Privacy Policy
Privacy Policy
This Privacy Policy (Policy) outlines the way in which the Springfield Group and its related entities (the Springfield Group) collects, holds, uses and discloses personal information.
About us
The Springfield Group (‘we’, ‘our’ or ‘us’) is made up of a number of entities (acting in their own capacity and, where applicable, as trustee of their respective trusts), including:
• Brookwater Golf Operations Pty Ltd ACN 094 878 243;
• Brookwater Realty Pty Ltd ACN 101 190 121;
• Coloconnex Pty Ltd ACN 646 603 287;
• Greater Realty Pty Ltd ACN 614 000 243;
• GS Specialist Suites Pty Ltd ACN 603 672 260;
• Hewbourne Pty Ltd ACN 010 651 242;
• Mur Pty Ltd ACN 009 100 458;
• Nightingale Specialist Suites Pty Ltd ACN 686 486 948;
• Park Avenue Development Corporation Pty Ltd ACN 603 672 457;
• Springfield Asset Holdings Pty Ltd ACN 159 981 870;
• Springfield Asset Holdings (Health) Pty Limited ACN 604 065 429;
• Springfield City Group Pty Ltd ACN 055 714 531;
• Springfield Development Projects Pty Ltd ACN 614 000 029;
• Springfield Land Corporation (No. 2) Pty Ltd ACN 056 462 205;
• Springfield Management Services Pty Ltd ACN 132 883 731; and
• Springfield Real Estate Sales Pty Ltd ACN 009 648 220,
and their related entities (as that term is defined in the Corporations Act 2001 (Cth)) and their respective successors and permitted assigns.
Greater Springfield’ is a 2,860 hectare site located in the western corridor between Brisbane and Ipswich in Queensland. The activities of the Springfield Group relate to the development of the master planned community at Greater Springfield and include the operation of the Brookwater Golf Club and the provision of real estate agency services.
Privacy Act 1988
The Federal Government has enacted privacy legislation which governs the use of a person’s personal information. We are bound by the Australian Privacy Principles (APPs) set out in the Privacy Act 1988 (Cth) (the Act), as well as any other applicable laws and codes affecting your personal information.
What is Personal information?
Personal information is information or an 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 a material form or not.
For example, this includes details such as your name, age, date of birth, gender and contact details, and can include certain details about your personal interests.
This Privacy Policy does not apply to the personal information of our employees.
How we collect personal information
We collect personal information in a number of ways, including:
• directly from you, for example when you provide your personal information over the telephone, in writing, during meetings, or via our websites;
• indirectly from you through emails, forms, interviews, event registrations, business cards, online queries and social media interactions (including LinkedIn channels);
• from publicly available sources, including social media;
• when you apply for a job or submit your resume;
• when you register or update an online profile;
• through participation in competitions or surveys;
• when you subscribe to our newsletters or email distribution lists; and
• from third parties, such as analytics providers who help us understand website traffic (for example, via use of cookies).
These are merely examples of some of the ways in which your personal information is collected and are not exclusive.
Wherever possible, we will take reasonable steps to ensure that your personal information is collected directly from you. If we obtain your personal information from someone else, we will take reasonable steps to inform you.
If it is lawful and practicable to do so, we will endeavour to provide you with the opportunity to deal with us anonymously or using a pseudonym.
If you choose not to provide us with certain personal information, we may not be able to provide you with the products or services you require, or the level of service that you expect.
What personal information we collect and why
We collect personal information about you where it is reasonably necessary for our business operations. The type of information depends on the nature of our dealings with you.
For example, if you are purchasing land your personal information will be required for the contract of sale.
In general, the personal information we may collect and hold includes:
• name, date of birth and contact details (including telephone numbers and email addresses);
• payment details; and
• feedback, preferences, and other information relevant to our services;
• occupation, company name, and username/password (as applicable);
• personal preferences, employment history education and qualifications;
• testimonials and feedback; and
• other information which assists us in conducting our business, providing and marketing our services, and meeting our legal obligations.
In some cases we may also collect 'sensitive information', such as criminal history or health information. If we do collect sensitive information, we do not share that information for any other purpose or disclose it to any person other than in accordance with the terms of any consent that you provide to us or where we are permitted or required to do so by the APPs or any other applicable law.
We may also collect non-personal information provided to us, such as IP address, browser type, and access times when you visit our websites.
How we use your personal information
We use your personal information for purposes for which it was collected, or as required or permitted by law. These include:
• verifying your identity;
• providing products and services (eg land sales, real estate services including leasing);
• administering and managing contracts, billing and records;
• communicating with you and responding to enquiries;
• maintaining proper records;
• to inform you of ways in which the products or services we provide to you can be improved;
• assessing job applications;
• complying with our legal obligations;
• conducting research and development; and
• improving our services and customer experience.
Marketing activities
We may also use your personal information to inform you of other products and services or upcoming events which may be of interest to you. Where it is practicable to do so, we will inform you of our intention to use information for marketing purposes at the time we collect your personal information or seek your consent to such a use. We will not use ‘sensitive information’ (such as information about your racial or ethnic origin) without your consent.
You have the right to request that we do not provide you with such material or information, and should you not wish to receive it, please indicate this in the opt-out provisions contained in our marketing material, or simply contact our Privacy Officer and advise them accordingly.
You may opt to change your mind at any time about receiving such information.
The Springfield Group does not and will not disclose your personal information to any unrelated party outside the Springfield Group for the express purpose of allowing them to direct market their products or services to you, unless we have your consent to do so.
We will also comply with any separate obligations that we have under other legislation such as the Spam Act 2003 or the Do Not Call Register Act 2006.
Disclosure of personal information
We may disclose your personal information to:
• related entities, agents and contractors;
• your authorised representatives and legal advisers (at your request);
• government agencies or regulators, as required by law;
• organisations who manage our business, including those involved in a transfer or sale of all or part of our assets or business; and
• third party service providers, both inside and outside Australia (including mailing houses, fraud monitoring systems, accounting services and professional advisers).
We may also disclose your personal information to the following overseas recipients in the following circumstances:
• where companies or individuals assist us in providing services or performing functions on our behalf, such as third party service providers and consultants;
• to anyone else to whom you authorise us to disclose it; and
• to anyone else where we are required to do so by law.
Where personal information is disclosed to a member of the Springfield Group this Privacy Policy will apply to it and every other member of the Springfield Group when it deals with your information.
Disclosure of personal information within the Springfield Group
Members of the Springfield Group in Australia that have collected personal information are permitted by the Act to disclose that personal information to other members of the Group.
Unless you have instructed us not to do so, personal information may be shared with all members of the Springfield Group and other related entities of the Springfield Group.
Where do we store personal information?
We keep personal information in both electronic and paper based records. Paper based records are kept on secure premises away from the general public. Our electronic records are kept in a secure system with password protection and restricted access both internally and from external sources.
Data Security
We will take reasonable steps to:
• protect the information from misuse, interference, loss or unauthorised access, modification or disclosure both physically and through computer security methods; and
• destroy or permanently de-identify the information if it is no longer needed for any purpose.
Website Use
When you visit one of our websites, the website may send cookies to your computer. Cookies are used in transactions over the Internet and can be used to monitor the areas of a website that are visited by you. Visitors to a website who do not wish to receive cookies should select the appropriate settings in their web browser, however this may mean that you are not able to use our websites.
We may collect the following information from visitors to our websites, obtained via cookies:
• Remote server address (RDNS);
• Date and time of their visit;
• Pages accessed;
• Documents downloaded;
• Previous site visited (HTTP Referrer);
• Type of browser used; and
• Any other information volunteered by you including web registrations and contact information.
Third party websites linked to our websites are not subject to this Privacy Policy. We take no responsibility for the content or privacy policies of other websites. Before using any third party website, you should review their privacy policies to ensure that you are satisfied with them.
Destruction of Information
All information held by us will be:
• kept for as long as required by law or is prudent having regard to administrative requirements; and
• destroyed or de-identified if it is no longer reasonably required for any purpose.
Personal information of third parties
If you supply us with personal information about another person, you should ensure that you are authorised to do so by that person. You also agree to provide that person with, or direct them to, a copy of this Privacy Policy.
Access to Your Information
You have the right to access personal information that we hold about you under the Australian Privacy Principles, subject to certain exceptions. We will tell you if one of these exceptions applies. If you would like access to any records of personal information that we may have about you, please contact our Privacy Officer.
We will not charge you a fee for making a request. However, we may charge a fee for giving you access to your personal information in some circumstances, for example where we will incur costs or time to respond to your request. We will tell you in advance of any such fees and we will not charge any fee that is excessive. We will respond to your request for access within a reasonable time (usually this will be within 30 days). You may also make arrangements for a mutually agreed intermediary to access your personal information on your behalf.
Accuracy of your personal information
In order to efficiently conduct our business by providing you with our range of products and services, we need to ensure that your personal information is accurate, up to date and complete.
We will not charge you a fee for requesting correction of your information. We will respond to your request within a reasonable time (usually within 30 days). When we become aware that information is inaccurate, incomplete or out of date, we will take reasonable steps to correct that information or delete it from our records. We will notify you if we do not agree to change the information, and if we do, we will inform you of your rights.
We may from time to time contact you to request that you confirm the personal information we hold is correct.
If you are concerned that information we hold about you is not accurate, complete, relevant or up to date or is misleading, please let us know by contacting our Privacy Officer.
Changes to this Privacy Policy
This Privacy Policy is subject to change at our discretion. The current version of this Privacy Policy will be available at www.greaterspringfield.com.au and will bear the date that the Privacy Policy was most recently updated. We advise you to check the website for any changes to this Privacy Policy.
Enquiries and complaints
Should you wish to:
• make an enquiry about our Privacy Policy or our handling of your information;
• request a copy of our Privacy Policy in a different form;
• obtain access to personal information that we hold about you;
• request a correction of the personal information that we hold about you; or
• make a complaint because you believe that we have breached the APPs or the Act,
please contact us at:
The Privacy Officer
Springfield City Group
PO Box 4167
SPRINGFIELD CENTRAL QLD 4300
Telephone: (07) 3819 9999
Email: legal@springfieldcity.com
We will investigate and respond to complaints promptly (usually within 14 to 30 days).
If we do not resolve a privacy complaint to your satisfaction, you have the right to contact the Office of the Australian Information Commissioner. For further information, you may wish to visit the 'Contact Us' page on their website at www.oaic.gov.au.