Privacy Policy

DATE OF LAST REVISION: 09 MARCH 2022

1. Background

   1. General

      JD DM Pty Ltd (ACN 619 773 778) is a proprietary company limited by shares. References to ‘Jinding’, ‘we’, ‘us’ or ‘our’ are references to JD DM Pty Ltd (ACN 619 773 778) and its related bodies corporate (as defined in the Corporations Act 2001 (Cth)).

      Jinding is committed to protecting your privacy, in accordance with applicable Australian privacy laws. This policy (‘Privacy Policy’) is designed to give you a greater understanding of how we collect, use, disclose and otherwise handle personal information.

      You can request a copy by contacting our Privacy Officer (details under heading 14 below).

   2. What is personal information?

      When used in this privacy policy, the term “personal information” has the meaning given to it in the Privacy Act 1988 (Cth) (Privacy Act). In general terms, legislation defines ‘personal information’ as information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information is true or not and whether the information or opinion is recorded in a material form or not. This may include your name, address, telephone number, email address and profession or occupation. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

   3. Our obligations

      We comply with the Australian Privacy Principles (APPs) in the Privacy Act. The APPs regulate the manner in which personal information is handled throughout its lifecycle, from collection to use and disclosure, security, accessibility and disposal.

      The Privacy Act also includes a data breach notification regime, which requires Jinding to address data breaches involving personal information held by Jinding.

      We also comply with more specific privacy legislation in some circumstances, such as the Spam Act and the Do Not Call Register Act.

   4. Employee records

      We are generally exempt from the Privacy Act when we collect and handle employee records and this Privacy Policy does not apply to that information. However, where State or Territory health privacy legislation applies, we are still required to protect the privacy of employee health information. This Privacy Policy will apply in those circumstances.

2. What we collect

   1. General

      The type of personal information that we collect about you depends on the type of dealings you have with us. For example, if you:

      • are a purchaser or prospective purchaser of a property, we will collect your name, contact details (such as address, telephone number and email address), date of birth, gender, employment details, details of the property that you are interested in or have agreed to purchase, what prompted you to inspect the project, how you heard about us, confirm whether you are an Australian resident, information relating to your financing arrangements.
      • are a supplier to us, we will collect your name and contact details, details about the goods or services you supply and payment details.
      • send us an enquiry, complete a registration of interest or provide us with feedback, we may collect your name, contact details, details of your enquiry or feedback and information about our response.
      • fill in a contact form at one of our sales offices, we will collect your name, age, address, contact details, details of the properties you are interested in (including price ranges), what prompted you to inspect the project, whether you are an owner occupier or investor and how you heard about us or the relevant property development.
      • ask us to send you information about our developments or other products and services, we will collect your name, address, contact details, details of the properties you are interested in and how you heard about us or the relevant property development.
      • apply for a job with us, we will collect the information you include in your job application, including your cover letter, resume, contact details and referee reports.
      • enter into any promotions, competitions or special offers, we will collect the information you provide when submitting your entry.

      In addition to the above, if you interact with Jinding generally, Jinding will collect your details (e.g. name, telephone number, email address), details of the properties you are interested in, how you heard about us or the relevant property development and details of your dealings with us. Other information may be collected from other sources but those sources should provide you with details of what personal information is being collected and why.

      The personal information collected may vary depending on your particular interaction with Jinding but will be limited to that information necessary to record and manage our interaction with you (e.g. your name, relevant contact details and information about the interaction) and to that information required to enable you to participate in our services and other products being offered on Jinding’s website.

      We may also collect some information that is not personal information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users use our website.

   2. Sensitive information

      Sensitive information is a subset of personal information that is generally afforded a higher level of privacy protection, such as health information. We only collect sensitive information where it is reasonably necessary for our functions or activities and either:

      • the individual has consented; or
      • we are required or authorised by or under law (including applicable privacy legislation) to do so.

   3. Collection of information other than personal information through our website

      When you visit our website, some of the information that is collected about your visit is not personal information, as it does not reveal your identity.

      Site visit information
      For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.

      We use and disclose this information in anonymous, aggregated form only, for purposes including statistical analysis and to assist us to improve the functionality and usability of our website. You are not individually identified, however we reserve the right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with our website, or where we are otherwise required or authorised by law to do so.

      Cookies
      A cookie is a small string of information that a website transfers to your browser for identification purposes. The cookies we use do not identify individual users, although they do identify the user’s internet browser.

      We use cookies to hold anonymous session information. This information is used to personalise your current visit to the website, for example to allow the website to remember who you are by keeping server variables linked to your session. We only use non-persistent cookies. That is, they are held on your browser’s memory only for the duration of your session.

      Most internet browsers are set to accept cookies. If you prefer not to receive them, you can adjust your internet browser to reject cookies, or to notify you when they are being used. There are also software products available that can manage cookies for you. Rejecting cookies can, however, limit the functionality of our website.

      Online Behavioural Advertising
      We use advertising programs that place cookies on your computer to collect information about your browsing history (including on external websites). This information, which does not identify you personally, is collected in order to improve your online experience by customising the advertising you see to your interests (including the display of more relevant ads on external websites). You can opt out of these programs by turning off the cookie setting in your own internet browser.

   4. What if you don’t provide us with your personal information?

      We will provide individuals with the option of not identifying themselves, or of using a pseudonym, when dealing with us if it is lawful and practicable to do so. A pseudonym is a name or other descriptor that is different to an individual’s actual name. For example, you can access our website and make general phone queries without having to identify yourself.

      In some cases however, if you don’t provide us with your personal information when requested, we may not be able to provide you with the product or service that you are seeking. For example, you must identify yourself to register your interest or purchase a property at any Jinding development.

3. How we collect personal information

   1. Methods of collection

      • We collect personal information in a number of ways, including:
        • where you provide information directly to us, including in person, by phone, through written correspondence (such as letters and emails), on hard copy forms or online (such as through our website or our pages on social media platforms);
        • where you provide information directly to us through our sales offices, project display suites and exhibitions;
        • through our database; or
        • through surveillance cameras at some of our premises (including at project display suites).
      • In some cases, we may also collect your personal information from third parties, such as:
        • marketing companies (e.g. for addresses for marketing material);
        • recruitment service providers;
        • other third-party companies such as credit reporting bodies, law enforcement agencies and government entities.

   2. Collection notices

      Where we collect personal information directly from you, we will take reasonable steps to notify you of certain matters, or to ensure that you are aware of those matters, in accordance with applicable law. For example, we may do this by including a collection notice in our hard copy or online forms, or in a recorded message on the phone. These matters may include:

      • our identity and how to contact us;
      • the purposes for which we are collecting the information;
      • whether the collection is required or authorised by or under an Australian law or a court or tribunal order;
      • the third parties (or types of third parties) to whom we may disclose the information;
      • whether any of those third parties are located overseas and, if practicable, the countries in which they are located;
      • the fact that this Privacy Policy contains information about how to access and seek correction of personal information, and how to make complaints about a breach of the Australian Privacy Principles (APPs).

4. Why we collect personal information

   1. General

      The main purposes for which we collect, hold, use and disclose personal information are set out below:

      • to provide our services (including enquiries and sales of real property) and to respond to queries;
      • to manage and improve the products and services we provide;
      • to manage our relationship with you;
      • to assess the performance of the website and to improve its operation;
      • to assess the performance of our marketing programs;
      • to communicate with you (including direct marketing);
      • to update our records and keep your contact details up to date;
      • to process and respond to privacy complaints;
      • to conduct marketing research and analysis;
      • to comply with any legal obligations (including in relation to health and safety and environmental requirements);
      • to manage our employment relationship with you;
      • to manage, train and develop employees, agents and representatives;
      • to administer our recruitment processes;
      • to protect Jinding’s lawful interests;
      • to fulfil purposes otherwise identified in a collection notice at the time of collection; and
      • to fulfil other purposes related to any of the above.

5. How we use personal information

   1. General

      We may use personal information we collect about you for our business functions and activities, which may include the following:

      • to provide you with information, products or services you have requested;
      • to promote and market our products and services to you;
      • to manage and administer your purchase or any contract that you have with us;
      • to manage our relationship with you and to contact you for follow up purposes;
      • to assess the performance of the website and to improve its operation;
      • to conduct marketing research and analysis;
      • to monitor the use of our products and services;
      • to seek your feedback in relation to the products and services we provide;
      • to verify your identity;
      • to assess, process and manage your application for employment;
      • to provide your updated personal information to our related bodies corporate, contractors or service providers;
      • to update our records and keep your contact details up to date;
      • to process and respond to privacy complaints;
      • to comply with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country (or political subdivision of a country); and
      • for any purpose for which you give your consent.