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—ID_Corp Group Privacy Policy

ID_Corp Group takes protecting its customers privacy rights seriously, and is committed to being open and transparent about how it manages and protects personal information, in compliance with privacy laws.

  • Under the Privacy Act 1988 (Cth) (the Privacy Act), the ID_Corp Group is legally obliged to protect and manage personal information in accordance with a set of detailed rules called the Australian Privacy Principles (APPs).
  • The Privacy Act imposes serious penalties for breaching the APPs, but importantly, any privacy breach could cause enormous damage to the reputation of ID_Corp Group’s brand and business.
  • It is therefore critically important that as staff members, you familiarise yourselves with the APPs and do everything you can to help ID_Corp Group comply with its obligations.
  • You need to read and understand this ID_Corp Group-wide Privacy Policy (published on the webpage for all entities in the Group including ID_Land, ID_Real Estate, Shape Home and Next Living but excluding Title Capital (which has a separate privacy policy)), which provides more detail about the personal information that ID_Corp Group collects, uses, discloses, stores and otherwise handles including through our network of websites, third-party social media platform (such as LinkedIn in connection with our recruitment and HR processes) and through the various activities conducted by each ID_Corp Group business unit.

In line with the privacy regulator’s, the OAIC, guidance, this Privacy Policy intended to:

  • be a clearly expressed, up-to-date and publicly available privacy policy that includes all mandatory information required under APP 1, including:
    • the kinds of personal information collected and held by ID_Corp Group;
    • how personal information is collected and held;
    • the purposes for which personal information is collected, held, used and disclosed by ID_Corp Group;
    • how an individual may access their personal information and seek its correction;
    • how an individual may complain if the entity breaches the APPs, and how the complaint will be handled;
    • whether ID_Corp Group is likely to disclose personal information to overseas recipients , and if so, the countries in which such recipients are likely to be located;
  • reflect the information handling processes across the whole of ID_Corp (excluding Title capital), not just one entity or business unit;
  • be followed by all staff members (including, for example, how to handle privacy complaints); and
  • be regularly updated to reflect changes to how ID_Corp Group handles personal information.

Escalation points

  • If you receive a privacy complaint or request to access or correct personal information from a customer/third-party, you must promptly report it to the General Counsel.
  • Further, if you notice a mistake in this Privacy Policy, for example, a category of personal information that your business unit collects from customers is not listed in the table, please ensure you inform the General Counsel.
Mathew Belford’s signature from the supplied policy

Mathew Belford, Managing Director

01ID_Corp Group’s commitment to privacy

1.1

The ID_Corp Group is committed to managing personal information in accordance with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles under the Privacy Act.

1.2

We understand the importance of being open and transparent with you in the way in which collect, hold, store, use and share your personal information. We take protecting your privacy rights very seriously.

1.3

This document sets out how we handle and protect your personal information, and provides information on your rights in relation to your personal information managed by the ID_Corp Group. This document is referred to as our Privacy Policy.

1.4

We strongly encourage you to read this document, so that you understand and are comfortable with how we handle your personal information. If you have any questions about this policy, or about ID_Corp Group’s handling of your personal information, please contact us using the relevant contact details set out in section 16.

02About the ID_Corp Group

2.1

The ID_Corp Group is committed to building connected, liveable and vibrant communities for Australian families, with its multi-billion dollar portfolio spanning property development and construction. In conducting this business, we may collect personal information.

2.2

The ID_Corp Group includes unrelated entities:

2.2.1

ID_Corporation Pty Ltd (ACN 644 183 522);

2.2.2

ID_Land Pty Ltd (ACN 129 819 626);

2.2.3

ID_Real Estate Pty Ltd (ACN 155 717 543);

2.2.4

Next Living Communities Pty Ltd (ACN 662 412 991);

2.2.5

Shape Homes Pty Ltd (ACN 619 008 874);

2.2.6

Shape Homes Qld (ACN 689 100 776);

2.2.7

their related bodies corporate (as defined in the Corporations Act 2001 (Cth);

2.2.8

as well as any other development entities created from time-to-time by another entity in the ID_Corp Group (together, the ID_Corp Group) for the purpose of a new development project, including but not limited to those development entities set out in Annexure A.

2.3

Title Capital is excluded from the ID_Corp Group for the purpose of this Privacy Policy. If applicable to you, please see Title Capital’s separate privacy policy, available at https://www.titlecapital.com.au, for information on how Title Capital handles your personal information.

2.4

In summary, the ID_Corp Group has a wide range of key operations which it pursues through its group of companies, as follows:

ID_Corp Group entities and key operations
No.ID_Corp Group entity nameKey operations

1.

ID_Corp

ID_Corp does not carry out operations. It owns the valuable intellectual property assets and portfolio of the broader ID_Corp Group (e.g., trademarks, copyrights etc), while the entities listed below are responsible for the day-to-day commercial activities of the ID_Corp Group. ID_Corp plays a key role in upholding and managing the ID_Corp Group’s various brands.

2.

ID_Land

Property development – our core operation is the development of residential projects and communities across Australia which we deliver through ID_Land.

ID_Land is a property development management company. In particular, our expertise is in delivering land estates, townhouses and apartments which work with the environment and existing local amenities, designed to deliver liveable and connected communities which result in happier and healthier residents.

3.

Shape Homes and Shape Homes Qld

Construction – as property developers, we also manage and oversee the construction of our developments with our trusted civil contractors.

Shape Homes is a residential house builder company focused on delivering turnkey solutions to owner occupiers, investors and developers. Shape Homes specialises in delivering townhouses and detached home in the growth regions of Melbourne. Shape Homes also delivers a number of townhouses as project builds for primarily ID_Land.

4.

ID Real Estate

Portfolio management – through ID Real Estate, we specialise in the leasing and responsible for the day-to-day management of our ID_Land projects. These include new developments along with established properties. ID_Real Estate focuses on medium density townhouses and apartment developments in Melbourne and surrounding suburbs.

5.

Next Living

Next Living is a land lease community venture which offers a variety of home builds within gated and managed lifestyle communities.

6.

Development Entity

Most ID_Land projects will involve a development entity entering into a management agreement with ID_Land to deliver the project.

03When does this Privacy Policy apply?

3.1

This Privacy Policy applies to the handling of personal information by:

  • the ID_Corp Group; and
  • any other special purpose vehicles as created from time to time which may be incorporated in respect of a Development.
3.2

This Privacy Policy does not apply to Title Capital, which has a separate privacy policy available at https://www.titlecapital.com.au.

04About this Privacy Policy

4.1

This document sets out our policies for managing your personal information and is referred to as our Privacy Policy.

4.2

In this Privacy Policy:

  • “we”, “us” and “our” refers to the ID_Corp Group;
  • “you” and “your” refers to any individual about whom we collect personal information; and
  • Development means a residential or other real estate project or development undertaken by the ID Corp Group.
4.3

This Privacy Policy sets out how we collect, store, process, use and disclose personal information (including personal information we collect, and personal information submitted to us, whether offline or online). For example, this may include information we collect from you:

  • as a purchaser or prospective purchaser of a property;
  • as a supplier to us;
  • when you apply for a job with us; or
  • when you otherwise interacted with us, including by:
4.4

The ID_Corp Group will regularly review its policies and procedures regarding personal information and may therefore update and amend this Privacy Policy from time to time, with or without notice to you. However, where we make a material change to this Privacy Policy, we will provide notice to you (including by updating our Websites, and, where appropriate, notifying you directly).

4.5

Any updated privacy policy will be made available on our Websites or can otherwise be obtained by contacting us and requesting a copy. We recommend that you visit this Privacy Policy regularly to keep up to date with any changes we make.

4.6

Other privacy related notices and terms and conditions may apply to you, such as a privacy collection notice provided:

  • when your register interest for a specific Development;
  • by either us or real estate agents when you agree to purchase a property;
  • when you sign-up for news and offers via our Websites; and
  • when you apply for a role with us or accept a position working for us.

05What is personal information?

5.1

“Personal information” is defined in the Privacy Act, and means 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.
5.2

In this Privacy Policy, whenever we use the term “personal information”, we are referring to this legal definition.

5.3

Personal information does not include:

  • aggregated or de-identified data;
  • information about the specifications of a property; or
  • if you are a contractor, real estate agent or supplier, your business information that does not identify a person or reasonably identify you (i.e. in certain circumstances, your business payment details).

06What kinds of personal information do we collect about you and how do we collect this information?

6.1

You may interact with the ID_Corp Group in a variety of different ways and the types of personal information that we collect about you will depend on the type of dealings you have with us.

6.2

From an overarching perspective, we are required to collect the following information to enable us to comply with our legal obligations under the including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and other related laws (AML CTF Laws).

6.3

Generally speaking, the kinds of personal information ID_Corp Group collects may include:

Types of personal information and how it is collected
Type of personal informationWhat this includesHow/when do we collect this information?

Personal and contact details

This may include your:

  • full name;
  • address;
  • telephone number;
  • email address;
  • date of birth; and/or
  • gender.

We may collect this information directly from you in person or via our Websites:

  • during our interactions with you;
  • when you submit a “Contact Us” form or otherwise make an enquiry;
  • when you register to receive updates about one of our projects;
  • when you otherwise subscribe to receive information from us including our newsletters or join our mailing list;
  • when you fill in a contact form at one of our sales offices;
  • when you contact us via our online forms, email, phone or social media (including LinkedIn);
  • when you complete a survey or enter a trade promotion or competition conducted by us;
  • when you visit a property or premises owned or occupied by us, such as our offices, one of our developments or a showroom connected with one of our developments;
  • if you apply for a position at an ID_Corp Group entity; or
  • when you otherwise interact with us on a commercial basis, including as a supplier to us.

We may also collect this information about you indirectly from third parties, for example:

  • real estate agents with whom you register your interest in a ID_Corp Group property;
  • your other representatives, including your lawyers, financiers or other authorised agents; or
  • other third parties who are involved in the marketing, promotion and sale of our properties and developments (including our sales agents and other real estate agents).

Details of lifestyle and preferences

This may include:

  • your living circumstances;
  • your buyer type (owner/investor);
  • your family demographics;
  • your current employment status;
  • details of the property that you are interested in or have agreed to purchase;
  • housing or lifestyle amenities that are of interest to you or your family;
  • the distance you travel for work; and/or
  • what prompted you to inspect the project.

We may collect this information directly from you:

  • when you fill in a contact form at one of our sales offices; and/or
  • during our interactions with you if you are interested in purchasing property in connection with one of our developments (including by phone, email or in person).

We may also collect this information about you indirectly from third parties, for example:

  • real estate agents with whom you register your interest in a ID_Corp Group property;
  • your other representatives, including your lawyers, financiers or other authorised agents; or
  • other third parties who are involved in the marketing, promotion and sale of our properties and developments (including our sales agents and other real estate agents).

Workplace information

This may include:

  • details of your employment history;
  • information about your education, qualifications and certifications;
  • details of any skill-specific licences you hold (for example, a forklift licence);
  • your tax file number;
  • your working eligibility rights;
  • your suitability for the role you are applying for;
  • details about your referees;
  • health information and incident reports - this may include sensitive information; and/or
  • other information provided as part of our recruitment process.

We may collect this information through our recruitment process when you apply for a position with us, or otherwise during your employment.

Background check information

Including national police check information (if applicable) – this may include sensitive information, such as if you have a criminal record

We may collect this information directly from you through our recruitment process, when you apply for a position with us, or otherwise during your employment.

We may also collect this information:

  • from third parties (for example, verification providers, referees, previous employers, professional registration authorities, or our contractors that employ you); and/or
  • publicly available information (for example, court decisions).

Proof of identity information

This may include:

  • your driver’s licence;
  • your nationality;
  • your visa (if applicable);
  • your tax file number; and/or
  • other similar identity information.

We may collect this information directly from you if you are applying to purchase a property that we are developing, or if you are a job applicant or employee.

We may also collect this information about you indirectly from third parties, for example, real estate agents you have engaged to assist with your purchase of an ID_Corp Group property.

Transactional and payment information

This may include:

  • information about transactions that you undertake in respect of any ID_Corp Group properties or developments; and/or
  • your bank account or credit card details.

We may collect this information:

  • if you enter into, or propose to enter into, a transaction with us, including the purchase of property in connection with one of our developments; or
  • during your employment with us.

Financial information

This may include information about your:

  • financial circumstances and objectives;
  • assets;
  • income;
  • liabilities and expenditure;
  • bank account details and transaction history; and/or
  • investment preferences.

We may collect this information if you enter into, or propose to enter into, a transaction with us, including the purchase or lease of property in connection with one of our developments.

We may also collect this information about you indirectly from third parties, for example:

  • real estate agents with whom you register your interest in a ID_Corp Group property;
  • you other representatives, including your lawyers, financiers or other authorised agents; or
  • other third parties such as mortgage brokers and/or financial service providers.

Call recording / CCTV information

ID_Corp Group may collect call recordings and CCTV footage.

We may collect call recording information from calls that you make to the ID_Corp Group, noting that you will always be advised of the call recording in advance if applicable.

We may collect CCTV footage of you from CCTV surveillance systems that monitor our properties and premises, including our corporate offices, sales suites and Development sites, when you enter such locations.

Information required to be collected by law

ID_Corp Group may also hold other kinds of personal information as permitted or required by law.

We may collect this as required.

Publicly available information

Information that is publicly available online, such as on online forums, websites, and social media channels (for example, information that relates to a complaint, ASIC search results, etc).

We may collect this directly from the publicly available source (e.g. the Land Titles Office, relevant State and Territory Valuers General, ASIC, online forums, websites, or social media channels).

Other types of information collected during our interactions

This may include information that you provide us so that we can provide you with information regarding our properties and related services, or so that we can undertake transactions or dealings with you.

We may collect this information:

  • when you request information about a property or related services from us;
  • when you attend an event conducted by us;
  • when you submit a form via the website;
  • if you post information to any of our social media sites, or interact with us on social media;
  • when you make an enquiry, provide feedback, or make a complaint (via phone, email or in person); and
  • in your responses to customer satisfaction, service development, quality control, research surveys and similar activities.

Company information

This may include:

  • company information such as the company’s ABN or ACN and director details;
  • ASIC search results; and/or
  • information about your company’s employees, contractors or suppliers.

We may collect this information from you as part of our supplier onboarding process if you are a current or prospective supplier, or from publicly available sources such as ASIC.

Online and digital services information

This may include information (that is not always identifiable) about your:

  • network and device information (such as your device ID, type and IP address);
  • geo-location information;
  • browsing information, including information about how you interact with our Websites, pages your visit, what content you viewed and your session duration;
  • web form inputs such as your name, address, email address and phone number;
  • transaction data and/or
  • information collected from cookies and/or tracking pixels

Please see 12 below for further information on the digital information we collect and when it may become personal information.

We may collect this information when you use our Websites, via use of online behavioural tracking technologies such as cookies and/or tracking pixels. For further information, see section 12.

Unsolicited information

Unsolicited personal information is personal information we receive that we have taken no active steps to collect (for example, an employment application sent to us by an individual on their own initiative, rather than in response to a job advertisement).

We may collect this information directly from you.

Please note that we may keep records of unsolicited personal information to the extent that it is permitted by the Privacy Act (for example, if the information is reasonably necessary for one or more of our functions or activities).

If not, we will destroy or de-identify the information as soon as practicable, provided it is lawful and reasonable to do so.

6.4

ID_Corp Group may also collect other kinds of personal information that we notify you of at the time of collection.

6.5

Generally, we do not collect sensitive information about individuals, except where we collect relevant information from employees, such as health information (as set out above) so that we can support you better. Information about your health, racial or ethnic origin, political affiliations, criminal record and religious or philosophical beliefs are all examples of sensitive information. If we do need to collect sensitive information about you, we will only do so with your consent or where we are required or permitted to do so by law.

6.6

In some cases, you may provide us with personal information which relates to another person (for example, an emergency contact, prospective purchaser (if you are a real estate agent) or a job referee). If you do so, you agree that you have received permission from these individuals for us to collect, use, and disclose their personal information in accordance with this Privacy Policy. You should also let them know about our Privacy Policy (including the information in this Privacy Policy).

07Can you deal with us without providing your personal information?

7.1

You are under no obligation to provide your personal information to ID_Corp Group. We will provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to an individual’s actual name. For example, you can access our Websites, make general phone queries or email us without having to identify yourself.

7.2

However, without certain information from you, the ID_Corp Group may not be able to provide you with information about our properties that is tailored to your requirements and needs, sell a property to you, or provide other services, and we may generally be limited in how we can interact with you.

08Why we collect, store and use your personal information

8.1

Generally speaking, ID_Corp Group collects and uses personal information so that we can develop, improve and promote our property development, and property-related services and so we can conduct our property development and related businesses.

8.2

Also from an overarching perspective, we are required to collect the following information to enable us to comply with our legal obligations under the including the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and other related laws (AML CTF Laws).

8.3

We may also use your personal information for purposes which are incidental to the development, improvement and promotion of our property development and related businesses, or for other purpose which are within your reasonable expectation or permitted by law.

8.4

The purpose for which we usually collect, store, and use your personal information depends on how you interact with us (for example, whether you are an employee or potential property purchaser), but may include the following purposes::

Purposes for collecting, storing and using personal information
PurposeExplanation

To sell you a property, or provide you with other property-related services

We may handle your personal information to:

  • verify your identity;
  • communicate with you, including by phone, email, or mail, generally as well as about projects you have enquired about, new ID_Corp Group projects and corporate marketing (in accordance with the “Do we use your information for direct marketing” section below);
  • respond to your queries and provide you with products, services and information you request from us;
  • carry out our obligations arising from any contracts we enter into with you;
  • enforce the terms of any contract that you enter into with us relating to our products and services;
  • administer, manage and process any transactions you enter into, or propose to enter into, with us, including the purchase of property, any applicable payments, our billing and account purposes or otherwise in connection with one of our developments;
  • help us to manage the property-related services we provide to you, including personalising your experience;
  • keep our records accurate, complete and up-to-date;
  • conduct trade promotions, competitions, giveaways and events;
  • investigate incidents (including potential incidents) which occur on or at our development sites, properties or premises;
  • manage our relationship with you, including by resolving complaints or improving our customer service;
  • develop and improve the residential and other properties we develop, and the property-related services we provide, including by obtaining your feedback regarding such or by conducting market research; and/or
  • comply with our legal and regulatory obligations including notifying you of matters that we may be required by law to notify you of.

To manage your working relationship with us (including if you are an employee or contractor)

We may handle your personal information to:

  • verify your identity;
  • recruit employees and contractors;
  • consider your suitability as a prospective employee or contractor;
  • manage our working relationship with you;
  • investigate incidents (including potential incidents) which occur on or at our development sites, properties or premises; and
  • collect, store and use your personal information for administration and management purposes.

To do business with you

We may collect, store and use your personal information if you interact with us on a commercial basis (such as if you are a service provider, real estate agent, contractor or supplier to us), or if you otherwise interact with us on a commercial basis.

To manage and improve our operations and business

We may collect, store and use your personal information to:

  • obtain finance for our developments;
  • conduct the general operation and management of ID_Corp Group, our property development business and to supply our services to you;
  • train staff (including IT, development, legal and finance teams);
  • maintain appropriate work, health and safety standards at our development sites, properties and premises;
  • test and maintain information technology systems;
  • protect the security of our offices, employees, customers and the property held on our premises;
  • administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
  • manage payments and debt recovery

To create de-identified or aggregate data for data analytics

We may collect, store and use your personal information to create deidentified or aggregate data sets (which is no longer personal information). We do this by de-identifying or aggregating your information such as combining your information with information we have about our other customers, for example purchasing information, and with data we obtain from other sources. We use this deidentified or aggregate data to assist with our business decisions, such as to:

  • help us in understanding trends in customer behaviour (such as the success of our properties, and our different marketing campaigns);
  • create look-a-like audiences for the purposes of providing targeted advertising to other customers;
  • perform research and statistical analysis, including for customer satisfaction and service improvement purposes;
  • improve the products and services we offer; and
  • design, engineer, construct and develop new properties and developments that better meet our customers’ preferences and behaviours.

To assist with any business, share sale or corporate restructure

We may collect, store and use your personal information for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business or if we undergo any other kind of corporate restructure, acquisition or sale.

To comply with legal and regulatory obligations

We may collect, store and use your personal information for the purpose of complying with our obligations under any applicable laws and regulations, including privacy laws.

8.5

In addition to the purposes listed above, ID_Corp Group may use your personal information for other purposes which we notify you of when we collect your personal information and for purposes otherwise permitted or required by law.

8.6

ID_Corp Group only uses and discloses your personal information for the purpose for which it was collected, including related secondary purposes as permitted by privacy laws.

09Who do we share your personal information with and why?

9.1

ID_Corp Group may share your personal information with third parties:

  • for the purpose for which we collect it, as set out in section 8 of this Privacy Policy;
  • for other purposes, if we notify you of such when we collect the information; or
  • where we have otherwise received your consent, or the disclosure is required or authorised by law, such as the AML CTF Laws.
9.2

Some of the third parties we may share your personal information with includes the following:

Recipients of personal information
RecipientExplanation

Other members of the ID_Corp Group (including both related an unrelated entities as described above at 2}

We may share your personal information with related or unrelated companies (including special purpose vehicles of the ID_Corp Group), as appropriate.

For example, we may share your personal information to another ID_Corp Group entity who provided backend services or other services to another ID_Corp Group entity.

Title Capital

We may share your personal information with Title Capital for the purposes of operating our respective businesses, including generating new business and business leads and contacts.

Real estate agents and authorised representatives

We may share your personal information with real estate / property agents who are assisting with the sale of our properties, where you have expressed interest in finding out more about a property, or making a purchase. We may also share your information with any of your authorised representatives or agents (for example, your financial planner), if applicable.

Relevant Land Titles Offices, service providers and partners who assist in the conveyancing process

We may share your personal information with the relevant land Titles Office in your jurisdiction, service providers, partners, and other third parties that provide their services to assist in the conveyancing process in property sales. This may include conveyancing lawyers and financial institutions.

Financial providers

We may share your personal information with our financiers and prospective financiers, financial institutions (for payment processing), and/or mortgage brokers (as relevant).

Our service providers, advisors and other entities we do business with

We may share your personal information with our:

  • service providers (including payment processors), agents, contractors, sub-contractors, builders and their housing consultants, and other third parties that provide services to us, including our technology service providers and administration service providers; and
  • professional advisors, including legal and accounting firms, auditors, consultants, insurers and other professional advisers.

Please note that 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.

Corporate restructure

We may share your personal information with people or entities considering acquiring an interest in the ID_Corp Group or any business or assets of the ID_Corp Group, for the purpose of facilitating or implementing a transfer or sale of all or part of our assets or business, or if we undergo any kind of corporate restructure. In this context, your personal information may be transferred to another entity.

Government and law enforcement agencies

We may share your personal information with law enforcement agencies, other governmental bodies or agencies (for example, the relevant State or Territory Valuers General, ASIC, etc) or third parties:

  • if we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority; or

in order to conduct our business, for example, if we believe that such action is necessary to prevent fraud or cyber-crime or to protect our website, our products or our technology assets or the rights, property or personal safety of any person).

Responsible authorities, such as local councils and water authorities

We may share your personal information with such authorities to facilitate your purchase or potential purchase of a property from us, or to provide you with other property-related services.

Referees

We may share your personal information with your nominated referees to validate details you have provided us with, including your resume, qualifications, experience, training or abilities.

Marketing organisations

We may share your information with marketing organisations that assist us with our marketing communications or who send you marketing communications on our behalf. Please see the “Do we use your information for direct marketing” section below for further information on how we engage in direct marketing.

9.3

If you post information or other content to public sections of our Websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant Website or social media site.

10Overseas disclosures

10.1

We do not currently disclose personal information to third parties located overseas.

10.2

If this changes at some point in the future, we will only ever share your personal information outside of Australia where we are permitted to do so under the Privacy Act. This means that we will take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act. If this happens, this Privacy Policy will be updated accordingly.

11Links to other websites

11.1

When you access our website or other online services, we may provide, as a convenience to you, links to other websites, including sites operated by our partners, associates, or independent third parties. Each website has its own privacy practices, as described in that website’s privacy policy. Those practices may be different than the practices described in this Privacy Policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that site.

11.2

Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party, and cannot and are not responsible for any information that you may submit to that site. We encourage you to read the relevant third party’s privacy policy before supplying any personal information to them.

12Cookies, Pixels and other third-party online tracking technologies

12.1

ID_Corp Group may collect statistical information when you access and use our websites and any online platforms available via our Websites, by utilising features and technologies of your internet browser, including cookies and tracking pixels. We use these tracking technologies for a variety of purposes, including to:

  • collect data about our website traffic;
  • analyse how our Websites are being used,
  • improve our Websites; and
  • provide more user friendly and customised websites and online services.
12.2

These features and technologies do not specifically identify you unless you otherwise provide personal information to us that enables identification. As such, information collected through these tracking technologies may be personal information.

12.3

We also use third-party service providers, such as Google and Meta, that may collect data related to your use of our online services through tracking technologies, such as third-party tracking pixels and web beacons, for analytic and marketing purposes. We use these third party providers to help us improve the advertising that you see from us, some of which may be personalised, when you visit their respective platforms or networks (such as Facebook and YouTube).

12.4

These third-party services may also link the information collected about you to your personal profiles on their platforms if you are logged in.

12.5

You may not be able to entirely disable ads that you see, however, you can control how these platforms use your information by adjusting your ad preference and personalisation settings by:

Third-party advertising preference settings
ProviderDescription

Meta Platforms Inc

If you use Facebook, Instagram, Threads or any other platforms or networks owned or used by Meta, you can generally adjust your ‘ad preferences’ in the account settings of the respective platform that you access and see ads in.

Alphabet Inc

If you use YouTube, Google or any other platforms owned by Alphabet, you can manage how tracking technologies are used by checking your browser or account settings and adjusting your ‘privacy & safety’ and ‘search personalisation’ settings.

12.6

These third party providers may update their policies and settings from time to time, so we encourage you to review their terms and policies for more information on their data collection practices and options available to you for managing your privacy. Please note that how these third parties handle and use your data is governed by their own privacy policies, not ours.

Cookies

12.7

Below are the main types of cookies we use a combination of:

Types of cookies and their uses
Type of CookieHow we use this Cookie

Session Cookies

Session cookies are used to track your movements from page to page. These cookies are usually erased when you close your web browser.

Persistent Cookies

Persistent cookies are stored on your device between browser sessions for a pre-defined amount of time. These cookies allow the site to remember your information or settings across the site.. These cookies also enable targeted advertising.

Functional Cookies

Functional cookies remember information such as usernames or language settings and may allow the site to display important alerts. These cookies are not considered necessary, and can be blocked by the user, although this may impact how the site functions. In some instances, functional cookies are used by the website.

First party Cookies

First party cookies are set by the website you are browsing.

Necessary Cookies

Necessary cookies are either session or persistent cookies, and are used to perform functions such as storing data and remembering you between pages. Similar to session cookies, these cookies are necessary for a number of functional features on our website.

Tracking and Social Cookies

Tracking and social cookies are either session or persistent cookies, but are not essential to the function of our website. These cookies help improve your experience by providing content relevant to you.

12.8

You can choose which sites and devices allow cookies to be used, by changing your web browser preferences. For example, depending on which browser your device uses, you may be able to disable certain third-party cookies. It may be necessary for you to opt out separately from each device and browser that you use to access online content.

12.9

To change your web browser preferences, please visit the relevant preferences or settings page on your browser and amend the privacy settings in relation to cookies and site data. As set out above, you can also change the settings on websites you receive tailored advertising (such as on Facebook, via your account settings), to control the extent to which you receive tailored advertising facilitated by cookies.

Tracking pixels

12.10

A tracking pixel is a piece of code that a business or third-party provider can place on its website or in email to collect information about a users’ activity, including the site pages they visit time spent on each page, IP address, and/or form inputs (as relevant). When users visit pages with pixels, the pixel “loads” and send the information it is designed to collect back to the server of e.g. in the case of third-party pixels this would be to the third-party service provider like Meta or Google (as set out above).

12.11

Below are the main types of tracking pixels we use a combination of:

Types of tracking pixels and their uses
Type of PixelHow we use these Pixels

Retargeting Pixels

These are coded to monitor specific actions you make, such as which pages you visit, how much time you spend on each page, or how far you scrolled down a page. These help us understand our users’ behaviour on our Websites.

Conversion Pixels

These are designed to track completed actions. When an action is completed it sends a signal back to the server. This data helps us understand how effective a particular webpage is at encouraging specific actions.

Analytical Pixels

These pixels collect a wide range of data, including page views, time spent on the site and visitor demographics

Email Tracking Pixels

We use these in email campaigns to track actions like email opens, link clicks and forwards. When you open an email, the pixel sends a signal back to the server, providing data that can help in understanding the effectiveness of email marketing strategies.

Affiliate Pixels

Affiliate pixels are used to track sales or leads generate through affiliate marketing. When a visitor clicks on an affiliate link and completes a specific action, the pixel fires, allowing the affiliate to earn a commission for the sale.

12.12

If you would like to opt out of this tracking, please contact us at info@idland.com.au.

13Do we use of share your personal information for direct marketing?

13.1

ID_Corp Group and/or our third party service providers may use and share your personal information for the direct marketing purposes set out in the table below through various channels, such as via regular amil, email, SMS, telephone or social media (through targeted advertisements on certain websites, mobile applications and social media channels).

  • products, services, discounts, competitions and special promotions that we consider may be of interest to you, including about developments or future developments of the ID_Corp Group;
  • offers or promotions based on how you use our products and services; and
  • third party products and services (including offers and discounts we may have negotiated for our customers) that we think may interest you, for example, if we are selling residential land, we may promote the services of one or more builders, brokers and other consultants and advisors in the property and building industry.
13.2

Where you provide personal information to an ID_Corp Group entity, we may share this personal information to another entity in the ID_Corp Group so that they may undertake direct marketing as set out in 13.1.

13.3

We will only send these communications in accordance with the Privacy Act (including Australian Privacy Principles 7) and the Spam Act 2003 (Cth), and only where you have not opted out from receiving such communication from the relevant ID_Corp Group entity or brand.

13.4

You are always in control of the direct marketing communications which you receive from us and can opt-out at any time using the methods described in the table below. Generally, you can opt-out by following the relevant opt-out or unsubscribe instructions in the relevant communication (such as email or SMS message). You can also contact us using the details set out in section 16 of this Privacy Policy to tell us you would like to stop receiving direct marketing communications from us.

13.5

If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so.

Direct marketing formats and how to opt out
Format / ChannelExplanationHow to opt-out?

Direct marketing via email, SMS message and mail

We may use your personal information to send you direct marketing communications to let you know about us and products and services (including promotions, special offers and events) offered by the ID_Corp Group, and carefully selected third party products and services, which we think might be of interest to you based on your interactions with us, or as otherwise allowed under applicable privacy laws.

You can opt-out by following the relevant unsubscribe instructions in the relevant communication (such as email or SMS message). To opt-out of direct marketing via mail/post, you can also contact us using the detail set out in section 16 to tell us you would like to stop receiving direct marketing communications from us in this way.

Cookies

We use advertising programs that place cookies on your computer to collect information about your browsing history (including on external websites). This information, which does not identify you personally, is collected in order to improve your online experience by customising the advertising you see to your interests (including the display of more relevant advertisements on external websites).

As set out in section 12, you can only opt-out of these types of cookies and tracking technologies by adjusting your device and browser settings and online privacy settings (for advertising on certain websites, mobile applications and social media channels).

Tracking pixels and other tracking technologies

Some tracking pixels and other tracking technologies we use may use your personal information for direct marketing (such as targeted advertising and personalising your experience).

As set out in section 12, you can opt-out of these types of tracking technologies by contacting us at info@idland.com.au.

Important points regarding opting out –

Importantly:

13.6

if you are a customer of or have signed-up, registered your interest or otherwise, with multiple ID_Corp Group member entities (for example, you have purchased a property through ID_Land, and are also separately signed-up to receive Shape Homes’ Sales & partnerships Newsletter), even if you opt out from receiving direct marketing communications from ID_Land, this will not mean you are opted out from receiving direct marketing communications from Shape Homes; and

13.7

regardless of whether you opt out from receiving any or all direct marketing communications, we will still communicate with you if required by law to provide you with information, or in relation to the property you are purchasing or other property-related services we are providing to you.

14How do we store and protect your personal information?

14.1

We are committed to protecting your personal information and ensuring that we securely store any personal information we collect (in accordance with applicable privacy laws). We may hold your personal information in hard copy (paper) or electronic form.

14.2

ID_Corp Group takes steps reasonable in the circumstances to ensure that the personal information it holds is accurate, complete, up-to-date and stored in a secure environment protected from misuse, interference and loss, and from unauthorised access, modification or disclosure.

Security and storage of personal information

Security and storage of personal information
FormExplanation

Paper-based files

We store personal information in paper-based files in secure storage, and maintain physical security measures to ensure that such personal information is protected, such as physical locks on drawers and cabinets, and security systems at our premises. Paper files may also be archived in boxes and stored offsite in secure facilities.

Electronic records

Your personal information will be stored on databases held on servers located in a technologically secured environment, accessed only by authorised personnel or contractors (with login and password protection). We also maintain physical security measures in relation to storage of our electronic records (such as locks and security systems), and maintain computer and network security, by using firewalls. Anti-virus software and other security systems to control access to our computer systems. ID_Corp Group also has polices and procedures in place in relation to document storage and security.

Our Websites (including for making payments)

Our Websites use encryption and other technologies to ensure that your personal information is securely transmitted via the internet.

We process payments using EFTPOS and online technologies. All transactions processed by us meet industry security standards to ensure payment details are protected.

How long do we keep your personal information?

14.3

We will only keep your personal information we store for as long as is necessary for the purposes set out in this Privacy Policy, or as required to comply with any applicable legal obligations. This will involve us regularly reviewing our files to check that information is accurate, up-to-date and still required.

14.4

If you close an account you have with us or you decide not to go ahead with purchasing a property or land for which you have registered, we may still keep your information to the extent allowed under applicable privacy laws.

14.5

When we no longer require (and in accordance with any applicable laws), we will take steps to delete, destroy or de-identify that information.

15How can you access or seek correction of your personal information?

15.1

You are entitled to request access to any of your personal information held by ID_Corp Group. To make such an access request, please contact us using the contact details below at section 16.

15.2

ID_Corp Group takes reasonable steps to ensure the personal information it holds is accurate, up-to-date, complete, relevant and not misleading. You can help us to do this by letting us know if you notice errors or discrepancies in information we hold about you, and informing us of any change in your personal details.

15.3

In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by ID_Corp Group. If at any time you consider any personal information we have about you is inaccurate, out of date, incomplete, irrelevant or misleading, you are entitled to request correction of that information using the contact details in section 16. ID_Corp Group will grant access to the extent required or authorised by the Privacy Act and will take reasonable steps to correct your personal information.

15.4

If we correct personal information about you, and we have previously disclosed that information to another agency or organisation that is subject to the Privacy Act, you may ask us to notify that other entity. If so, we will take reasonable steps to do so, unless this would be impracticable or unlawful.

15.5

ID_Corp Group will respond to your request within 30 days. We may decline your request to access or correct your personal information in certain circumstances in accordance with applicable privacy laws, however if we do so, we will provide you with written reasons for the refusal and details of complaint mechanisms.

15.6

If you are dissatisfied with ID_Corp Group’s refusal to grant access to, or correct, your personal information, you may complain to us using the contact details at section 13 below.

16How can you contact ID_Corp Group?

16.1

For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact us using any of the following details:

Contact details for ID_Corp Group
Contact ID_Corp Group

Email

ID_Corp: info@idland.com.au

ID_Land: info@idland.com.au

ID_Real Estate: info@idland.com.au

Shape Homes and Shape Homes Qld: info@shapehomes.com.au

Next Living: info@idland.com.au

Phone

03 9867 4700

Postal address

Privacy Officer, Level 11, 484 St Kilda Road, Melbourne VIC 3004

17Privacy complaints and questions

17.1

If you have any questions or concerns about this Privacy Policy or how we have handled your personal information, you may contact us at any time using the relevant contact details set out above in section 13.

17.2

Please also contact us if you have a complaint about privacy. If you make a complaint about privacy, the following will occur:

Steps for handling a privacy complaint
No.Step

1.

We will first consider your complaint to determine whether there are simple or immediate steps which can be taken to resolve the complaint. We will generally acknowledge your complaint within a week.

2.

If your complaint requires more detailed consideration or investigation:

  • we will acknowledge receipt of your complaint within a week and endeavour to complete our investigation into your complaint promptly.; and
  • we may ask you to provide further information about your complaint and the outcome you are seeking. If your initial complaint was not written, we may ask you to submit your complaint in writing.

3.

We will then typically gather relevant facts, locate and review relevant documents and speak with the individuals involved.

4.

In most cases, we will respond to your complaint within 30 days from when we receive your complaint. If the matter is more complex or our investigation may take longer, we will let you know, and tell you when we expect to provide our response.

17.3

If you are not satisfied with our response to a complaint, or you consider that we may have breached the Privacy Act (including the Australian Privacy Principles), you are entitled to make a complaint to the Office of the Australian Information Commissioner (the Australian privacy regulator).

17.4

The Office of the Australian Information Commissioner can be contacted by telephone on 1300 363 992, or you can fill out this form to make a complaint about our handling of your personal information. Full contact details for the Office of the Australian Information Commissioner can be found online at www.oaic.gov.au.

AAnnexure A – Development Entities

Development entities listed in Annexure A
Name of DevelopmentDevelopment Entities (if relevant)

1.

Canvas

  • ID Barkly Apartments Developments Pty Ltd
  • ID Barkly St Pty Ltd
  • JG Barkly St Pty Ltd
  • MB Barkly St Pty Ltd

2.

Dawn

  • ID Walloon Pty Ltd
  • ID Walloon Developments Pty Ltd

3.

Glenlee

  • ID-Occasio Reserve Developments Pty Ltd
  • ID Reserve Road Pty Ltd

4.

Haymont

  • ID TC Harriott Development Pty Ltd
  • ID Harriott Road Pty Ltd

5.

Next Living Charlemont

  • NL Charlemont Developments Pty Ltd
  • NL Charlemont LLC Pty Ltd
  • NL Boundary Road Pty Ltd

6.

Next Living Gisborne

  • NL Ross Watt Road Developments Pty Ltd
  • NL Ross Watt Road Pty Ltd
  • NL Gisborne LLC Pty Ltd

7.

Port Lane

  • IDF Port Melbourne Pty Ltd
  • ID Williamstown Road Pty Ltd
  • JG Williamstown Road Pty Ltd
  • MB Williamstown Road Pty Ltd

8.

Reserve

  • ID Title Geelong Pty Ltd
  • ID 86 Reserve Road Pty Ltd
  • ID 108 Reserve Road Pty Ltd

9.

Rosalia

  • ID Ross Watt Road Pty Ltd

DocuSign Envelope ID: 14D7102A-FC26-8356-824D-533CEC7DBA18

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