1. Introduction

At Impact Group Aus Pty Ltd ACN 100 923 297 trading as the Privium Group (Privium Group), we appreciate your use and contributions to the Privium Group Platform and other related websites. Privium Group respects your privacy and is committed to protecting your personal information.

This Privacy Policy sets out the manner in which we collect, use, disclose and manage personal information. By using the Privium Group Platform, subscribing to our services or entering into an agreement with us in relation to the websites, you are taken to have read and agreed to the collection, use, disclosure and handling of your personal information in accordance with this Privacy Policy. We may modify this Privacy Policy at any time. You should review this Privacy Policy periodically so that you are updated on any changes.

2. Relevant Legislation

We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (“Privacy Act“) (subject to exemptions that apply under that Act). We do not collect sensitive information as defined under the Act such as racial or ethnicity information, political opinions or associations, criminal records or health information.

3. What is Personal Information, why we collect personal information and how we use it

Personal Information is information or an opinion that identifies an individual. Examples of Personal Information we collect include: names, addresses, email addresses, phone and facsimile numbers.

Privium Group generally collects your personal information as part of providing you its products and services, informing you about them, complying with its contractual and other legal obligations, running promotions and other marketing activities or administering Privium Group’s relationship with you by responding to your enquiries and providing you with information about Privium Group events, products and services that may be of interest to you.

Privium Group needs your personal information to carry out these aims. Privium Group may use your personal information for those purposes, any other purpose listed on a collection statement at the point of collection or in any other way made clear at the time of collecting the personal information.

4. Sensitive Information

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by us only:

  • For the primary purpose for which it was obtained
  • For a secondary purpose that is directly related to the primary purpose
  • With your consent; or where required or authorised by law.

5. Information Sourced
5.1 Information you provide

When interacting with Privium Group, you may provide information about yourself, such as your name, address, phone number, email and details pertaining to a potential transaction. This may occur, for example, when we collect your information via a website, at a display home, a face to face sale discussion, an online promotion, interactive advertisement or a telephone call to us.   You may also provide information about a third party through the Privium Group Platform, for example, if you share a real estate listing with a recipient via email. We may combine this information with other information we collect in person by sales and customer service staff, via its websites, social media pages, smart phone applications, phone calls and at display sites and other installations on paper forms or electronic devices (Collection Channels).

Our Collection Channels may include other related companies or brands within the Privium Group, or related parties to the Privium. These include:

  • Impact Homes
  • Privium Homes
  • Joii Limited
  • Joii Homes
  • Build Today
  • Privium Construction
  • Ink, by Privium

5.2 Third Parties

Privium Group may also obtain customer or potential customer information from partners, such as Real Estate Agents, real estate brokers, finance brokers, service providers to Privium Group and other marketing channel partners.

In such a case we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.

In addition, when you order products or services through the Privium Group Platform, Privium Group may collect your credit/debit card information. This information is secured using industry-standard encryption technology. Privium Group will use this information solely to complete your order and will not share this information with outside parties, except to the extent necessary to complete the order or comply with applicable law.

5.3 Information of Usage

  1. Metadata – Metadata is the collecting of “data about the data” that occurs on the Privium Group Platform. The Privium Group Platform brings several parties together around a Property transaction and we see it as our duty to collect relevant information about the usage of the Privium Group Platform that may be of material use, especially in the event of a dispute. For this reason, we record certain transactions on the Privium Group Platform for the security of our users. Some of these methods of collecting metadata is set out below;
  2. Cookies and Web beacons – Cookies are bits of electronic information that can be transferred to your computer or other electronic device to uniquely identify your browser. When you use the Services, we may place one or more cookies on your computer or other electronic device. We may use cookies to connect your activity on the Services with other information we store about you in your account profile or your prior interactions on the Services to, for example, store your preferences. The use of cookies helps us improve the quality of the Services to you, by identifying information which is most interesting to you, tracking trends, measuring the effectiveness of advertising, or storing information you may want to retrieve on a regular basis, such as your favorited properties. At any time, you may adjust settings on your browser to refuse cookies according to the instructions related to your browser. However, if you choose to disable cookies, many of the free features and Services will not operate properly;
  3. Usage logs – When you use the Services, your computer or other electronic device communicates a variety of information to computer servers, including the existence of cookies, your Internet Protocol address, and information about your browser program. We also create a record of what information you are requesting, such as the page or subject areas you are visiting; and
  4. Social Networks – If you use the Social Networking connection functions offered through the Services, we may access all of your Social Network profile information that you have made available to be shared and to use it in accordance with this Privacy Policy. Please refer to the instructions governing your Social Network account to manage the information that is shared through your account.

6. Usage and Disclosure

In general, Privium Group uses the information collected from you to communicate with you and operate the Privium Group Platform. Privium Group also uses this information to respond to your requests and present you with advertising that we believe will be of interest or useful to you and to ensure that proper tracking of transactional information is kept for your and Privium Group’s protection.

Your privacy is important and we are committed to protecting information that identifies you personally, where you have chosen to keep it private (“Personal Information”). We will only share Personal Information that you provide outside the public areas of the Services in the following circumstances:

  1. Consent: When you consent or direct Privium Group to share the Personal Information or document.  For example, we would request that you take responsibility for the documents that are to be shared via the Privium Group Platform and with whom, and for this reason the Privium Group Platform has mechanisms that facilitate you being able to choose what information and documents you share, with whom and at what stage of the transaction;
  2. Partners with whom we conduct business: Privium Group may give business partners access to Personal Information only as necessary to offer products and services with those business partners, and subject to the terms of this Privacy Policy;
  3.  Legal obligation or protection from harm:  When Privium Group  has a good faith belief that access, use, preservation or disclosure of the Personal Information is reasonably necessary to (a) satisfy any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of Privium Group , its users, or the public against harm.

7. Advertising

When we deliver advertising based on data about your use of the Services, we keep your identity anonymous. We will not identify you personally to third parties, except in accordance with this Privacy Policy. Of course, if you choose to respond to an advertised offer with your name and contact information, you will no longer be anonymous to the advertiser. Further, while we do not share your Personal Information with third parties unless permitted above, Privium Group may share aggregate anonymous information with third parties. This information does not personally identify individuals, but rather provides a helpful understanding of the groups of people who prefer certain types of information and services.

8. Direct Marketing

If you provide us with your personal information and you consent to receiving direct marketing communications from Privium Group, you authorise us to send you promotional messages and materials related to Privium Group’s products and services, unless you submit a later request not to receive direct marketing communications.

Privium Group’s direct marketing messages and materials will contain a prominent statement (including, for electronic messages, a functional unsubscribe facility) that you may request not to receive direct marketing communications.

If you do not wish to receive marketing or other communications from us, please submit a request not to receive direct marketing communications or use the unsubscribe facility provided in the most recent communication from us or contact us on the details provided.

Please note that even if you unsubscribe from certain email correspondences, we may still need to email you with important transactional or administrative information.

9. Behavioural Advertising

We may participate in behavioural advertising. This means that, for example, when you use the Services, we or third-party service providers or advertisers may use cookies (that they collect or that we provide to them) or other similar technologies to collect information about your use of the Services (including mobile applications) or your online activities over time and across different websites. Collected information may include the content you view, the date and time that you view this content, and the website that referred you to the Services, and this information may be associated with your unique browser, device identifier, or Internet Protocol address. These practices help tailor advertisements that are relevant and useful to you. These tailored advertisements may appear on the Services or on other websites, applications or properties.

In addition, if you have provided your email address to us, we may use a scrambled, unreadable form (a hash) of your email address to deliver tailored advertisements to you on the Services or on other websites, including via Facebook’s Custom Audience Feature or other similar Facebook tools. We will not share your email address with Facebook.

You may opt-out of cookie tracking and analysis as described in the section below entitled ‘Opting out of Collection of Information’. The Services do not otherwise respond to ‘do not track’ signals.

10. Location Data

Privium Group can provide you with helpful information based on where a Property is located or where you would like to purchase a Property. If you share your location with Privium Group (e.g., by allowing your mobile device to send Privium Group your location), the Privium Group Platform may use that information to provide you with location-based information and advertising. If you wish to deactivate this feature, you can disable location services on your mobile device.

11. Windows Live® Virtual Earth®

Windows Live Virtual Earth imagery is supplied by Microsoft Corporation, and use is subject to the Microsoft MapPoint Privacy Statement.

12. Third-Party Websites

Throughout the Services, we may link to the websites of other companies and/or individuals. Further, certain functionalities on the Privium Group Platform may involve the distribution of your listing information to third-party websites. These third-party websites may collect Personal Information about users on those websites, and Privium Group’s Privacy Policy does not extend to these external websites and third parties. Please refer directly to these third parties and websites regarding their privacy policies.

13. Storage, Security and Retention of Information

Privium Group has taken reasonable steps to protect the information users share with us, including, but not limited to, setup of processes, equipment and software to avoid unauthorised access or disclosure of this information. No transmission of information via the Internet can be entirely secure, however, so please always use caution when submitting Personal Information.

We will retain your Personal Information for as long as you have an active account, as needed to provide you with the Services, to comply with our legal, financial reporting, or compliance obligations, and to enforce this Privacy Policy.

14. Access to your Personal Information

You may access the Personal Information we hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please contact us in writing.

Privium Group will not charge any fee for your access request but may charge an administrative fee for providing a copy of your Personal Information.

In order to protect your Personal Information, we may require identification from you before releasing the requested information.

15. Maintaining the Quality of your Personal Information

It is an important to us that your Personal Information is up to date. We  will  take reasonable steps to make sure that your Personal Information is accurate, complete and up-to-date. If you find that the information we have is not 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 quality services to you.

16. Policy Updates

This Policy may change from time to time and is available on our website, www.priviumgroup.com.au.

Privacy Policy Complaints and Enquiries

If you have any queries or complaints about our Privacy Policy please contact us at:

07-3489 6000

admin@priviumgroup.com.au

Privium Group

Compton House

Level 2

54-66 Perrin Drive

Underwood QLD 4119.