Introduction

Our organisation and obligations

D & C Realty Pty Ltd ACN 609 880 668 ("Focus Estate Agents") is a leading entity providing the Real Estate Industry with a diverse range of services and products. We are bound by the Privacy Act and Australian Privacy Principles (APPs). The APPs regulate the way we handle personal information. The Privacy Act does not apply to handling of information that is not related to individuals such as information about corporations.

Protecting your privacy

Protecting your privacy and the confidentiality of your personal information is fundamental to the way Focus Estate Agents does business. For the purposes of this Privacy Policy the words "you or your" include visitors to the www.focusestate.com.au website (Website)As an organisation, Focus Estate Agents has a long history of handling personal information, including sensitive information, confidentially. We value the ongoing trust you have in us to protect your privacy. Personal information is information or an opinion about you.

This Privacy Policy explains how Focus Estate Agents will manage and protect your personal information, including information that Focus Estate Agents collects during the course of providing a product or service to you and the information Focus Estate Agents holds after your product or service is terminated (where we are required to hold this information or it is necessary for our business functions). This Privacy Policy also applies to information that Focus Estate Agents collects from third parties.

This Privacy Policy contains information about how you can access the information Focus Estate Agents holds about you, how you can ask Focus Estate Agents to correct your information and how you can make a complaint if you have concerns about how Focus Estate Agents has managed your information.

How to contact Focus Estate Agents

If you have any questions or would like more information about this Privacy Policy you may contact us on 02 9669 4971 during business hours or email your question or request to enquiries@focusestate.com.au.

Our privacy framework

Focus Estate Agents is bound by the Privacy Act and the Australian Privacy Principles (APPs) set out in that Act. The APPs regulate the way that certain entities handle personal information.

The Privacy Act does not apply to the handling of information that does not relate to individuals, for instance information about corporations.

Collecting your personal information

• Focus Estate Agents collects your personal information, (which may include your photograph as taken at our Company events you attend), so that we can perform our various business functions and activities, including marketing.
• Focus Estate Agents also collects your personal information if the law requires us to collect it.
• If attending one of our events: If you do not wish your photograph to be taken whilst at the event and / or you do not want your photo to be used by us in our marketing, you may advise the photographer and our staff on site or email your request to us.
• To access our products or services or for employment, Focus Estate Agents may collect and hold information from you or your associated corporation such as your name, address, telephone number, email address, credit card and bank account details, date of birth and place of work.
• Focus Estate Agents collects most personal information directly from you or the corporation you are associated with such as your past or current Employer or Franchisor. As examples, you or the organisation provide us with your information by various methods such as in person, fill in a form, deal with us over the telephone, send us a letter, email or text message, use our website or social media, give us your business card or contact details at conferences, Trade Exhibits, events or meetings or by various other methods of engagement. Other data about you may be collected from public information such as websites, social media, Australian Securities & Investments Commission (ASIC), Government Departments eg Fair Trading’s Licence Check webpage.
• If Focus Estate Agents does not collect all or some of your personal information, we may not be able to assist or provide you with a product or service eg brokerage services, provide support or a service under a Licence or Service Agreement, deliver training or industry products or employ you.

Collecting information from third parties

In addition to the information stated above which may reference a third party, Focus Estate Agents may also collect information about you that is publicly available, such as information from telephone directories, print media, websites and your personal marketing material.There may be occasions when Focus Estate Agents collects personal information about you from other third parties. For example, Focus Estate Agents may collect personal information from:

• organisations that Focus Estate Agents has an arrangement with to jointly offer products and/or has an alliance with to share information for marketing purposes to provide you with products or services and/or to promote a product or service
• other related entities so we can better manage your relationship with us
• marketing companies if we acquire contact information to tell people about Focus Estate Agents products and services that may interest them; and
• other parties who may have introduced you to Focus Estate Agents

Focus Estate Agents may also collect information about how you use our website and other websites to help us better tailor our services to you. For example, Focus Estate Agents may do this when you click on a link from a Focus Estate Agents website or visit a website which displays a Focus Estate Agents advertisement. Usually, the information we collect in this way is general information only derived from cookies – such as the number of visitors to a site or statistics about how a site is browsed – and does not identify you. If Focus Estate Agents does identify you with this information (for example, if you have been logged onto an online Focus Estate Agents service), any use or disclosure of that information will be in accordance with this Privacy Policy.

Collecting sensitive information

Sensitive information is personal information about a person’s racial or ethnic origin, political opinion, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, genetic information or health information

Focus Estate Agents does not collect, use or disclose sensitive information about you unless you give the information to us and require us to know the information eg health details that we should be aware of during employment. Disclosure of such information is not disclosed without your consent.

Collecting information required by law

Focus Estate Agents may collect information from you because we are required or authorised by an Australian law or court or tribunal order to collect that information. We will tell you if collection is required or authorised by law and provide you with details of the law, court or tribunal order.

We may use and disclose personal information we collect about you for several purposes including:

• to consider your request for a product or service
• to enable us to provide a product or service requested
• to tell you about other products and services that may interest you
• to identify you
• for employment processes
• direct marketing
• to assist in arrangements with other organisations in relation to promotion or provision of a product or service
• to manage systems and perform other administrative and operational tasks, including risk management, system development and testing, staff training, collecting debts and market or customer satisfaction research related to our functions and activities and database maintenance.
• to consider any concerns or complaints you raise against Focus Estate Agents and/or to manage any legal action between you and Focus Estate Agents
• to prevent or investigate any actual or suspected fraud, unlawful activity or misconduct; and
• as required by relevant laws, regulations and codes of practice

Disclosure

• Focus Estate Agents may need to disclose your information to a third party as relevant to the particular service or product, function or activity that Focus Estate Agents performs. Third parties may include but are not limited to: Independent Contractors or Licensees or other contracted support and service providers performing functions or services on behalf of Focus Estate Agents, Financiers, Solicitors, Others as authorised by you eg to contact your employment references, your Superannuation Company, Work Cover, Insurer, other industry and related service providers, Guest Speaker or Trainer presenting at our events you attend, Valuer, Franchisor, Accountant, Receiver, Debt Collector, as required by a legal Order or by Law eg Australian Taxation Office.
• We need your consent before we can use or disclose your information in our marketing. Likewise we need your consent if we need to use your information for a purpose that is not related to the purpose for which we collected your information in the first place as detailed in this Notification. Depending on the circumstances, this consent may be express (for example, you expressly agree to the specific use of your information by ticking a box) or implied by some action you take or do not take (for example, your agreement is implied by the fact that you have agreed to our product terms and conditions which contains information about the use of disclosure).

Your consent is important

Focus Estate Agents may require your consent to use and/or disclose your information in particular ways. For instance, we need your consent before we can use it in our marketing. Likewise we need your consent if we need to use your information for a purpose that is not related to the purpose for which we collected your information in the first place.

Depending on the circumstances, this consent may be express (for example, you expressly agree to the specific use of your information by ticking a box) or implied by some action you take or do not take (for example, your agreement is implied by the fact that you have agreed to your product terms and conditions which contains information about the use or disclosure).

Marketing and privacy

As part of Focus Estate Agents service to you, Focus Estate Agents may use personal information we have collected about you to identify a product or service that may benefit you. Focus Estate Agents may contact you from time to time to let you know about new or existing products or services. Focus Estate Agents may also disclose your personal information to its related entities or business partners to enable them or Focus Estate Agents to tell you about a product or service.

You can contact us at any time if you do not want to receive direct marketing information from Focus Estate Agents.

Managing your personal information

Focus Estate Agents protects your information

Focus Estate Agents protects your personal information from misuse and loss. We also protect it from unauthorised access, modification and disclosure by ensuring that your personal information can only be accessed by people authorised to have access.

Focus Estate Agents may store your personal information in hardcopy documents or electronically. Focus Estate Agents maintains physical security, such as locks and security systems, over our paper and electronic data stores and premises.

Focus Estate Agents also maintains computer and network security. For example, Focus Estate Agents uses firewalls (security measures for the internet) and other security measures such as Member Logins and passwords to control access to computer systems.

Focus Estate Agents continually maintains and monitors its online security systems to ensure that Focus Estate Agents online services are secure and that your personal information is appropriately protected when you use these services.

Protecting your privacy

You can help us to protect your privacy by observing our security requirements and contacting us immediately if your contact details change.

Focus Estate Agents require you to keep your allocated BOSS product passwords and access codes confidential and secure at all times. This means that you should not disclose your passwords or access codes to any other person. You should contact Focus Estate Agents immediately if you believe that your passwords or access codes may have been disclosed to another person or if you would like to change your password.

How do I access my personal information?

Subject to some exceptions, you can find out what personal information Focus Estate Agents holds about you.

You should contact Focus Estate Agents in writing if you wish to find out about the personal information Focus Estate Agents holds about you. Focus Estate Agents will need to verify your identity before giving you access.

Focus Estate Agents will normally be able to deal with your request immediately. If the request is complex, we can usually deal with such a request within 14 business days. Focus Estate Agents will usually provide access to your information at our office to protect the confidentiality and security of your information. However, you may elect to receive your information by registered mail or courier, where practicable. Fees for these services are charged to you at the cost of your selected service.

In certain circumstances, Focus Estate Agents may not be able to tell you what personal information is held about you. In these circumstances, Focus Estate Agents will write to you to explain why we can not provide you with the information and attempt to find alternative means to enable you to access your information.

How do I request correction of my information?

If you believe that the personal information Focus Estate Agents holds is inaccurate, incomplete or out-of-date, you should contact Focus Estate Agents in writing and provide the correct details.

Email: enquiries@focusestate.com.au
Mail: Shop 2, 131B King St, Mascot NSW 2020

Focus Estate Agents will promptly update any personal information that is inaccurate, incomplete or out of date.

If Focus Estate Agents do not agree that your information is inaccurate, incomplete or out of date, Focus Estate Agents will write to you and tell you the reason(s) why Focus Estate Agents does not agree with you. Focus Estate Agents will also tell you what you can do if you are not satisfied with our response.

Resolving your concerns

You are entitled to complain if you believe that your privacy has been compromised or that Focus Estate Agents has breached the Privacy Act, or the Australian Privacy Principles.

If you have a privacy complaint, you can contact the Focus Estate Agents Privacy Officer. Formal complaints are to be in writing. The Privacy Officer’s contact details are:

Email: enquiries@focusestate.com.au
Mail: Shop 2, 131B King St, Mascot NSW 2020

If your complaint is not satisfactorily resolved, you may also contact a Director of Focus Estate Agents at the above addresses, who will review the determination of the Privacy Officer.

Making a complaint

If you believe that Focus Estate Agents have interfered with your privacy in the handling of your personal information, you may lodge a complaint in writing to any of the addresses in the preceding paragraph.  Focus Estate Agents will respond to your complaint within two business days to inform you of the identity of our staff member who will manage your complaint.  Focus Estate Agents will try to resolve your complaint within 10 business days of its receipt however, when this is not possible Focus Estate Agents will contact you within such time period to provide an alternative estimate of time.

Focus Estate Agents will investigate your complaint and will make a decision about your complaint and write to you to advise of our decision. If you are unhappy with the resolution of your complaint or with the way that Focus Estate Agents has handled your complaint, you may be able to refer the matter to the Office of the Australian Information Commissioner the contact details for which are as follows:

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001
Telephone: 1300 363 992
www.oaic.gov.au

Meaning of Words

In this Privacy Policy:
Words that are defined in Our Terms and Conditions have the same meaning in this Privacy Policy, unless expressly stated to the contrary.
Australian Privacy Principles means the Australian Privacy Principles contained in Schedule 1 to the Privacy Act l988 (Cth) (or an applicable privacy code approved by the Federal Privacy Commissioner pursuant to that Act).
Personal information means any information or an opinion about You from which Your identity is apparent or can reasonable be ascertained.

Changes to this Privacy Policy

We may alter this Privacy Policy as a result of changes in the law, our Privacy audit and review procedures or as our business requirements change. Any changes to this Privacy Policy will be updated on www.focusestate.com.au