Pello Privacy Policy
1. Purpose and nature
Premprop Sales Mosman Pty Ltd (ACN 164 036 882) (trading as Pello Lower North Shore)
(Pello) recognises the importance of your privacy. This Privacy Policy explains how Pello
intends to collect, store, use, disclose, protect and otherwise handle your personal information
having regard to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988
(Cth) (Privacy Act).
This Privacy Policy does not constitute a contractual representation, promise, guarantee or
warranty by Pello to you as to the manner in which Pello will or may collect, store, use,
disclose, protect or otherwise handle your personal information.
This Privacy Policy applies to Pello and its related entities, including its subsidiaries, and their
employees. These related entities comply with the same obligations that Pello has to protect
your personal information under this Privacy Policy.
2. What is personal information?
Personal information is information or an opinion about you, whether true or not and whether
recorded in a material form or not, from which you can be reasonably identified.
3. Why does Pello collect personal information?
Pello collects and uses personal information in connection with providing, administering,
improving and personalising its products and services, marketing and to support its business
functions in relation to its real estate agency services. Pello may also use your personal
information for related purposes.
If Pello does not collect your personal information, it may not be able to provide you with its
products and services.
4. What personal information does Pello collect?
The types of personal information collected by Pello include:
(a) name;
(b) contact details (including address, email address, telephone number(s) and other
contact details);
(c) date of birth;
(d) tax file number (TFN);
(e) banking details; and
(f) identification
(g) other information you provide to us.
4.2 Sensitive Information
The personal information collected by Pello may include sensitive information, which is
defined in the Privacy Act as information or an opinion about such things as an individual's
racial or ethnic origin, political opinions, membership of a political association, religious or
philosophical beliefs, membership of a trade union or other professional body, criminal record
or health information.
Pello will only use sensitive information:
(a) for the primary purpose for which it was obtained;
(b) for a secondary purpose that is directly related to the primary purpose;
(c) with your consent; or
(d) where required or authorised by law.
5. How does Pello collect your personal information?
Where possible, Pello will collect personal information only by lawful and fair means and not
in an unreasonably intrusive manner. When you provide Pello with personal information you
consent to the use, disclosure and handling of your personal information in accordance with
this Privacy Policy and any subsequent amendments (see clause 14).
5.1 Collecting information from you
If it is reasonable and practical to do so, Pello will collect personal information directly from
you.
Depending on how you choose to interact with Pello, Pello may collect your personal
information when you contact, or are contacted by, Pello or its service providers by telephone,
by email, through Pello's website, apps, social media and other digital services or when you
complete a form or document. Pello will also collection personal information from you when
attend a property that is open for inspection.
5.2 Collecting information from third parties
Pello may also collect information about you from other people or independent sources. For
example, Pello may collect personal information about you from its service providers,
including Pello's customer relationship management system (AgentBox) and related entities
of its corporate group. However, Pello will only do so where it is not reasonable and
practicable to collect the information from you directly. Where Pello has collected your
information from a third party, such personal information will be held, used and disclosed by
Pello in accordance with this Privacy Policy.
5.3 Collecting information from visits to Pello's website
Pello may collect information about how you use and visit its Website. For example, we
record your server address, the date and time of your visit, the pages you visited, any
documents you downloaded, the previous site you visited and the type of device, browser and
operating system you used.
We use and disclose this information in anonymous, aggregated form only for purposes
including statistical analysis and to assist us to improve the functionality and usability of our
website. You are not individually identified, however we reserve the right to use or disclose
this information to try to locate an individual where we reasonably believe that the individual
may have engaged in any unlawful or inappropriate activity in connection with our website, or
where we are otherwise required or authorised by law to do so.
Pello may also collect information based on how you use its website, including through
'cookies', web beacons and other similar technologies.
Cookies are small text files that are transferred to your computer's hard drive through your
web browser to enable Pello's systems to recognise your browser and record non-personal
information such as the date, time or duration of your visit and the pages accessed, for
website administration, statistical and maintenance purposes (Cookie Information).
We use cookies to provide you with a more consistent experience across our services. No
attempt is made by Pello to use Cookie Information to personally identify you. However, if
Cookie Information is linked with personal information as set out above, this Cookie
Information becomes personal information and will be treated in the same manner as the
personal information to which it has been linked.
You can remove or reject cookies by adjusting the settings on your web browser. Please note
that some parts of Pello's website may not function fully for users that disable cookies.
5.4 Unsolicited information
If Pello receives personal information that it has not requested and determines that the
personal information received is not reasonably necessary to provide its services, Pello will
take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.
6. Anonymity/pseudonymity
Where practicable, you may be able to interact with Pello anonymously or by using a
pseudonym. Circumstances where it is not practicable, however, include where personal
information is required to complete a credit card transaction or to contact you about our
services.
7. How does Pello hold your personal information?
The security of your personal information is important to Pello. Accordingly, Pello takes
reasonable steps to protect your personal information from misuse, loss and unauthorised
access, modification or disclosure.
These steps include the implementation of the following safeguards:
(a) password protected databases;
(b) staff training;
(c) system firewalls;
(d) internal information security policies.
Pello will take reasonable steps to permanently de-identify or responsibly destroy personal
information if it is no longer needed for the purpose for which the information was used or
disclosed.
7.1 Security breach procedures
Pello's data security practices have been adopted with a view to protecting the data held by
Pello. Notwithstanding this, individuals should be aware that there are inherent risks
associated with the transmission of data over the internet and other mediums. Accordingly,
Pello cannot guarantee any transmission will be completely secure.
8. How does Pello use your personal information?
Pello may hold, use or disclose your personal information so that it can manage and sell
properties, contact tenants, property owners and other third parties in relation to properties it
is or may be marketing for sale or lease and to provide you with any products and services
that you request.
Pello may also hold, use or disclose your personal information to:
(a) consider any concern or complaint that you raise against Pello or to manage any
legal action between you and Pello;
(b) ensure your safety and security, the security of the occupants of any property that is
open for inspection and the safety and security of our staff;
(c) manage your property or take you on as a client;
(d) allow us to call or email you or write to you to inform you of properties we have listed
for sale or lease that may suit your needs;
(e) keep you informed of developments in the real estate market;
(f) enable us to give feedback to a vendor or owner regarding interest in a property;
(g) help us carry out the services we have contracted to provide by way of an agency
agreement with you;
(h) provide you with information, newsletters or other communications requested by you;
(i) enable you in participate in promotions, competitions and surveys conducted by us;
(j) prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;
or
(k) comply with any relevant laws, regulations, codes of practice and court orders.
8.1 Direct Marketing
Pello may also use your personal information to identify and promote products or services
that may be of interest to you.
At any time you may opt out of receiving direct marketing communications from Pello. To do
so, please advise the Real Estate Agent before leaving the Pello office or property that is
open for inspection that you have attended. You may also opt out of receiving direct
marketing communications by clicking the opt out link within an email from us or contact the
person in clause 13.
9. How is personal information disclosed to others?
Pello does not sell, rent or trade personal information to, or with third parties.
Pello may however, in order to provide its products and services to you, disclose your
personal information to third parties in limited circumstances, including with:
(a) external providers that perform services on behalf of Pello;
(b) financial institutions for payment processing;
(c) to potential vendors or purchasers;
(d) its contracted service providers or partners, including:
(i) real estate advertising and listing portals and services;
(ii) clients of agents and third parties engaged to evaluate and manage
properties;
(iii) customer management service providers;
(iv) data storage and archive service providers;
(v) marketing and communications agencies;
(vi) research and statistical analysis providers;
(vii) delivery and shipping providers; and/or
(viii) business advisers (such as accountants, auditors and lawyers).]
In each case, we may disclose personal information to the service provider and the service
provider may in turn provide us with personal information collected from you in the course of
providing the relevant services to you.
[Pello will not disclose your personal information to third parties who are overseas.]
9.2 Cross-border disclosure
Pello may transfer your personal information to an entity which is in a foreign country to assist
Pello in providing its products and services.
In these circumstances, Pello will take such steps as are reasonable in the circumstances to
ensure that the information that is transferred to third parties located outside of Australia will
not be held, used or disclosed by the recipient of the information in a manner that is
inconsistent with the Australian Privacy Principles.
9.3 Third Party Links
Pello's website may contain certain links to other websites. Pello does not share your
personal information with those websites and it is not responsible for the privacy practices
applying in respect of those websites.
10. Change of control
If Pello sells, assigns or otherwise transfers part or the whole of its business, your personal
information, which was collected by Pello pursuant to the terms of this Privacy Policy, may be
among the items transferred or sold to the extent that it is relevant to Pello's business and
required under the terms of any transaction.
11. How you may access or correct your personal information
You may contact Pello to request access to the personal information it holds about you at any
time. You may also ask Pello to correct information about you that you may believe is
inaccurate, incomplete or out of date.
Please contact Pello using the contact details set out in clause 13. Pello will need to verify
your identity before giving you access to, or correcting, your personal information. Pello will
respond to the request within a reasonable period after the request is made. There is no
charge to make a request, however Pello may charge a reasonable fee to cover the
administrative costs of retrieving your personal information.
In certain circumstances, Pello may refuse, or be unable, to correct or provide you with
access to your personal information. In these circumstances, Pello will write to you to explain
the reasons why this is the case.
12. How you may complain if you have concerns about how Pello has
managed your personal information
If you have a complaint related to how Pello has managed your personal information, please
contact Pello using the contact details set out in clause 13. Pello may ask you to place your
concerns in writing so that its compliance staff can fully understand and investigate your
complaint.
Pello will provide you with an estimated response timeframe in relation to your complaint. In
any event, Pello will endeavour to respond to your complaint within 30 days.
If a complaint remains unresolved, you may contact the Office of the Australian Information
Commissioner (OAIC) at www.oaic.gov.au to have the complaint heard and determined.
13. How to contact us
If you have any questions about this Privacy Policy or Pello's management of your personal
information, please contact Pello on:
Attention: Privacy Officer
Tel: (02) 9969 9833
Email: welcome.lns@pello.com.au
Mail: 5 Vista St, Mosman, NSW, 2088
14. Changes to Pello's privacy policy and information handling practices
This Privacy Policy is subject to change at any time so we encourage you to review this
Privacy Policy at regular intervals. If Pello changes this Privacy Policy an updated version will
be posted on Pello's website to notify you of this change. By continuing to use Pello's
services after that time you will be deemed to have accepted any changes to its Privacy
Policy.