Privacy Policy

This Privacy Policy sets out our commitment to protecting the privacy of your personal information provided to us, or otherwise collected by us, offline or online, including through our website www.stationstreetcottesloe.com.au (Site) in accordance with the Privacy Act 1988 (Cth) (Privacy Act) including the Australian Privacy Principles. In this Privacy Policy “we”, “us” or “our” means Sirona Urban Pty Ltd ABN 45 657 066 325 and Station Street Partners Pty Ltd ACN 637 231 415, and their related bodies corporate, officers, employees, agents and contractors.

Personal information and sensitive information

Personal information is defined in the Privacy Act as information or opinion about an identified individual (or an individual who is reasonably identifiable) whether the information or opinion is true or not and whether the information or opinion is recorded in material form or not.

Sensitive information is a subset of personal information that is afforded higher levels of protection under the Privacy Act. It includes information or opinion about an individual’s racial or ethnic origin, political opinion, religious beliefs, sexual orientation, criminal record or health information.

Collection of personal information

Your personal information that we collect and hold will include information which is relevant to providing our services to you, including responding to your enquiries about our Station Street Cottesloe project and our other property development projects.

The types of personal information we may collect about you include:

your name;
your contact details, including email address, mailing address, street address and/or telephone number;
your demographic and/or geographic information, such as postcode;
financial information (including salary and investments);
visa or work permit status;
educational qualifications, employment history and personal information about your spouse and dependants;
information you provide to us through customer surveys;
details of products and services we have provided to you and/or that you have enquired about, and our response to you;
your browser session and geo-location data, device and network information, statistics on page views and sessions, acquisition sources, search queries and/or browsing behaviour;
information about your access and use of our Site, including through the use of Internet cookies, your communications with our Site, the type of browser you are using, the type of operating system you are using and the domain name of your Internet service provider;
additional personal information that you provide to us, directly or indirectly, through your use of our Site, associated applications, associated social media platforms and/or accounts from which you permit us to collect information; and
any other personal information requested by us and/or provided by you or a third party.

We may collect these types of personal information directly from you or from third parties, including in the following ways:

when you visit or use the Site;
as part of any registration or expression of interest process on the Site;
direct contact with you;
from third parties with whom we collaborate;
from individuals, agents and representatives (e.g., lawyers, settlement agents, accountants, financial advisers, banks);
from third party entities such as law enforcement agencies and other government or regulatory bodies; and
from our existing or potential agents (including selling, marketing and advertising), contractors or business and/or promotion partners.

Collection and use of personal information

We may collect, hold, use and disclose personal information for the following purposes:

to enable you to access and use our Site, associated applications and associated social media platforms;
to contact and communicate with you in response to your enquiries about our Station Street Cottesloe project and our other property development projects;
for internal record keeping and administrative purposes;
for analytics, market research and business development, including to operate and improve our Site, associated applications and associated social media platforms;
for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you; and
to comply with our legal obligations and resolve any disputes that we may have.

Disclosure of personal information to third parties

We may disclose personal information to:

third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, web-hosting and server providers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
our employees, contractors and/or related entities and our existing or potential agents (including selling, marketing, advertising and settlement), advisors, banks, contractors or business and/or promotion partners to manage and perform any contract entered into between you and us in respect of our Station Street Cottesloe project and our other property development projects;
anyone to whom our business or assets (or any part of them) are, or may (in good faith) be, transferred;
credit reporting agencies, courts, tribunals and regulatory authorities;
courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you. This may include parties located, or that store data, outside of Australia; and
third parties to collect and process data, such as Google Analytics, Salesforce or other relevant businesses. This may include parties that store data outside of Australia.

By providing us with personal information, you consent to the disclosure of your personal information to third parties who reside outside Australia and acknowledge that we are not required to ensure that those third parties comply with Australian privacy laws.

How we treat personal information that is also sensitive information

We will only collect ‘sensitive information: (a) with your consent; (b) if required or authorised by Australian law or court/tribunal order; or (c) an exemption exists under the Privacy Act.

Your rights and controlling your personal information

Choice and consent: Please read this Privacy Policy carefully. By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, however, if you do not, it may affect your use of this Site or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below.

Access: You may request details of the personal information that we hold about you by contacting us at the details below. An administrative fee may be payable for the provision of such information and any charge we make for providing access will be reasonable and will not apply to lodging a request for access. Your request to access your personal information will be dealt with in a reasonable time. In certain circumstances, as set out in the Privacy Act, we may refuse to provide you with personal information that we hold about you (including if a request is frivolous, or where to provide access would pose a threat to health or public safety, unreasonable interference with another person’s privacy, or be a breach of the law). If we refuse access, we will provide you with reasons for doing so

Correction: If you believe any personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Complaints: If you believe that we have breached the Australian Privacy Principles and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

Storage and security

We are committed to ensuring that the personal information we collect is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.

We cannot guarantee the security of any information that is transmitted to or by us over the Internet. The transmission and exchange of information is carried out at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that the personal information we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy.

It is not our standard practice to disclose personal information to overseas recipients. Indirect overseas disclosure may occur where, and if, we back up collected information on a cloud-based system provided by a third-party data storage provider, if we, from time to time, utilise cloud-based computing services. In such cases, personal information may be disclosed to hosting entities overseas. As a result, we will not disclose personal information to entities without a privacy policy meeting or exceeding the standard of stringency contained in this Privacy Policy.

Cookies and web beacons

We may use cookies on our Site from time to time. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally identifiable information. Generally, we use cookies to learn about the way you interact with, and to help us improve your experience when visiting, our Site.

We may record your visit through the use of cookies and may log the following information for purely statistical purposes:

your server address;
your to-level domain name (e.g. .com, .gov, etc);
the date and time of your visit to our Site;
the pages accessed and documents downloaded by you on our Site;
the previous site(s) visited by you; and
the type of browser used by you.

We will not facilitate the merging of personally-identifiable information with non-personally identifiable information collected through any cookies, tracking / web pixels or Google advertising products or features, unless it has robust notice of and the relevant party’s consent to that merger.

Our Site makes use of third-party cookies – these are cookies sent by businesses that provide content, such as advertising, on websites that you visit – that is, businesses other than us. Third party cookies are used on our Site website to enable remarketing and reporting for impression assisted visits, website conversions, user demographics and user interests.

The third-party cookies used on our Site include, but are not limited to, Google Analytics Advertising Features (via the use of Google advertising cookies), cookies from Tik Tok and the META (Facebook) tracking / web pixel. These cookies cause our advertisements to appear on your social media and online media feeds as part of our retargeting campaigns. If and when you choose to provide our Site with personal information, this information may be linked to the data stored in the cookie.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to deny or accept the cookie feature. You should note that cookies may be necessary to provide you with features and / or functions on our Site and on other websites.

If you want to opt out of the operation of third-party cookies – such as those associated with the Google Analytics Advertising Feature – you will need to refer to the privacy policies of the relevant third-party website(s).

We may use web beacons on our Site from time to time. Web beacons (also known as Clear GIFs) are small pieces of code placed on a web page to monitor the visitor’s behaviour and collect data about the visitor’s viewing of a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

Links to other websites

Our Site may contain links to other websites. We do not have any control over those websites and we are not responsible for the protection and privacy of any personal information which you provide whilst visiting those websites. Those websites are not governed by this Privacy Policy or our privacy standards and procedures. You will need to contact the operators of those other websites directly to ascertain their privacy standards.

Amendments

We may, at any time and at our discretion, vary this Privacy Policy by publishing the amended Privacy Policy on our Site. We recommend you check our Site regularly to ensure you are aware of our current Privacy Policy.

Notifiable eligible data breach

We are committed to protecting information we hold about you, and to compliance with the provisions of the Privacy Amendment (Notifiable Data Breaches) Act 2017 (Cth) dealing with notifiable eligible data breaches.

Where we become aware of a potential eligible data breach which is likely to result in serious harm to any individuals about whom we hold personal information, we will:

investigate the suspected breach and determine scope of any breach that has occurred and the risk of harm to affected individuals whose personal information may have been compromised;
notify you and the Office of the Australian Information Commissioner of the potential breach; and
take steps to minimise any harm caused to affected individuals as a result of the breach.

Privacy Policy Complaints and Enquiries

For any questions or notices, please contact us at:

Sirona Urban Pty Ltd ABN 45 657 066 325
Email: hello@sironaurban.com

Last update: 24 September, 2024