Valocity Pty Ltd
(ACN 613 496 790)
APIX Service Privacy Policy
(July 2021)
VALOCITY PTY LTD APIX SERVICE – PRIVACY POLICY
1.1. This Privacy Policy applies to the practices and activities of Valocity Pty Ltd (ACN 613 496 790) (Valocity, Us, We, Our).
1.2.
We collect, hold, use and disclose Personal Information for the
purpose of carrying out our functions and activities, in accordance with the Privacy Act 1988 (Act) and
the Australian Privacy Principles
(APPs) set out in Schedule 1 of the
Act.
1.3. Valocity is committed to respecting the privacy of individuals. This Privacy Policy sets out how Valocity handles Personal Information and has been prepared in accordance with APP 1.
1.4. Any individual who provides Personal Information to Valocity consents to Us using, storing, and disclosing that Personal Information in accordance with this Privacy Policy.
1.5. This Privacy Policy is freely available on Our website at https://valocityglobal.com/privacy or by contacting Us directly to request a copy free of charge.
1.6. We may update this Privacy Policy from time to time by publishing a revised version on Our website. Revised versions take effect from the time published.
2.1. The Personal Information You provide is important to Us as it can be used to identify You, make it easy for Us to contact You, and to allow Us to efficiently carry out Our business functions and activities.
2.2. We may collect, hold, and use Personal Information of individuals to enable Us to perform our core functions, and provide various products, services, and offerings. This includes:
(a)
communicating with you about
your enquiry;
(b)
processing any transactions you
might make on our site;
(c) researching, developing and marketing products, services, merchandise and special offers made available by us and third parties;
(d) administering, managing and providing access to the Valocity website, APIX Service or any other database used by Valocity;
(e) providing services and publications, including historical property sales data via the APIX Service;
(f) providing information, education, training, and technical support to those that engage with Us;
(g) sending invitations to events;
(h) conducting market research and surveys to improve services, and analyse trends;
(i) completing administration for Your interactions;
(j) complying with Our corporate governance obligations;
(k) communicating with You during the provision of Our services;
(l) communicating with Our related entities, network of partners, customers, and supporters;
(m) processing payments;
(n) communicating offerings from us, and third-party offerings;
(o) security and access control;
(p) identifying related third sales; and
(q)
Our other
related activities from time to time.
(Activities and Functions)
2.3. We try at all times to only collect the Personal Information We require to enable Us to perform the particular function or activity We are carrying out.
2.4. We do not resell Personal Information.
3.1. Subject to this clause 3, when dealing with Us, You may ask not to identify yourself, and remain anonymous. Alternatively, when dealing with Us, You may use a Pseudonym, and require Us to use a Pseudonym when dealing with You, in lieu of providing Your Personal Information.
3.2. .
3.3. In most instances We may require You to provide Your Personal Information and are unable to deal with You in a particular manner in the absence of Your Personal Information, including where:
(a) We are required or authorised by or under an Australian law, or a court/tribunal order, to deal with individuals who have identified themselves.
(b) it is impracticable for Us to deal with individuals who have not identified themselves or who have used a Pseudonym.
3.4. If you do not provide some or all of the Personal Information that Valocity requests from You, You may be prohibited from certain Valocity services and products.
4.1. We collect and hold Personal Information relating to a range of individuals, including: website users, Valocity account holders, brokers, the individuals who work for our suppliers or other providers, members of the public who have contacted Us or communicated with Us, people whose personal information is contained in property sales data which is provided to us by a third-party, newsletter subscribers, suppliers, sponsors, employees, prospective employees, and other individuals from time to time.
4.2. The information collected by Valocity about a particular person will vary depending on the circumstances of collection.
4.3. Personal Information We collect, and hold may include:
(a) Your full name and prefix (eg. Mr or Ms);
(b) Your email address, so that we can authenticate you and electronically administer your account;
(c) Your employment information, such as employer and role description;
(d) other contact details;
(e) communication preferences
(f) Your gender;
(g) Your credit card details; and
(h) Other information required to process a transaction for purchased goods or services.
4.4. Personal Information we may hold in relation to property sales data provided to us by third parties may include:
(a) names and details of spouse (if any);
(b) addresses and other contact details; and
(c) details of the property transaction including year and value of transaction.
4.5. We may collect more detailed Personal Information from You, examples of which include to assist Us with Our marketing materials and staff emergencies.
4.6. We may incidentally collect Personal Information from You relating to any existing membership held by You to the Australian Property Institute.
5.1. The main way We collect Personal Information about You, is when You give it to Us.
5.2. We may collect Your Personal Information directly from You through various means including via Our website, in person, email, fax, online and written forms, phone calls, or other forms of correspondence, writing, or recording.
5.3. Examples of when We may collect Your Personal Information include when, You:
(a) enter Your Personal Information into, or agree to having your Personal Information entered into, one of Valocity’s online systems or programs, such as APIX;
(b) become a user of the APIX Service or Valocity account holder;
(c) complete onboarding documentation such as forms relating to the APIX Service distributed by a user’s employer and/or bank;
(d) enquire as to our services;
(e) subscribe to Our mailing list;
(f) access the Valocity website;
(g) register for our newsletter subscription or any other Valocity publication, including electronic publications;
(h) provide details to Us in an application, consent form, survey, feedback form or incident report form;
(i) supply Us with goods or services;
(j) apply for a job with Us or are employed by Us or to volunteer with Us;
(k) contact Us for information on Our products or services;
(l) make a complaint to Us, or obtain a refund or credit;
(m) contact us through Our website or by another means;
(n) order or otherwise obtain products, services, or information from Us or an authorised agent or licensee;
(o) otherwise correspond with us by various means.
5.4. From time to time We may obtain Personal Information from third parties not disclosed in this Privacy Policy. When We do so, We will take reasonable steps to ensure that We make You aware of the collection of Your Personal Information in accordance with the Act.
5.5. We will only collect Personal Information about You indirectly from third parties if it is not reasonable or not practicable to collect the Personal Information directly from You, or where You have otherwise consented to the Personal Information being provided to Us through that third party.
5.6. Personal Information may also be collected where Valocity is required or permitted to do so by law.
5.7. We may collect Personal Information from third parties such as:
(a) direct marketing database providers;
(b) publicly available sources;
(c) State Government departments and Local councils; and
(d) property sales data providers as described in clause 5.8.
(a) Australian Property Institute Limited (ACN 608 309 128);
(b) State and Territory governments (as provided by way of external data sets);
(c) Valuer-Generals in Western Australia, Victoria and other States and Territories from time to time, or corporate entities providing land data services to such States and Territories;
(d) Experian Australia Pty Ltd (ACN 082 851 474);
(e) third party vendors;
(f) third party owners in the Northern Territory;
(g) any other government or law enforcement bodies as required by law.
5.9. Where We receive Personal Information about You from You directly, or a third party, which was not solicited, then that Personal Information will be dealt with in accordance with this Privacy Policy and the Act. We may keep records of unsolicited Personal Information if the Act permits it (for example, if the Personal Information is reasonably necessary for one or more of Our Activities and Functions).
5.10. Valocity will not collect information via unlawful means or by means that are unfair or intrude to an unreasonable extent on the personal affairs of the individual concerned.
6.1. Where We collect Personal Information directly from you, We will take reasonable steps to notify You, at the time of collection, or as soon as practicable afterwards, of:
(a) Our identity and how to contact Us;
(b) the purposes for which we are collecting the Personal Information;
(c) whether the collection is required or authorised by or under an Australian law or a court or tribunal order;
(d) the third parties (or types of third parties) to whom We would normally disclose information of that kind;
(e) whether any of those third parties are located overseas and, if practicable to specify, the countries in which they are located;
6.2. Where Personal Information is collected on a paper form or website page, We will generally include a collection notice, or a clear link to a collection notice, on the form or website page.
7.1. We take reasonable steps to ensure that Personal Information that We collect is accurate at the time of collection, up to date and complete. This includes by:
(a) recording Personal Information in a consistent format where possible; and
(b) promptly adding updated or new Personal Information to existing records where We become aware that the records are incorrect or out of doubt.
7.2. You can assist Us to keep Your Personal Information up to date by letting us know about any changes to your Personal Information, such as your email address or phone number, if you are a user of Our online systems, You may be able to update Your details online.
8.1. We do not collect Sensitive Information about You.
8.2. If we were to collect any Sensitive Information, We would handle in in accordance with the Act.
9.1. We will make You aware at the time of collection of Your Personal Information, how We intend to use that Personal Information.
9.2. We will use and disclose Your Personal Information for the purposes advised to You at the time of collection and may also use and disclose Your Personal Information to enable us to perform and undertake Our Activities and Functions.
9.3. We may also make secondary use or disclosure of Your Personal Information, in addition to Our Activities and Functions, where:
(a) You would reasonably expect Us to use or disclose the Personal Information, that is not Sensitive Information, and such secondary use is related to the primary purpose for which it was collected; or
(b) You have consented to Our use and disclosure of Your Personal Information; or
(c) the use or disclosure is permitted or authorised by the Act, or any other Australian law or court/tribunal order.
9.4. We do not sell Your Personal Information to third parties, but it may be disclosed to third parties from time to time in order to facilitate and administer our Activities and Functions, including applying for a visa.
10.1. Our policy is to not:
(a) use a government related identifier of an individual (such as a Medicare number or driver’s licence number) as Our own identifier of individuals; or
(b) otherwise use or disclose such a government related identifier unless this is permitted by the Act, or reasonably required for the performance or undertaking of Our Activities and Functions.
11.1. Valocity may disclose Personal Information contained in property sales data via the APIX Service for the purpose of conducting valuations.
11.2. If you are an individual user of the APIX Service, we may disclose Personal Information about you to:
(a) your employer for the purpose of them administering and managing the subscription to the APIX Service;
(b) financial institutions and customers that you are preparing valuations reports for;
(c) Australian Property Institute Limited (ACN 608 309 128); and
(d) suppliers of property sales data where We are contractually obligated to assist or allow audit of the property sales data.
11.3. Valocity will not make available your Personal Information to any other party or organisation unless:
(a) Stated in this Privacy Policy;
(b) We believe it is reasonably necessary to conduct Our Functions and Activities; or
(c) You give Your consent; or
(d) it is required or authorised by law including in emergency situations or to assist law enforcement, in which case the disclosure will be conducted in accordance with the Act and relevant law, including that We will make a written note of the use or disclosure.
11.4. We may disclose Your Personal Information, that is not Sensitive Information, in order to:
(a) manage and administer the products We provide to You;
(b) enable third parties engaged by Us to provide services on Our behalf, for example deliver products You have ordered, or investigate complaints;
(c) assist You with enquiries;
(d) charge You for the products We provide and collect any amounts You may owe to Us, including any debt recovery action;
(e) ensure that Our internal business operations are running smoothly including any reporting or legal requirements We may be required to fulfil; and
(f) otherwise to conduct Our Functions and Activities.
11.5. We will not disclose any Sensitive Information about You, unless You have provided express consent for Us to do so, or We are required by Law.
11.6. We outsource information technology (IT) services to various providers. We require these providers to confirm their compliance with this Privacy Policy.
11.7. We currently utilise Office365 (SaaS) for email services and to facilitate other office productivity activities.
11.8. Currently, Our our invoicing process utilises a cloud platform provided by Xero Limited We recommend You consider the privacy policy are available on the Xero Limited website, or by contacting Xero Limited directly.
11.9. We may disclose Your Personal Information to third parties who are contracted by Us to carry out advisory, administrative, analytical or technical research functions for Us or Our related bodies corporate. Where We do so, We will require those third parties to comply with the Privacy Act and Australian Privacy Principles. These third parties may include:
(a) financial institutions for payment processing;
(b) service providers involved with or engaged by Valocity;
(c) translators, where You or We require a translator to enable Us to provide services;
(d) referees whose details are provided to us by job applicants;
(e) third parties who have complained to Valocity;
(f) Valocity’s contracted service providers, including:
(i) electronic content delivery providers;
(ii) information technology service providers and data storers;
(iii) publishers of our newsletters and other publication materials;
(iv) marketing and communications agencies;
(v) call centres and call training centres (including the third party that conducts surveys on our behalf);
(vi) mailing houses, freight and courier services;
(vii) printers and distributors of direct marketing material, such as Mailchimp;
(viii) external business advisers (such as recruitment advisers, auditors and lawyers);
(g) regulatory bodies as required by law;
(h) any other government or law enforcement bodies as required by law; and
(i) other enforcement bodies where We believe the disclosure is reasonable necessary to an enforcement related activity.
11.10. In the case of these contracted service providers, 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 products or services.
11.11. We may disclose Personal Information to overseas parties, in the following situations:
(a) using secured cloud services from time to time, the location of which is not reasonably available;
(b) providing Your details to an overseas direct mail provider to send marketing material to You;
(c) disclosing information to disciplinary tribunals to consider complaints.
11.12. In each case, Our policy is to comply with the requirements of the Act that apply to cross border disclosures of Personal Information, as well as with any legal requirements applicable in the relevant jurisdiction.
12.1. Valocity is a related body corporate of a New Zealand based company called Valocity Limited (NZBN 9429041106112). Personal Information may be disclosed to Valocity’s New Zealand branch for the purpose of technical and product development, support, and data backup of the APIX Service;
12.2. APP 8.1 requires Valocity to take reasonable steps to ensure the overseas recipient does not breach the Privacy Act or APPs. This does not apply if:
(a) the overseas recipient is subject to a law having a similar effect to the Privacy Act and APPs, and providing similar mechanisms for individuals to enforce the protection of their personal information; or
(b) Valocity expressly informs the individual of the overseas disclosure, and the individual consents.
12.3. New Zealand’s privacy laws are of similar effect to the Privacy Act and APPs and provide similar mechanisms for individuals to enforce the protection of their personal information and you may seek action against Valocity Limited (NZBN 9429041106112) and these other entities under New Zealand’s privacy laws.
13.1. We take reasonable steps to protect the Personal Information We hold from misuse, interference and loss and unauthorised access, modification, or disclosure.
13.2. In the event of a data breach, Valocity is committed to complying with the requirements of the Privacy Act.
13.3. Information may be stored in hard copy or electronic format in facilities that We own and operate, or that are owned and operated by Our service providers.
13.4. Personal Information is primarily stored in secure onshore cloud services located in Australia.
13.5. If We engage service providers or third parties to perform services for Us, We will endeavour to require them to comply with Our Privacy Policy.
13.6. Our employees, contractors, and third-party service providers are required to ensure that Personal Information they are privy to is not divulged, except under appropriate circumstances. They are required to ensure that any such Personal Information available to them is protected from theft, damage, loss, unauthorised access and any other form of abuse or improper use.
13.7. Personal Information held by Us may be accessed by our employees, contractors, and third-party service providers including for the purposes of providing technical support and development of the APIX Service. Access is managed and traceable through our service desk tickets and is subject to quarterly review.
13.8. To ensure network security, it is Our policy that:
(a) data is encrypted at rest and in motion;
(b) password policies are enforced for internal and external users;
(c) data on the APIX Service and its supporting underlying systems is only accessible via Our internal network or via virtual private network with soft token if not on site;
(d) Our Information Security Policy applies to all users;
(e) Servers are patched, updated, and regularly maintained; and
(f) Our data only stored on devices owned and operated by Us.
13.9. Improper use or suspected improper use of Personal Information by our Our employees, contractors, and third-party service providers, will result in appropriate disciplinary action being taken.
13.10. Our electronic databases are secured by a firewall and anti-virus software to ensure, so far as practicable, that it is not accessed by unauthorised parties. Our website has security measures designed to protect against loss, misuse, or alteration to Your Personal Information under Our control.
13.11. Where we use online technologies to process payments (if any) we will endeavour to ensure that all transactions meet industry security standards to ensure payment details are protected. Any payment information We store is encrypted.
13.12. We conduct regular internal and external audits to assess the suitability of Our security measures.
13.13. All unencrypted information exchanged via the internet may be accessed and used by people other than those for whom it is intended. If You provide Us any Personal Information by email or online, you do so at Your own risk.
13.14.
If You wish to have Your
Personal Information removed from Our database, We will take reasonable steps
to comply with Your request unless We need to keep the information for legal,
auditing or internal risk management reasons.
14.1. Where We have collected Your Personal Information directly from You, We may use or disclose Your Personal Information, for the purposes of Direct Marketing if:
(a) the Personal Information is not Sensitive Information;
(b) You would reasonably expect that Your Personal Information would be used for the purposes of Direct Marketing; and
(c) You have not advised Us that You do not want Your Personal Information to be used for the purposes of Direct Marketing.
14.2. We may collect Personal Information from someone other than You, excluding from property sales data, for the purpose of Direct Marketing, where:
(a) the Personal Information is not Sensitive Information;
(b) You have consented to the disclosure of Your Personal Information for that purpose; and
(c) You have not advised Us that You do not want Your Personal Information to be used for the purposes of Direct Marketing.
14.3. If we have collected Personal Information from someone other than You for the purpose of Direct Marketing, You can ask Us to provide you the source of the Personal Information. Our policy is to do so unless it is unreasonable or impracticable.
14.4. We may disclose Your Personal information, that is not Sensitive Information, to MailChimp for the purpose of it conducting Direct Marketing, provided it is conducted in accordance with Australian Privacy Principle 7.3.
14.5. Where Your consent is impractical to obtain, We may use or disclose Your Personal Information in accordance with Australian Privacy Principle 7.3.
14.6. We may collect and use Your Personal Information for the purpose of Direct Marketing, if We enter a service provider contract with the Commonwealth which directly or indirectly obliges us to do so.
14.7. In any Direct Marketing, We will provide a clear and simple means by which You may easily request, free of charge, not to receive direct marketing communications from Us.
14.8. Alternatively, You can update Your communications preferences, free of charge, by:
(a) visiting the Valocity Website at https://www.portal.valocity.com.au if you have an account;
(b) sending a letter or email to: Mark Nassif, Country Head, Valocity Pty Ltd, 4/11 York Street, Sydney, 2000; or
(c) if You receive a marketing call, advising the caller that You no longer wish to receive marketing calls.
14.9. This clause 14 is subject to the operation of other Direct Marketing legislation including the Do Not Call Register Act 2006 (Cth) and the Spam Act 2003 (Cth), and any other applicable Commonwealth legislation, regulation, or enactment.
15.1. Under the Australian Privacy Principles, You have a right to access Your Personal Information held by Us, unless a permitted exception exists at law.
15.2. You can request access to your personal information at any time by contacting Valocity at the contact details on this webpage.
15.3. We will request that You verify Your identity, before We provide You with access to Your Personal Information.
15.4. We may refuse to provide You with access to Your Personal Information, or to provide access in the manner You have requested, if:
(a) We reasonably believe doing so would pose a serious threat to the life, health or safety of any individual, or to public health or safety;
(b) giving access would have an unreasonable impact on the privacy of other individuals;
(c) the request is frivolous or vexatious;
(d) the Personal Information relates to existing or anticipated legal proceedings between Us and You, and would not be accessible by the process of discovery in those proceedings;
(e) giving access would reveal the intentions of Us in relation to negotiations with You in such a way as to prejudice those negotiations;
(f) giving access would be unlawful;
(g) denying access is required or authorised by or under an Australian law or court/tribunal order;
(h) both of the following apply:
(i) We have reason to suspect that:
(i) unlawful activity, or misconduct of a serious nature, that relates to Our functions or activities has been, is being or may be engaged in; and
(ii) giving access would be likely to prejudice the taking of appropriate action in relation to the matter;
(j) giving access would be likely to prejudice one or more enforcement related activities conducted by, or on behalf of, an enforcement body;
(k) giving access would reveal evaluative information generated within Our company in connection with a commercially sensitive decision-making process; or
(l) We are otherwise permitted or authorised to refuse at law.
15.5. If We refuse to provide You access to Your Personal Information, We will provide You with written notice that sets out Our reasons (other than to the extent it would be unreasonable to do so) and inform You of the mechanisms available to complain about the refusal.
15.6. If You would like to access the Personal Information that We hold, please make a request directly to Us using the contact details provided in clause 24 of this Privacy Policy. We will provide You with access to Your Personal Information, within a reasonable period after the request, and in a way that is reasonable in the circumstances, unless exempted by the Act.
15.7. We may charge a reasonable fee for providing You with access to Your Personal Information, which will be confirmed at the relevant time.
16.1. We take reasonable steps to ensure that the Personal Information We collect, hold, use and disclose is complete, up-to-date, accurate and relevant.
16.2. We will correct, update or delete Your Personal Information if You request that We do so on the basis it is inaccurate, out of date, incomplete, irrelevant, or misleading, or if We are otherwise satisfied that this is the case.
16.3. If We correct Your Personal Information after We have disclosed it to a third party who is also subject to the Act, We will only inform that third party of the corrected details at Your request. If You do request that We inform that third party of the correction, We will take reasonable steps to do so at no cost, unless this would be unreasonable, impracticable, or unlawful.
16.4. If We refuse to correct Your Personal Information:
(a) We will provide You with written notice in a reasonable timeframe that sets out Our reasons (other than to the extent it would be unreasonable to do so) and inform You of the mechanisms available to complain about the refusal; and
(b) if You request Us to do so, We will associate with Your Personal Information a statement that You believe the Personal Information is incorrect and the reason why.
16.5. If we refuse to correct Your Personal Information, you may request that We make a record of Your claim that the Personal Information is inaccurate, out-of-date, incomplete, irrelevant, or misleading. We will take reasonable steps to associate the record in such a way that will make it apparent to users of the Personal Information.
16.6. You can contact Us if you would like to correct the Personal Information that We hold about You. We may ask You to verify Your identity before processing any correction requests, to ensure that the Personal Information we hold is properly protected.
17.1. We collect the following Personal Information either ourselves through Our website :
(a) details about a product enquiry you have made via Our website including name, company name, email address, and free text, which you elect to enter into the enquiry page;;
(b) information you enter into Our online systems such as details when setting up an account; and
(c) the date and time you accessed the online system or website.
(d) date and time when website pages were accessed.
17.2. We will treat any Personal Information collected through Our website in the same way as other Personal Information we collect.
18.1. A cookie is a piece of data sent from a website and stored in a user’s web browser. Valocity may collect cookies to understand how online services are used.
18.2. We may use Cookies for a number of reasons, including utilising cookies to remember your log-in status and viewing preferences from a previous use of an online service.
18.3. Our website may also transfer cookies on computers and devices that access Our website for record-keeping purposes. You may be able to change Your browser preferences to reject all cookies before accessing Our website.
19.1. Our website may contain links or references to other websites or organisations. We are not responsible for the privacy practices or content of the linked websites, even if you access that website via a link on portal.valocity.com.au, velocity.co.nz or valocityglobal.com.
19.2. Third party websites may have their own privacy and security policies, which we encourage You to read before supplying any Personal Information to them.
19.3. Links to third party websites are provided for information, and do not indicate Our endorsement of that business or any assurances about the content on that site.
20.1. We use social media networks, including, LinkedIn and Instagram, to communicate with the public. When You communicate with Our social media platforms or the APIX Service We may collect Your Personal Information, for the purpose of using it to communication with You and the public. The social media webpages may also collect, use and hold Your Personal Information, for its own purpose. We recommend You consider the Privacy Policies of these social media websites prior to using the same.
20.2. These social media websites may store Your Personal Information overseas.
21.1. Any issues or complaints in relation to the collection, use, disclosure, quality, security of, access to and correction of Your Personal Information should be made to Us directly, via the contact details provided in clause 24 of this Privacy Policy.
21.2. We will respond to Your complaint within a reasonable period, and in the first instance Our Privacy Officer will endeavour to take any steps necessary to resolve the matter within five business days.
21.3. If Your complaint can not be resolved at the first instance, We will ask You to complete a Privacy Complaint Form, which details the date, time and circumstances of the matter that You are complaining about, how You believe Your privacy has been interfered with and how would You like your complaint resolved.
21.4. We will endeavour to acknowledge receipt of the Privacy Complaint Form within five business days of receiving it, and to complete our investigation into Your complaint in a timely manner. This may include, for example, gathering facts, locating and reviewing relevant documents, and speaking to relevant individuals.
21.5. Our response to the Privacy Complaint Form will set out:
(a) whether in the Privacy Officer’s view there has been a breach of this Privacy Policy or any applicable privacy legislation; and
(b) what action, if any, Valocity will take to rectify the situation.
21.6. If We are unable to resolve Your complaint or You are unhappy with the outcome, You may be able to lodge a complaint with the relevant regulator, such as the Office of Australian Information Commissioner via its enquiries line on 1300 363 992, or via its website at http://www.oaic.gov.au.
22.1. All Personal Information that has been collected from you will only be kept for a limited duration that is relevant to the purpose for which your Personal Information is to be used and for as long as required by applicable law.
23.1. In this Privacy Policy the following words have the following meaning:
(a) “Act” means the Privacy Act 1988 (Cth);
(b) “Activities and Functions” as defined in clause 2.2;
(c) “Australian Privacy Principles” means the privacy principles set out in Schedule 1 of the Act;
(d) “APIX Service” means the APIX online software product and website];
(e) “Direct Marketing” means the use or disclosure of Personal Information for the purposes of communicating directly with an individual to promote goods or services;
(f) “Personal Information” has the same meaning as in the Act;
(g) “Privacy Policy” means this document;
(h) “Pseudonym” means a name, term or descriptor that is different to an individual’s actual name;
(i) “Sensitive Information” has the same meaning as in the Act;
(j) “Us” means Valocity Pty Ltd (ACN 613 496 790), and all other related entities “Valocity”, “Our”, “We” has a corresponding meaning; and
(k) “Valuer” means a member of the Australian Property Institute (ACN 608 309 128) who is a valuer with the qualifications and expertise required in determining the market value of properties or some other suitably qualified person
(l) “You” means a person to whom this Privacy Policy applies and “Your” has a corresponding meaning.
If You would like to request
access to or amend Your Personal Information, would like to make a
complaint regarding Our conduct in relation to Your Personal Information, or have any general
enquiries in relation
to Your Personal Information, please contact
Us via the following details:
Mark Nassif
Mail: 4/11 York Street, Sydney, 2000
Phone: (02) 8073 5107
E-mail: support@valocity.com.au
As part of a continuous improvement system this
Privacy Policy shall be reviewed annually, upon recommendation following review
by senior management in consultation with staff, or following changes to
relevant legislation.
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