Privacy Policy
Little Hinges Pty Limited and its related bodies corporate operate the following websites across desktop, mobile, tablet and apps (including any subdomains):
- Littlehinges.com.au; and
- www.littlehinges.com
collectively known as the “Websites” in this Privacy Policy.
Little Hinges Pty Limited and its related bodies corporate are together known as “we”, “our” and “us” in this Privacy Policy (unless the context requires). Where we refer to the data practices of a specific business in this Privacy Policy, “we”, “our” or “us” refers to the operating entity of that business, as specified above.
This Privacy Policy sets out the manner in which we collect, use, disclose and manage personal information. By using the Websites, subscribing to our services or entering into an agreement with us in relation to the Websites, you are taken to have read, and agreed to the collection, use, disclosure and handling of your personal information in accordance with this Privacy Policy.
We may modify this Privacy Policy at any time. You should review this Privacy Policy periodically so that you are updated on any changes. If you are a customer and the modification would result in a material change to either party’s rights or obligations and, for that reason, may cause you material detriment, we will give you at least 30 days’ written notice via email before the modification is to take effect and you may terminate your agreement with us during this period if you consider that the modification will cause you material detriment. For non-material changes we make that would not cause material detriment to a customer, we will notify customers by email at least 30 days before the modification is to take effect, but customers may not terminate as a result of this modification during this period.
Respecting Information Privacy
We recognise the importance of protecting personal information. We do not, without your consent, collect sensitive information as defined under the Privacy Act 1988 (Cth) (“Privacy Act“), such as racial or ethnicity information, political opinions or associations, criminal records or health information.
In collecting and handling personal information, we are bound by the Privacy Act, including the Australian Privacy Principles (“APPs“), and applicable privacy regulations.
The personal information we collect about you
We may collect personal information about you including, but not limited to your name, address, phone number, email, gender, occupation, personal interests and any other information provided.
If you access any of our services through a social network site or login to our Websites using your social network credentials such as Facebook, we will collect limited information provided to us by that social network site, such as user name, site ID, profile photo and email address.
If you are a shareholder of Little Hinges Ltd (“Little Hinges“), Little Hinges (or its services providers) may collect information about your shareholdings, banking details and tax file numbers for payment of dividends and other amounts. If you subscribe to alert services on the Little Hinges Website, we may collect your name and email address.
If you submit personal information to us in relation to an employment opportunity, we may also collect information about your employment and academic history.
We may also collect non-personal information about you including, but not limited to, data relating to your activities on the Websites and Little Hinges Website (including IP addresses) via tracking technologies such as cookies, web beacons and measurement software or data relating to survey responses.
You acknowledge that the personal information you provide us and which we collect from you, is your own information or information which you have been authorised to provide to us.
For some services and products, we may also collect your personal information to enable verification of your identity, including information from your passport, driver’s licence and health care and concession cards.
Additional information for Smartline customers
If you apply for a home loan or connect with a mortgage broker using our Websites, we may also collect information such as your date of birth, bank account details, occupation, age and number of dependants and cohabitants, how long you have resided at your current address and proof of earnings and expenses. In some cases such as where you apply for an insurance product, we will, with your consent, collect sensitive information such as your health information. We may also collect credit information about you. Credit information is information which is used to assess your eligibility to be provided with finance and may include any finance that you have outstanding, your repayment history in respect of those loans and any defaults. Usually credit information is exchanged between credit and finance providers and credit reporting bodies.
How we collect your personal information
We may collect personal information about you from a variety of sources including, but not limited to:
(a) registering to use the Websites or parts of them through a MyRealestate or MyCommercial account;
(b) logging in to use our Websites via your social networking site (“SNS“) account;
(c) subscribing to receive Alerts/reports and filling in forms, applications (e.g. in submitting an offer or enquiry), surveys or research, participating in promotions and competitions on the Websites or websites of our service providers;
(d) contacting us or our service providers for any reason including, but not limited to, reporting a problem with the Websites, requesting further services or seeking our assistance;
(e) posting or contributing material on our Websites;
(f) using our services and any enhanced features of our product such as a chatbot; and
(g) applying for an employment opportunity with us directly, via an SNS site (eg. LinkedIn) or through your nominated referees.
Little Hinges may collect personal information about you if you are a shareholder of Little Hinges Ltd, then Little Hinges may collect personal information about you from third parties (including, for example, collection of information from its share or share plan registrar).
We may also collect your personal information through our related bodies corporate, our service providers and third parties so that we may provide a better or more relevant service or product to you.
HOW WE USE YOUR PERSONAL INFORMATION
We use the personal information we have collected largely for the purpose of providing you with products and services that you have requested, responding to your enquiries, creating and maintaining your account, and ensuring you comply with and adhere to our website terms of use.
More specifically, we may use personal information which we have collected to:
(a) ensure that content from the Websites is presented in the most effective manner for you and for your computer;
(b) provide a better or more relevant service or product to you, for instance by automatically populating forms on the Websites when you make enquiries of selected estate agents;
(c) combine your personal information with information that we have collected from our service providers, third parties, cookies or web beacons in order to provide you with a better or more relevant and personalised experience and to improve the quality of our services and the services of third parties. For example, we may combine behavioural data we have collected about you through the use of cookies or web beacons and combine it with your personal information from requests you send to third parties through our Websites;
(d) personalise and customise your services, experience, advertising and content that you view and engage with on the Websites or the websites of our service providers and business partners
(e) respond to or provide you with services, products, information and assistance that you request from us;
(f) contact you to conduct surveys, research and feedback about our products, services or the Websites;
(g) verify your identity when you register or log into our Websites via your SNS account and remind you of your password and username;
(h) allow you to participate in interactive features of our service, when you choose to do so;
(i) notify you about changes to our products and services; and
(j) enhancing your security when you visit our Website.
If all or part of this information is not provided, we may not be able to provide these services.
If you are a shareholder of Little Hinges Ltd, Little Hinges may also use your personal information to:
(a) communicate with, and comply with Little Hinges’s legal obligations to, its shareholders, and to process payments to them; and
(b) enable its service providers to provide it with services relating to Little Hinges’s share register and group employee share plan.
If you submit personal information to us in relation to an employment opportunity with us, we may also use your personal information to:
(a) consider you for the position for which you have submitted your personal information to us or any other positions that are or become available in the future;
(b) respond to you in relation to any future application you make for an employment opportunity with us; and
(c) contact your referees in order to collect the information you have consented to us collecting about you in order to consider you for employment opportunities with us.
USING AND DISCLOSING YOUR PERSONAL INFORMATION FOR MARKETING PURPOSES
We may:
(a) use your personal information to provide you with information about offers, promotions, goods or services, which we believe may be of interest to you; and
(b) share your information with our service providers and other third parties so that they can provide you with products or services on our behalf or help us to provide you with the requested products or services including contacting you in relation to the products or services.
If we do contact you by using your personal information in accordance with either of the above, we will give you the opportunity to request that your information not be used for further direct marketing in the future.
We may also, if you request us to by opting-in, share your information with third parties so they may contact you directly about their offers, promotions, goods or services.
HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose personal information to our related bodies corporate, service providers or business partners.
We may also disclose your personal information:
(a) to real estate agents or agencies, property developers, builders, retirement community operators and landlords that have listings or advertising on our Websites and which you have requested information from by submitting an enquiry;
(b) to our service providers, so that they can provide you with products or services on our behalf or products or services that you have requested directly from them, or to help us to provide you with our products or services (including if you are a shareholder, to share registrar and share plan management service providers). If you have subscribed to a service through the operating system on your mobile device (including, but not limited to Google’s “Google Now” service), we will disclose information such as your search history to Google. You can opt out of us providing such information to Google through the operating system on your mobile device;
(c) to third parties where you have requested information, services or products from them (eg through using the InspectNow offer form);
(d) in conjunction with a sale or similar transfer of a business;
(e) relevant public, government or regulatory authorities, our legal representatives or other concerned parties, in special situations where we have reason to believe that disclosing your personal information is necessary to help identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users or anyone else who could be harmed by such activities; and
(f) where we are otherwise authorised or required by law to do so.
If you request information from any organisation through our Websites, you will need to check their privacy policy to find out how they handle your personal information. We are not responsible for the way these organisations collect, use, disclose or handle personal information you provide to them through our Websites.
DISCLOSURE AND STORAGE OF PERSONAL INFORMATION OUTSIDE AUSTRALIA
Personal information submitted by our customers and visitors to our Websites may be held on servers located in Australia or in the data centres of our outsourced data processors with data centres in Australia, the United States of America, Europe and Asia. We transfer data outside of Australia to our service providers in order to obtain secure storage, back-up and data retrieval services and to provide services. We have implemented policies and procedures to safeguard the secure storage and processing of data with our related companies and have verified the security arrangements of our outsourced data processors. When you provide us with your personal information you give us your consent to store your personal information outside of Australia for the purposes described above.
Where we have obtained your consent to do so, we may also share your personal information with our service providers and other third parties located outside Australia so that they can provide you with any products or services requested by you, including contacting you in relation to the products or services. As these entities are located outside of Australia, they are not required to comply with the Privacy Act and you will not be able to seek any redress under the Privacy Act in connection with the use of your information.
SECURITY
We strive to ensure the security, integrity and privacy of personal information we collect. We have established safeguards and use reasonable security measures to protect your personal information from unauthorised access, modification and disclosure. Our employees, contractors, agents and service providers who provide services related to our information systems, are obliged to respect the confidentiality of any personal information held by us. We review and update our security measures in light of current technologies. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure.
CORRECTION AND ACCESS
We will endeavour to take all reasonable steps to keep accurate and up to date, any information which we hold about you. If, at any time, you discover that information held about you is incorrect or you would like to review and confirm the accuracy of your personal information, you can contact us.
You can also gain access to the personal information we hold about you, subject to certain exceptions provided for by law. To request access to your personal information, please contact us.
COMPLAINTS RESOLUTION
We are committed to providing our customers with a fair and responsible system for the handling of complaints.
If at any time you have any concerns, complaints, or questions in relation to your privacy or the operation of any of our businesses, please contact our Privacy Officer at privacyofficer@littlehinges.com.au so that we may resolve your concerns.
Our Privacy Officer will consider your query and endeavor to respond to you promptly.
For more information about privacy issues in Australia and protecting your privacy, visit the Office of the Australian Information Commissioner’s website.
COOKIES AND WEB BEACONS
General
We use cookies, web beacons and measurement software and tools on the Websites and so do our services providers and third parties such as our analytics, advertising or ad serving partners. We use and disclose the information collected through the use of cookies, web beacons and measurement software and tools in accordance with this Privacy Policy. This includes using the information to report statistics, analyse trends, administer our services, diagnose problems and target and improve the quality of our products and services. We may allow other third parties to use their own cookies and web beacons to collect information about your visits to the Websites.
We may combine our cookies, information collected through the cookies and web beacons on the Websites with other information (including information collected by third parties using their own cookies and web beacons and providing our cookies and information to third parties) and use analytics services to provide better or more relevant services and advertising to you on the Websites and third party websites. Our service providers and other third parties may do the same in order to provide more relevant services and advertising to you through other websites that you may visit.
COOKIE CHOICES
If you do not want information collected through the use of cookies, web beacons or measurement software and tools, you may be able to delete or reject Cookies or some of the measurement software features through your browser or the settings section of your mobile or tablet device. Disabling these features may cause some of the functions on the Websites, or products and services not to work properly.
APPLICATIONS, WIDGETS OR LINKS TO OTHER WEBSITES
We provide links to websites outside of the Websites, as well as to third party websites. We also allow some third parties to display widgets and applications on our Websites that allow you to interact and share content including social media buttons such as Facebook share and like, Twitter, Pinterest and email services. These linked sites, applications and widgets are not under our control, and we cannot accept responsibility for the conduct of companies linked to the Websites, or their collection of information through these third party applications or widgets. Before disclosing your personal information on any other website, or using these applications or widgets we advise you to examine the terms and conditions of using that website and the relevant third party’s data collection practices and controls in their privacy policy.
USERS BASED IN THE EUROPEAN ECONOMIC AREA
If you access our Websites from the European Economic Area (EEA), you may have additional rights under the General Data Protection Regulation, being Regulation 2016/679 (GDPR) in relation to the handling of your Personal Data (as defined in Article 4 of the GDPR).
In providing our services to you, we may monitor your activity on the Websites using automated processes, including for the purposes of counting usage of our Websites and creating audience profiles. We do this to provide you with more tailored and relevant services, including to show you more relevant properties.
In addition to other rights set out in this Privacy Policy, in certain circumstances you may:
- request access to Personal Data that we hold about you;
- request a copy of Personal Data that that you have provided to us, in a structured electronic format;
- request that we update any inaccurate Personal Data that we hold about you;
- request that we restrict the processing of Personal Data that we hold about you. This enables you to ask us to suspend the processing of Personal Data, for example if you want us to establish its accuracy or the reason for processing it;
- object to our processing of your Personal Data;
- request that we delete any Personal Data that we hold about you, subject to any legal obligations we have to retain your Personal Data; and
- withdraw your consent to the processing of the Personal Data that we hold about you. Once you have withdrawn your consent, we will no longer process your Personal Data for the purpose(s) you originally agreed to, unless we are required to do so by law. This will not affect the lawfulness of any processing of Personal Data based on your consent before its withdrawal.
Where your Personal Data is transferred outside of the EEA, it will only be transferred to countries that have been identified as providing adequate protection for Personal Data, or to a third party where we have approved transfer mechanisms in place to protect your Personal Data – i.e., by entering into the European Commission’s Standard Contractual Clauses, or by ensuring the entity is Privacy Shield certified (for transfers to US-based third parties).
For further information or to exercise any of your rights as a EEA data subject under the GDPR, please contact privacyofficer@littlehinges.com.au.