Privacy Policy

1. Introduction

This Privacy Policy applies to The Coghlan Group Pty Ltd ACN 625 356 523 and all of its subsidiaries & related entities (collectively referred to as (“The Coghlan Group”) for the purposes of this Privacy Policy). The Coghlan Group is defined as DMC Business Services (Ryan Realty Pty Ltd as trustee for DMC Investment Group Trust), DMC Accounting Plus Pty Ltd, True North Property Agents (Ryan Realty Pty Ltd as trustee for DMC Investment Group Trust), Vivid Life Group Pty Ltd as trustee for Vivid Life Trust, FinishWell (D & B Wealth Services Pty Ltd as trustee for D & B Wealth Trust); and AG Norman & Associates Pty Ltd.

At The Coghlan Group your privacy is important to us. We are committed to protecting your privacy when managing your personal information. We have policies and procedures to ensure that all personal information is handled carefully and securely in accordance with the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (“Privacy Act”).

The purpose of this Privacy Policy is to tell you:

• what kind of personal information we may gather about you;
• how we may use that information and the choices you have regarding our use of such
  information;
• whether we disclose your personal information to anyone;
• how you may inquire, access and/or seek correction of your personal information and our access and correction handling procedure; and
• how you may alert us about an alleged breach of the APPs and our complaint handling procedure.
  
  

2. Collection of information

The type of personal information collected will be directly related to the specified purpose it has been collected for. How much of your personal information that you choose to disclose to us is completely up to you. The only way we know something about you personally is if you provide it to us. However, failure to provide certain information may result in The Coghlan Group being unable to provide you with the relevant product or service. We will make you aware of the purpose for which we collect the personal information and, where possible, the consequences of not providing it at the time of collection.

3. What information do we collect?

We collect information about you when you use our products or services, or deal with us. We may also collect information about you from other people and organisations.

a. Information we collect from you

We collect personal information about you when you contact us, use our products or services, visit our websites or use our mobile apps or deal with us in some other way.

The information we collect from you may include but is not limited to:

• Information about your identity — including your name, address, date of birth, gender and marital status;
• Your Tax File Number or tax residency status;
• Health information — for example for insurance purposes;
• Financial and transaction information;
• When you visit our websites or use our mobile apps — your location information, IP address, mobile device and network information, and any third-party sites you access.
• Other personal information, such as details of your interactions with us.

b. Information we collect from others

We collect information about you from others, such as:

• Service providers
• Agents
• Advisers
• Brokers
• Employers
• Companies or bodies that you own shares in or have an interest in
• Family members

For example, if you apply for credit, we may ask a credit reporting body for your credit report. If you apply for life, income protection or travel insurance, we might ask you or your doctor for your medical information. We may also collect information about you that is publicly available (for example, in public registers or on social media) or provided by businesses we deal with.

c. Sensitive information

The Privacy Act protects your sensitive information — such as information about your religion, ethnicity, health or biometrics (for example, your fingerprints). If we need this type of information, we’ll ask for your permission — except where otherwise allowed by law.

4. Unsolicited information

Where unsolicited information is received by us, we will determine, within a reasonable period of time, whether or not we would be permitted to collect the information under the APPs. If it would not be permitted for us to collect the information, we will destroy the information or ensure it is de-identified as soon as practicable. Otherwise, we may retain the information in accordance with the terms of this policy.

5. Anonymous information

We may also collect information about visitors to our website(s). For example, we may collect:

• statistical information about the number of visitors to the websites and the date, time and
  duration of visits;
• the name of the domain/URL from which you access our websites; and
• the internet protocol address.

However, we do not collect information about the identity of the visitors unless they voluntarily provide that information.

6. Use of personal information

This personal information will only be collected through lawful and fair means and not in an unreasonably intrusive way.

The Coghlan Group collects your personal information when you deal with us directly, including but not limited to, via our website(s), via forms or correspondence (ie by mail or email), over the phone or in person.

We may also collect personal information through our related bodies and our third party service providers (such as data relating to survey responses) so that we may provide a better or more relevant product or service to you.

We may use your personal information to effect the following:

• to process sales transactions (whether in store or online);
• to deliver the products or services to you;
• to register you for a service requested by you, such as our newsletter(s) and e-newsletters,
  mail outs, rewards program(s) or competitions and administering such services;
• to respond to any inquiries, feedback or complaints made by you;
• direct marketing of products and services which we believe may interest you, including product updates and developments, special events or promotions;
• assisting us to improve our products and services and making them more relevant to you;
• assisting us to improve our website(s);
• processing and assessing employment applications for current and future positions; and
• otherwise managing our internal business operations and processes.
  
  

7. Direct Marketing

The Coghlan Group will only use your personal information for the purpose of direct marketing activities where we have obtained your consent to do so, or in circumstances where we have collected the information directly from you and you would reasonably expect that your personal information would be used or disclosed for this purpose. We may also share your personal information with our related entities, so that they can provide you directly with marketing material about their products and services.

The Coghlan Group will provide you with the opportunity to “opt out” of receiving marketing materials at the time of collection and/or at any time afterwards by either unsubscribing from the email service or contacting our Privacy Officer via the contact details provided below.

8. Disclosure

There will be occasions where it will be necessary for The Coghlan Group to disclose your personal information to third parties. The Coghlan Group may disclose your personal information to:

• contractors and third-party service providers on a confidential basis that we use in the ordinary course of our business to assist with the delivery of a product or service;
• organisations such as marketing agencies, data processing companies, printing and mailing houses, delivery companies, or finance agencies or debt collection agencies;
• other members of The Coghlan Group’s corporate group for marketing purposes (subject to obtaining your prior consent, if necessary);
• government authorities or other third parties as required by law; or
• any other purpose that you have consented to.
  
  

9. Transfer of information outside Australia

The Coghlan Group may transfer your personal information to our related entities and third-party service providers based overseas. We may also transfer your personal information to service providers who will hold your information on a cloud computing system which may hold your data on servers located outside of Australia.

However, where your personal information is disclosed to an overseas recipient or a cloud computing system, we will take adequate measures to ensure that your personal information is handled in accordance with the APPs, the Privacy Act and our instructions in accordance with this Privacy Policy. By providing us with your personal information, you consent to your personal information being stored or sent overseas for the purposes set out in this Policy.

Other than as stated above, we do not disclose personal information that you may give us to any organisation or person outside of The Coghlan Group unless you have authorised us to do so.

Under no circumstances will The Coghlan Group sell or receive payment for licensing or disclosing your personal information.

10. Security

The security of your information is important to us. The Coghlan Group operates secure data networks that are designed to protect your privacy and security. When we have collected information about you it cannot be seen or modified by anyone else. The Coghlan Group has implemented generally acceptable standards of technology and operational security to ensure personal information (in both physical and electronic form) is protected against loss, misuse, interference and unauthorised access.

Only authorised The Coghlan Group personnel and contractors are provided access to personal information and have agreed to ensure the confidentiality of this information. Reasonable steps are taken to destroy or permanently de-identify any personal information that is no longer required.

We review and update our security measures in light of current technologies. You should however be aware that the internet is not a secure environment and information sent via the internet (including email) cannot be guaranteed to be totally secure.

11. Access and correction

Access

You may at any time, request access to personal information that The Coghlan Group holds about you by making a request to our Privacy Officer at the address or email address below. We will endeavour to process any requests for access to personal information within a reasonable period of time. Where possible, we will provide you with access to that information either by providing you with copies of the information requested, allowing you to inspect the information requested, or providing you with a summary of the information held. If we need to deny your request for access we will let you know why and inform you how you may lodge a complaint regarding this decision.

Generally, this will only be in cases where providing access would be unlawful or is subject to a potential legal claim or proceeding. The Coghlan Group may charge a nominal fee for supplying personal information.

Correction

We will try to ensure that all information we collect, use or disclose about you is accurate, complete, up-to-date and relevant to the service or products being provided.

Otherwise, if you discover or suspect that there is an error or information is missing, please forward your request for correction to our Privacy Officer in writing at the address or email address below. Our Privacy Officer will consider your request as soon as practicable, manage the correction of your personal information and will update you in writing. If your correction request is refused, our Privacy Officer will provide you within a reasonable period of time the reasons for such refusal and inform you of the complaint process (see below).

12. Complaints about privacy and our complaint handling procedure

If you have any complaints relating to the management of your personal information or if you believe there has been a breach of the APPs by The Coghlan Group, please forward your complaint in writing to our Privacy Officer at the address below:

2/12 Millaroo Drive, Helensvale QLD 4212

Alternatively, you can forward your written complaint to ‘admin@thecoghlangroup.com.au’.

Our Privacy Officer will consider the complaint and advise you of their decision in writing within a reasonable time from receipt of the complaint. If our Privacy Officer determines that there has been a breach of the APPs or this Privacy Policy, s/he will endeavour to ensure that the breach is rectified within 30 days from the date of the decision and will update you in writing. If the breach has not been rectified within 30 days, then our Privacy Officer will inform to The Coghlan Group’s Managing Director in order to resolve the matter.

If a breach is of such a nature that The Coghlan Group is required under the Privacy Act to notify you or the Office of the Australian Information Commissioner, The Coghlan Group will provide this notice in accordance with the Privacy Act.

If you are still not satisfied after lodging a complaint with us and given us a reasonable time to respond, then we suggest that you contact the Office of the Australian Information Commissioner by:

• Phone: 1300 363 992 (local call cost, but calls from mobile and pay phones may incur higher charges). If calling from overseas (including Norfolk Island): +61 2 9284 9749 TTY: 1800 620 241 (this number is dedicated to the hearing impaired only, no voice calls.)
• TIS: Translating and Interpreting Service: 131 450 (If you don’t speak English or English is your second language and you need assistance and ask for the Office of the Australian Information Commissioner)
• Post: GPO Box 2999 Canberra ACT 2601
  Fax: +61 2 9284 9666
  Email: enquiries@oaic.gov.au

Miscellaneous

“Personal information” has the same meaning as in the Privacy Act.

Document description –  Privacy Policy
Document applies to The Coghlan Group Ltd ACN 625 356 523
Document owner – Company Secretary
Document approved / adopted by Board of Directors
Version number 1.1
Adoption date September 2017

The Coghlan Group reserves the right to modify or amend this Privacy Policy at any time. The effective date will be displayed at the beginning of the policy. For more information about your privacy rights in Australia, visit the Office of the Australian Commissioner’s website, www.oaic.gov.au