1. Privacy generally
• Dahua Group Melbourne Investment Pty Ltd (ACN 604 279 736) of Level 50, 360 Elizabeth Street, Melbourne, 3000, Victoria (Dahua Melbourne);
• Dahua Group Sydney Investment Pty Ltd (ACN 606 376 416) of Suite 2, Level 20/201-217 Elizabeth St, Sydney NSW 2000 (Dahua Sydney); and
• the Australian related companies of Dahua Melbourne or Dahua Sydney from time to time and other entities forming part of Dahua’s Australian corporate group from time to time;
(Dahua, we us, our).
In collecting, holding, using, disclosing and otherwise managing your personal information, Dahua will comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles in the Privacy Act.
2. Kinds of personal information collected
Dahua is as a developer of residential and other real estate projects and undertakes related property development activities. In conducting this business, we may collect personal information.
Personal information is information or an opinion about an identified, or reasonably identifiable, individual.
The kinds of personal information that Dahua collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information Dahua collects may include:
(a) your contact information such as your name, address, telephone number, email address and date of birth;
(b) details of your employment history, and other information provided as part of our recruitment process;
(c) proof of identify information such as your driver licence or other similar identity information including your nationalities and tax file number;
(d) information regarding your preferences regarding our products and services (including information regarding the residential developments, housing or lifestyle amenities that may be of interest to you or your family);
(e) details regarding the transactions you undertake in respect of any Dahua developments (including about your financial information including bank accounts, credit card details, your financial circumstances and objectives, assets, income, liabilities, expenditure and investment preferences);
(f) your device ID, device type, geo-location information, IP address, browsing information and any personal information that you may provide to us directly or indirectly via our websites; and
(g) other information necessary to provide you with information regarding our products or services or undertake any transactions or dealings with you.
Dahua may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.
Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. If we do need to collect sensitive information about you, we will only do so with your consent or where we are required or permitted to do so by law.
3. How we collect personal information
Generally, Dahua collects your personal information directly from you. For example, Dahua may collect your personal information:
• when you request information or services from us;
• where you enter into, or propose to enter into, a transaction with us, including the purchase of property;
• where you use our website or other services or otherwise interact with us;
• if you attend an event conducted by us;
• when you complete a survey or enter a trade promotion or competition conducted by us;
• when you submit a “Get in Touch” form via our website;
• from individual project or development websites for marketing and selling of Dahua products and services;
• through our recruitment process when you apply for a position with us; or
• if you post information to any of our social media sites or interact with us on social media.
Generally, Dahua will only collect your personal information from sources other than you if it is unreasonable or impracticable to collect that personal information from you. However, in some cases, Dahua may collect your personal information from someone other than you, for example:
• from our other service providers that help us provide our services;
• from third parties you authorise to disclose your information to us;
• from marketing agencies, data collection and research organisations; and
• from a publicly maintained record or other publicly available sources of information including social media and similar websites.
4. Purposes for which personal information is used
Generally speaking, Dahua collects and uses personal information so that we can develop, improve and promote our services and conduct our property development and related businesses.
Some examples of the purposes for which Dahua collects, holds, uses and discloses your personal information include to:
• communicate with you;
• respond to your queries and provide you with information you request from us;
• conduct the general operation and management of Dahua, our property development business and supply our services to you;
• conduct trade promotions, competitions, giveaways and events;
• develop and improve the products and services we provide and the residential and other properties we develop, including obtaining your feedback regarding our services or to conduct other market research;
• administer, manage and process any transactions you enter into, or propose to enter into, with us, including the purchase of property;
• help us to manage the services we provide to you, including personalising your experience with our services;
• consider the suitability of prospective employees;
• security and risk management purposes; and
• comply with our obligations under any applicable laws.
In addition to the purposes listed above, Dahua may use your personal information for other purposes which we notify you of when we collect the information and for purposes otherwise permitted or required by law.
Where personal information is used or disclosed, Dahua takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Dahua. However, without certain information from you, Dahua may not be able to provide services or information to you or may be limited in how we can interact with you.
5. Disclosure of personal information
• related companies of Dahua, including companies in the Australian and overseas corporate groups of Dahua and joint venture entities that Dahua or its related companies have an interest in;
• our service providers, agents, contractors and other third parties that provide services to us, including our technology service providers and administration service providers;
• people or entities considering acquiring an interest in Dahua’ or any business or assets of Dahua;
• other parties who invest in or acquire an interest in Dahua or any business or assets of Dahua;
• Dahua’ professional advisors (including legal and accounting firms, auditors, consultants, insurers and other professional advisers); and
• government authorities where required by law.
Dahua may also disclose your personal information for other purposes if we notify you of the disclosure at or about the time of collecting the information, we have otherwise received your consent or the disclosure is required or authorised by law.
If you post information or other content to public sections of our website or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.
6. Overseas disclosures
Some of the parties that Dahua discloses your personal information to may be located outside Australia, including China and Hong Kong China.
We take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act.
7. Links to other websites
Dahua may collect statistical information when you access and use our websites and any online platforms available via our websites, by utilising features and technologies of your internet browser, including cookies and pixel tags. We use this information to analyse how our websites and other online services are being used and seek to improve our websites and other online services and provide more user friendly and customised websites and online services. These features and technologies do not specifically identify you unless you expressly provide to us personally identifiable information. You may also elect to turn off the internet browser features which allow us to collect statistical information by selecting certain options on your browser. However, this may slow down or cause certain web pages to be inaccessible to you.
9. Direct marketing
Dahua and/or our third party service providers may send you direct marketing communications and information about:
• products, services, discounts, competitions and special promotions that we consider may be of interest to you;
• offers or promotions based on how you use our products and services;
• third party products and services (including offers and discounts we may have negotiated for our customers) we think may interest you, for example, if we are selling residential land, we may promote the services of one or more builders.
10. Security of personal information
Dahua takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.
Your personal information will be kept on databases held on servers kept in a technologically secured environment, accessed only by authorised personnel or contractors.
Dahua will destroy or de-identify personal information in circumstances where it is no longer required, unless Dahua is otherwise required or authorised by law to retain the information.
11. Access and correction
Dahua takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading.
In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Dahua. If at any time you would like to access or correct the personal information that Dahua holds about you, or you would like more information on Dahua’ approach to privacy, please contact the Dahua Privacy Officer using the details set out in paragraph 12 below. Dahua will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.
To obtain access to your personal information:
• you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
• Dahua requests that you be reasonably specific about the information you require; and
• Dahua may charge you a reasonable administration fee, which reflects and will not exceed the cost to Dahua for providing access in accordance with your request.
Dahua will endeavour to respond to your request to access or correct your personal information within 30 days from your request. If Dahua refuses your request to access or correct your personal information, Dahua will provide you with written reasons for the refusal and details of complaint mechanisms.
If you are dissatisfied with Dahua’ refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.
12. Contacting Dahua
For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact Dahua’ Privacy Officer using any of the following contact details:
Email: [email protected]
Post: Level 50, 360 Elizabeth Street, Melbourne, VIC 3000
Phone: +61 (3) 9021 2565
13. Privacy complaints
Please direct all privacy complaints to Dahua’ Privacy Officer. At all times, privacy complaints:
• will be treated seriously;
• will be dealt with promptly;
• will be dealt with in a confidential manner; and
• will not affect your existing obligations or affect the commercial arrangements between you and Dahua.
Dahua will endeavour to acknowledge your complaint within 14 days of receipt and endeavour to resolve it within 60 days, unless Dahua informs you otherwise and seeks your agreement in writing.
The Dahua Privacy Officer will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which Dahua will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.