This statement applies to personal information collected by Halcyon Management Pty Ltd ACN 103 817 090 as trustee for Halcyon Management Unit Trust ABN 60 367 634 401 and its related bodies corporate (“Halcyon”, “we”, “us” and “our”). You agree that Halcyon may collect, use and disclose information about you for the purposes of owning, operating and managing Halcyon.
Halcyon supports the importance that the community places on the maintenance of informational privacy of individuals’ personal and/or sensitive information. This extends to the collection and management of information held in its records regarding individuals.
Halcyon undertakes to use any personal information it collects from you only for:
- The purposes for which it was collected, including:
- Provision of our products and services to you;
- Comparing sales data that relates to purchasing or selling a residential dwelling at a Halcyon community;
- To make statistical data, for product improvement;
- To make statistical data for marketing purposes;
- For product training with employees;
- Or such other purpose as notified to you at the time of collection;
- Marketing and promotional activities by us;
- Such other purposes as are subsequently agreed between Halcyon and you;
- Such additional purposes as may be required by law; and
Halcyon is committed to safeguarding your personal privacy and recognises that you have a right to choose how your personal information is used. We take our obligations in relation to your personal information seriously and are committed to the Australian Privacy Principles and complying with the Privacy Act 1988 (Cth) (‘Privacy Act’).
How to contact us
For further information, please contact Halcyon at [email protected] or alternatively you can write to us at PO Box 110, Sanctuary Cove Qld 4212.
1. What is personal information?
Personal information is defined in the Privacy Act as meaning information or an opinion, whether true or not and whether recorded in a material form or not, about an individual whose identity is reasonably identifiable, from the information or opinion.
2. Sensitive information
2.1 What is sensitive information?
(a) Sensitive information is a subset of personal information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information, genetic information and biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
(b) In general, we attempt to limit the collection of sensitive information we may collect from you, but depending on the uses you make of our products this may not always be possible and we may collect sensitive information from you in order to carry out the services provided to you. However, we do not collect sensitive information from you without your consent.
(c) The types of sensitive information we may collect from you or record about you is dependent on the services provided to you by Halcyon and will be limited to the purpose(s) for which it is collected. We do not use sensitive information to send you Direct Marketing Communications.
2.2 Exempt sensitive information consent
Exempt sensitive personal information may be collected by us and you consent and agree to the collection of such information. Exempt sensitive personal information is personal information relating to:
(a) The criminal record of an individual; and
(b) The health or medical information about you,
But only to the extent that where you volunteer such information or it is necessary for, or incidental to, the purposes of collection set out in paragraph 4 of this Policy.
3. Collecting information about you
3.1 We will only collect personal information that is necessary for what we do. The type of information we may collect from you includes (but is not limited to) the following:
(a) Your contact information such as full name (first and last), email address, current postal address, delivery address (if different to postal address) and phone numbers;
(b) Details relating to your employment (if applicable) or your previous employment;
(c) Your date of birth;
(d) Proof of your date of birth (including, but not limited to, driver’s licence, passport, birth certificate);
(e) Your opinions, statements and endorsements collected personally or via surveys and questionnaires, including, but not limited to, your views on the products and services offered by Halcyon;
(f) Details relating to the purchase of a home or rental of a site or other products you have obtained from us;
(g) Details relating to the purchase of any residential dwelling purchased from us, if applicable, including, but not limited to, details of purchaser(s), purchase price, deposit, payment dates, location, type of home purchased and any variations thereof;
(h) Any photographs or video footage, which include you, taken at a Halcyon community or on the purchase of your residence from us or during the attendance of any Halcyon function or event;
(i) Details relating to your residence at any Halcyon community, including, but not limited to, your hobbies and interests, number and type(s) of pet(s) residing with you, types of functions you would be interested in attending, number of residences owned, number of cars owned, next of kin and relative details, any Government support you may be receiving, and any additional details which may be collected as part of or incidental to your residence in any Halcyon community; and
(j) If you are requesting products or services from us or we are purchasing goods or services from you, then any relevant payment or billing information (including, but not limited to, bank account details, direct debit, credit card details, billing address, repayment information and invoice details).
3.2 When you engage in certain activities, such as entering a contest or promotion, filling out a survey or sending us feedback, we may ask you to provide certain information. It is optional for you to participate in these activities.
3.3 If you use our website, we may utilise “cookies” which enable us to monitor traffic patterns to serve you more efficiently if you revisit a Halcyon website. A cookie does not identify you personally but may identify your Internet service provider or computer. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance.
4. For what purposes do we collect, hold, use and disclose personal information?
4.1 We will only use or disclose your personal information for the primary purposes for which it was collected or as consented to and/or set out below.
4.2 You consent to us using and disclosing your personal information to facilitate a purpose in connection with:
(a) The verification of your identify, if required;
(b) The verification of your date of birth, if applicable;
(c) The provision of our products and services to you;
(d) Facilitating the administration and management of a residential community such as those managed by Halcyon;
(e) Administration and management of our products and services, including charging, billing, credit card authorisation and verification, checks for financial standing, credit worthiness, fraud and collecting debts;
(f) The improvement of our service (including contacting you about those improvements and asking you to participate in surveys about our products and services);
(g) The use of testimonials written by you for marketing purposes;
(h) The maintenance and development of our products and services, business systems and infrastructure;
(i) Marketing and promotional activities by us and our related bodies (including by direct mail, telemarketing, email, SMS and MMS messages) such as our customer loyalty programmes and newsletters;
(j) Providing customer service functions, including handling customer enquiries and complaints;
(k) Offering updates, or other content, or products and services that may be of interest to you;
(l) Our compliance with applicable laws;
(m) The sale, and matters in connection with a potential sale, of our business or company to a third party; and
(n) Any other matters reasonably necessary to continue to provide our products and services to you.
4.3 We will not use or disclose any information about you for other purposes which are not mentioned without your consent. The exception to this may be in exceptional circumstances, such as if disclosure is required by law or is necessary to protect the rights or property of Halcyon or any other member of the public or to lessen a serious threat to a person’s health or safety.
5. Who do we disclose your personal information to and why?
5.1 We may disclose your personal information to organisations outside of Halcyon. Examples of organisations and/or parties that your personal information may be provided to include:
(a) Offshore service providers, if any;
(b) Related entities and subsidiaries of Halcyon;
(c) Third parties, such as banking institutions (required for the selling of your residential dwelling); and
(d) Our contractors and agents, including but not limited to advertisers, utility providers, builders, plumbers and other companies in the construction or trade industry (where necessary) or other companies who assist us in providing our products and services to you.
6.1 We may take photographs of you on the purchase of your home, at functions or other events and intend to use them for marketing and advertising purposes. Unless you advise us otherwise, you expressly agree and consent to the use of any photographs, which may include you, for the previously mentioned purposes.
7. Use of Closed Circuit Television Cameras
7.1 As part of our security system at our Halcyon community, we use closed circuit televisions (CCTV) at certain locations. Use of CCTV is integral to our security system. In some circumstances, a home owner may view the recordings to ascertain who may have been seeking access to their homes. The CCTV images are stored for seven (7) days and may be used if there is a major security incident.
8. Direct Marketing
8.1 You expressly consent to us using your personal information, including any email address you give to us, to provide you with information and to tell you about our products, services or events or any other direct marketing activity (including third party products, services, and events) (Direct Marketing Communications) which we consider may be of interest to you.
8.2 Without limiting clause 8.1, if it is within your reasonable expectations that we send you Direct Marketing Communications given the transaction or communication you have had with us, then we may also use your personal information for the purpose of sending you Direct Marketing Communications which we consider may be of interest to you.
8.3 If at any time you do not wish to receive any further Direct Marketing Communications from us, you may ask us not to send you any further information about products and services and not to disclose your information to other organisations for that purpose. You may do this at any time by using the “unsubscribe” facility included in the email or by contacting us at [email protected] or by writing to us at PO Box 110, Sanctuary Cove Qld 4212.
9. Cross Border Disclosure
9.1 Any personal information provided to Halcyon may be transferred to, and stored at, a destination outside Australia, including but not limited to Canada, where we may utilise overseas data and website hosting facilities or have entered into contractual arrangements with third party service providers to assist Halcyon with providing our goods and services to you. Personal information may also be processed by Halcyon staff or by other third parties operating outside Australia who work for us or for one of our suppliers, agents, partners or related companies.
9.4 If you do not agree to the transfer of your personal information outside Australia, please contact us by email at [email protected] or write to us at PO Box 110, Sanctuary Cove Qld 4212.
10. How do we hold your personal information?
10.1 We have taken steps to help ensure your personal information is safe. You will appreciate, however, that we cannot guarantee the security of all transmissions or personal information, especially where the Internet is involved.
10.2 Notwithstanding the above, we will take reasonable steps to:
(a) make sure that the personal information we collect, use or disclose is accurate, complete and up to date;
(b) protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
(c) destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.
10.3 However, the accuracy of personal information depends largely on the information you provide to us, so we recommend that you:
(a) let us know if there are any errors in your personal information; and
(b) keep us up-to-date with changes to your personal information (such as your name or address).
11. Access to and correction of personal information
11.1 You can request at any time the personal information we hold about you. You can also ask for any corrections to be made or for personal information to be deleted unless we are required by law to retain it. We may keep track of past transactions for our accounting and audit requirements. Furthermore, it may be impossible to completely delete your information because some information may remain as backups.
11.2 If you would like to access, delete or correct any records of personal information we have about you, you are able to access, update and delete that information (subject to the above) by contacting us at [email protected] or by writing to us at PO Box 110, Sanctuary Cove Qld 4212, attention ‘Community Manager’ and we will attempt to resolve the issue. We reserve the right to charge a fee for searching for and providing access to your information.
12. Governing law
13. Resolving your privacy concerns and complaints – your rights
13.1 If you are concerned about how your personal information is being handled, or if you have a complaint about a breach by us of the Australian Privacy Principles, please contact us in writing.
13.2 We will acknowledge your complaint as soon as we can after receipt of your complaint. We will let you know if we need any further information from you to resolve your complaint.
13.3 We aim to resolve complaints as quickly as possible. We strive to resolve complaints within ten (10) business days, but some complaints may take longer to resolve. If your complaint is taking longer, we will let you know what is happening and a date by which you can reasonably expect a response.
13.4 We can be emailed at [email protected] or write to us at PO Box 110, Sanctuary Cove Qld 4212 attention ‘Community Manager’ and we will attempt to resolve the issue.
13.5 If you are unhappy with our response, under the Privacy Act you may make a complaint to the Office of the Information Commissioner about the way we have handled your personal information.
14. Contact Us
14.1 You can contact us by:
Calling: (07) 5509 3777
Emailing: [email protected]
Visiting us at: 1 Halcyon Way, Hope Island Qld 4212
Writing to us at: PO Box 110, Sanctuary Cove Qld 4212