Allure Realty Privacy Policy

Your privacy is important to us.

Brocon Enterprises Pty Ltd trading as Allure Realty ("Allure Realty", "we", "us" or "our") is committed to protecting the privacy and security of personal information that we collect, hold, use and disclose.

We comply with applicable privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs) to the extent they apply to us.

In connection with residential tenancies in Queensland, we also comply with applicable requirements of the Residential Tenancies and Rooming Accommodation Act 2008 (Qld) and associated regulations concerning the collection, use, storage, access and destruction of personal information.

This Privacy Policy explains:

• the kinds of personal information we collect and hold;
• how we collect personal information;
• why we collect, hold, use and disclose personal information;
• who we may disclose personal information to;
• how we manage rental applicant and tenant information;
• how we protect and retain personal information;
• how you can access or correct your personal information;
• how we respond to privacy complaints and data breaches; and
• how you can contact our Privacy Officer.

Personal information generally means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

You are not required to provide us with personal information. However, if you choose not to provide information that is reasonably required, we may be unable to process a rental application, provide property management or real estate services, respond to an enquiry or otherwise provide the service you have requested.

The personal information we collect depends on your relationship and dealings with us.

It may include:

• your name, residential or postal address, email address, telephone number and other contact details;
• identity and identity-verification information;
• date of birth where reasonably required;
• employment, occupation and income information;
• rental history and tenancy information;
• rental, employment and personal references;
• information about your financial capacity where relevant to a tenancy application or transaction;
• bank account and payment information required for authorised payments, rental disbursements or other transactions;
• property ownership, title and property information;
• information relating to property sales, purchases, leasing and management;
• residential tenancy agreements, condition reports, maintenance records and related tenancy documentation;
• photographs, videos or images obtained in connection with property inspections, condition reporting, maintenance or management, which may include images of personal possessions or the condition in which a person lives;
• correspondence, enquiries, complaints and communications with us;
• information obtained from referees, employers, previous property managers, landlords or other authorised third parties;
• website and technical information, including information relating to how our website is accessed and used;
• information relating to suppliers, contractors and professional advisers; and
• information relating to employees and applicants for employment where relevant.

We will only collect sensitive information where it is reasonably necessary for our functions or activities and collection is permitted by law, including where your consent is required and has been obtained.

We generally collect personal information directly from you.

We may collect information through:

• telephone conversations;
• emails and other correspondence;
• our website and online forms;
• property enquiries;
• rental applications;
• property inspections and open homes;
• face-to-face meetings;
• tenancy and property management processes;
• sales and property management documentation;
• third-party property websites, portals and software platforms;
• maintenance and service requests;
• social media communications; and
• other interactions with us.

We may also collect personal information from third parties where it is lawful and reasonable to do so.

These third parties may include:

• property owners;
• previous property managers or landlords;
• employers;
• referees;
• tenancy databases;
• contractors and service providers;
• government and regulatory authorities;
• professional advisers;
• publicly available records and property information; and
• persons whom you have authorised to provide information to us.

Where practicable and lawful, you may interact with us anonymously or using a pseudonym. This will not generally be practicable where we need to establish your identity to provide real estate, tenancy or property management services.

If you provide us with personal information about another individual, you should only do so where you are authorised to provide that information.

We collect, hold and use personal information where reasonably necessary to conduct our real estate and property management business.

This may include:

• responding to enquiries;
• providing property management services;
• advertising and leasing residential property;
• assessing rental applications;
• entering into and managing residential tenancy agreements;
• arranging inspections;
• arranging repairs, maintenance and services;
• managing rental payments, owner disbursements and accounts;
• communicating with property owners, tenants, applicants, buyers and sellers;
• marketing, listing, selling and purchasing property;
• arranging appraisals;
• managing contracts and transactions;
• confirming identity and information provided to us;
• managing complaints and disputes;
• maintaining business and accounting records;
• managing suppliers and contractors;
• complying with legislation, court or tribunal orders and regulatory requirements;
• protecting our systems, staff, clients and business from fraud or misuse;
• improving our services and business operations; and
• sending marketing communications where permitted by law.

We will not use personal information for an unrelated purpose unless you have consented or the use is otherwise permitted or required by law.

Additional requirements apply to personal information collected in connection with residential tenancy applications and residential tenancy management in Queensland.

We may disclose personal information where reasonably necessary for the purposes for which it was collected, for a related purpose you would reasonably expect, with your consent, or where disclosure is authorised or required by law.

Depending on the circumstances, recipients may include:

• property owners and their authorised representatives;
• prospective purchasers or owners where disclosure is lawful and appropriate;
• tradespeople and contractors engaged to inspect, repair or maintain a property;
• employers and referees for rental application verification;
• previous property managers and landlords;
• tenancy database operators where permitted by law;
• insurers and insurance assessors;
• valuers;
• body corporate managers;
• solicitors, conveyancers, accountants and other professional advisers;
• utility and service providers where you have authorised or requested the service;
• government departments and agencies;
• the Residential Tenancies Authority;
• Queensland Civil and Administrative Tribunal and other courts or tribunals;
• law enforcement agencies and regulatory authorities;
• IT, software, cloud storage, communications and data service providers;
• mailing and marketing service providers where appropriate;
• our accountants, auditors and advisers;
• parties involved in an actual or proposed sale, restructuring or transfer of our business, subject to appropriate confidentiality and legal requirements; and
• other persons where you have authorised disclosure or disclosure is required or permitted by law.

When providing personal information to a contractor or service provider, we will take reasonable steps appropriate to the circumstances to protect that information.

We do not sell personal information.

We may send you information about properties, market updates, services, newsletters or other information we reasonably believe may be relevant to you where permitted by law.

You may opt out of marketing communications at any time by:

• using the unsubscribe facility provided in an electronic communication; or
• contacting us.

We will process opt-out requests in accordance with applicable law.

Personal information collected specifically for a rental application or the management of a residential tenancy will not automatically be used for unrelated marketing purposes.

Where consent is required to use that information for marketing, we will obtain consent separately.

Some of the technology and service providers we use may store, process or back up information using infrastructure located outside Australia.

Whether this constitutes a disclosure of personal information overseas depends on the particular service and arrangement involved.

Where we disclose personal information to an overseas recipient and Australian privacy laws require us to take particular steps, we will take reasonable steps to ensure the information is handled appropriately and in accordance with applicable privacy requirements.

The location of technology providers and their data infrastructure may change from time to time. You may contact our Privacy Officer if you would like further information regarding overseas handling of personal information relevant to your dealings with us.

We take reasonable technical and organisational steps to protect personal information from:

• misuse;
• interference;
• loss;
• unauthorised access;
• unauthorised modification; and
• unauthorised disclosure.

Measures may include:

• access controls and password protection;
• secure electronic systems and cloud services;
• restricting access to staff and service providers who require information for their role;
• staff confidentiality obligations;
• reasonable computer, device and network security;
• secure handling of physical records; and
• appropriate confidentiality and privacy requirements for third-party service providers.

Personal information may be held electronically, in cloud-based systems, in physical files and on authorised business devices.

No electronic or internet-based system can be guaranteed to be completely secure. We nevertheless take reasonable steps to protect the information entrusted to us.

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected and to comply with applicable legal, accounting and record-keeping requirements.

When personal information is no longer required and we are not legally required or permitted to retain it, we will take reasonable steps to securely destroy or de-identify it.

Specific destruction requirements applying to Queensland rental applicants and residential tenancies are described in section 5 of this Privacy Policy.

A data breach may occur where personal information is subject to unauthorised access or disclosure, or is lost in circumstances where unauthorised access or disclosure is likely to occur.

If we become aware of a suspected data breach, we will take reasonable steps to:

• contain the breach where possible;
• identify what occurred and what information may be affected;
• assess the risk to affected individuals;
• take appropriate remedial action;
• determine whether notification is required under the Notifiable Data Breaches scheme or any other applicable law; and
• take reasonable steps to reduce the risk of a similar incident occurring again.

Where the Notifiable Data Breaches scheme applies and a breach is likely to result in serious harm to one or more individuals, we will notify affected individuals and the Office of the Australian Information Commissioner where required by law.

You may request access to personal information we hold about you by contacting our Privacy Officer.

We may need to verify your identity before providing access.

We will respond within a reasonable period.

There may be circumstances where we are permitted or required by law to refuse access to some or all of the information requested. Where appropriate, we will explain the reason for the refusal.

We take reasonable steps to ensure personal information we hold is accurate, complete, up to date and relevant.

Please contact us if:

• your personal information changes;
• you believe information we hold is inaccurate or incomplete; or
• you would like us to correct information we hold about you.

We will take reasonable steps to consider and respond to correction requests in accordance with applicable law.

Our website may use cookies and analytics technologies to understand how visitors use the website, maintain functionality and improve our website and services.

Information collected through these technologies may include:

• device and browser information;
• IP address;
• pages visited;
• date and time of visits;
• referring websites; and
• interactions with website features.

Some information may be collected by third-party technology providers.

Most internet browsers allow you to manage or disable cookies. Disabling cookies may affect some website functionality.

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those websites and recommend reviewing their privacy policies separately.

Technology and computer programs may be used in the administration and delivery of our services.

Where we arrange for a computer program to use personal information to make, or substantially assist in making, a decision that could reasonably be expected to significantly affect an individual's rights or interests, we will provide the information required by applicable privacy law in our Privacy Policy.

We will review this section if our use of automated decision-making technology changes.

If you have a question, concern or complaint regarding privacy or the way we have handled your personal information, please contact our Privacy Officer.

Please provide sufficient information for us to understand and investigate your concern.

We will:

• acknowledge and consider your complaint;
• investigate the circumstances where appropriate;
• contact you if we require further information; and
• provide you with our response or determination.

We aim to respond to privacy complaints within 30 days, although more complex matters may take longer. If additional time is required, we will communicate with you about the progress of the matter.

If the Privacy Act applies to your complaint and you are not satisfied with our response, you may be entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC).

We may update this Privacy Policy from time to time to reflect changes to our business practices, technology or legal obligations.

The current version will be published on our website.

Where changes are significant, we may take additional reasonable steps to notify affected individuals.

For privacy enquiries, requests for access or correction, or privacy complaints, please contact:

Privacy Officer
Brocon Enterprises Pty Ltd trading as Allure Realty
PO Box 2768
Nerang QLD 4211

Phone: 07 5573 6600
Email: info@allurerealty.com.au

Please mark written correspondence Attention: Privacy Officer.