1.1 “Keylin Group”, “we”, “us” and “our” means Keylin Group Pty Ltd ACN 608 055 214, any other entity trading under the ‘Keylin’ brand and the related bodies corporate, officers, employees, agents and contractors of such entities.
1.3 We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. Our commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles (APPs). The APPs set out the way that personal information must be treated.
1.4 By providing your details, you consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.
1.5 This policy applies to any person in relation to whom we currently hold, or may in the future collect, personal information. Broadly, we collect personal information from our customers, prospective customers, other individuals that contact us with enquiries, prospective and current contractors and agents and prospective employees.
1.6 This policy does not apply to acts and practices in relation to ‘employee records’ of our current and former employees, as these are exempt from the Privacy Act.
1.7 This policy applies to personal information (including sensitive information). In broad terms, 'personal information' is information or opinions relating to a particular individual who can be identified.
1.8 Information is not personal information where the information cannot be linked to an identifiable individual.
Anonymity and pseudonymity
1.9 We will take reasonable steps to destroy or de-identify personal information if that information is no longer needed for the purposes for which we are authorised to use it.
1.10 If you want to use a pseudonym or remain anonymous when dealing with us, you should notify us and we will try to accommodate your request, subject to our ability to interact with you without having your personal information.
1.11 You do not have to provide your personal information to us but if you do not provide the information requested by us, we may not be able to provide you with our products or services or otherwise engage with you.
2.1 The personal information we may collect differs, depending on the nature of our interaction with you.
2.2 If you are a customer or prospective customer, we may collect and hold personal information about you, which may include:
(a) contact information;
(b) profile related details such as home ownership status, income bracket, marital status, lifestyle interests;
(c) financial and credit information;
(d) date and place of birth;
(e) your history of purchases and use of our products and services;
(f) details of enquiries or complaints that you make;
(g) banking details;
(h) employment history;
(i) insurance information;
(j) government related identifiers such as passport numbers and driver licence numbers; and
(k) any other personal information required to provide our products and services.
2.3 If you are a current or prospective contractor or agent or a prospective employee, we may collect and hold personal information about you, which may include:
(a) sensitive information (see below);
(b) contact information;
(c) date of birth;
(d) employment history;
(e) tax file number information;
(f) insurance information and claims history;
(g) credit information;
(h) licence details;
(i) education details;
(j) driving history;
(k) banking details;
(l) government related identifiers such as passport numbers and driver licence numbers;
(m) any other personal information required to engage you as our contractor, agent or employee; and
(n) records of contact and details of enquiries, conversations or correspondence made or received with you.
2.4 If you are a user of our website, we may also collect information (that may include personal information) about how you access, use and interact with our website. This information may include:
(a) the location from which you have come to the site and the pages you have visited;
(b) technical data, which may include IP address, the types of devices you are using to access the website, device attributes, browser type, language and operating system; and
(c) page clicks, time spent and other automatically collected meta-data.
2.5 ‘Sensitive information’ is a subset of personal information and includes personal information that may have serious ramifications for the individual concerned if used inappropriately.
2.6 We may collect sensitive information about prospective or current contractors or agents or prospective employees including:
(a) health information (including but not limited to drug and alcohol testing results);
(b) criminal history;
(c) membership of professional or trade associations; and
(d) membership of trade unions.
2.7 We generally do not collect sensitive information from our current or prospective customers but on occasion we may collect health information from these individuals if it is relevant to the delivery of our products or services.
2.8 In any case, we will not collect sensitive information without the individual’s consent to whom the information relates unless permitted under the Privacy Act.
3.1 We may collect personal information directly from the individual concerned (for example via online forms, telephone calls, face-to-face meetings and email) or from third parties such as:
(a) your representatives and advisers;
(b) through referrals from individuals or other entities;
(c) from banks and financial institutions;
(d) your current and previous employers;
(e) government bodies (such as relevant departments, regulatory authorities etc.);
(f) our employees, contractors and agents;
(g) paid search providers; and
(h) through marketing and business development events.
4.1 Our usual approach to holding personal information is to store it electronically, in computer systems, databases and cloud server either operated by us or our external service providers, including Sharepoint and Dropbox.
4.2 We implement and maintain processes and security measures to protect personal information which we hold from misuse, interference or loss, and from unauthorised access, modification or disclosure.
4.3 Some of these processes and systems include:
(a) using secure servers to store personal information;
(b) using unique usernames, passwords and other protections on systems that can access personal information;
(c) arranging for our employees to complete training about information security;
(d) holding certain sensitive documents securely; and
(e) monitoring and reviewing our policies.
5.1 We take reasonable steps to hold, use and disclose personal information for the primary purpose for which we collect it. The primary purpose for which we collect information varies depending on the individual that we are collecting the information from but is generally as follows:
(a) in the case of customers and prospective customers, to provide our products and services – for example:
(i) to manage and perform any contract entered into with you;
(ii) to help us identify and develop products and services that may interest you;
(iii) to maintain and enhance our relationship with you;
(iv) to conduct market or customer satisfaction research;
(v) to conduct promotions and invite you to events;
(vi) to send you newsletters;
(vii) to ensure compliance with legislative and regulatory requirements;
(viii) to provide your contact details to a builder when you are considering purchasing a house and land package from us; and
(ix) to provide you with information about other products and services that you may be interested in;
(b) in the case of a current contractor or agent, to assist us in providing our products and services;
(c) in the case of a prospective contractor, agent or employee, to assess your suitability for employment or engagement; and
(d) in the case of other persons that contact us (including users of our website), to assist us to respond to your enquiries or complaints.
5.2 Personal information may also be collected, held, used or disclosed by us for secondary purposes that are within your reasonable expectations and that are related to the primary purpose of collection.
5.3 We may disclose personal information to:
(a) our contractors, agents, employees and related entities;
(b) our external auditors, brokers and insurance providers, legal and other advisers;
(c) employers of individuals;
(e) your advisers;
(f) government bodies (such as relevant departments, regulatory authorities etc.);
(g) law enforcement agencies; and
(h) third parties considering the acquisition of the whole or part of our assets or business.
5.4 We will only disclose personal information to third parties if:
(a) we are required or authorised by law to do so;
(b) we have received express consent to the disclosure, or consent may be reasonably inferred from the circumstances; or
(c) we are otherwise permitted to disclose the information under the Privacy Act.
6.1 We will disclose personal information outside of Australia if you expressly request us to do so.
6.2 In some cases, we may indirectly disclose personal information overseas through disclosures to our service providers that have data servers located overseas. For example, we disclose personal information to:
(a) Dropbox which has data centres located in the United States of America, Germany, Japan, and the United Kingdom;
(b) SharePoint which has data centres located outside of Australia;
(c) Salesforce which has data centres located in the United States of America, Germany, France, Japan, and the United Kingdom.
6.3 Where we disclose your personal information to parties located overseas (or which have data centres located in other countries), we take reasonable steps to ensure that those parties will handle the personal information in accordance with the Australian Privacy Principles. We are not required to take such steps if we believe that the overseas recipient is already subject to a law that has the effect of protecting personal information in a substantially similar way to the relevant law in Australia, or with your consent.
What kinds of credit information may we collect?
7.1 In the course of offering and providing our products and services, we may collect and hold the following kinds of credit information:
(a) identification information;
(b) payment details;
(c) your repayment history;
(d) information about your overdue payments;
(e) the terms of credit made available to you;
(f) if terms and conditions of your credit arrangements are varied;
(g) any publicly available information about your credit worthiness; and
(h) any information about you where you may have fraudulently or otherwise committed a serious credit infringement.
How and when do we collect credit information?
7.2 In most cases, we will only collect credit information if it is relevant to provide our products and services.
7.3 We usually collect credit information directly from you.
7.4 We do not collect and hold credit information from credit reporting bodies unless it is incidentally collected in providing our goods and services.
How do we store and hold the credit information?
7.5 We store and hold credit information in the same manner as outlined in section 4 of this policy.
Why do we collect the credit information?
7.6 Our primary purpose for collecting, holding, using and disclosing credit information is to provide our products and services on credit and to process payments.
Overseas disclosure of the credit information
7.7 We may disclose your credit information to entities outside of Australia in the same manner as outlined in section 6 of this policy.
How can I access my credit information, correct errors or make a complaint?
7.8 You can seek access to and request a correction to your credit information or complain about a breach of your privacy in the same manner as set out in section 8 of this policy. We will deal with a complaint in the same manner as set out in section 8 of this policy.
8.1 It is important that the information we hold about you is up-to-date. You should contact us if your personal information changes.
Access to information and correcting personal information
8.2 You may request access to the personal information held by us or ask us for your personal information to be corrected by using the contact details in this section.
8.3 We will grant you access to your personal information as soon as possible, subject to the request circumstances.
8.4 In keeping with our commitment to protect the privacy of personal information, we may not disclose personal information to you without proof of identity.
8.5 We may deny access to personal information if:
(a) the request is unreasonable;
(b) providing access would have an unreasonable impact on the privacy of another person;
(c) providing access would pose a serious and imminent threat to the life or health of any person; or
(d) there are other legal grounds to deny the request.
8.6 We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.
8.7 If the personal information we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it where it is appropriate to do so.
8.8 If you would like to complain about an interference with your privacy, then you must follow the following process:
(a) The complaint must first be made to us in writing, using the contact details in this section. We will have a reasonable time to respond to the complaint.
(b) If the privacy issue cannot be resolved, you may take your complaint to the Office of the Australian Information Commissioner.
Who to contact
8.9 A person may make a complaint or request to access or correct personal information about them held by us. Such a request must be made in writing to the following address:
Privacy Officer: Dorothy Xu
Postal Address: PO Box 109 Underwood QLD 4119
Telephone number: +61 (7) 3540 5968
Email address: email@example.com
9.1 We may update, modify or remove this policy at any time without prior notice.
9.2 This policy is effective 22/09/2021. If you have any comments on the policy, please contact the Privacy Officer with the contact details in section 7 of this policy.