This policy sets out how Easy Wealth Pty Ltd trading as SOLOVEY (Solovey) and its related companies and trusts collects, uses, discloses and manages the personal information you provide and how Solovey complies with its obligations under the Privacy Act 1988 (Cth) ("Privacy Act").
If you have any queries or complaints regarding your personal information, please contact our Privacy Officer using the contact details listed below.
What is your personal information?
When we refer to 'personal information' we mean personal information as defined in the Privacy Act. In simple terms, this means any information that can be used to personally identify you or from which you may be reasonably identifiable. This may include your name, address, telephone number, email address and profession or occupation.
What personal information do we collect?
The information we collect about you depends on the products, services or information that you are interested in or ask us to provide to you. We may collect information such as:
- your name, date of birth, gender and contact details including your, street address, email address and telephone number(s);
- bank account and credit card details;
- information to verify your identity such as your driver's licence number;
- information relating to your income and expenses, assets and liabilities and credit-worthiness;
- 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 or services when you tell us what they are;
- information about you and your family and your financial circumstances that are relevant to the products and services that we may provide to you;
- information relating to any loan statement in relation to any loan provided by Solovey to you; and
- information you provide to us through customer surveys from time to time.
How is your personal information collected?
Solovey 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, customer loyalty programs and promotions run by or on behalf of Solovey;
- during conversations between you and our employee and representatives; or
- when you make an enquiry, complete an application or attend an interview with us.
We may also collect personal information from third parties including from our related companies, third party companies including but not limited to, banks, credit reporting agencies, law enforcement agencies and other government entities.
What happens if Solovey cannot collect your personal information?
If you decide not to provide Solovey with the personal information described above Solovey's ability to provide products, services and information may be limited or precluded altogether. Specifically, we will not be able to assess your suitability to purchase a home.
For what purposes does Solovey collect, hold, use and disclose your personal information?
Solovey collects personal information in order to carry on its business as a property developer and to sell homes and potentially other property related products, services and advice.
Personal Information may also be disclosed between Solovey's businesses, related companies and trusts.
Solovey also collects, holds, uses and discloses your personal information for a range of purposes which may include:
- providing products and services to you and to sending information and communications requested by you;
- providing you with newsletters and informing you of updates concerning asy Wealth Pty Ltd and its products and services;
- conducting business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
- the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of asy Wealth Pty Ltd and its contractors and service providers;
- providing your updated personal information to our contractors or service providers in order for us to provide our products and services to you;
- updating our records and keeping your contact details up to date;
- responding to any enquiry or complaint made by you;
- for risk management purposes including incident investigation, claims management and litigation; and
- complying with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority.
Your personal information will not be shared, sold, rented or disclosed other than as described in this policy.
Solovey 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 Solovey by contacting us or by using the opt-out facilities provided in the marketing communications. If you opt-out 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 let us know.
Opting out of direct marketing
You can opt out if you prefer to not receive direct marketing communications from us. You may wish to opt-out of selected mailing lists or all Solovey mailing lists.
In order to opt-out, please use the opt out facility in the communication or contact our Privacy Officer.
If you are a customer of Solovey you will not be able to opt out of receiving account statements or other information and communications that are required by law to be sent to you or otherwise essential to the management of your account of the provision of services to you.
To whom does Solovey disclose personal information?
Parties to whom Solovey may disclose relevant personal information include:
- consultants, agents or contractors acting on Solovey's behalf, including real estate agents, marketing agencies, surveyors, conveyancers, builders and property developers;
- valuers where Solovey is seeking to value a property or other asset;
- panel lenders, lenders mortgage insurers, credit reporting agencies, guarantors;
regulatory authorities where required by law;
- related parties, entities and trusts of Solovey; and
- parties to whom Solovey has outsourced business processes or functions. Those parties may include contractors or service providers for the purposes of operation of our website or our business, information technology systems administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, insurers and insurance brokers, real estate agents, marketing agents, claims management services, property management services and professional advisors such as accountants, lawyers and business advisors.
If any Solovey business, company or trust is sold to a third party organisation, we may transfer any personal information that we regard as proper or relevant that we hold about you to that organisation.
Security of information
We take steps to ensure that employees are only able to access the information they require for their duties.
Access and correction of personal information
If you wish to seek access to the personal information we may hold about you, please contact our Privacy Officer. Where we hold information that you are entitled to access, we will 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 ask us to amend it. If you wish to update the personal information that Solovey may hold please advise us in writing. In some cases we may not agree to amend 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 requesting or effecting 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, in where appropriate, provide suitable evidence to support your request.
You may contact our Privacy Officer by emailing firstname.lastname@example.org
What is the process for complaining about a breach of privacy?
Complaints about breaches of privacy should be made in writing and directed to our Privacy Officer. We will attempt to confirm 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.
After Solovey 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 Solovey has changed its view. If you are unsatisfied with the outcome, Solovey will advise you about further options including, if appropriate, initiating a review by the Privacy Commissioner within the Office of the Australian Information Commissioner.
Do we disclose your personal information outside Australia?
We may disclose personal information to our related bodies corporate and third party suppliers and service providers, some of who may be 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 may disclose personal information to entities outside Australia, including date hosting and other IT service providers.
Solovey takes reasonable security measures to protect personal information from loss, unauthorised access, destruction, misuse, modification or disclosure.
Last updated September 2016