Privacy Policy

This Privacy Policy applies to any of your personal information collected by Ingham Property Holdings Pty Limited (ABN 34 160 339 855) and Ingham Property Pty Ltd (ABN 95 644 793 046) and Ingham Rural Property Group Pty Ltd (ABN 40 160 339 882) (hereinafter referred to as we, us, and our).

1. We understand the importance of the privacy of an individual’s personal information. This Privacy Policy governs:
   1. how we collect, store, use, handle and disclose your personal information as you use websites https://inghamproperty.com.au and https://inghamandco.com.au (Site) and/or purchase our products and/or services; and
   2. how we aim to protect the privacy of your personal information.
2. We respect the rights and privacy of all individuals and are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs), and are omitted to responsible privacy practices.
3. Please read this Privacy Policy carefully to understand how we collect, use, disclose, store, handle and protect your personal information. This Privacy Policy applies to all information collected through the Site, and any other websites we operate.
4. This Privacy Policy sits alongside our Terms of Use, and any other terms and conditions that apply to our products and/or services you acquire from us.

What Personal Information Do We Collect?

1. In this Privacy Policy, personal information has the meaning given in the Privacy Act. Generally, personal information is information (whether a fact or an opinion) about an individual who is identified or reasonably identifiable from that information or other information combined with that information.
2. Some types of personal information are classified as ‘sensitive information’ and/or ‘health information’, which are subject to additional protection under the Privacy Act. Sensitive information may include information about your racial origin and health status, and health information may include information about a health-related service you have had or will receive, including test results and appointment details.
3. We collect the types of personal information required to assist us in providing our products and/or services, fulfilling our functions and activities and informing you about them.
4. This includes personal information such as:
   1. in the case of customers procuring our products and/or services – your name, billing or shipping address, phone number, email address, and your order details;
   2. technical information and general analytics, such as web browser type and browsing preferences, Internet service provider, referring/exit pages, date/time stamps, IP address, time zone and geolocation data (if applicable), some of which is collected automatically, arising from your use of the Site and/or platforms, as well as information about your usage of the Site and/or platforms when browsing;
   3. if you have requested to receive news about exclusive offers, promotions or events from us – your name, mailing or street address, email address, and phone number(s);
   4. if you have contacted us to make a complaint, provide feedback, submit an enquiry, request a call-back or request a product replacement – your name, mailing or street address, email address, and phone number(s);
   5. in the case of trade credit applicants – information required to assess your credit worthiness, including your credit or business history and any trade referees;
   6. in the case of prospective employees or contractors – information contained in your application or résumé, recorded during any interview, or obtained through any pre-employment checks, and government-issued identifiers such as tax file numbers; and
   7. in the case of our suppliers and distributors – your name, mailing or street address, email address and phone number(s).
5. We do not collect sensitive information.

How Do We Collect Personal Information?

1. We collect personal information directly from you, including when you:
   1. access or use the Site;
   2. subscribe to or purchase our products or services;
   3. sign up to receive news and exclusive offers, promotions or events;
   4. enter surveys, competitions, promotions or request information or material from us;
   5. make inquiries about us or our products or services or otherwise communicate with us by email, by telephone, in person, via a website or otherwise; and
   6. apply to work with us or are engaged by us as a contractor.
2. Where it is reasonable and practicable to do so, we will only collect personal information about you from you directly and not from third parties.
3. In limited circumstances, we may collect personal information about you from publicly available sources (such as the Internet) and from third parties (such as mutual contacts, or if someone makes a purchase on your behalf, or from your referees during the recruitment process if you apply for a job with us).  We may also collect personal information through third parties such as our service providers or through promotional and marketing activities.
4. Whilst we will always maintain robust privacy practices, we are not responsible for the privacy practices of third parties, so you should review their relevant privacy policy to satisfy yourself as to how they protect and handle your personal information.
5. We also use the following technologies to collect technical information and general analytics:
   1. cookies, which are data files that are placed on your device and often include an anonymous unique identifier.  For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org; and
   2. log files, which track actions occurring on the Site.
6. You may disable your web browser from accepting cookies and other tracking technologies used to collect technical information and general analytics when browsing the Site. If you do so, you can still access the Site, but it may impact your user experience.
7. In addition to our cookies, certain third parties may deliver cookies to your device for a variety of reasons. For example, we sometimes use various web analytics tools that help us to understand how visitors engage with the Site. Any third-party links or advertising on the Site may also use cookies. You may receive these cookies by clicking on the link to the third-party site or advertising. We do not control the collection or use of information by these third parties, and these third-party cookies are not subject to this Privacy Policy. You should contact these companies directly if you have any questions about their collection and/or use of information. When linking to any other website, you should always check its website’s privacy policy before providing any personal information.
8. You may also opt out of targeted advertising by visiting Facebook, Google and Bing. Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal.

How Do We Use Your Personal Information?

1. We will use the Personal Information you provide for purposes including to:
   1. provide and inform you about our products and/or services;
   2. enable the proper operation and functionality of, and improve, our business and our products and/or services;
   3. verify your identity (for example, if you request access to the personal information we hold about you);
   4. consider you for a job (whether as an employee or contractor) or other relationships with us;
   5. communicate with you, and to address any issues or complaints that we or you may have regarding our relationship and our products and/or services;
   6. prevent, detect and investigate suspicious, fraudulent, criminal or other activity that may cause you, us or others harm, including in relation to our products and services;
   7. comply with our legal obligations such as notifying you of matters that we may be required by law to do so;
   8. gain insights about you so that we can serve you better, understand your preferences and interests, personalise your experience and/or enhance products and services you are offered and receive;
   9. for direct marketing purposes; and
   10. contact you regarding any of the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.
2. We may also use or disclose your personal information for [our administrative, marketing (including direct marketing), planning, product or service development, quality control, survey and research purposes and] for other purposes to which you have consented, or as otherwise permitted or required by law.
3. Technical information and general analytics is used for the purpose of gauging visitor traffic, trends and delivering personalised content to you while you are using the Site, and to improve the Site and our products and services.

To Whom Do We Disclose Your Personal Information?

1. We may use and disclose your personal information to:
   1. our professional advisers (such as lawyers, accountants or auditors) and insurers;
   2. our employees, contractors and third party service providers who assist us in performing our functions and activities;
   3. governmental or regulatory authorities upon request being made or otherwise as required by law;
   4. any potential third party acquirer of our business or assets, and advisors to that third party;
   5. organisations authorised by us to conduct promotional, research or marketing activities;
   6. third parties to whom you have authorised us to disclose your information (e.g., referees); and
   7. other members and entities of our corporate group.
2. We use third party service providers to provide us with web analytics services, such as Google Analytics. You can read more about how Google Analytics uses your personal information here.

Will You Receive Direct Marketing?

1. We will only send you promotional messages and materials related to our products and/or services (including through a third-party service provider) (i.e., direct marketing communications) through mail, SMS or email, including news and exclusive offers, promotions, and events, where you have consented for us to do so.
2. If you do not wish to receive direct marketing communications from us, you may contact us at any time to opt out of such communications or use the unsubscribe facility provided in our marketing communications.

Security and Storage of Your Personal Information

1. We store your personal information in both hard copy and/or electronic forms in secure databases on secure premises, accessible only by authorised staff. We do not combine or link personal information we hold about you with other personal information about you from third party sources.
2. We store personal information in servers located in Australia. Your personal information will not be disclosed to recipients outside Australia without your express consent. Except where an exception applies under the Privacy Act or other relevant legislation, we will take commercially reasonable steps to ensure that overseas recipients to whom we disclose personal information do not breach the Privacy Act and APPs in relation to such personal information.
3. We implement measures to protect and safeguard your personal information from misuse, loss, theft, and unlawful accessed, modification and disclosure. We maintain physical security over electronic data stores, such as through locks and security systems at our premises.  We also maintain computer and network security, for example, we use firewalls (security measures for the internet) and other security systems such as user identifiers and passwords to control access to our computer systems.
4. However, particularly for electronic data stores and since the Internet is inherently insecure, we cannot guarantee the security of transmission of personal information disclosed to us online.  Accordingly, you transmit your personal information to us online at your own risk and are encouraged to exercise care in sending personal information via the internet. Please notify us immediately if you know or reasonably suspect that your personal information has been subject to any data breach, breach of security or any other unauthorised activity.
5. Subject to any retention period required by law or if it is reasonably necessary for us to comply with our legal obligations, resolve a dispute or maintain security, we will retain your personal information for the period necessary for the purposes for which your personal information was collected (as outlined in this Privacy Policy).

How Can You Access and Correct Your Personal Information?

1. You may request access to any personal information we hold about you at any time by contacting us at admin@inghamproperty.com.au. We will provide access to that information in accordance with the Privacy Act.
2. We encourage you to contact us if you believe the personal information, we hold about you is inaccurate, incorrect or incomplete. Where we agree that the information needs to be corrected, we will update it. If we do not agree, you can request that we make a record of your correction request with the relevant information.
3. We may charge you a reasonable administration fee in limited circumstances for providing access to your personal information, but we will let you know in advance if that is the case.

Can You Remain Anonymous or Withhold Personal Information?

1. You do not have to identify yourself or provide any personal information if you contact us. You can also notify us that you wish to deal with us using a pseudonym.
2. However, if we cannot collect personal information or you use a pseudonym, we may not be able to provide you with the products and/or services, information or assistance, you require.

Will This Privacy Policy Change?

We may amend this Privacy Policy from time to time to keep up-to-date with legal requirements and the way we operate our business. An up-to-date version of this Privacy Policy is available anytime on this page. You are responsible for reviewing this Privacy Policy periodically and informing yourself of any amendments. We suggest you check back regularly. If we make significant changes to our privacy policy, we will seek to inform you on the Site or by email.

How Can You Complain About Privacy Breaches?

1. If you have a complaint in relation to the collection, use and/or disclosure of your personal information, wish to access or update your personal information or have a general query with respect to this Privacy Policy or your personal information, please contact our Privacy Officer at admin@inghamproperty.com.au.
2. Our Privacy Officer will promptly review all complaints and other requests received and respond to each complainant upon due consideration (which may require further information to be provided).

Who Can You Contact About Your Personal Information?

To contact us about your personal information, concerns or complaints, email or call our Privacy Officer on:

• Email: admin@inghamproperty.com.au
• Phone: +61 2 8730 3843
• Address: Suite 1.02, 4F Huntley Street, Alexandria NSW 2015

Additionally, if you have raised a complaint with us and you are unsatisfied with the outcome or have further concerns about the way we handle your personal information, under the Privacy Act, you may complain to the Information Commissioner at the Office of the Australian Information Commissioner, whose contact details are set out below:

• Office of the Australian Information Commissioner
• Address: GPO Box 5218, Sydney NSW 2001
• Phone:    1300 363 992
• Online:    www.oaic.gov.au
• Email:     enquiries@oaic.gov.au

Last updated: 1 September 2023