LIV is subject to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth).
This Policy describes how we, at LIV, comply with privacy obligations in protecting the personal information we hold about individuals.
Overview of LIV's functions and activities
LIV is part of the Mirvac Group, comprising Mirvac Limited and Mirvac Property Trust and their respective controlled entities (collectively known as Mirvac or Mirvac Group). Mirvac is an Australian real estate group, with an integrated development and asset management capability.
LIV is the Build to Rent arm of the Mirvac Group. LIV's key activity is to operate large scale apartment buildings that are purpose designed and built for renters for the sole purpose of leasing. Currently, LIV's operations are located in Sydney and Melbourne.
For more information regarding LIV, please visit our website www.livmirvac.com.
Collection of personal information
Personal information is defined as information or an opinion about an individual or an individual who is reasonably identifiable. This may include an individual's name, address, email address and telephone numbers. The type of personal information that we collect will depend upon what dealings the you have with LIV.
We may collect and hold information about individuals who:
- lease, or express an interest to lease premises or spaces including any related guarantors (for example, when negotiating, entering into or applying to enter into a lease with LIV);
- register or subscribe for electronic newsletter or updates (either in person or online) customer loyalty programs, competitions or promotions run by LIV;
- enter or park in a LIV managed building or car park that may collect CCTV footage or still images of individuals and vehicles as well as licence plate details for security purposes or at some LIV managed buildings, visitors are required to register before entry for building safety purposes;
- supply goods and services (for example, when establishing records and systems to enable payment for goods);
- use LIV's websites, social media and other online services; and
- may otherwise come into contact with LIV.
We only collect personal information which is reasonably necessary for our dealings with the relevant individual. The types of personal information may include, but are not limited to:
- information that identifies the individual (for example, name, gender, address, contact details, date of birth, photographic or video images);
- information needed to verify an individual's identity such as driver's licence number;
- information about the individual's financial position and creditworthiness;
- an individual's employment history, and other information an individual provides as part of the leasing process;
- information about the individual's image collected via our CCTV systems;
- information about the individual that is required or authorised by law; and
- the individual's opinion or preferences about LIV 's products, services or staff.
The Privacy Act imposes restrictions on collecting sensitive personal information such as information about religious views, ethnicity, political opinions and personal health. We generally do not collect sensitive information about an individual. However, in certain circumstances, we may collect some sensitive information if it is necessary to allow LIV to deal with the individual and provided the individual has given consent for LIV to do so.
Whenever it is reasonable and practical to do so, we collect personal information directly from the individual. However, in some circumstances, personal information may be provided to LIV by other parties such as the individual's employer. We will take reasonable steps to inform the individual that it has the individual's personal information, unless it is obvious from the circumstances.
Notification of collection of personal information
Use and disclosure of personal information
LIV's policy is only to use personal information for the purpose which was either specified or reasonably apparent at the time when the information was collected. We may also use or disclose the information collected for any other related purpose the individual would reasonably expect it to be used.
If we wish to use or disclose the personal information in other circumstances, we need to obtain the individual's consent to do so.
In general, we use personal information for the following purposes:
- providing products or services that have been requested;
- communicating with the individual;
- assessing the suitability of prospective tenants;
- helping LIV manage and enhance our products and services, including analysing resident feedback and future resident needs;
- providing ongoing information and marketing about products and services to individuals that we believe may be of interest and where the individual has signed up;
- managing security and safety requirements in LIV managed buildings and sites;or
- complying with regulatory and legal obligations.
Disclosing personal information to other parties
LIV may disclose personal information to other entities within the Mirvac Group.
External parties may be given access to personal information held by LIV in certain circumstances. These include, but are not limited to:
- LIV's or the Mirvac's contractors, consultants, advisers and service providers who assist LIV in the operation of our business or to provide a customer service (for example, a company which helps maintain LIV's computer systems or sends out LIV's mail);
- external data storage systems used to process and retain personal information;
- joint venture partners for the purposes of seeking relevant regulatory approvals;
- third party lenders and insurers;
- the Australian Securities Exchange, the Australian Securities and Investments Commission and to other regulatory authorities or government agencies as agreed to or required by law;
- the institutional owners of the build to rent assets that are managed by LIV (i.e. the landlords);
- anyone authorised by a provider of personal information; or
- relevant parties in situations when LIV is required, by law, to provide the information.
From time to time, we may disclose personal information to external parties located outside Australia to allow the external parties to perform their services for Mirvac. LIV currently uses Salesforce and XMS which are hosted in Japan and United Kingdom respectively. LIV will only disclose personal information overseas when it is necessary for the services provided by these external parties and when it is in accordance with the Australian Privacy Principles. This includes taking reasonable steps to ensure that the external party has appropriate data handling arrangements in place.
LIV does not sell personal information to entities outside the Mirvac Group.
We may send marketing materials to its residents or potential residents where we have collected the personal information from the individual and the individual would reasonably expect us to use the information for that purpose.
The individual’s prior consent will be obtained before personal information is used for marketing purposes in situations where the personal information has been collected from the individual and the individual would not reasonably expect LIV to use the information for that purpose, the personal information has not been collected directly from the individual or where sensitive information is involved.
If the resident or potential resident no longer wishes LIV to use his or her personal information in order to provide marketing materials, the resident or potential resident is to advise LIV via the relevant method provided for in the electronic marketing message (e.g. via an ‘unsubscribe’ link) or to write to the Mirvac Privacy Officer (refer to contact details below). Mirvac will act and amend its records promptly.
Security of personal information
We will take reasonable steps to protect personal information that we hold from unauthorised access, modification, misuse, interference and loss. We maintain physical security measures over our physical premises, and a range of computer and network security measures (such as systems access, firewalls, data encryption) over our electronic systems. LIV employees are required to maintain the confidentiality of any personal information held.
If other parties provide support services, we generally require them to agree to appropriately protect the privacy of the information provided to them.
Access to your personal information
We believe you have a right to know about what information organisations have about you. As such, any individual can request access to the personal information LIV may hold about them. To obtain access to the information, the individual needs to write to the Mirvac Privacy Officer (refer to contact details below). LIV will require evidence to verify the identity of the individual.
This service is free of charge unless the personal information requested requires preparation time. In this situation, we will provide an estimate of how much this service will cost and request agreement before proceeding. In normal circumstances, we will provide the individual with access to the individual’s personal information. However, in some circumstances, there may be legal, regulatory or administrative reasons to deny the requested access. If access is denied, we will provide the individual with the reasons for doing so.
The Mirvac Privacy Officer can be contacted as follows:
Changing personal information
If an individual wishes to change personal information that the individual believes may be inaccurate, out-of- date, incomplete, irrelevant or misleading, the individual may write to the Mirvac Privacy Officer requesting the information to be changed. If we disagree with the individual that the personal information should be changed, we will provide the individual with the reasons for doing so. The individual has the right to request that a notation be included with their personal information to indicate their disagreement with their personal information held by LIV.
Collection of other information
We will only collect information about you with your consent. When you browse our website, you do so anonymously. We do not collect information about you or your email address without your consent.
Information collected for statistical purposes
When you look at the livmirvac.com website, we may record the following information for statistical purposes and for general accommodation business practice:
- your ISP address;
- visitor contact details and personal information (where provided);
- your top level domain name (for example .com, .gov, .au, .uk etc);
- the pages you accessed, and documents downloaded;
- the previous site you have visited;
- the type of browser you are using.
Changes in the Future
LIV Mirvac reserves the right to change this Policy at any time. LIV Mirvac will notify any changes to this Policy by posting an updated version of the Policy on the LIV Mirvac website at http://www.mirvac.com.
You can make a complaint about the way in which LIV has handled your personal information by writing to the Mirvac Privacy Officer. LIV Mirvac will endeavour to act promptly in response to a complaint. If you feel your complaint remains unresolved or you wish the Office of Australian Information Commissioner (OAIC) to further investigate your complaint or you would like further information about privacy issues and the protection of privacy, you can contact OAIC as detailed below:
For further information about privacy issues and the protection of privacy, visit the Office of the Australian Information
Commissioner’s website at http://www.oaic.gov.au.