COYLE EVERETT PRIVACY POLICY
OVERVIEW
The purpose of this policy is to ensure that COYLE EVERETT manages personal and sensitive information responsibly, transparently, and in compliance with the Australian Privacy Principles (APPs) under the Privacy Act 1988. This policy outlines how personal information is collected, used, disclosed, stored, and protected by COYLE EVERETT.
This policy applies to all personal and sensitive information collected by COYLE EVERETT in relation to clients, customers, personnel, contractors, and other stakeholders. It covers all methods of information handling, including digital, physical, and verbal communications.
COYLE EVERETT is committed to protecting the privacy of individuals and ensuring the confidentiality, security, and integrity of personal and sensitive information. The agency will comply with the Australian Privacy Principles and other relevant legislation while fostering trust and transparency in all interactions.
COYLE EVERETT complies with the Privacy Act 1988 (Cth) including the 13 Australian Privacy Principles (APPs) as outlined in the Privacy Amendment (Enhancing Privacy Protection) Act 2012 (Cth). Providing an overall framework for our privacy practices, COYLE EVERETT has developed and implemented this APP Privacy Policy.
APPLICABLE LEGISLATION
This policy is designed to maintain requirements with additional jurisdictional requirements including:
- Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth),
- Information Privacy Act 2014 (ACT),
- Privacy and Personal Information Protection Act 1998 (NSW),
AUSTRALIAN PRIVACY PRINCIPLES (APP)
COYLE EVERETT manages personal information in an open and transparent way. This is evident in the implementation of practices, procedures and systems we outline in this policy, that ensure our compliance with the APPs and any binding registered APP code and provide suitable procedures for COYLE EVERETT personnel to be able to deal with related inquiries and complaints that may be received from time to time.
The following sections of this policy outline how we manage personal information.
Purpose Of Collection (APP1.4c)
COYLE EVERETT collects your Personal Information for the primary purpose of providing real estate services to our clients and marketing. We may also use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by contacting us in writing.
When we collect Personal Information, we will, where appropriate and where possible, explain to you why we are collecting the information and how we plan to use it.
You do not have to provide us with your personal information, however, if you do not, we may not be able to provide you with our services or information or allow you to any inspect property under our control.
We request the information from you so that we can provide you with the services and products you have requested from us, and the manage our obligations to you under any customer contract or applicable law. Some of the services we provide as a real estate agency include: –
- Any service or information we provide acting as an agent for the buying, selling, leasing, managing properties, or strata complexes:
- Marketing purposes and to provide you with information about products or services that may be of interest to you
- Enabling us to conduct our business, including meeting any legal or regulatory obligation placed upon us.
We will only collect your sensitive information if you have provided us with consent to do so. Where possible, we will give you the option of interacting with us anonymously.
The Kinds of Personal Information Collected and Held (APP1.4a)
COYLE EVERETT collects personal information, which can include: –
- Contact information (name, address, phone number, email).
- Occupation
- Next of Kin (in case of emergency)
- Identification information (driver’s license, passport details)
- Financial information (bank account details, income information)
- Rental and Employment references
- Property information (details of properties owned, rented, or being sought)
- Sensitive information such as credit worthiness and other details necessary to assess applications
- Other relevant information (marital status, family details, employment history).
How Personal Information is Collected and Held and Used (APP1.4b; APP1.4c; APP1.4f; APP1.4g)
We only use your personal information for the purpose for which it was provided to us, or
- related purposes that you would reasonably expect, and
- as permitted or required by law.
Such purposes would include: –
- Internal Use
- In the ordinary course of conducting our business such as
- Assisting you with purchasing, leasing or managing property
- Responding to your enquiries and feedback
- Informing you of property we have for sale or lease or may be open for inspection
- Reporting to vendors or owners of properties that you, may have inspected or made enquiries about
- Providing you with marketing information regarding the services we or third parties acting on our behalf provide.
- Performing general administration or management functions
- Any other purpose associated with our core function as a real estate agency
We may use the information to contact you by phone, email or text.
- Disclosure to Third Parties
We may disclose your personal information to related companies, service providers, contractors’ business partners other parties involved in the transaction, but only if one or more of the following apply:
- You have consented to the disclosure
- You would reasonably expect us to disclose your information this way
- We are authorised by legislation to do so
- Legislation requires us to disclose the information
- If an urgent health emergency or threat to life emergency arises
- International Disclosure
We do not ordinarily disclose or hold personal information overseas. If this becomes necessary, we will notify you and advise you of the country where the information will be sent or held, and the level of privacy protection in that country.
If we engage any additional overseas providers in the future, we will notify you and update this Privacy Policy to reflect the countries involved.
Automated Decisions
We do not use automations, computer programs or artificial intelligence in any decision-making process that uses your personal information and would significantly affect your rights or interest
Data Security (APP1.4g; APP11)
COYLE EVERETT has the following data security measures in place to protect your personal information from unauthorised access, use or disclosure.
All personal information collected by us through our platforms listed is stored in a variety of formats including electronically in databases, in hard copy files and on personal devices including laptop computers, mobile phones, cameras and other recording devices.
We take reasonable steps (both technical and organisational) to ensure that your personal information is stored both securely and is protected by: –
- Having a robust physical security of our premises and database/records/files.
- Taking measures to restrict access to only personnel who need that personal information to effectively provide services to you
- Having technical measures in place (e.g. anti-virus software, firewalls, the use of a VPN, secure payment portals, and the use of Secure Sockets Layer (SSL) protocols.
When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information. Unless legislation requires otherwise, most of the Personal Information is or will be stored in client files which will be kept by us for a minimum of 7 years, in order that we can meet legislative requirements.
If you are sending us personal information, it is transmitted to us at your own risk. You must take the necessary steps to protect your information by protecting things like user names and passwords, customer details etc. You should notify us as soon as practical if you become aware of a security breach.
Data Breaches
If COYLE EVERETT becomes aware of any security breach, an internal process will be immediately commenced in accordance with our Data Breach Response Plan. This will guide a conduct of an assessment of the breach and commence notification and rectification procedures if they are necessary.
Accuracy, Access and Correction of Personal Information (APP1.4d)
It is an important to us that your Personal Information is up to date. COYLE EVERETT will take reasonable steps to ensure the information we collect and hold about you is accurate, up-to-date, and complete.
You may access the Personal Information we hold about you and update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.
If you believe or find that the information we have may not be up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide a quality service.
COYLE EVERETT will not charge any fee for your access request but may charge an administrative fee for providing a copy of your Personal Information that we hold.
So that we may protect your Personal Information, we may require identification from you before releasing the requested information.
How do I Make Enquiries or Lodge Complaints? (APP1.4e)
If you have an inquiry or complaint relating to our Privacy Policy or compliance with applicable APPs please contact us using the contact details below. You will need to provide us with sufficient details regarding your complaint, as well as any supporting evidence and/or information.
We will refer your inquiry or complaint to our Privacy Officer whose details are below. They will, within a reasonable time, investigate the issue and determine the steps that COYLE EVERETT will undertake to resolve any complaints. We will contact you if we require any additional information from you and will notify you in writing of the response or determination of our Privacy Officer.
If you are not satisfied with our response or determination, you can contact us or raise your concerns with the Australian Privacy Commissioner via
www.oaic.gov.au.
If you believe we have breached the APPs or mishandled your personal information, or you have any questions about this Privacy Policy, please call immediately us on 02 9365 5566.
Revision of Our Privacy Policy
We may revise this Privacy Policy or any part of it from time to time. Please review this policy periodically for changes. If We make significant changes to this policy, We may notify you using the contact details provided by you or by putting a notice on our website
www.cere.com.au.
Your continued use of our website, services, requesting our assistance or the provision of further personal or sensitive information to us after this Privacy Policy has been revised, constitutes your acceptance of the revised Privacy Policy.
How to Contact COYLE EVERETT
