In this Policy:
personal information means any information or opinion about a natural person (whether or not true) which is reasonably identifiable;
sensitive information means (without limitation) information about an individual’s race, political opinions, religious beliefs, philosophical beliefs, membership of a trade union, sexual preference, criminal record, or health, genetic or biometric information;
“we” “us” and “our” are reference to EPYC Pty Ltd (ACN 145 377 448); and
“you” and “your” means a natural person whose personal information we have knowingly collected.
2. What personal information we collect
2.1 Personal information is information that can reasonably be used to identify a specific person. Personal information we collect or hold may include your name, telephone or mobile phone number, information obtained from a state land titles office, and any other personal information you or a person ostensibly authorised by you submits to us, as well any other information that we consider is necessary (such as information about your opinions) to perform our functions and activities.
3. How we collect personal information
3.1 We collect personal information in a number of ways, including:
(a) where you provide information directly to us on a hardcopy form;
(b) where you interact directly with our employees and such other persons acting for us or on our behalf, such as our customer service team;
(c) when you participate in a community consultation process in relation to an EPYC project;
(d) where you provide information directly to us during a recruitment process;
(e) from third parties, such as our service providers;
(f) where you provide feedback to us;
(g) from members of your community;
(h) from related entities in our corporate group; and
(i) from publicly available sources of information.
3.2 Where we collect, use and disclose sensitive information about you, we will only do so where it is reasonably necessary to conduct our business and either:
(a) we have obtained your consent; or
(b) it is permitted by law.
(a) in our ability to keep you informed of company updates and services information;
(b) in our ability to properly conduct our operations;
(c) in engaging with you as part of a community consultation process;
(d) in considering your application for employment with us; and
(e) in our ability to respond to your inquiry or request.
4. Purpose of collection, use and disclosure
4.1 We collect, use and disclose personal information for the primary purpose of conducting our business, which includes:
(a) providing and managing the delivery of our services;
(b) delivering service and company update notices to you to inform you about proposed or existing EPYC projects;
(c) assessing a person’s application for employment with us;
(d) improving our services;
(e) responding to an inquiry or request;
(f) resolving disputes;
(g) confirming ownership of land in areas where EPYC projects are located;
(h) research and assessment to improving our services;
(i) engaging with you as part of a community consultation process;
(j) compiling and maintaining mailing lists derived from communicating with the communities where we operate and from publicly available sources of information, and communicating with persons on those lists;
(k) collecting and disclosing personal information to our related entities in connection with our operations;
(l) fulfilling obligations to, and cooperating with, government authorities, including the Department of Planning and Environment;
(m) doing something that one would reasonably expect us to do using the information;
(n) where you otherwise provide your consent, whether express or implied; or
(o) where otherwise required by law.
4.2 In conducting our operations, we may share some of you personal information with third parties such as outsourced service providers and contractors. Unless you have agreed, these parties are not allowed to use your personal information for any other purpose except to assist in conducting our business.
5. Overseas disclosure
5.1 Due to the structure of our business, personal information collected by us may be disclosed to our joint venture partner and non-resident directors in Spain all of whom are considered as team members. In the event that personal information must be disclosed overseas other than as described above, we will endeavour to obtain consent from you.
5.2 Please contact us if you do not wish for your personal information to be disclosed overseas.
6. Direct marketing
6.1 From time to time, we may use your personal information for direct marketing purposes (for an indefinite period). This includes sending you newsletter updates about EPYC projects and services offered by us and our related entities. When we contact you, it may be by mail, telephone, email or SMS.
6.2 Where we use or disclose your personal information for the purpose of direct marketing, we will:
(a) allow you to ‘opt out’ or in other words, allow you to request not to receive direct marketing communications; and
(b) comply with a request by you to ‘opt-out’ of receiving further communications within a reasonable time frame.
6.3 We will only ever contact you for direct marketing purposes where you have consented or where you would reasonably expect us to use your personal information for that purpose.
7. Storage and security of personal information
7.1 Where we hold your personal information, we will take reasonable steps to ensure that the information is secure and may only be accessed by authorised persons. Where we store your personal information electronically on our database, there are restrictions as to who has access to that information through password protection and all access to our database is logged. All hardcopies of personal information are stored in lockable rooms.
7.2 Although we take all reasonable measures, we are not responsible for third party circumvention of security measures on our electronic databases or at any of our premises. Please note that third party recipients of personal information may have their own privacy policies and we are not responsible for their actions, including their handling of personal information.
7.3 We cannot control the actions of other users with whom you share your information. Further, we cannot guarantee that only authorised persons will access your personal information. Please notify us immediately if you believe there has been any unauthorised access to your information.
7.4 If any personal information that we hold is no longer required for the purpose for which it was collected and no applicable law requires us to retain that information, we will take reasonable steps to de-identify or destroy the information.
8. Access and correction
8.1 We will use reasonable steps to ensure the personal information we hold is complete, up to date and accurate, so far as it is practicable for us to do so.
8.2 You may request access to the personal information we hold about you by contacting our Privacy Officer. We may, at our discretion, provide you with access to your personal information and we reserve the right to charge you an inexcessive fee for giving access. We will not disclose your personal information to third parties, unless such disclosure is contemplated by this policy or we obtain your consent.
8.3 Subject to paragraph 8.4, if personal information we hold about you is incorrect, we will, on your request to correct it or where we are satisfied that the information is inaccurate, out of date, incomplete, irrelevant or misleading, take such steps as are reasonable in the circumstances to ensure that the information is corrected.
8.4 If you request us to correct personal information that we hold about you and we refuse to do so, we will, to the extent reasonable, provide you a written response as to our reasons.
9. Questions and complaints
9.1 If you have a question about how we handle personal information, or wish to lodge a complaint about our management of personal information, you may contact our Privacy Officer:Attention: Privacy Officer
EPYC Pty Ltd
Suite 202, Level 2, 10 Help Street, Chatswood NSW
Telephone: + 61 2 9925-8400
9.2 The Privacy Officer will co-ordinate the investigation of any complaint and any potential resolution of a complaint. We will aim to resolve all complaints as soon as practicable for us to do so.
10. Changes to this Policy