Privacy and Your Rights

Apt.Residential Pty Limited (“Apt”) is a development, investment, and property manager of Australian build-to-rent (“BTR”) assets which deploys capital to create attractive investment returns for investors.

Our customers and investors expect the treatment of any information provided within the terms of relevant privacy responsibilities. This includes Australian Commonwealth Government legislation in relation to privacy. This policy sets out how Apt collects and uses personal information. We encourage anyone reading this policy to refer to the Office of the Australian Information Commissioner’s website at www.oaic.gov.au which contains important information about privacy laws in Australia.

Collection of personal information

Personal information is information or an opinion that can identify an individual or from which the identity of the individual can be reasonably ascertained. An individual’s name, address and telephone number are examples of personal information.

We collect personal information provided by you or your authorised intermediaries which is reasonably necessary to:

  • provide you with quality products and services;
  • do all things necessary to administer, manage, develop and protect those products and services;
  • consider applications and approaches which you make to us; and
  • maintain your contact details.

When Apt provides you with products and services, we may need to collect certain information from you. The type of personal information which we collect will depend upon the dealings which you have with Apt and may include:

  • name;
  • address;
  • email address;
  • telephone number;
  • age or birth date;
  • profession, occupation or job title;
  • employer details;
  • social media profiles;
  • any additional information relating to you that is provided to us directly (including through our website) or indirectly through the use of third party intermediaries, including marketing contractors, third party websites, portals and registries; and
  • information you provide to us through our service centre, customer surveys, web forms or visits by our representatives from time to time.

Consequences if information not provided

When we ask you to provide us with personal information, if you do not provide us with that information or if that information is incomplete or inaccurate, it may:

  • prevent us from providing our products and services to you;
  • limit our ability to provide you with the level of service which you would normally expect from us; or
  • prevent us from being able to contact you.

Sensitive information

We only collect sensitive information about you with your consent or otherwise in accordance with the law in relation to the services we provide. Sensitive information also includes information or opinion relating to:

  • racial or ethnic origin;
  • political opinions;
  • membership of a political association;
  • religious beliefs or affiliations;
  • philosophical beliefs;
  • sexual preferences or practices;
  • criminal convictions; or
  • membership of a professional or trade association.

Indirect collection of information

We generally try to collect personal information directly from you or through authorised intermediaries. This may include service providers that assist us in the provision of products and services.

Use and disclosure of personal information

Personal information which is collected by Apt is generally used and disclosed for the main purpose for which the information was collected or for related purposes, which would be within your reasonable expectations. This may include the following purposes:

  • to provide products and services to you and to send communications requested by you;
  • to answer enquiries and provide information or advice about existing and new products or services;
  • to conduct business processing functions including providing personal information to our related bodies corporate, contractors, service providers or other third parties;
  • for the administrative, marketing (including direct marketing), planning, product or service development, quality control and research purposes of Apt, its related bodies corporate, contractors or service providers;
  • to provide your updated personal information to our related bodies corporate, contractors or service providers;
  • to update our records and keep your contact details up to date; and
  • to process and respond to any complaint made by you.

We may otherwise use or disclose your personal information where the use or disclosure is required or authorised by law (for example, disclosure to government regulatory and law enforcement agencies) or in emergency situations.

If Apt wishes to use or disclose your personal information in other circumstances, we will seek your consent to do so.

Members of Apt may share an individual’s personal information with their related entities. In this case, the information may only be used or disclosed by the related entity for the main purpose for which it was collected, for purposes related to the main purpose, where required or authorised by law, or for other purposes if the individual has consented.

Apt does not sell personal information to companies outside Apt.Residential Pty Limited.

We may disclose your personal information to our contractors and service providers that assist us in the operation of our business or the provision of services (for example, an internet service provider, mailing house, marketing contractor or providers of any website, portal or share registry). Apt requires these organisations to agree to comply with this Privacy Policy.

If third party service providers are located in countries outside of Australia, our agreements with these parties generally include an obligation for them to comply with Australian privacy law and our Privacy Policy.

Marketing and Affiliated Support Services

We may send you direct marketing communications and information about our or affiliated support services or products that we consider may be in your best interests.

These communications may be sent in various forms, including email, mail, SMS and fax, in accordance with applicable marketing laws. The Spam Act 2003 (Cth) restricts the circumstances in which Apt can send you commercial electronic messages (including email and SMS text messages). Apt may send other advertising material to you where the advertising material is related to the purpose for which the personal information was collected.

You consent to us sending you those direct marketing communications by any of the above methods. If you indicate a preference for a particular method of communication, we will endeavour to use that method wherever practical to do so. If you no longer wish to receive such promotional information from Apt, you may advise us in writing. Commercial electronic messages from Apt will include information about how to contact us, and unsubscribe if required. Apt records would normally be amended within 30 days or as otherwise required by the Spam Act. Details of how to contact us are set out below.

The Apt website

Collection of personal information

Personal information may be collected when an individual uses the Apt website under the domain name https://aptresidential.au/

An individual may visit the Apt website without providing us with any personal information. However, we may collect personal information about an individual accessing the website if they use the ‘Contact us’ section of the website.

Website security

As with any internet transaction, the transmission of data over the internet is not completely secure. While we take reasonable steps to protect all the personal information in our possession that we have collected via the website in accordance with our general personal information management practices to reduce the risk of misuse and loss and from unauthorised access, modification or disclosure, we cannot guarantee the security of all data submitted to us over the internet.

Use of cookies and web tracking

Apt does not use cookies or web bugs to keep personal profiles of its customers’ use of the Apt website. Cookies are used to optimise your visit to our website.

A cookie is a small data file that contains information about your visit to a website. This information is provided by your computer during your first visit to a web server. The server records this information in a text file and stores this file on your hard drive. When you visit the same website again, the server looks for the cookie and structures itself based on the information provided.

Browsers are often default set to accept cookies. You can change your browser to refuse all cookies or to warn you before accepting cookies. If you have set your browser to warn you before accepting cookies, you will receive the warning message with each cookie.

Links

We may, from time to time, include links in the website to the websites of other organisations which may be of interest to you. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

Email

If an individual emails us, the email may contain personal information about that individual. We will treat the information in accordance with our general personal information management practices outlined in this Privacy Policy.

Third Party Website Service Providers

Where we outsource the development, maintenance and hosting of the website to third party service providers. We may disclose personal information about an individual to our third party service providers so that they can effectively provide these services.

Security of personal information

We take reasonable steps to protect all of the personal information we hold from misuse, loss, unauthorised access, modification or disclosure. This protection applies in relation to information stored in both electronic and hard copy form.

Apt will destroy or permanently de-identify any personal information collected which is no longer required.

External organisations which provide support services to Apt are also required to appropriately safeguard the security of the personal information which we provide to them.

Accessing and updating personal information

You may request access to your personal information or request us to correct information which we hold about you. To make a request, please put your request in writing using the contact details below. We may require proof of your identification before we can provide you with access to your personal information.

In normal circumstances we will give you full access to the personal information which we hold about you. However, in some circumstances, we may not be required by law to provide an individual with access to or to correct their personal information. If this is the case, you will be provided with the reason(s) for our decision.

We will normally provide access without charge unless you request access to a large volume of personal information, or we have to access our archived records to obtain the information. In these circumstances, we may impose a fee to recover our reasonable costs.

Complaints

If you wish to make a privacy complaint, you may contact the Privacy Officer using the contact details above. You will need to provide us with sufficient details regarding your complaint, as well as any supporting evidence and/or information.

We will investigate the issue and determine the steps we will undertake to resolve your complaint. We will contact you if we require any additional information and will notify you in writing of the determination of our Privacy Officer. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.

If you feel that we have not adequately dealt with your complaint, you may contact the Australian Privacy Commissioner via www.oaic.gov.au.

Contact us

If you have any questions or feedback about this Privacy Policy or your personal information, please contact the Company Secretary at:

Privacy Officer
Apt.Residential Pty Limited
Email: wei.shi@aptresidential.au

Maintenance and Acceptance of our Privacy Policy

This is the latest Privacy Policy and it replaces any other Privacy Policy published by us to date, whether on the website or in hard copy. We reserve the right to revise this Privacy Policy from time to time and your continued use of our website or services constitutes your acceptance of any revised Privacy Policy.