In this policy, “us”, “we”, “our”, “TIR” refer to Think Investment Realty Pty Ltd ABN 12 129 431 787 and its related body corporates. This Privacy Policy explains how TIR may collect and use the personally information or personal data (“Personal Information”) that we obtain through your use of our website (www.thinkinvestmentrealty.com.au (the “Site”) and TIR’s online and offline products, and makes you aware of how and why your Personal Information will be used and the rights you have to access and control the use of your Personal Information.
This Privacy Statement (“Statement”) applies to our sites, products, workshops, and services relating to Think Investment Realty (collectively, “Services”) that link to this Statement.
Whenever TIR collects, holds, uses, discloses or otherwise deals with your personal information, we are bound and must comply with Australia’s national privacy laws. These are mainly found in the Privacy Act 1988 (Privacy Act) as amended from time to time, and the Australian Privacy Principles (APPs) in the Privacy Act.
By visiting and/or using this site, participating in our online course you agree to the terms of this policy and you consent to our use and disclosure of your personal information in accordance with this policy.
1 WHAT IS “PERSONAL INFORMATION”?
(a) The Privacy Act 1988 (Cth) currently defines “personal information” as meaning information or an opinion about an identified individual or an individual who is reasonably identifiable:
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- whether the information or opinion is true or not; and
- whether the information or opinion is recorded in a material form or not.
(b) If information does not disclose your identity or enable your identity to be ascertained, it will in most cases not be classified as “personal information” and will not be subject to this privacy policy.
2 WHAT INFORMATION DO WE COLLECT?
The kind of personal information that we collect from you will depend on how you use the website. The personal information which We collect and hold about you may include.
In connection with accessing our Services, we may collect information from you which can be used to identify you (“Personal Information”), such as:
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- your name, shipping/billing address, email address, phone, username and password;
- Employment status;
- credit card and bank account details;
- Information regarding tax and super;
- financial information (including assets and liabilities).
We collect information when you register, sign up for our course or open an account, sign in, pay a bill, purchase a Service, use a Service, call us for support, or give us feedback. We may also get information from other companies or third parties, such as when we may use service providers to supplement the Personal Information you give us (e.g., validate your mailing address) to help us maintain the accuracy of your data and provide you with better service. Finally, we also collect content or other information that you may provide or create when you interact with our Services.
We may also automatically collect certain usage information when you access our Services (“Usage Data”), such as Internet Protocol (“IP”) addresses, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our Services, and other usage information collected from cookies and other tracking technologies. For example, we collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate to our Services. We also collect IP addresses from users when they log into the Services as part of our log-in and security features. We may also, when you enable location-based Services, collect Global Positioning System (GPS) location data and/or motion data.
Our Services may change over time and we may introduce new features that may collect new or different types of information.
3 HOW WE COLLECT YOUR PERSONAL INFORMATION
(a) We may collect personal information from you via telephone, electronic means, meeting with us or whenever you input such information into the website.
(b) We also collect cookies from your computer which enable us to tell when you use the website and also to help customise your website experience. As a general rule, however, it is not possible to identify you personally from our use of cookies.
4 PURPOSE OF COLLECTION
(a) The purpose for which we collect personal information is to provide you with the best service experience possible on the website and to provide you with our course.
(b) We customarily disclose personal information only to our service providers who assist us in operating the website. Your personal information may also be exposed from time to time to maintenance and support personnel acting in the normal course of their duties.
(c) By using our website, you consent to the receipt of direct marketing material. We will only use your personal information for this purpose if we have collected such information direct from you, and if it is material of a type which you would reasonably expect to receive from us.
(d) We do not use sensitive personal information in direct marketing activity. Our direct marketing material will include a simple means by which you can request not to receive further communications of this nature.
(e) We may use your name, address, phone number, and email address to register your account for certain Services we provide and to communicate important information to you. We may obtain additional Personal Information about you, such as address change information, from commercially available sources, to keep our records current.
(f) We may use your information to operate our business, including providing Services you requested, provide you with support related to our Services, and to help us protect our Services, including to combat fraud and protect your information.
(g) We may use your name, address, phone number, email address, how you interact with our Services, and information about your computer configuration to resolve questions you may have about our Services and to follow up with you about your experience. We also offer various Internet chat services, for example, to speak with a TIR support representative. Internet Chat transmissions are encrypted but you should not supply more Personal Information, other than is required to address your specific issue.
(h) We may use your information to communicate with you about our Services and to give you offers for third party products and services that we TIR may be of use to you.
(i) We will use your information to personalize or customize your experience and the Service, develop new features or services, and to improve the overall quality of TIR’s Services.
(j) We may use any information you volunteer in surveys you answer for us and combine them with answers from other customers in order to better understand our Services and how we may improve them. Answering any survey is optional.
5 PROVIDING YOUR PERSONAL INFORMATION TO OTHERS
(a) We may disclose your Personal Information to:
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- any member of our company insofar as reasonably necessary to provide you with our Services, and on the legal bases, set out in this policy.
- to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- our third parties or any other parties we see reasonably necessary in order to provide the services to you.
- Suppliers, contractors, service providers and other third parties with whom TIR have a commercial relationship with, for business, marketing and related purposes.
- To comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.
(b) Financial transactions relating to our website and services may be handled by our payment services providers, Stripe or other payment service providers as we may engage from time to time. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices by visiting their individual websites.
(c) In addition to the specific disclosures of Personal Information set out in this section, we may disclose your Personal Information where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your Personal Information where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6 LINKS
Our website may contain links to other websites. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that we are not responsible for the privacy practices of such other websites. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal information. This privacy policy applies solely to information collected by TIR.
7 ACCESS AND CORRECTION
Australian Privacy Principle 12 permits you to obtain access to the personal information we hold about you in certain circumstances, and Australian Privacy Principle 13 allows you to correct inaccurate personal information subject to certain exceptions. If you would like to obtain such access, please contact us as set out below.
8 COMPLAINT PROCEDURE
If you have a complaint concerning the manner in which we maintain the privacy of your personal information, please contact us as set out below. All complaints will be considered by our privacy office and we may seek further information from you to clarify your concerns. If we agree that your complaint is well founded, we will, in consultation with you, take appropriate steps to rectify the problem. If you remain dissatisfied with the outcome, you may refer the matter to the Office of the Australian Information Commissioner.
9 OVERSEAS TRANSFER
Your personal information may be transferred overseas or stored overseas for a variety of reasons. It is not possible to identify each and every country to which your personal information may be sent. If your personal information is sent to a recipient in a country with data protection laws which are at least substantially similar to the Australian Privacy Principles, and where there are mechanisms available to you to enforce protection of your personal information under that overseas law, we will not be liable for a breach of the Australian Privacy Principles if your personal information is mishandled in that jurisdiction. If your personal information is transferred to a jurisdiction which does not have data protection laws as comprehensive as Australia’s, we will take reasonable steps to secure a contractual commitment from the recipient to handle your information in accordance with the Australian Privacy Principles.
10 GDPR
In some circumstances, the European Union General Data Protection Regulation (GDPR) provides additional protection to individuals located in Europe. The fact that you may be located in Europe does not, however, on its own entitle you to protection under the GDPR. Our website does not specifically target customers located in the European Union and we do not monitor the behaviour of individuals in the European Union, and accordingly the GDPR does not apply.
11 YOUR RIGHTS
In this section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
12 CHANGES TO THIS PRIVACY POLICY
TIR may amend this Privacy Policy from time to time, with or without notice to you. We recommend that you visit our website and read the Privacy Policy regularly to keep up to date with any changes.
13 HOW TO CONTACT US ABOUT PRIVACY
If you have any queries, or if you seek access to your personal information, or if you have a complaint about our privacy practices, you can contact us on 07 5451 1080
