, upon receiving access to personal information or at any other time, you believe that the personal information held by SPG is inaccurate, incomplete, or out of date, please notify SPG immediately. We will take steps to correct the personal information so that it is accurate, complete and up to date.

If we refuse to correct your personal information, we will provide you with a written notice that set out the reasons for our refusal (unless if would be unreasonable to provide those reasons).

PRIVACY COMPLAINTS

If you believe that the SPG or any of its subsidiaries have not dealt with your personal information in accordance with the Australian Privacy Principles in the Privacy Act (or any amendments), you may lodge a privacy complaint. Please contact us as set out below and we will take reasonable steps to investigate the complaint and respond to you. If you are not happy with our response, you may complain directly to the federal Information Commissioner.

Privacy complaints made to SPG must:

Be in writing
State an address of the complainant to which notices may be forwarded under the Privacy Act
Provide certified identification
Give particulars of the act or practice the subject of the complaint.

Privacy complaints need to be marked PRIVATE AND CONFIDENTIAL and addressed to:

POST: The Privacy Officer

EMAIL: [email protected]
SPG Brookville Pty Ltd
PO Box 460
North Sydney NSW 2059

OPT OUT/UNSUBSCRIBE

You may request that your details be removed from SPG’s marketing list at any time by sending an email to [email protected], or by contacting the SPG Head Office on 02 8920 1999.

SPG’s contact details for any issues relating to personal information and this policy are

The Privacy Officer
SPG Brookville Pty Ltd
PO Box 460
North Sydney NSW 2059
Telephone: 02 8920 1999
Email: [email protected]

MORE INFORMATION

For more information about privacy in general, you can visit the federal Information Commissioner’s website at www.oaic.gov.au.