Privacy Policy

1. Dahua’s commitment to privacy

Dahua understands the importance of protecting the privacy of your personal information. Dahua is committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles under the Privacy Act.

This Privacy Policy sets out how Dahua handles and protects your personal information, and provides information on your rights in relation to your personal information managed by Dahua.

We strongly encourage you to read this document, so that you understand and are comfortable with how we handle your personal information.

Dahua is a developer of residential and other real estate projects and undertakes related property development activities. In conducting this business, we may collect personal information.

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

• Dahua Group Melbourne Investment Pty Ltd (ACN 604 279 736) (Dahua Melbourne);
• Dahua Group Sydney Investment Pty Ltd (ACN 606 376 416) (Dahua Sydney);
• the Australian related companies of Dahua Melbourne or Dahua Sydney from time to time, and other entities forming part of Dahua’s Australian corporate group from time to time; and
• any other special purpose vehicles as created from time to time,
  (together, “Dahua, Dahua Group“, “we“, “us“, “our“).

Dahua 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).

Any updated privacy policy will be made available on our website located at https://dahuaaustralia.com.au 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.

2. What is personal information?

“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.

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

Personal information does not include:

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

3. What kinds of personal information do we collect and how do we collect this information?

The kinds of personal information that Dahua collects will vary depending on our particular interaction or dealing with you.

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

Type of personal information	What this includes	How do we collect this information?
Contact details	This may include your: full name; address; telephone number; email address; and date of birth.	We may collect this information: directly from you during our interactions with you; when you submit a “Get in Touch” form via our website; indirectly from real estate agents with whom you register your interest in a Dahua property; when you contact us via our online form, via email, phone or social media; when you complete a survey or enter a trade promotion or competition conducted by us; when you visit a property; if you apply for a position at Dahua; or when you otherwise interact with us on a commercial basis.
Workplace information	This may include: details of your employment history; information about your education and qualifications; 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; and 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.
Proof of identity information	This may include: your driver’s licence; nationality; tax file number; or other similar identity information.	We may collect this information if you are applying to purchase a property that we are developing, or if you are a job applicant or employee.
Preference information	This may include information regarding your preferences in relation to our properties, such as housing or lifestyle amenities that are of interest to you or your family.	We may collect this information if you are interested in purchasing property that we develop.
Transactional and payment information	This may include: information about transactions that you undertake in respect of any Dahua properties; and 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.
Financial information	This may include information about your: financial circumstances and objectives; assets; income; liabilities and expenditure; and investment preferences.	We may collect this information if you enter into, or propose to enter into, a transaction with us, including the purchase of property.
Online and digital services information	This may include information (that is not always identifiable) about your: device ID; device type; geo-location information; IP address; and browsing information.	We may collect this information when you use our website, via use of technologies such as cookies. For further information, see section 8.
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 “Get in Touch” 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.
Call recording / CCTV information	Dahua may collect call recordings and CCTV information.	We may collect call recording information from calls that you make with Dahua, noting that you will always be advised of the call recording in advance. We may collect CCTV information from CCTV surveillance systems that monitor our properties and premises.
Information required to be collected by law	We may collect information that is publicly available online, such as on online forums, websites, and social media channels (for example, information that relates to a complaint).	We may collect this directly from the publicly available source (e.g. on the online forum, website, or social media channel).

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

Generally, we do not collect sensitive information about individuals, except where we collect relevant information from employees, such as health information 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.

Dahua usually collects your personal information directly from you. However, in some cases, Dahua may collect your personal information from someone other than you, for example:

• from real estate agents and other third parties who are involved in the sale of our properties to you;
• from our other service providers that help us develop our properties and provide our property-related services (i.e. we may engage a third party to conduct surveys on the property features that you and your family would be interested in us developing);
• from third parties you authorise to disclose your information to us;
• from marketing agencies, data collection and research organisations; and
• from a publicly maintained record or other publicly available sources of information including social media and similar websites.

Can you deal with us without providing your personal information?

You are under no obligation to provide your personal information to Dahua. However, without certain information from you, Dahua may not be able to provide you with information about our properties that is tailored to your needs, sell a property to you, or provide other services, and we may be limited in how we can interact with you.

4. Why we collect, store and use your personal information

Generally speaking, Dahua 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.

Some examples of the purposes for which Dahua collects, holds, uses and discloses your personal information include:

Purpose	Explanation
To sell you a property, or provide you with other property-related services	We may handle your personal information to: communicate with you; respond to your queries and provide you with information you request from us; administer, manage and process any transactions you enter into, or propose to enter into, with us, including the purchase of property; help us to manage the property-related services we provide to you, including personalising your experience; 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; and 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.
To manage your working relationship with us (including if you are an employee or contractor)	We may handle your personal information to: consider your suitability as a prospective employee; 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: conduct the general operation and management of Dahua, 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; undertake security and risk management; 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; improve the products and services we offer; and develop new properties 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.

In addition to the purposes listed above, Dahua 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.

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

5. Who do we share your personal information with and why?

Dahua shares your personal information with third parties:

• for the purpose for which Dahua collects it, as set out in section 4 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.

This may include disclosing your personal information to:

Recipient	Explanation
Related companies of Dahua	We may share your personal information with related companies or special purpose vehicles of within the Dahua Group, as appropriate. This includes companies in the Australian and overseas corporate groups of Dahua, as well as joint venture entities and special purpose vehicles that Dahua or its related companies have an interest in.
Real estate agents	We may share your personal information with real estate 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.
Service providers and partners who assist in the conveyancing process	We may share your personal information with 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.
Our service providers, advisors and other entities we do business with	We may share your personal information with our: service providers, agents, contractors 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.
Corporate restructure	We may share your personal information with people or entities considering acquiring an interest in Dahua or any business or assets of Dahua, 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 government and law enforcement authorities where required by law.

If you post information or other content to public sections of our website 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.

Overseas disclosures

Some of the parties that Dahua discloses your personal information to may be located outside Australia, including our related companies located in China and Hong Kong China.

We only ever share your personal information outside of Australia where we are permitted to do so under the Privacy Act. This means that we 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.

Links to other websites

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.

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.

8. Cookies

Dahua 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 pixel tags. Cookies and pixel tags collect data about website traffic, assist in managing customised settings of the website and help deliver content. We collect certain information such as device type, IP address, and browsing information.

We use this information to analyse how our websites and other online services are being used, to improve our websites and other online services and provide more user friendly and customised websites and online services. These features and technologies do not specifically identify you unless you otherwise provide personal information to us that enables identification. If you do not wish to receive any cookies or pixel tags (other than those that are strictly necessary), you may use the settings in your browser to control how your browser deals with cookies. However, this may slow down or cause certain web pages to be inaccessible to you.

Direct marketing

Dahua and/or our third party service providers may use your personal information to send you direct marketing communications and information about:

• products, services, discounts, competitions and special promotions that we consider may be of interest to you;
• 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.

These communications may be sent in various forms, including by telephone, post, email, SMS or any other form of electronic communication, in accordance with the Privacy Act and the Spam Act 2003 (Cth).

If you do not wish to receive such communications, you can opt-out at any time by contacting us via the contact details set out in section 12 of this Privacy Policy or through the opt-out mechanism contained in a marketing communication to you. We note that regardless of whether you opt out, 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.

10. Security of personal information

Dahua takes steps reasonable in the circumstances to ensure that the personal information it holds is protected from misuse, interference and loss, and from unauthorised access, modification or disclosure, in accordance with applicable privacy laws.

Steps we take to protect your personal information include:

• 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. We also maintain physical security measures in relation to storage of our electronic records (such as through locks and security systems at our electronic data stores), and maintain computer and network security, by using firewalls and other security systems to control access to our computer systems.
• 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 and security systems at our premises.
• Our websites: Our websites use encryption and other technologies to ensure that your personal information is securely transmitted via the internet.

Access and correction

Dahua 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.

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 Dahua. If at any time you would like to access or correct the personal information that Dahua holds about you, or you would like more information on Dahua’s approach to privacy, please contact the Dahua Privacy Officer using the details set out in paragraph 12 below. Dahua will grant access to the extent required or authorised by the Privacy Act and will take reasonable steps to correct your personal information.

To obtain access to your personal information:

• you will have to provide proof of identity so that we can ensure that personal information is provided only to the correct individual and that the privacy of others is protected;
• please be reasonably specific about the information you require; and
• Dahua may charge you a reasonable administration fee, which reflects and will not exceed the cost to Dahua for providing access in accordance with your request (i.e. reasonable staff costs involved in searching and retrieving your requested personal information). If we intend to charge you

Dahua 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.

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

Contacting Dahua

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 Dahua’s Privacy Officer using any of the following contact details:

Email: privacy@dahuaaustralia.com.au
Post: Level 50, 360 Elizabeth Street, Melbourne, VIC 3000
Phone: +61 (3) 9021 2565

Privacy complaints and questions

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 12.

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

#	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.
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.

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).

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.