Carlisle Homes Pty Ltd (“we”, “us”, “Carlisle”, “Carlisle Homes” “the Policy”) will help you understand how Carlisle Homes manages the information that we collect, use and disclose and how you can contact us if you have any queries. The Policy applies to and is adopted by all Carlisle Homes employees, related entities and associated companies and contractors which are subject to the Privacy Act 1988.
Personal information is defined as information, or an opinion, in any form and whether true or not, about an individual whose identity is reasonably apparent or can reasonably be ascertained from the information or opinion.
Sensitive information encompasses information including health information and information about a person’s race, ethnicity, political opinion, religious and philosophical belief, sexual preferences, membership to a political association, professional or trade association or trade union and criminal history.
In this Policy, we will refer to personal information and sensitive information collectively as personal information. Carlisle Homes will not collect sensitive information about you unless you consent or unless we are required to by law.
Information We Collect and How We Use It
Carlisle Homes only collects and holds, uses and discloses (“handles”) personal personal information that is reasonably necessary to help us deliver our products and services. We also collect and handle personal information reasonably necessary for marketing, research, planning and product development purposes. We collect personal information through a variety of channels including our website, at our display centres or over the telephone. We may also collect personal information provided by you if you enter a competition or reply to a survey conducted by or on behalf of Carlisle Homes. We may also collect specific personal information if the law requires us to collect it or receive it from another source.
Carlisle Homes may also obtain information using technologies such as cookies, tags, web beacons and navigational data collection. We have implemented Google Analytics features based on Display Advertising (Google Analytics Remarketing, Display Network Impression Reporting and Demographics and Interest Reporting). You can opt-out of Google Analytics for Display Advertising or customise Google Display Network ads using the Ads Settings. Whilst this information is generally not linked to your personal identity, except where you have identified yourself (for example via e-mail), Carlisle Homes may use this information collected to obtain a better understanding of your experience and what products or services may be of interest to you.
Depending on your interaction with us, the personal information we collect from you will vary. However it may include (amongst other things):
- personal information that you give us when you enter your information through our website or over the telephone to review your eligibility for finance. This information may include contact details, financial information, employment and current living conditions;
- personal information that you give to us when you place a deposit on a new home: This information may include your contact details and financial details.
- communication between you and Carlisle Homes.
- transactional information about your experience with our products and services (for example: feedback that you provide to us).
Carlisle Homes only uses the personal information you provide to us for the purpose that was either directly specified or for a secondary purpose where it could be reasonably expected at the time the information was collected that it would be used a secondary purpose and this secondary purpose is related to the directly specified purpose. The primary purpose for collecting your personal information is to assist in providing you with our products and services, to assist with communications you make with us and for internal administrative purposes.
Although we may use your personal information as stated above, we may also use your personal information for direct marketing where it could be reasonably expected that Carlisle Homes would handle your personal information for direct marketing or you have provided express or implied consent to the use of your personal information for direct marketing. We may communicate news, promotional offers or special events to you or we may use personal information for marketing, research, planning and product development purposes.
Carlisle Homes will take reasonable steps to ensure that you are aware of the purposes for which we collect and handle personal information at the time the information is collected, except where our collection or disclosure of the personal information collected is required by law.
You may visit our website or a display centre anonymously or using a pseudonym if you wish. If you choose to not provide us with personal information that we consider essential or necessary, regrettably, we may have no choice but to cease the sales process; suspend, cancel or renew a contract, subject to its terms and conditions and relevant laws; revoke an event invitation or; decline your entry into a competition or your application for membership to My Carlisle.
You have the right to remove your name from our mailing list at any time without penalty. Similarly, you may apply to add your name to our mailing list at any time should you desire.
If we receive unsolicited personal information (that is not sensitive information) and the personal information is reasonably necessary for, or directly related to one or more of Carlisle Homes’ functions or activities then the personal information is deemed to have been collected that same as if it were solicited from the individual concerned.
Integrity of your Information
Carlisle Homes will use reasonable endeavours to ensure the personal information we collect and handle is accurate, up-to-date and complete, and in the case or use and disclosure, relevant.
Where we collect the personal information from the individual concerned or a reliable source it is reasonable to regard the information as accurate, up-to-date and complete.
Where and How Your Information is Stored
Where we store your information depends on the product or service you have requested from Carlisle Homes.
Carlisle Homes takes reasonable precautions to protect personal information collected and stored by us. These precautions include, but are not limited to security systems and monitoring, secure access to offices and archives, encrypted passwords, firewalls, anti-virus programs and other security measures put in place to prevent accidental or malicious loss of data or personal information.
While Carlisle Homes takes reasonable precautions to protect the personal information we possess, unfortunately there is always risk involved with storing information. Therefore, we cannot guarantee that personal information will not be stolen or used without permission. To the extent permissible by law, we will not be responsible for any unauthorised access, disclosure or use of your personal information. If you suspect that someone has your personal information collected by Carlisle Homes, and you do not wish for them to have it, please contact our Privacy Officer immediately.
- Because it is required or authorised by law;
- To provide you with a product or service you have requested;
- To lessen a serious threat to a person’s health or safety;
- To investigate or report on suspected unlawful activity; or
- To protect our rights or property or those of any member of the public.
Information Sharing Outside of Australia
Carlisle Homes will only disclose personal information collected from our customers, suppliers, service providers, applicants, employees, temporary team members or contractors to an organisation or individual in a foreign country in limited circumstances. Carlisle Homes will only provide your personal information where we reasonably believe the recipient is subject to binding laws or contracts which effectively upholds the principles of privacy which are substantially similar to the APPs, or where Carlisle Homes has taken all reasonable steps to ensure information will not be held, used or disclosed by the recipient in a manner which is inconsistent with the APPs. Carlisle Homes may also provide your personal information where it is necessary in order to perform and conclude a contract that exists between you and Carlisle Homes.
Such disclosure may include the transfer of your information between Carlisle Homes and its service providers located in Australia, New Zealand, Vietnam and Singapore. Carlisle Homes notes that some service providers may back-up personal information in the Cloud, which could also be located overseas.
How You Can Access and Correct Your Personal Information
Carlisle Homes is happy to assist you should you request access to your personal information held by us, subject to relevant exceptions.
To maintain the security of your personal information, we may require you to prove your identity to us. The form of identification we require will depend on the nature of the personal information you seek access to. Forms of identification may include but are not limited to:
- The presentation of photo identification (e.g. passport or Australian drivers license);
- Correct responses to qualifying questions;
- Supply of specific particulars pertaining to your identity; or
- Divulging login names and corresponding passwords.
These responses will be checked against our records to satisfy us that you are who you say you are prior to releasing the requested personal information.
Due to the nature of some requests for access to personal information, Carlisle Homes may require the request to be submitted in writing for auditing purposes. Should this be required, you will be notified in direct response to your initial request for access. This also aids in avoiding confusion regarding the request for access to your personal information. How Carlisle Homes responds to your request will depend on the personal information that you require access to, how you submitted your request, where the information sought is stored, how that information is accessed and any exemptions to disclosure that may apply.
We will give you access to the personal information in the manner requested by you if it is reasonable and practical to do so.
Carlisle Homes will not charge you for making a request to access personal information held by us. However, you may be liable for any costs associated in making the personal information sought available to you. This cost is entirely dependent on the nature of the information sought and the steps required to obtain it. Where possible, Carlisle Homes will endeavour to provide you with an estimated cost prior to us incurring any real cost to provide access to the personal information requested. If the real cost of supplying the requested personal information is greater than the estimate, you may be required to pay the true cost prior to us providing access to the requested personal information.
Carlisle Homes reserves it rights to deny or refuse access to personal information in accordance with Australian Privacy Principle 12.3, Privacy Act 1988 (Cth) Schedule 1.
Where Carlisle Homes denies or refuses access to personal information, we will provide you with a written response outlining the reasons behind our decision. Where we deny access to personal information that may involve or reveal commercially sensitive business details, we will provide you with a summary of the information requested and a written explanation as to why full access was not granted. We may agree to the use if a mutually acceptable intermediary to allow limited access to personal information that would otherwise be denied to you under one of the permitted exceptions. If it is decided that an intermediary will be used, you may be liable to pay the intermediaries’ fees and expenses.
We will respond to your request to update your personal information within a reasonable period and will not charge for the request, correcting the information, or for providing an associate statement.
If we deny or refuse to provide you access to personal information or we cannot update your personal information please refer to the Complaints procedure below.
If you have a complaint about this Policy or the way we have dealt with your personal information, please contact our Privacy Officer at email@example.com. Once we have received your complaint, we will make all attempts to respond to your complaint within a reasonable timeframe.
If you are not satisfied with how we have dealt with your complaint or if we have been unable to resolve your complaint, under the Privacy Act 1988, you can make a complaint to the Office of the Australian Information Commissioner (“OAIC”). The procedure for making a complaint with the OAIC is located at the following website: http://www.oaic.gov.au/privacy/making-a-privacy-complaint.
This Policy is effective from 16 March 2015.
Carlisle Homes may amend this Policy at any time and from time to time. If we do amend this Policy the amended Policy will be available on our website at carlislehomes.com.au so that you are aware of how your personal information is collected, used and stored.
Carlisle Homes Pty Ltd
2 Nexus Court
Mulgrave, Victoria, 3170
P: +61 3 8561 4777
F: +61 3 9561 5320
For more information on privacy in Australia, please visit the Australian Commonwealth Government’s, Australian Federal Privacy Commissioner’s website at www.privacy.gov.au