Connected Property Services Pty Ltd

Privacy Policy

In this privacy policy, reference to “CPS” is a reference to Connected Property Services Pty Ltd ABN 79 672 079 444 and references to “you” (or similar personal pronoun) is a reference to the person about whom CPS collects information under this privacy policy.

This privacy policy applies to personal information, including sensitive information, and credit related personal information (“credit related information”) collected by CPS. CPS is bound by the Privacy Act 1988 (Cth)(“Privacy Act”), which governs the way private sector organisations collect, use, keep secure and disclose personal information. CPS is also bound by the Spam Act 2003 (Cth) (“Spam Act”) which governs the way CPS conducts some of its direct marketing activities.

This privacy policy is to inform people of:

• how and when CPS collects personal and credit related information;
• how CPS uses and discloses personal and credit related information;
• how CPS keeps personal and credit related information secure, accurate and up-to-date;
• how an individual can access and correct their personal and credit related information; and
• how CPS will facilitate or resolve a privacy complaint.

If you have any concerns or complaints about the manner in which your personal or credit related information is collected, used or disclosed by CPS, CPS has put in place an effective mechanism and procedure for you to contact CPS so that CPS can attempt to resolve the issue or complaint.

Please note that the CPS website may contain links to other websites. When a user has clicked on a link to another site, they leave the CPS site and are no longer protected by this privacy policy.

CPS recommends that you keep this information for future reference.

1) What is personal information?

a) The Privacy Act defines “personal information” to mean information or an opinion, whether true or not, and whether recorded in a material form or not, about an individual whose identity is reasonably identifiable, from the information or opinion.

2) Sensitive Information

a) What is Sensitive Information?

1. Sensitive information is a subset of personal information. It means information or opinion about an individual’s racial or ethnic origin, political opinions, membership of a political organisation, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, health information about an individual, genetic information, biometric information that is to be used for the purpose of automated biometric verification or biometric identification or biometric templates.
2. In general, CPS seeks to limit the collection of sensitive information CPS may collect from you, but depending on the use you make of CPS services, this may not always be possible and CPS may collect sensitive information from you in order to carry out the services provided to you. However, CPS does not collect sensitive information from you without your consent.
3. The type of sensitive information CPS may collect from you or record about you is dependent on the services provided to you by CPS and will be limited to the purpose(s) for which it is collected. CPS does not use sensitive information to send you Direct Marketing Communications (as defined in paragraph 7 below) without your express consent.

3) Consent to collection of certain types of sensitive information

a) While CPS does not provide credit and is not engaged in credit activities, CPS may collect certain types of sensitive information where you have consented and agree to the collection of such information.

4) What is credit related information?

a) Credit related information is broadly defined under the Privacy Act, but relevantly includes personal information, that is: identification information and the type of credit and commercial credit sought by an individual or which an individual may access, and the credit record of that individual.

5) Collection of your personal and credit related information

a) CPS only collects personal and credit related information that is necessary for what CPS does and CPS holds the personal and credit related information CPS collects within its own data storage devices or with a third party provider of data storage. The type of information CPS may collect from you depends ultimately upon the purpose of collection and CPS set out the general purposes of collection at paragraph 6 below.

b) The type of personal information CPS may collect from you includes (but is not limited to) the following:

1. your contact information such as full name (first and last), e-mail address, current postal address, delivery address (if different to postal address) and phone numbers;
2. details of the property address to be enrolled in the service, contact information of the property’s occupants (such as full name, e-mail address, phone numbers), contact information of who manages the property;
3. information concerning or relating to your purchases of services over this website;
4. financial and billing information (such as a credit card number /expiration date / security code, bank account details, billing address, repayment information and invoice details and purchasing history);
5. proof of your identity (including, but not limited to, date of birth, driver’s licence, passport, birth certificate);
6. your opinions, statements and endorsements collected personally or via surveys and questionnaires, including but not limited to your views on the services offered by CPS; and
7. your participation in, or response to, CPS’s marketing and promotional activities, such as entering into a promotional contest.
8. CPS may also collect and hold the following credit related information:
   1. identification information – name, date of birth, current or previous address, driver’s licence number;
   2. type and amount of credit sought by you from credit providers;
   3. trade references – name of entity, ABN, contact name, telephone number, fax number, email, years trading with you;
   4. publicly available information about an individual’s creditworthiness;
   5. consumer credit liability information – name of credit provider, type of consumer credit, details of the consumer credit provided;
   6. default information;
   7. repayment history information; and
   8. payment information in relation to an overdue amount.

c) Your personal and credit related information may be collected in a number of ways, including:

1. directly by CPS staff when you seek, or enquire about, CPS services; or
2. when you use the CPS website or complete a form on the CPS website.
3. via an authorised integration with a third-party real estate software program such as PropertyMe.

d) As much as possible or unless provided otherwise under this privacy policy, CPS will collect your information directly from you. In some circumstances, where it is unreasonable or impractical to collect information from you, CPS may collect information about you from a third party source. For example, CPS may collect information from a publicly maintained record or from credit providers, subject to any restrictions at law. If CPS collect details about you from someone else, CPS will, whenever reasonably possible, make you aware that CPS has done this and why. CPS may also collect personal or credit related information about you when it is provided by third parties with your consent. Typically, CPS will seek consent for the use or disclosure of your personal and credit related information at the time of collection. In certain circumstances, CPS may seek your consent to a new use or disclosure of your personal information after your information has been collected, but before CPS engages in such new use or disclosure.

e) When you engage in certain activities, such as entering a contest or promotion, filling out a survey or sending CPS feedback, CPS may ask you to provide certain information. It is completely optional for you to engage in these activities.

f) Depending upon the reason for requiring the information, some of the information CPS asks you to provide may be identified as mandatory or voluntary. If you do not provide the mandatory data or any other information CPS requires in order for CPS to provide its services to you, CPS may be unable to effectively provide its services to you.

g) If you use the CPS website, CPS may utilise “cookies” which enable CPS to monitor traffic patterns and to serve you more efficiently if you revisit the CPS website. A cookie does not identify you personally but may identify your internet service provider or computer. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance.

h) CPS may gather your IP address as part of its business activities and to assist with any operational difficulties or support issues with its services. This information does not identify you personally.

6) How CPS may use and disclose your personal and credit related information

a) CPS will only use or disclose your information for the primary purposes for which it was collected or a purpose related to the primary purpose or the purposes otherwise described in this policy, if this use would be reasonably expected by you or otherwise with your consent on a reasonable reading of this policy.

b) CPS collects, holds, uses and discloses your personal and credit related information to facilitate a purpose in connection with:

1. if required, the verification of your identity;
2. the provision of CPS services and any ancillary or secondary services to you, which shall include but is not limited to:
   1. the administration and management of CPS services and any ancillary or secondary services, including charging, delivery, billing, credit card authorisation and verification, checks for financial standing, credit-worthiness (including but not limited to undertaking an assessment for credit loss and obtaining credit references, if applicable), fraud and collecting debts; and
   2. to offer you updates, or other content or products and services that may be of interest to you (unless as directed otherwise);
3. facilitating the administration and management of CPS, including but not limited to the use of your personal information collected in accordance with paragraph 3.1 in the administration and management of CPS;
4. the improvement of CPS services (including to contact you about those improvements and asking you to participate in surveys about CPS services and any ancillary or secondary services including anonymous comparative research unless as directed otherwise);
5. the maintenance and development of CPS services and any ancillary or secondary services, business systems and infrastructure;
6. marketing and promotional activities by CPS and its related bodies (including by direct mail, telemarketing, email, SMS and MMS messages, and advertisements on social media) such as CPS newsletters (unless as directed otherwise);
7. marketing and promotional activities by CPS (including by direct mail, telemarketing, email, SMS and MMS messages, and advertisements on social media) that promote the goods and/or services provided by CPS commercial partners that may be of interest to you (for which CPS may derive a commercial benefit from); (unless as directed otherwise);
8. to provide customer service functions, including handling customer enquiries and complaints, to offer you updates, or other content or products and services that may be of interest to you (unless as directed otherwise);
9. CPS’s compliance with applicable laws;
10. the sale, and matters in connection with a potential sale, of the CPS business or company to a third party;
11. any other matters reasonably necessary to continue to provide CPS services and any ancillary or secondary services to you including the ongoing business development of CPS; and
12. other purposes related to any of the above.

c) CPS may also use or disclose your personal and credit related information without seeking your additional consent:

1. if CPS reasonably believe that the use or disclosure is necessary to lessen or prevent a serious or imminent threat to an individual’s life, health or safety or to lessen or prevent a threat to public health or safety;
2. if CPS has reason to suspect that unlawful activity has been, or is being, engaged in; or
3. if it is required or authorised by law.

7) The types of organisations to which CPS may disclose your information

a) CPS may disclose your information to organisations outside of CPS. Examples of organisations and/or parties that your information may be provided to include:

1. offshore service providers, if any;
2. related entities and subsidiaries of CPS;
3. third parties, such as PayWay for processing online payment card transactions for payment of orders;
4. third parties, such as service providers who install, maintain or service smoke alarms purchased via this website, including but not limited to electricians and technicians;
5. third parties, such as advertising agencies, for the purpose of advertising and promoting the goods and services of CPS and its commercial partners which may be of interest to you; and
6. CPS contractors, agents, and venture partners, including but not limited to CPS suppliers and distributors, or other companies who assist CPS in providing CPS services and ancillary and secondary services to you.

b) Your personal information is disclosed to these organisations and/or parties only in relation to the goods or services CPS provide to you or for a purpose permitted by this privacy policy.

c) CPS will take such steps as are reasonable to ensure that these organisations and/or parties are aware of the provisions of this privacy policy in relation to your personal information. However, information provided to third parties will be dealt with in accordance with that entity’s privacy policy.

8) Direct Marketing

a) By giving your personal information and credit related information to CPS, you expressly consent to CPS using your personal information and credit related information, including any email address and mobile phone numbers you give to CPS, to tell you about CPS services, ancillary or secondary services or events or any other direct marketing activity (including third party products, services, and events from CPS’s commercial partners) (Marketing Communications) which CPS consider may be of interest to you. These Marketing Communications may be sent directly by CPS and/or via third parties by email, SMS and social media and you consent to CPS providing your email and mobile phone number to external advertising agencies for this purpose.

b) If at any time you do not wish to receive any further Marketing Communications from CPS, you may ask CPS to cease sending you further Marketing Communications about products and services and not to disclose your information to other organisations for that purpose. You may also ask CPS to not provide further Marketing Communications solely in respect of CPS’ commercial partners. You may do this at any time by using the “unsubscribe” facility included in the email, SMS or MMS message, or by contacting CPS via the details set out in paragraph 14) b).

9) Cross Border Disclosure

a) Any personal information provided to CPS may be transferred to, and stored at, a destination outside Australia, including but not limited to New Zealand where CPS may utilise overseas data and website hosting facilities or have entered into contractual arrangements with third party service providers to assist CPS with providing CPS services to you. Personal information may also be processed by staff or by other third parties operating outside Australia who work for CPS or for one of CPS’s suppliers, agents, partners or related companies.

b) By submitting your personal information to CPS, you expressly agree and consent to the disclosure, transfer, storing or processing of your personal information outside of Australia. In providing this consent, you understand and acknowledge that countries outside Australia do not always have the same privacy protection obligations as Australia in relation to personal information. However, CPS will take steps to ensure that your information is used by third parties securely and in accordance with the terms of this privacy policy.

c) The Privacy Act requires CPS to take such steps as are reasonable in the circumstances to ensure that any recipients of your personal information outside of Australia do not breach the privacy principles contained within the Privacy Act. By providing your consent, under the Privacy Act CPS is not required to take such steps as may be reasonable in the circumstances and sub-clause 8.1 of Principle 8 of the Australian Privacy Principles shall not apply. However, despite this, CPS acknowledges the importance of protecting personal information and may take reasonable steps to ensure that your information is used by third parties securely and in accordance with the terms of this privacy policy.

d) If you do not agree to the transfer of your personal information outside Australia, please contact CPS via the details set out in 14) b).

10) Data quality and security

a) CPS will take reasonable steps to help ensure your personal and credit related information is safe. You will appreciate, however, that CPS cannot guarantee the security of all transmissions or information, especially where the Internet is involved.

b) Notwithstanding the above, while CPS will take reasonable steps to:

1. make sure that the personal information CPS collect, use or disclose is accurate, complete and up to date;
2. protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and
3. destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection, you acknowledge and agree that electronic information handling, storage, use and management, fax and electronic mail and Short Message Services and other electronic messaging services (together electronic information) are not secure and there are risks of legally or commercially or personally sensitive information being inadvertently misdirected, security breaches, loss or non-delivery of material, and you confirm that your arrangements and conduct, including with regard to your identity, passwords and electronic information management, are sufficiently secure and confidential to protect your interests and we are not obliged to take steps to verify or confirm electronic information and whether we take such steps or not we will have no duty or liability as a result of an electronic information breach that does not originate from us and you will carry out effective procedures and conduct yourself to protect the integrity of your electronic information.

c) Your personal and credit related information will be stored as physical files in a secured area, on CPS’s electronic data base system, on cloud based servers and on computers with appropriate back up and security systems. CPS aims to protect your personally identifiable information from loss, misuse, interference, unauthorised access or alteration by:

1. imposing confidentiality requirements on CPS’s employees;
2. implementing security measures to govern access to CPS’s systems;
3. only providing access to personal information once proper identification has been given;
4. controlling access to CPS’s premises; and
5. implementing website protection measures.

d) However, the accuracy of personal information depends largely on the information you provide to CPS, so CPS recommends that you:

1. let CPS know if there are any errors in your personal information; and
2. keep CPS up-to-date with changes to your personal information (such as your name or address).

11) Access to and correction of your information

a) You are entitled to have access to any personal information relating to you which CPS possess, except in some exceptional circumstances provided by law. You are also entitled to edit and correct such information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.

b) If you would like access to or to correct any records of personal information CPS has about you, you are able to access and update that information (subject to the above) by contacting CPS via the details set out in paragraph 14) b). CPS requires that requests for access to or to update or correct your information to be in writing outlining the details of your request.

c) CPS will take appropriate steps to verify your identity (or verify that you act as an authorised agent of the individual concerned) before granting a request to access your personal information.

d) CPS will respond to your request for access to your personal information within a reasonable time after you make the request and if access is granted, access will be provided within 30 days from your request. CPS will, on request, provide you with access to your personal information or update or correct your personal information, unless CPS is lawfully excluded from granting your request, including if:

1. giving access would be unlawful;
2. CPS is required or authorised by law or a court/tribunal order to deny access; or
3. giving access is likely to prejudice one or more enforcement related activities conducted by an enforcement body.

e) Where your request for access is accepted, CPS will provide you with access to your personal information in a manner, as requested by you, providing it is reasonable to do so.

f) Your request for correction will be dealt with within 30 days, or such longer period as agreed by you. If CPS deny your request, CPS will provide you with a written notice detailing reasons for the refusal and the process for making a complaint about the refusal to grant your request.

g) CPS will accept your request for correction of your credit related information where CPS is satisfied that it is inaccurate, out-of-date, incomplete, irrelevant or misleading.

h) Upon accepting a request for correction of your personal information, CPS will take all steps that are reasonable in the circumstances, having regard to the purpose for which your information is held, to correct your personal information.

i) If your request for correction of credit related information is accepted CPS will provide written notice of this correction to any entity to which CPS has disclosed this information previously, to the extent that this is practicable.

12) Dealing with CPS anonymously

a) Where lawful and practicable to do so, you can deal with CPS anonymously or using a pseudonym. You can deal with CPS anonymously or using a pseudonym when making a general enquiry about the goods and services that CPS can offer to you including via telephone or CPS’s website.

b) At the time you engage CPS’s services, it is no longer practicable for you to deal with CPS anonymously or using a pseudonym.

13) Credit information notifiable matters

a) As CPS is not a credit provider or engaged in credit activities, CPS does not disclose your credit related information to any credit reporting bodies. Any credit related information CPS collects or holds about you will be dealt with in accordance with this privacy policy.

14) Resolving privacy complaints

a) CPS has put in place an effective mechanism and procedure to resolve privacy complaints. CPS will ensure that all complaints are dealt with in a reasonably appropriate timeframe, but not more than 30 days after receiving the complaint, so that any decision (if any decision is required to be made) is made expeditiously and in a manner that does not compromise the integrity or quality of any such decision.

b) If you have any concerns or complaints about the manner in which CPS has collected, used or disclosed and stored your personal information or other questions about this policy, please contact CPS in writing by:

1. Email: privacyofficer@smokealarmsolutions.com.au
2. Post: PO Box 1009, Hamilton Central, QLD 4007

c) Please mark your correspondence to the attention of the Privacy Officer.

d) In order to resolve a complaint, CPS:

1. will liaise with you to identify and define the nature and cause of the complaint;
2. will keep you informed of the likely time within which CPS will respond to your complaint; and
3. will inform you of the legislative basis (if any) of CPS’s decision in resolving such complaint.

e) CPS will keep a record of the complaint and any action taken in a Register of Complaints.

f) If you are unsatisfied with the outcome of your complaint you may refer your complaint to the Office of the Australian Information Commissioner to be resolved.

15) Consent

a) By voluntarily supplying CPS with your personal information, using CPS’s website or by accepting the terms of CPS’s terms of service which refer to this privacy policy, you are agreeing to the terms of this privacy policy.

b) CPS reserves the right to modify its privacy policy as its business needs require. CPS will notify you of such changes (whether by direct communication or by posting a notice on its website), after which, your continued use of CPS, services or website or your continued dealings with CPS shall be deemed to be your agreement to the modified terms. If you do not agree to CPS’s continued use of your personal or credit related information due to the changes in its privacy policy, please contact CPS via the details set out in paragraph 14) b) of this document.