PRIVACY POLICY – LAST UPDATED JUNE 2020
Lease Equity Pty Ltd ABN 54 108 751 661 (Lease Equity, ‘we’, ‘us’ or ‘our’) is committed to protecting the information provided to us and respecting the trust of our stakeholders. This includes all personal information that you provide to Lease Equity. Lease Equity is bound by the Australian Privacy Principles in the Privacy Act 1988 (Cth). This Privacy Policy outlines how we collect and use your personal information.
WHAT INFORMATION IS COLLECTED AND HOW DO WE COLLECT IT?
We collect personal information about you in order to provide you with our services. You may choose whether to provide us with this information, however your choices may affect our ability to offer you part or all of our services.
Personal information we collect may include (as, and where, applicable):-
Identity Information: Whenever you send us an email, communicate with us, request or submit information or make an application to Lease Equity, including completing any forms electronically or in person, Lease Equity collects identity information including your name, email address, gender or date of birth (as supplied by you);
Financial Information: When you inquire about our goods and services, place an order online, have services provided by us or purchase our goods and services we collect financial information, which may include bank details, credit card details or other billing information in order to facilitate payments to us and to receive invoices;
Delivery Information: When you purchase goods and services from us we may collect information such as your address for the purposes of delivery;
Communication Information: When you communicate with us via telephone, email, SMS or online, we may collect any information that you choose to provide us;
Preference Information: When you enter a promotional competition or participate in other promotions we offer, or otherwise engage with our services and advertisements, including responding to any questions we may ask or leaving reviews and comments, we may collect information about you opinions or preferences that you choose to provide us;
Historical Information: Over the course of your engagement with us, including your entry into our promotions and your history of purchasing, or enquiring about, goods or services from us, we will collect records and details of your prior engagement with us;
Employment Information: When you apply for a job with us we may collect personal information included within your resume and application form, including you profession or job position, experience level, education and qualifications, employment history, tax file number and working entitlement status or availability;
Third Party Information: Wherever reasonable and practical to do so, we will collect personal information about you directly from you. However, in some cases we may be required to collect personal information about you from third parties, such as our business associates, regulatory bodies or other third parties you direct us to. This may include information provided to businesses we partner with to provide our services to you, information about you provided by referees in the context of an employment application or confirmation of your identity from regulatory bodies or agencies, among others. Where we collect information about you from a third party, we will take reasonable steps to ensure that you are made aware of the fact and circumstances of that collection. We may also receive information from third parties where you have authorised the third party to provide such information to us;
Cookie Information: We use cookies and similar tracking technologies on our website in order to track the use, and interaction with, our website and maintain and improve our services to you. Further information on cookies and online data collection is contained in the “IP Address and Cookies” paragraph below;
Third Party Plugin Information: In some cases, we may have integrated a third party plugin into our website. The use of such third party plugins may result in data collection by both us and the relevant third party. We do not control the information you share with third parties via these plugins. You should refer to the third party’s privacy policy to understand their data handling practices. Further information regarding these plugins is contained in the “Remarketing” paragraph below; and
Sensitive Information: Other than any sensitive information that may be provided inadvertently in the course of the provision of information in the categories above, we will not collect any information that is ‘sensitive information’ under the Privacy Act. In the event that we need to collect any ‘sensitive information’ in order to provide our services to you, we will only do so with your consent or as otherwise permitted by law.
We collect personal information to enable us to provide you with our on-line services, conduct business with you or process your job application. We will only request and use personal information that is necessary for the conduct of our business.
If you don’t supply the information, we request from you, we may not be able to process your transaction including leasing, purchasing or selling a property , deliver your purchases, provide you with information you have requested, accept your entry into promotional competition or consider your job application. We will let you know at the time of collection which information we need to collect and which information you only need to provide us on an optional basis.
By using the website, providing details to us via any other medium (including in-store) or applying for a job with us, you are consenting to the collection and use of this information in accordance with this Privacy Policy.
WHY DO WE COLLECT YOUR INFORMATION AND HOW DO WE USE IT?
We collect your personal information in order to carry out our business operations in the most professional and efficient manner possible. We use your information for the purpose for which it was collected, which may include any of the following:-
to conduct our business with you;
to facilitate the manager dealings and relationships with you;
to notify you occasionally about important changes to the website, new products and services and special offers we think you may find valuable;
to request that you write to review a recent purchase;
to carry out our obligations arising from any contracts entered into between you and us;
to allow you to participate in, to administer, and to contact you regarding any promotions you may have entered with us;
to allow you to participate in interactive features of our services, when you choose to do so;
for research purposes;
to contact you for response and messages or email;
to send you information you request; and
for any other purpose for which you disclose your personal information to us.
Where your personal information is not ‘sensitive information’ we may also use your information for reasonably expected secondary purposes related to the above. In addition we may use your personal information as otherwise authorised by law.
WHEN DO WE DISCLOSE YOUR INFORMATION?
Lease Equity does not sell, trade or rent any of the personal information provided to us. We will only disclose your information to the extent required to provide our services to you, for the purposes outlined in the “Why Do We Collect Your Information and How Do We Use It?” paragraph above or as otherwise requested or authorised.
In particular we may disclose your personal information to third parties in the following circumstances:-
to pass the information to our affiliates or certain suppliers or sub-contractors (some of which may have services located in countries other than Australia, such as Asia, USA, UK and Europe) to supply information requested by you, or to administer marketing, research or promotional programs where you have consented to receiving marketing or promotional material (with respect to which, any such disclosure will be provided on the basis that any recipient will be required to treat your information as confidential and will be forbidden from on selling information or using it in any other way than as requested by Lease Equity);
send you promotional material by post or email where you have indicated your preference and consent to receipt;
to send you any items you order from us;
to enforce or apply terms of agreements with you;
to protect the rights, property or safety of Lease Equity, our users or others;
if we sell or buy any business or assets, in which case we may disclose your personal information to the buyer or seller of such business or assets; or
if you are under a duty of disclosure or you share your personal information and enquire with us with regarding any legal obligation, to enforce the terms of agreement we have with you or where we need to protect our rights, property or safety of our clients or employees, we may exchange information with other companies and organisations, such as law enforcement or legal advisers, in these contexts or for the purpose of responding to such circumstances, including forward prevention.
Overseas data TRANSfers
In connection with providing our services to you, we may store, use or disclose your personal information in countries outside of Australia for the purposes described in paragraph 3(a) above and for general data-processing and storage purposes. Currently we do not disclose any information overseas, however this could change and we may disclose information to our partners and service providers in jurisdictions such as the US, UK, Europe or Asia. In the event we disclose information overseas, this Privacy Policy will be updated and further information regarding that disclosure provided.
We will not send your personal information to recipients outside of Australia without first:
taking reasonable steps to ensure that the overseas recipient complies with the Australian Privacy Principles and this Privacy Policy;
obtaining your consent; or
otherwise complying with the Privacy Act.
By reviewing this Privacy Policy and using our services, you consent to any such overseas transfers, provided that they are otherwise in accordance with this Privacy Policy.
HOW WE HANDLE INFORMATION
We take reasonable steps to protect personal information held by us from misuse, loss or unauthorised access, modification or disclosure.
Personal information we collect and hold is stored on secure servers and is only accessible by those persons who need access to the information or in order to carry out our services. We also maintain physical security measures to protect the use and storage of physical records containing your personal information.
We will only retain your information for as long as required for the purposes we use your information in accordance with the Privacy Policy, or to comply with legal obligations or resolve disputes. We will take reasonable steps to destroy or de-identify your personal information when we are no longer permitted to keep it.
DIRECT MARKETING
We will only send you direct marketing materials and other information where you have “opted in” to receive such communications from us. If you change your mind or do not want to receive this information in the future, then please let us know by clicking the Unsubscribe button at the bottom of our promotional communication.
IP ADDRESS AND COOKIES
Our website automatically collects certain information when you visit it. This includes, where available, your internet protocol address, operating system and browser type, and other details of data downloaded from our server. Although in some circumstances, it may be possible to identify you from this information, we do not attempt to use this information for that purpose. The information is used for system administration, statistical analysis and similar related purposes.
For the same reason, we may obtain information about your general internet usage while using a Cookie filter which is stored on the hard drive of your computer. Cookies contained information that is transferred to your computer hard drive. They help us to improve our website and to deliver better and a more personalised service. They enable us:-
To estimate our audience size and usage patterns;
To store information about your preferences, and allow us to customise our website according to individual needs and interests;
To speed up your searches; and
To recognise you and automatically log you on when you return to our website.
You may refuse to accept Cookies by activating the setting on your browser which allows you to refuse the setting of Cookies. If you select this setting, you may be unable to access certain parts of our website or order on-line from us. Unless you have adjusted your browser settings so that it will refuse Cookies, our system will issue Cookies when you log on to our website.
REMARKETING
We use remarketing with Google analytics and other partners to advertise online. Third party vendors including Google, show our ads on sites across the internet. Third party vendors including Google, use third party Cookies (such as Google analytics Cookies) and third-party Cookies (such as the double click Cookie) together to inform, optimise and serve, based on someone’s past business to our website.
HOW CAN YOU UPDATE YOUR PERSONAL PREFERENCES AND INFORMATION AND WHAT RIGHTS DO YOU HAVE?
We encourage you to regularly update your own details as often as possible. To do this, simply contact Lease Equity and ask to speak to one of our accounts administrators or email your request to mdpa@lease-equity.com.au.
You are entitled to access the personal information we hold about you and may request that we correct any errors in the information we hold. If you want to understand the information that we are currently holding about you, then please contact our Managing Director on mdpa@lease-equity.com.au. We will take reasonable steps to allow you to access your information unless circumstances exist that would prohibit use from doing so. Should we deny access to any personal information, you will be advised why.
We will correct your personal information where we are satisfied that the information is inaccurate, out of date, incomplete, irrelevant or misleading. If we correct any personal information that we have disclosed to third parties we will take reasonable steps to notify those parties of the change or update.
Please note, you will need to pass a number of security filters to provide proof of identity in advance, which may include confirmation with third parties.
AMENDMENT OF THIS PRIVACY POLICY
From time to time we will need to change our Privacy Policy. Any changes that Lease Equity applies to the Privacy Policy will be displayed on our website. If we amend our policy, your level of protection will not be diminished and we will continue comply with the Privacy Act. We ask that you periodically visit this site to review the current terms of the Privacy Policy.
CONTACTING US
If you have any queries regarding our Privacy Policy or would like any matter explained relating to your personal information that we have collected about you or have any complaints on how we have handled your personal information, please contact our Managing Director via the following: –
Phone: 08 94261777
Post: PO Box Z5633, St George’s Terrace, Perth WA 6831
Email: mdpa@lease-equity.com.au
If you have a complaint, you will need to provide our Managing Director with sufficient evidence and information to conduct an investigation and determine the necessary steps that will be taken to resolve your complaint. Our Managing Director will contact you if any further evidence or information is required from you.
You will be advised of the outcome of the investigation. If you are unhappy with the outcome, you can contact us to discuss your concerns or you may want to contact the Australian Privacy Commissioner via www.oaic.gov.au.