Cubetec’s commitment to privacy
Cubetec Pty Ltd ABN 15 140 585 495 and its members are committed to complying with the Privacy Act 1988 (the Privacy Act) and the Australian Privacy Principles (the APPs).
What is personal information and why do we collect it?
Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not. Examples of personal information we collect include: names, addresses, email addresses, phone and facsimile numbers. In some instances we also collect ownership or tenancy information of individuals or corporations as part of our day to day activities.
We collect your personal information for the primary purpose of conducting the various business activities or functions of Cubetec or its Related Bodies Corporate (as that term is defined by the Corporations Act 2001 (Cth)), which include, amongst other things:
- the provision of property valuation and/or other business advisory services;
- collating and using property or asset information (for valuation and/or other business advisory services);
- planning and conducting marketing campaigns and/or other promotional activities;
- collecting information on people who responded to marketing campaigns;
- assisting with the administration of Cubetec’s operations; and
- future business planning.
Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.
Sensitive information will be used by us only:
- for the primary purpose for which it was obtained;
- for a secondary purpose that is directly related to the primary purpose;
- with your consent; and/or
- where required or authorised by law.
Unsolicited personal information
Where reasonable or practicable to do so, we will collect your personal information only from you. However, in some circumstances we may be provided with information by third parties. In such cases:
- We will take reasonable steps to determine if we could have collected the personal information, and if we could not have, we will, if it is lawful and reasonable to do so, destroy or de-identify it as soon as practicable.
Use and Disclosure of personal information
We use and disclose personal information for the purposes for which we collect that personal information and any directly related purpose, or as required by law. This includes disclosing personal information to:
- data analysis companies, outsourced service providers or other contractors (that will, in some cases, be ‘overseas recipients’ as defined by the Privacy Act) who assist Cubetec in our functions and activities but only to the extent reasonably necessary to assist in those functions and activities;
- Cubetec’s franchisees or Related Bodies Corporate as necessary for the operations or administration of those entities or Cubetec’s business;
- Cubetec’s clients, professional advisers or financiers; or
- Parties involved in a prospective or actual transfer of assets or our business.
Security of personal information
We will take such steps as are reasonable in the circumstances to protect information from misuse, interference, loss and from unauthorised access, modification or disclosure.
When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However, most of the personal information we collect or store is, or will be, used for or retained in records that concern services provided to our clients, which will be kept by us for a minimum of seven (7) years.
Please be aware that no security measures are perfect or impenetrable so Cubetec cannot guarantee that only authorised persons will access or view your personal information.
We cannot ensure that information you share on the Website or provide to us will not become publicly available. We are not responsible for third party circumvention of security measures on the Website, our electronic databases or at any of our premises.
Quality of your personal information
Cubetec will take such steps as are reasonable in the circumstances to ensure that any personal information which we:
- Collect is accurate, complete and up-to-date.
- Use or disclose is accurate, complete, up-to-date and relevant, having regard to the purpose of the use or disclosure.
Access to and correction of personal information
Subject to any exceptions in the APPs, upon request, Cubetec will give an individual access to their personal information. We will give access to the information in the manner requested by the individual, where it is reasonable and practicable to do so. Cubetec reserves the right to reasonably charge the individual for the giving of access to the personal information. If access is refused, we will provide written notice as required by the APPs.
In respect of personal information, if:
- Cubetec is satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out of date, incomplete, irrelevant or misleading; or
- An individual requests that Cubetec corrects the information,
we will take such steps (if any) as are reasonable in the circumstances to correct that information to ensure that, having regard to the purpose for which it is held, the information is accurate, up to date, complete, relevant and not misleading. If Cubetec refuses to correct information.
- We will provide written notice as required by the APPs.
- If the individual requests Cubetec to associate with the information a statement that the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, we will take such steps as are reasonable in the circumstances to associate the statement in such a way that will make the statement apparent to users of the information.
Deal with us anonymously
Where it is lawful and/or practicable, you can deal with us anonymously or under a pseudonym (e.g. general enquiries about the services which Cubetec offers).
The Privacy Amendment (Notifiable Data Breaches) Act 2017 established the Notifiable Data Breaches (NDB) scheme in Australia.
Cubetec will comply with the requirements of the NDB scheme as detailed in the Privacy Act including:
- Assessing whether an Eligible Data Breach (as that term is defined by the Privacy Act) has occurred, and if so, if it gives rise to a “likely risk of serious harm”, and deciding whether or not notification is required to an impacted individual and/or the OAIC.
- In respect of any Eligible Data Breach, liaising with, or providing any required notification to, the Office of the Australian Information Commissioner or other regulators, as required by law.
Complaints or enquiries
If you have any enquiries or wish to make a complaint about the way Cubetec has handled your personal information (including if you think we have breached the Privacy Act), you may do so to our Privacy Officer in writing, by mail or email to the address below. Please include your full name, contact details and a detailed description of your complaint. Our Privacy Officer will acknowledge your complaint and respond to you regarding your complaint within a reasonable period of time. If you consider that we have failed to resolve the complaint satisfactorily, we will provide you with information about the further steps you can take.
Ground floor, 737 Bourke Street
Docklands VIC 3008