Equiem (Australia) Privacy Policy

Last updated 27 November 2020

This privacy policy (“Privacy Policy”) explains when, why and how personal information is collected, used and disclosed by Equiem Services Pty Ltd (ACN 158 834 256) (“Equiem” “we” “us”) including with respect to your access and use of the website, which is owned and operated by Equiem (the Chifley site (located at https://mychifley.com.au/) (the “Website”)) and the cloud-based portal application made available to you through the Website or via mobile application by Equiem in relation to any building or site for the purpose of facilitating access to programs and services (the "Platform” and, together with the Website, the “Service”). You acknowledge that this Policy is part of our Terms and Conditions of Use with you, and by accessing or using the Service, you agree to be bound by the Terms and Conditions of Use, including this Policy. If you do not agree to our Terms and Conditions of Use, including this Policy, please do not access or use the Service.

Our Privacy Policy may be modified from time-to-time and we will alert you that changes have been made by indicating on our Privacy Policy the date it was last updated. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof, which may be given by means including, but not limited to, issuing an e-mail to the primary e-mail address that you specified on your account or posting the revised Policy on this page. You acknowledge and agree that it is your responsibility to maintain a valid e-mail address as a registered user, review this site and this Privacy Policy periodically and to be aware of any modifications. Your continued use of the Service after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by the modified Policy.

We are committed to responsible privacy practices and compliance with the Privacy Principles contained in the Privacy Act 1988 (Cth) (“Privacy Act”).  By visiting the Chifley Platform you are accepting the practices described in this Privacy Policy.

What Is Personal Information?

"Personal information" means information that reasonably allows us to identify you, your device or your household, such as a name, address, telephone number, mobile number, date of birth, e-mail address, or geolocation data. Personal information does not include aggregate or deidentified information we collect about the use of the Services (and which does not include information or an opinion about an identified individual or an individual who is reasonably identifiable). Our Privacy Policy does not restrict or limit our collection, use or disclosure of aggregate or deidentified information.

What Personal Information Do We Collect?

User Personal Information

We may collect and store your Personal Information in the following scenarios:

  • Information you voluntarily provide to us, such as when you create an account and profile, call us, send us an email, complete a survey, participate in a contest or other promotion, initiate a transaction with a merchant or other third party ( such as order products or services) or post information or other content to the Service. This information may include your name, address, telephone number, mobile number, date of birth, vehicle registration number, vehicle make, model and year, details of any parking spaces you may have in the building, the company you are employed or engaged by, transaction data, payment information or other financial information (details such as card type, card number, expiry date and CVV), e-mail address, and tenancy role within the building (i.e. fire warden, customer representative);
  • Information we receive from a building owner, your employer or other third-party with whom you have a relationship, including your name and email address, which we may use to facilitate your enrollment in the Service;
  • Information we request from you about your interests and activities, your gender and age, your opinion about products and services that we offer, and other demographic and/or consumer information. Depending upon the activity, some of the information we ask you to provide is required in order for you to engage in an activity and some is purely voluntary. If you do not provide the required data with respect to a particular activity, you will not be able to engage in that activity; and
  • Information we collect from you at other points on the Service, such as when you send emails, fill out online forms, or provide content on the Service, even though there may be no notification at the time such information is being collected.

All of the personal information we collect may be sent to servers located in Australia as well as other countries around the world.

Device Identifiable Information

We automatically collect and store certain information when you use the Service, such as your geolocation data, Internet Protocol (IP) address, your operating system, the browser type, device identifier, the address of a referring website, the geographical location of your device and your activity on our Service and location details when you access the Platform. We treat this information as Personal Information unless it is aggregated or de-identified or is otherwise unable to be associated with a particular individual or household.

We may also automatically collect and store geolocation data to enable your 'digital access pass' (where available), even when the mobile app is closed or not in use.

We may also automatically collect and store certain information through the use of "cookies" or “web beacons”. When you visit the Service, we may assign your computer one or more cookies to facilitate access to the Service and to personalise your online experience. Through the use of a cookie, we also may automatically collect information about your online activity on the Service, such as the web pages you visit, the links you click, and the searches you conduct on the Service. For additional information on how we use cookies, please see our cookie policy (https://mychifley.com.au/cookies).  Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the interactive features offered through our Service.  

We may also use other tracking technologies, such as “web beacons” or other similar technologies, to track your use of the Service. We may also include web beacons and other similar technologies in promotional or other e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customise the Service for our visitors, to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.

We may allow third parties, including our authorised service providers, vendors, building owners and managers, merchants, our other companies, advertising companies, and ad networks, to display advertisements within the Service or provide other services in connection with the Service. These companies may use tracking technologies, such as cookies, to collect information about users who view or interact with their advertisements.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities.  The Service does not currently support Do Not Track requests at this time.

Sensitive Information

Except as described in this policy, we do not generally require you to disclose any sensitive information (e.g. medical information, details of race, religious belief, sexual orientation or membership of a trade union) to us. If you do provide us with sensitive information for any reason, you consent to us collecting that information and using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.

How Do We Use the Personal Information We Collect?

We use Personal Information for the purposes described in this Privacy Policy or elsewhere within our Service or as otherwise disclosed to you at the time the Personal Information is collected or as permitted by law. For example, we may use Personal Information we collect:

  • to establish and manage your account with us;
  • to manage your access to services and electronic resources with or managed by the owner of the building and its related bodies corporate which the Platform relates (“Building Owner”) or the building manager (“Building Manager”);
  • to provide the Services or any information you request, and to process and complete any transactions you initiate;
  • to fulfil your requests for products, services or information and to process your transactions including to manage pick up or delivery options from local providers and retailers, including dry-cleaning and every day essentials and other vendors;
  • to keep you informed about your orders for demos, products or services;
  • to contact you when necessary or appropriate and to respond to your emails, submissions, questions, comments, requests, and complaints and provide customer service;
  • to monitor and analyse Service usage and trends, and to personalise and improve the Service and our users’ experiences with the Service, such as providing, content, or features that match their profiles or interests, and to increase the Service’s functionality and user friendliness;
  • to facilitate the operation, maintenance and improvement of the Services, our business operations, and internal record keeping;
  • to enforce our Terms and Conditions of Use, including this Privacy Policy;
  • to help us make e-mails more useful and interesting, we often receive a confirmation when you open an email from the Service if your computer supports such capabilities;
  • to send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Service;
  • where you have consented to us doing so, to send you promotional materials, including newsletters, discounts and promotions from third parties, competitions and surveys;
  • to allow you to access, book and utilise health and wellbeing services through the Platform;
  • to keep your payments safe and secure and protect against fraudulent transactions;
  • to protect the security and integrity of the Service and our business against illegal or fraudulent activity or misuse (including cyber-attacks);
  • to access and participate in polls and surveys so that we can better understand you, your behaviour and your interests and provide you with a more tailored service;
  • to book in and attend community events, lobby activations, presentations and professional networking opportunities;
  • to issue building and Building Owner or Building Manager related information including when necessary or appropriate that is specific to your organisation, location within the building and/or duty that you carry out on behalf of their organisation / tenancy with regard to building related matters;
  • for any other purpose for which the information was collected (and related purposes which would be reasonably expected by you);
  • for other purposes to which you have consented; and
  • as otherwise authorised or required by law.

We also may use, disclose or otherwise transfer and assign your information:

  • In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us.
  • When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our customers, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies.
  • To third parties in connection with a business transaction involving our company, such as the sale of our business, a divestiture, merger, consolidation, asset sale, or the like or in the unlikely event of bankruptcy.

Direct marketing

Direct marketing involves communicating directly with you for the purpose of promoting our services or the goods or services of third party organisations. We may also communicate with you for the purpose of providing you with special offers. Direct marketing can be delivered by a range of methods including mail, telephone, email or SMS.

We may use and disclose your Personal Information for the purpose of direct marketing to you where:

a) you have consented to us doing so; or
b) it is otherwise permitted by law.

You can unsubscribe from our direct marketing, or change your contact preferences, by contacting us (see section our contact section below).

What Personal Information Do We Share With Third Parties?

We will not share the Personal Information we collect from you through our site or our services with third parties, except as described in our Privacy Policy or as otherwise disclosed to you as permitted by law. For example, we share personal information as follows:

  • with service providers who: (a) are working with us in connection with the operation of the Service; (b) who process such information for us or on our behalf (such as website or database hosting companies, address list hosting companies, email service providers, analytics companies, search engine providers, distribution companies, fulfilment companies and other similar entities that help us to operate the website and / or provide functionality, content and services); and (c) are maintenance service providers in order to contact you in relation to maintenance requests
  • to other third parties with whom we have a commercial relationship, for business, marketing and related purposes;
  • to our subsidiaries and affiliates, defined as any other entity that, directly or indirectly through one or more intermediaries, controls, is controlled by, or is under common control with us;
  • with the Building Owner and the Building Manager so that we, the Building Owner and the Building Manager can provide certain services, amenities and facilities from time to time in relation to the building which the Platform relates;
  • with third party organisations who provide products or services to persons in the building which the Platform relates, to the extent that such third-party organisations require personal data for the purpose of performing their obligations under contracts with you;
  • when you give us your consent to do so, including if we notify you on the Service that the information you provide will be shared in a particular manner and you provide such information;
  • when we are lawfully authorised or required to do so or where doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests or legal authorities, including responding to lawful subpoenas, warrants or court orders;
  • to enforce or apply this Privacy Policy, our Terms and Conditions of Use or our other policies or agreements;
  • in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where Personal Information may be disclosed or transferred as one of the business assets of us;
  • in the unlikely event of bankruptcy; and
  • otherwise as permitted or required by law.

Where we disclose your personal information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the Privacy Principles under the Privacy Act.

We are not otherwise responsible for the actions of service providers or other third parties, nor are we responsible for any additional information you provide directly to any third parties. De-identified visitor information may be provided to other parties for marketing, advertising, or other uses.

Does personal information leave Australia?

We may disclose Personal Information outside of Australia to our related bodies corporate, service providers and other third parties including those located in the United States.

Except in some cases where we may rely on an exception under the Privacy Act, we will take reasonable steps to ensure that such overseas recipients do not breach the Privacy Principles in the Privacy Act in relation to such information.

Links to Other Sites

The Service may contain links to other sites. Any Personal Information you provide on the linked pages is provided directly to that third party and is subject to that third party's privacy policy. Our Privacy Policy does not apply to such linked sites, and we are not responsible for the content or privacy and security practices and policies of these sites or any other sites that are linked to from the Service.

How do we store and secure personal information?

We store Personal Information on computer databases and/or in hard copy and will take reasonable commercial physical and electronic security measures to protect your Personal Information in an effort to prevent loss, misuse and unauthorised access, disclosure, alteration and destruction.

Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. As a result, you acknowledge and agree that our system may not be completely secure including, but not limited to the following: (a) there are security and privacy limitations of the Internet that are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through the Service cannot be guaranteed; (c) any such information and data may be viewed or tampered with in transit by a third party and (d) you provide information to us at your sole risk. Except to the extent that liability cannot be excluded due to the operation of statute, we exclude all liability (including in negligence) for the consequences of unauthorised access to, disclose of, misuse or loss or corruption of your Personal Information.

We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our Payment gateway providers database only to be accessible by those authorized with special access rights to such systems, and are required to keep the information confidential.

We destroy Personal Information in a secure manner when we no longer need it and after a transaction, your private information (credit cards, personal information, financials, etc.) will not be stored on our servers.

What Choices Do You Have Regarding the Use of Your Information?

You may "opt out" of receiving marketing or promotional emails from us by following the instructions in those emails or by emailing us at support@equiem.com.au. If you opt out, we may still send you non-promotional emails, such as emails about your accounts or our ongoing business relations.

Terms and Conditions

Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our Platform at https://mychifley.com.au/legal

How can you access and correct personal information we hold about you?

We believe you should have the ability to access and edit the information that you have provided to us. You may seek access to Personal Information which we hold about you by contacting us as described below. We will provide access to such information in accordance with the Privacy Act, subject to certain exemptions which may apply. We may require that the person requesting access provide suitable identification and where permitted by law we may charge an administration fee for granting access to your Personal Information. We encourage you to promptly update your account information if it changes. You may ask to have the information on your account deleted or removed; however, because we keep track of past transactions, you cannot delete information associated with past transactions on the Service. In addition, it may be impossible to completely delete your information without retaining some residual information because of backups.

If you become aware that any Personal Information we hold about you is incorrect or if you wish to update your information, please contact us at support@equiem.com.au.

Miscellaneous Provisions

You must be at least 18 years old to have our permission to use the Service. Our policy is that we do not knowingly collect, use or disclose any Personal Information about visitors that are under 18 years of age.

You should also be aware that when you voluntarily disclose information (i.e., your name, e-mail address, etc.) in any discussion forums, chat rooms, blogs or other public areas on the Service, that information, along with any information disclosed in your communication, can be collected and used by third parties and may result in unsolicited messages from third parties. Such activities are beyond our control, and this Policy does not apply to such information. Any submissions to discussion forums, chat rooms, blogs or other public areas on the Service are accepted with the understanding that they are accessible to all third parties. If you do not want your comments to be viewed by third parties, you are advised not to make any submissions. Ultimately, you are solely responsible for maintaining the secrecy of your password and/or account information. Please be careful and responsible whenever you are online.

This Policy is intended to cover collection of information on the Service from residents of Australia. If you are located outside Australia, please be aware that your information may be transferred to, stored, and processed in Australia. The data protection and other laws of Australia and other countries might not be as comprehensive as those in your country. By using our Service, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.

How to Contact Us

If you have any questions, comments or complaints about our Privacy Policy and collection, use or disclosure of personal information, or if you believe that we have not complied with this policy or the Privacy Act, please contact us by email at privacy@equiem.com.au or by mail at Equiem Services Pty Ltd, L4 525s Collins Street Melbourne VIC 3000.

We will take any privacy complaint seriously and any complaint will be assessed with the aim of resolving any issue in a timely and efficient manner. We request that you cooperate with us during this process and provide us with any relevant information that we may need.

If you are not satisfied with the outcome of our assessment of your complaint, you may wish to contact the Office of the Australian Information Commissioner.