This Privacy Policy (‘this Policy’) deals with our collection, use and disclosure of, and your access to, information we may have recorded about you. This Policy applies to all members of the Springfield City Group.

ABOUT US

The Springfield City Group (‘we’, ‘our’ or ‘us’) is a collection of related companies, being:

• Springfield Real Estate Sales Pty Ltd ACN 009 648 220;
• Springfield City Group Pty Ltd ACN 055 714 531;
• Springfield Land Corporation (No. 2) Pty Limited ACN 056 462 205;
• Springfield Asset Holdings Pty Ltd ACN 159 981 870;
• Brookwater Golf Operations Pty Limited ACN 094 878 243;
• Brookwater Realty Pty Ltd ACN 101 190 121;
  Springfield Management Services Pty Ltd ACN 132 883 731;
• Park Avenue Development Corporation Pty Ltd ACN 603 672 457;
• Greater Realty Pty Ltd ACN 614 000 243;
• GS Specialist Suites Pty Ltd ACN 603 672 260.

The Springfield City Group is the master developer of the entire 2,860 hectare site known as ‘Greater Springfield’ located in the western corridor between Brisbane and Ipswich in Queensland. The activities of the Springfield City Group relate to the development of the master planned community and include the operation of the Brookwater Golf Club.

PRIVACY ACT 1988

The Federal Government has enacted privacy legislation which governs the use of a person’s personal information. We are bound by the Australian Privacy Principles (APP’s) set out in the Privacy Act 1988 (Cth) (the Act), as well as any other applicable laws and codes affecting your personal information.

WHAT IS PERSONAL INFORMATION?

Personal information is 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.

For example, this includes details such as your name, age, date of birth, gender and contact details, and can include certain details about your personal interests.

HOW WE COLLECT PERSONAL INFORMATION

We collect personal information in a number of ways, including:

• directly from you, for example when you provide your personal information over the telephone, in writing, in face to face meetings or consultations, or via our websites;
• from publicly available sources of information;
• when you submit your resume or application to us for consideration of employment;
• when you register or update an online profile, which may include personal data such as your name and contact details;
• information submitted if you participate in a competition or survey (including online participation);
• any message or comments submitted to us via this website, or where you subscribe to our newsletters or email distribution lists, which may include personal data such as your name, email address and telephone number.

These are merely examples of some of the ways in which your personal information is collected and are not exclusive.

Wherever possible, Springfield City Group will take reasonable steps to ensure that your personal information is collected directly from you. If we obtain your personal information from someone other than yourself, we will take reasonable steps to make you aware of the fact we have collected the information, our identity and contact details, your right to access and seek correction of information that we hold about you, your right to complain about a suspected breach of the APP’s by us, why we collect information, to whom we disclose information, any law that requires us to collect information and the consequences if all or part of the information that we request is not provided to us.

If it is lawful and practicable to do so, we will endeavour to provide you with the opportunity to deal with us anonymously or using a pseudonym.

If you choose not to provide us with certain personal information, we may not be able to provide you with the products or services you require, or the level of service that you expect.

WHAT PERSONAL INFORMATION WE COLLECT AND WHY

We collect personal information about you where it is reasonably necessary for us to carry on our business. The information that we collect depends upon the nature of our dealings with you.

Without your personal information such as your name, address, and other essential details it is not possible for the Springfield City Group to conduct its business. For example if you are purchasing land or a house and land product, your personal details will be required to ensure a contract of sale can be proceeded with.

The types of personal information that we collect depends on the nature of our dealings with you. We may collect contact details and information to verify your identity, educational qualifications and employment history (if you are applying for employment with us), details of any complaints that you make to us or details related to payment arrangements (if you are a supplier to us).

We do not generally collect sensitive information about individuals, we would only do so where it is necessary for us to carry on our business functions. Sensitive information includes information about race, political or religious beliefs, sexual preferences, criminal convictions and health information.

If we do collect sensitive information, we do not share that information for any other purpose or disclose it to any person other than in accordance with the terms of any consent that you provide to us or where we are permitted or required to do so by the APP’s or any other applicable law.

HOW WE USE YOUR PERSONAL INFORMATION

We will only use your personal information for the reasons we collected it or for the purposes set out in this Policy or for purposes expressly permitted or required by law. These reasons will be reasonably apparent to you when we collect your personal information and our use and disclosure of that information will only be for our business activities or as required by law.

Some examples of the manner in which we may use your personal information include to:

• verify your identity;
• provide products, ( including land) or services you require;
• administer and manage the products and services we provide (for example, for completing Contracts of Sale, accounting and billing purposes);
• maintain proper records;
• inform you of ways in which the products or services we provide to you can be improved;
• research and develop our products and services, and our service levels;
• ascertain how we can provide you with better service.

MARKETING ACTIVITIES

We may also use your personal information to inform you of other products and services or upcoming events which may be of interest to you. Where it is practicable to do so, we will inform you of our intention to use information for marketing purposes at the time we collect your personal information or seek your consent to such a use. We will not use ‘sensitive information’ (such as information about your racial or ethnic origin) without your consent.

You have the right to request that we do not provide you with such material or information, and should you not wish to receive it, please indicate this in the opt-out provisions contained in our marketing material, or simply contact our Privacy Officer and advise them accordingly.

You may at any stage, opt to change your mind about receiving such information.

The Springfield City Group does not and will not disclose your personal information to any unrelated party outside the Springfield City Group for the express purpose of allowing them to direct market their products or services to you, unless we have your consent to do so.

We will also comply with any separate obligations that we have under other legislation such as the Spam Act 2003 or the Do Not Call Register Act 2006.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose your personal information to:

• related bodies corporate, agents and contractors;
• your authorised representatives and legal advisers (when requested by you to do so);
• government authorities and other organisations, as required or authorised by law;
• organisations who manage our business, including those involved in a transfer or sale of all or part of our assets or business; 
• third party service providers, both inside and outside Australia (including mailing houses, fraud monitoring systems, accounting services and professional advisers).

Where personal information is disclosed to a member of the Springfield City Group we will take reasonable steps to ensure that the recipient does not breach the Australian Privacy Principles in relation to that information.

DISCLOSURE OF PERSONAL INFORMATION WITHIN THE SPRINGFIELD CITY GROUP

Members of the Springfield City Group in Australia that have collected personal information are permitted by the Act to disclose that personal information to other members of the Group.

Unless you have instructed us not to do so, personal information may be shared with all members of the Springfield City Group and other related companies of the Springfield City Group.

WHERE DO WE STORE PERSONAL INFORMATION?

We keep personal information in both electronic and paper based records. Paper based records are kept on secure premises away from the general public. Our electronic records are kept in a secure system with password protection and restricted access both internally and from external sources.

DATA SECURITY

We will take reasonable steps to:

• protect the information from misuse, interference, loss or unauthorised access, modification or disclosure both physically and through computer security methods;
• destroy or permanently de-identify the information if it is no longer needed for any purpose.

WEBSITE USE

When you visit one of our websites, the website may send cookies to your computer. Cookies are used in transactions over the Internet and can be used to monitor the areas of a website that are visited by you. Visitors to a web site who do not wish to receive cookies should select the appropriate settings in their web browser, however this may mean that you are not able to use our websites.

We may collect the following information from visitors to our websites, obtained via cookies:

• Remote server address (RDNS);
• Date and time of their visit;
• Pages accessed;
• Documents downloaded;
• Previous site visited (HTTP Referrer);
• Type of browser used;
• Any other information volunteered by you including web registrations and contact information.

Third party websites linked to our websites are not subject to this Privacy Policy. We take no responsibility for the content or privacy policies of other websites. Before using any third party website, you should review their privacy policies to ensure that you are satisfied with them.

DESTRUCTION OF INFORMATION

All information held by us will be:

• kept for as long as required by law or is prudent having regard to administrative requirements;
• destroyed or de-identified if it is no longer reasonably required for any purpose.

PERSONAL INFORMATION OF THIRD PARTIES

If you supply us with personal information about another person, you should ensure that you are authorised to do so by that person. You also agree to provide that person with, or direct them to, a copy of this Privacy Policy.

ACCESS TO YOUR INFORMATION

You have the right to access personal information that we hold about you under the Australian Privacy Principles, subject to certain exceptions. We will tell you if one of these exceptions applies. If you would like access to any records of personal information that we may have about you please contact our Privacy Officer.

We will not charge you a fee for making a request. However we may charge a fee for giving you access to your personal information in some circumstances, for example where we will incur costs or time to respond to your request. We will tell you in advance of any such fees and we will not charge any fee that is excessive. We will respond to your request for access within a reasonable time (usually this will be within 30 days). You may also make arrangements for a mutually agreed intermediary to access your personal information on your behalf.

ACCURACY OF YOUR PERSONAL INFORMATION

In order to efficiently conduct our business by providing you with our range of products and services, we need to ensure that your personal information is accurate, up to date and complete.
We will not charge you a fee for requesting correction of your information. We will respond to your request within a reasonable time (usually within 30 days). When we become aware that information is inaccurate, incomplete or out of date, we will take reasonable steps to correct that information or delete it from our records. We will notify you if we do not agree to change information and when we do we will tell you about other rights that you may have in our notice.

We may from time to time contact you to request that you confirm the personal information we hold is correct.

If you are concerned that information we hold about you is not accurate, complete, relevant or up to date or is misleading, please let us know by contacting our Privacy Officer.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is subject to change at our discretion. The current version of this Privacy Policy will be available at www.brookwater.com.au and will bear the date that the Privacy Policy was most recently updated. We advise you to check the website for any changes to this Privacy Policy.

ENQUIRIES AND COMPLAINTS

Should you wish to:

• make an enquiry about our Privacy Policy or our handling of your information;
• request a copy of our Privacy Policy in a different form;
• obtain access to personal information that we hold about you;
• request a correction of the personal information that we hold about you;
• make a complaint because you believe that we have breached the APP’s or the Act,

please contact us at:

General Counsel
Springfield Land Corporation
PO Box 4167
SPRINGFIELD QLD 4300

Telephone: (07) 3819 9999
Facsimile: (07) 3819 9900
Email: legal@springfieldcity.com

We will investigate and respond to complaints promptly (usually within 14 to 30 days).

If we do not resolve a privacy complaint to your satisfaction, you have the right to contact the Office of the Australian Information Commissioner. For further information, you may wish to visit their website at www.oaic.gov.au.