Privacy

This Privacy Policy applies to Hometown Australia Management Pty Ltd ACN 31 614 528 746 and its related companies and affiliations (“Hometown Australia”, “we”, “our” or “us”). Hometown Australia is a leading operator of Land Lease Communities and is a wholly-owned subsidiary of Hometown America.

This Privacy Policy explains how we manage the personal information we collect and hold about you. How we handle your personal information is governed under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) established under the Privacy Act.

In this Privacy Policy, “personal information” describes information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not, and whether the information is recorded in a material form or not.

This policy applies to information collected from residents within our communities (including their family, guests and representatives), prospective residents as well as employees/staff and contractors.

What kinds of personal information do we collect?

The types of personal information we may collect include, but are not limited to:

• your name, date of birth and address (PO boxes, home and work addresses)
• contact telephone numbers, fax numbers and email addresses
• any correspondence between Hometown Australia, its’ representatives and you
• personal information provided to us when you make an inquiry, request information, respond to marketing or lodge a complaint posts on social media.
• information collected from background or police checks The Privacy Laws impose more onerous obligations on us regarding the handling of your sensitive information. We will only collect your sensitive information if you have expressly consented to us doing so
• health information.

If you are a resident or guest of one of our Communities, we may also collect:

• contact and identification details of any third party you have authorised to negotiate or provide your personal information on your behalf (including any family members, legal advisers, or attorneys appointed by you under a power of attorney)
• your banking or payment details (for example, for payment of services or site fees)
• we may also collect sensitive personal information about you, such as health information which may include any illness, injury or disability you may have and any treatment or medication that you are receiving
• we are permitted to do so under the APPs (for example, where the collection is necessary to lessen or prevent a serious threat to life, health or safety, or to provide a health service to you) or we are required or authorised to do so by law
• contact numbers in case of emergency
• responding to your requests and inquiries, including providing you with any information requested by you
• processing your application for residency with us
• managing and maintaining our communities.

If you are an employee, contractor, business partner, service provider, job applicant or visitor on our site, we may also collect:

• personal information provided when you commence or seek to commence employment or enter into a business relationship with us
• personal information obtained from background screening providers (including credit checks) before you commence employment or enter into a business relationship with us;
• health information including details of any allergies or dietary requirements you have or other medical conditions which you consider important for us to be aware of
• banking, tax and superannuation funds details (including your tax file number and ABN if applicable)
• criminal record information obtained through our screening processes before you commence, or during the course of your employment or business relationship with us.

How do we collect personal information?

We may collect your personal information in a variety of ways, for example:

• directly from you, such as when you correspond with us in writing (such as by letters and emails), request information or contact us through our website or by telephone, provide your business card or other documents to us (such as application forms) or meet with us in person
• from third parties we deal with, such as relatives, powers of attorney, our professional advisers, contracted service providers, health care providers or any other organisation with whom we do business
• from third party websites we advertise on, such as contact forms on realestate.com.au and downsizing.com.au
• if you provide us with personal information about another person, you must ensure that you are authorised to do so. You must also inform that person of who we are, that we will use and disclose their personal information in accordance with this policy, and that they can gain access to that information in accordance with this policy.

Why do we or would we collect, hold, use and disclose your personal information?

We may collect, hold, use and disclose your personal information to provide you with the services and information you request, and to perform our functions and activities. If you do not provide us with the information we request, we may be unable to provide you with a service or maintain a relationship with you. In particular, we may collect, hold, use and disclose your personal information for the purposes of:

• maintaining and updating our records, where required
• providing access to our website
• any other purpose which relates to or arises out of requests made by you
• responding to any complaint you have raised with us
• doing anything which you authorise or consent to us doing
• taking any action we are required or authorised by law to take.

If you are an employee, contractor, business partner, service provider, job applicant or visitor on our site, we also collect, hold, use and disclose your personal information for the purposes of:

• assessing your application for employment
• your employment relationship with us
• your business or other professional relationship with us.

Who may we disclose your personal information to?

Our employees:

• to health care professionals or other individuals (such as family members or carers), with your consent or where required or authorised by law
• your representative, for example, lawyer or attorney, as authorised by you
• our business partners and service providers, for example, IT and administrative service providers
• our professional advisers, such as insurers, accountants, auditors and lawyers
• government and regulatory authorities, including taxation authorities or the police, where required or authorised by law to disclose your personal information
• social media sites and organisations (such as Facebook) and other virtual communities and networks where people create, share or exchange information
• other entities, with your consent (either express or implied).

From time to time, we may disclose your personal information to entities outside of Australia, including other companies within the Hometown Corporate Group primarily in the United States.

We will take reasonable steps to ensure that any overseas entity to whom we disclose your personal information is carefully chosen and has policies, procedures and systems in place to ensure your personal information is otherwise handled in accordance with the Privacy Act.

Dealing with Hometown Australia online

This Privacy Policy applies to your use of our website www.hometownaustralia.com au and any personal information you may provide to us via our website.

When you visit our website, we may collect certain information about your visit including the time and date of your visit, any information or documentation that you download, your IP address, your browser type, domain names, referring website address and internet protocol details of the device used to access the site and cookies. For further information, please refer to the Disclaimer and Privacy Policy on our website.

Our website may contain links to other websites which are outside our control and are not covered by this Privacy Policy. If you access other websites using the links provided, the operators of these websites may collect information from you which will be handled in accordance with their privacy policy. 

Security of your personal information

We may hold your personal information in many ways including in physical documents as well as in electronic form. The security of your personal information is important to us and we will take reasonable steps to protect your personal information from misuse, interference and loss, and from unauthorised access, modification and disclosure. We have implemented policies, procedures and systems to keep your personal information secure.

We will take reasonable steps to destroy or de-identify personal information where we no longer require the information, or we are no longer required by law to retain that information.

Access and correction of information

In general, you may request access to the information that we hold about you at any time by either contacting your community manager (if you are a resident or guest) or by using our details provided below. We will respond to your request for access within a reasonable time. If we refuse to give you access to any personal information, we will provide you with reasons for our refusal and the relevant provisions of the Privacy Act we rely on to refuse access.

We may recover the reasonable costs of our response to a request for access to personal information.

We take reasonable steps to make sure that the information that we collect, use or disclose is accurate, complete, up-to-date, relevant and not misleading. However, if you believe your information is incorrect, incomplete or not current, you can request that we update this information by contacting your community manager (if you a resident or guest) or by using our details provided below. We will respond within a reasonable period after the request is made. If we decide not to correct your personal information, we will provide you with reasons for our decision. You may request that we associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading.

Lodging a complaint

If you have a complaint about how we have handled your personal information, you can either contact your community manager (if you are a resident or guest) or contact us using the contact details below. You may wish to consider putting your complaint to us in writing. This will help us understand your complaint and may assist you if you wish to take your complaint further (for example by going to the Australian Information Commissioner). We will acknowledge receipt of your complaint and endeavour to provide a response within a reasonable timeframe.

If you are not satisfied with how your complaint is handled by us, then you may lodge a formal complaint with the Office of the Australian Information Commissioner at:

• Telephone 1300 363 992 (if calling from outside Australia including Norfolk Island please call +61 2 9284 9749)
• If you are deaf or have a hearing or speech impairment, contact the Office of the Australian Information Commissioner through the National Relay Service:
• TTY users phone 133 677 then ask for 1300 363 992
• Speak and Listen users phone 1300 555 727 then ask for 1330 363 992 
• Internet relay users connect to the National Relay Service then ask for 1300 363 992
• Post: Office of the Australian Information Commissioner, GPO Box 5218, SYDNEY NSW 2001
• Fax: +61 2 9284 9666
• Email: enquiries@oaic.gov.au
• Website privacy complaint form: https://forms.business.gov.au/aba/oaic/privacy-complaint-/

Contacting us

If you wish to contact us regarding our handling of your personal information or any of the matters covered in this Privacy Policy, please either contact your community manager (if you are a resident or guest of one of our Communities) or contact us:

• by post at Hometown Australia, Level 2, 117 Clarence Street, Sydney NSW 2000
• via email info@hometownaustralia.com.au.

Hometown Australia is committed to protecting your privacy and welcomes your comments regarding this Privacy Policy.

Changes to this policy

Hometown Australia reserves the right to amend this Privacy Policy from time to time. In the event that amendments are made to this Privacy Policy, the amended version will be posted on our website https://www.hometownaustralia.com.au/ and will be effective from the date of posting.

This Privacy Policy was last updated March 2018.