Version 3 – April 2017
PART 1 - ABOUT THIS POLICY
In this Privacy Statement, "Sellable", "we", "our" and "us" means Sellable Services Pty Ltd (ABN 73 611 351 190) and Sellable Finance Pty Ltd (ABN 90 611 352 071) as applicable.
Sellable is committed to respecting the privacy and confidentiality of your personal information.
Sellable must comply with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APPs) included in the Privacy Act and other privacy laws that govern how companies like Sellable handle your personal information.
1.2 The short version
Most Privacy Policies aren't exactly riveting reading. Unfortunately, this one isn't any different. That's just the nature of Privacy Policies. We won't take it personally if you want to just review the summary version below – the full version is always available for you to read whenever you're suffering from insomnia.
- We take the privacy and security of your data very seriously
- We recognise that your data is just that, yours, and will endeavour to do everything in our power to protect it, and keep it safe and secure
- There are a select number of third parties that we may disclose your personal information to, although this will only ever be in the context of assisting you in exploring your property or loan options
- You have the right to request that we delete all information held by us for you at any time (which we will do, subject to legal and legislative restrictions)
- In the unlikely event that we don't address your complaint to your satisfaction, you can contact the Office of the Australian Information Commissioner (OAIC) through their website www.oaic.gov.au
PART 2 – HOW SELLABLE HANDLES YOUR PERSONAL INFORMATION
2.1 Sellable's legal obligations
As a private sector company providing real estate services and property valuation services, Sellable is required to comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).
The APPs regulate how Sellable may collect, use, disclose and store personal information and how individuals (such as Sellable customers) may access and correct personal information which Sellable holds about them.
If you want Sellable to help you sell your property, we will need to collect and use your personal information. There's simply no way around that. Not only do we require this information to comply with various pieces of state legislation (e.g. verification-of-identity (VOI) legislation for transfers of property) but part of our offering is to advance you a substantial sum of money prior to your home being sold, so it would be irresponsible business practice and poor risk management if we didn't unambiguously verify your identity. If you provide incomplete or inaccurate information to us or withhold personal information from us we may not be able to provide you with the services you want.
2.2 What information does Sellable collect?
We collect information from you that is necessary to provide you with real estate and property valuation services. We will only ask you for information that we need to provide you with the particular service you have requested – no more and no less.
The type of personal information we collect about you includes your name, email address, physical address and telephone number. If you access any of our services through a social network site such as Facebook, we will collect limited information provided to us by that social network site, such as user name, site ID and email address.
We may also ask you to provide information which we would use to verify your identity, including your date of birth and details of your passport, driver's licence and/or Medicare card. Additional forms of identification may also be requested if necessary to comply with VOI legislation.
Finally, we may ask you for information, such as mortgage and bank statements, which we would use for our internal risk management procedures. This is used to confirm your outstanding loan balance, help us calculate your upfront payment, and to ensure that your property meets Sellable's minimum equity requirements.
Since Sellable is all about helping you sell your property, we assume that you are either the sole owner, joint owner or have a controlling stake in the property you are submitting for evaluation. Our identity checks and risk management procedures are in place to detect any discrepancies and ensure that we only deal with the property owners.
While not strictly personal information, we will also be asking you to provide details about your property (e.g. address, number of beds/baths/car spaces, and an assessment of the condition of various rooms and fixtures). While we will verify these details independently during physical inspections, we expect that you will provide complete and accurate information to us so that we can make an early assessment of the suitability of your property.
We may also collect non-personal information about you including, but not limited to, data relating to your activities on the Sellable websites (including IP addresses) via tracking technologies such as cookies, web beacons and measurement software or data relating to survey responses.
2.3 How does Sellable collect your personal information?
We will usually collect your personal information directly from you. For example, we may collect personal information about you via our website and your use of it, when you chat to us over the telephone, send us correspondence (whether by letter, fax or email) or when you have contact with us in person. If you contact our call centre, the service provider that operates the call centre will collect your information on our behalf.
2.4 How does Sellable use your information?
We will use your personal information for the primary purpose for which it was collected i.e. to provide you with real estate and property valuation services. We will also use your personal information to respond to your inquiries, improve our service and communications and to contact you about other services offered by us.
More specifically, Sellable may use your personal information to:
- ensure that website content is presented in the most effective manner for you and for your device;
- respond to or provide you with service, products, information and assistance that you request from Sellable;
- contact you to conduct surveys, research and feedback about our products, services or our website;
- verify your identity when you register or log into our website and remind you of your password and username;
- help carry out our obligations arising from any contracts entered into between you and us; and
- notify you about changes to our products and services
There are a select number of third parties that we may disclose your personal information to. These third parties include government departments dealing with property title deeds (e.g. Land and Properties Information Office in NSW) and identity verification services as well as trusted third partner agencies and loan providers.
- It goes without saying that we'll need to confirm that you're the owner of a particular property. Part of this process involves sending your name and property details to the government department in your State which holds property title deeds. We'll also check whether there are any outstanding mortgages or other caveats on the property.
- We are required by law to confirm your identity when dealing with transfers of property (e.g. VOI legislation). In addition, it simply makes good business sense for Sellable to do so, particularly when advancing you a substantial sum of money prior to your home being sold. We send relevant personal information to third party identity verification partners to ensure that we can unambiguously identify you.
We may also disclose limited personal information to real estate agents or agencies who will assist us in preparing your property for sale, marketing the property and closing the sale. We may also disclose limited personal information to other third parties involved in this process (e.g. trades people, lawyers and conveyancers) so that they can provide you with products or services on our behalf.
There may be some additional circumstances where we need to disclose your personal information to third parties. This may be where we are required or authorised by law to do so, or you later consent for us to use your information for another purpose.
We may share your personal information with a small number of trusted partners which include real estate agencies and loan professionals. Our trusted partners may contact you in relation to assisting you in exploring any options you might have in regards to your property or financing needs and may offer you related products and services.
You can choose to revoke sharing permissions with a third party at any time. Contact us directly and we'll investigate on how best to accommodate your request.
2.5 Access to your personal information
You have a right to access your personal information that we hold. We will, on request, provide you with a suitable means of access to your personal information unless there is an exception which applies under the Privacy Act 1988 (Cth).
Your request to obtain access will be dealt with in a reasonable time. Please note that Sellable may recover reasonable costs associated with supplying this information to you.
Should you wish to obtain access to your personal information, you can contact our Privacy Officer (see details below) who can give you more detailed information about Sellable's access procedure.
2.6 Keeping your personal information up-to-date
Sellable will take reasonable steps to ensure that your personal information which we may collect, use or disclose is accurate, complete and up-to-date.
If you believe that any of the personal information we hold about you is inaccurate, incomplete or out-of-date then you have the right to request we amend it. Please contact our Privacy Officer immediately (see below for details). We will consider if the information requires amendment. If we do not agree that there are grounds for amendment then we will add a note to the personal information stating that you disagree with it.
Sellable is obliged by law to retain certain information related to customer identification procedures and transaction records for at least seven years. However, in general, personal information is destroyed or de-identified when it is no longer needed.
2.7 Data security
We are committed to ensuring the information you provide us is secure. We have established safeguards and use reasonable security measures to protect your personal and credit 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 and information held by us. We review and update our security measures in light of current technologies and we also train our employees to keep information secure.
At the moment, all your data is held on servers located in Australia. However for technical, performance, backup and best practice security reasons, we may need to make use of data storage companies that are owned and exist outside Australia in future. A full list of these companies will be available from time to time from our Privacy Officer. We will only work with partners who take your privacy as seriously as we do. 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 you have consented to share data with a third party, we will only share relevant personal information and for that particular purpose. Where possible and appropriate, we will endeavour to share your information on an anonymous basis, so your identity is not disclosed.
2.8 How to contact us
Address: Attention: The Privacy Officer
Sellable Services Pty Ltd
Level 2, 76-80 Clarence Street
Sydney NSW 2000
Phone: +61 (0)2 8188 4760
Email: [email protected]
If you make a complaint we will attempt to confirm as appropriate and necessary with you your understanding of the conduct relevant to the complaint and what you expect as an outcome. We will inform you within 30 days whether we will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.
After we have completed our enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, we will assess it and advise if we have changed our view.
While we'd like to think we can answer all your questions and resolve any issues to your satisfaction, you may not always agree. In that case, or if you think we have breached an APP, you can choose to lodge a complaint with the Australian Information Commissioner (OAIC) through their website: http://www.oaic.gov.au.
We may amend this Privacy Statement as our business requirements or the law changes. Any changes to this Privacy Statement will be updated on our website, so please visit periodically to ensure that you have our most current privacy statement.