Privacy Policy

1. Introduction
This policy sets out how R.W and E.B Sheargold Holdings Pty Ltd and its related companies and trusts ("Sheargold") collects, uses, discloses and manages your personal information and how Sheargold complies with the Australian Privacy Principles contained in the Privacy Act 1988 (the Act) and the Privacy Amendment (Enhancing Privacy Protection) Act 2012.

2. Personal Information
When used in this privacy policy, the term 'personal information' has the meaning given to it in the Act. In general terms, it is any information that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the information Sheargold collects personally identifies you, or you are reasonably identifiable from it, the information will be considered to be personal information.

3. Collection of Personal Information
The information we collect about you depends on the products, services or information that you ask us to provide to you.
• purchasers or potential purchasers (for example, when purchasing a Sheargold development, or when responding to requests for information about a Sheargold development)
• individuals as tenants (for example, when entering into or applying to enter into a lease with Sheargold)
• suppliers or contractors (for example, when establishing records and systems to enable payment for goods or services)
• job applicants (for the purposes of employment)
• individuals as contractors (for example, when establishing records and systems to enable payment for services)
• other individuals who may come into contact with Sheargold

We may collect information such as:

• your name, date of birth, gender and contact details including your, physical address, email address and telephone number
• bank account and credit card details
• information to verify your identity such as your driver's licence number
• information relating to your income and credit-worthiness
• your employment history, if you apply for a job with us
• details of products and services that we have supplied to, or you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries
• your preferences for particular products, services, facilities or lifestyle activities when you tell us what they are
• information about you and your family and any characteristics, preferences or requirements that are relevant to the products and services that we may provide to you
• any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence or otherwise. That information may include information regarding what web pages you access
• information you provide to us through our representatives or customer surveys from time to time

The Privacy Act imposes restrictions on collecting sensitive personal information (this includes information about religious views, ethnicity, political opinions, personal health information). Sheargold generally does not collect sensitive personal information about an individual. However, in certain circumstances, Sheargold may collect some sensitive information if it is necessary to allow Sheargold to deal with the individual and the individual has provided consent for Sheargold to do so.

Whenever it is reasonable and practical to do so, Sheargold only collects personal information directly from the individual. In some circumstances, personal information may be provided to Sheargold by other parties such as the individual’s agent. Sheargold will take reasonable steps to inform the individual that it has the individual’s personal information, unless it is obvious from the circumstances.

4. Cookies
A cookie is a small text file that a website may write to your hard drive when you visit the website. A cookie file can contain information, such as a user ID that the website uses to track the pages you have visited. The only personal information a cookie can contain is information you personally supply. A cookie cannot read data on your hard disk or read cookie files created by other websites.

Sheargold's websites use cookies to track user traffic patterns and whether prior registration information has been provided to better serve you when you revisit the website. You can set your browser to notify you when you receive a cookie, providing you with the opportunity to either accept or reject it. You can also refuse all cookies by turning them off in your browser.

5. Methods of Collection of Personal Information
Sheargold will collect your personal information directly from you unless it is unreasonable or impracticable to do so.

When collecting personal information from you, we may collect it in ways including:

• through your access and use of our websites
• through your enrolment and participation in surveys, questionnaires, competitions and promotions run by or on behalf of Sheargold
• during conversations between you and our representatives
• when you make an enquiry, complete an application or purchase order

We may also collect personal information from third parties including but not limited to, marketing agencies, credit reporting agencies, law enforcement agencies and other government entities.

6. Notification of Collection of Personal Information
When Sheargold collects personal information, Sheargold provides notification of the collection to the individual to inform the individual about the purpose for the collection, the types of entities that the information is disclosed to, the overseas recipients the information is disclosed to (where applicable), and that the Sheargold Privacy Policy contains information about how the individual may access the personal information held by Sheargold and how the individual may make a complaint.

7. Purpose, Use and Disclosure of Personal Information
Sheargold operates the following businesses:

• property development
• investment in and leasing of commercial and industrial property
• investment in and leasing of shopping centres
• investment in residential property
• investment in and leasing of retirement living property

Sheargold collects personal information in order to carry on the above businesses, to provide property-related products and services, to improve our products and services and to communicate with our customers.

Sheargold also collects, holds, uses and discloses your personal information for the following purposes:

• to provide products and services to you and to send information and communications requested by you
• to inform you of updates concerning Sheargold and its products and services
• to provide you with access to protected areas of our websites
• to assess the performance of the website and to improve its operation
• to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties
• for the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of Sheargold and its contractors and service providers
• to provide your updated personal information to our contractors or service providers in order for us to provide our products and services to you
• to update our records and keep your contact details up to date
• to process and respond to any enquiry or complaint made by you
• 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
• assessing the suitability of prospective tenants
• recruiting of employees and contractors

Your personal information will not be shared, sold, rented or disclosed other than as described in this policy.

8. Consequence of not Providing Personal Information
If you decide not to provide Sheargold with the personal information described above, some or all of the following may happen:

• Sheargold may not be able to provide the requested products or services to you, either to the same standard or at all.
• Sheargold may not be able to provide you with information about the products and services that you may want; or
• Sheargold may be unable to tailor the content of its websites to your preferences and your experience of the websites may not be as enjoyable or useful.

9. Direct Marketing Communications
Sheargold may send you direct marketing communications and information about:

• products, services, discounts, competitions and special promotions that we consider may be of interest to you
• offers or promotions based on how you use our products and services
• other companies' products and services (including offers and discounts we've specially negotiated for our customers) we think may interest you, if you've chosen to receive this information

These communications may be sent in various forms, including by telephone, post, fax, email, SMS or by other forms of electronic messages.

You consent to us sending you those direct marketing communications by any of those methods. If you indicate a preference for a method of communication, we will try to use that method whenever practical to do so.

In addition, at any time you may opt-out of receiving marketing communications from Sheargold by contacting us (see the details below) or by using any opt-out facilities provided in the marketing communications. If you opt-out using the opt-out details specified in a marketing communication, we will ensure that your name is removed from the mailing list that we used to send you that particular communication. If you wish to opt-out of other (or all) marketing communications or mailing lists, please see below.

10. Opting out of Marketing Communications
You can opt out if you prefer to not receive direct marketing communications about our latest products, services, promotions and offers. You may wish to opt-out of selected mailing lists or all Sheargold mailing lists.

In order to opt-out, please contact us using the contact details below.

Please note that, if Sheargold is currently providing you with services or products, Sheargold will still need to send you essential information about your account, the relevant services or products and other information required by law.

11. Disclosing Personal Information to Other Parties
Sheargold does not disclose your personal information, except as stated below. Sheargold takes reasonable steps to ensure that third party recipients do not use personal information for their own purposes and that those parties comply with Sheargold's privacy policy.

Parties to whom Sheargold may disclose relevant personal information include:

• consultants, agents or contractors acting on Sheargold's behalf, including real estate and travel agents, marketing agencies, surveyors, conveyancers, builders and property developers
• valuers where Sheargold is seeking to value a property or lease
• panel lenders, lenders mortgage insurers, credit reporting agencies, guarantors;
• regulatory authorities where required by law
• related parties, entities and trusts of Sheargold; and
• parties to whom Sheargold has outsourced various functions; those parties may include the providers of catering and restaurant services, contractors or service providers for the purposes of operation of our website or our business, custodians, IT systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, insurers, insurance brokers, real estate agents, marketing agents, travel agents, claims management services, property management services and professional advisors such as accountants, lawyers and business advisors

If any Sheargold business, company or trust is sold to another organisation, we may transfer any personal information we hold about you to that organisation.

12. Security of Information
Sheargold will take reasonable steps to protect personal information that it holds from unauthorised access, modification, misuse, interference and loss. Personal information is held on secure servers or in storage located in password controlled environments. Sheargold employees are required to maintain the confidentiality of any personal information held. If other parties provide support services, Sheargold requires them to agree to appropriately protect the privacy of the information provided to them.

13. Access and Correction of Personal Information
If you wish to seek access to the personal information we may hold about you, please contact us. Where we hold information that you are entitled to access, we will try to provide you with a suitable means of accessing it (for example, by mailing or emailing it to you).

There may be instances where we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or it would result in a breach of confidentiality. If that happens we will give you written reasons for the refusal.

If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. If you wish to update the personal information that Sheargold may hold, please forward the correct information to us and we will update the information as soon as we are reasonably able. In some unusual cases we may not agree that there are grounds for amending your personal information. If that happens, we will add a note to the personal information stating that you disagree with it.

We will not charge you for simply making the request and will not charge for making any corrections to your personal information. Depending on the nature of the request, we may ask you to verify your identity, put your request in writing and to complete an enquiry form, which will be sent to you.

You may contact us by:

• Email: mail@sheargoldgroup.com; or
• Post: Sheargold, P.O. Box 6423 Frenchs Forest NSW 2086

14. Complaints Process
Sheargold requests that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. We will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After Sheargold has completed its enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if Sheargold has changed its view. If you are unsatisfied with the outcome, Sheargold will advise you about further options including, if appropriate, review by the Privacy Commissioner within the Office of the Australian Information Commissioner.

15. Disclosure of Personal Information Outside Australia
We may disclose personal information to our third party suppliers and service providers located overseas for some of the purposes listed above. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information. We do not sell personal information.

16. Changes to Sheargold's Privacy Policy
Sheargold reserves the right to modify or amend this privacy policy at any time and will update the privacy policy on Sheargold's website if it has been changed. If you have any further questions about Sheargold's privacy policy, please contact us directly.

Last updated 24 September 2014