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Assemble Communities Pty Ltd (Assemble Communities) operates a business and offers services under the following brands, project and trading names; Assemble Communities, Assemble Futures and Assemble Papers. Make MRK Pty Ltd as trustee for the Make MRK Unit Trust operates the Assemble Connect business (Assemble Connect). Assemble Communities and Assemble Connect together are Assemble (“Assemble”, “we” or “us”).
This policy does not cover the privacy practices of third parties that we do not own or control, such as Facebook, Twitter or other social media platforms our partners or advertisers that may be linked on our Online Services (as defined below). In addition, we may provide links to other services and on occasion links to other sites that may interest you. Sites and online services that are owned independently of Assemble should have their own privacy policies. For your best online experience, we encourage you to review their privacy policies before submitting personal information to them.
2. What is personal information?
When used in this policy, the term “personal information” has the meaning given to it in the Privacy Act. Personal information 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.
3. Why we collect personal information
Assemble collects your personal information for the purpose of providing, administering, improving and personalising its products and services, marketing and to support the business functions of each of Assemble Communities and Assemble Connect.
We may also use your personal information in connection with any of the brands or services operated or provided by Assemble, including when you interact with any of Assemble’s websites, online services, Assemble Communities’ mobile application (Assemble App), the Assemble Connect web portal, or any other native or web-based application made available from time to time (together the Online Services).
If we do not collect your personal information, Assemble may not be able to provide you with its products or services.
4. Information Assemble gathers
Assemble gathers personal information about you that generally falls into one of the following categories:
CCTV footage and site access at our Assemble properties
voicemail recordings of those who get in touch with us via telephone
information about preferences, interests and opinions relevant to our services and activities (e.g. preferred home size)
information collected through technology, which includes tracking information collected as you navigate the Assemble’s Online Services.
To provide its services, Assemble Connect may also collect additional personal information including:
credit card details
types of life support equipment you use (if applicable)
your national metering identifier
additional demographic information such as your age, sex, household income, suburb and interests
4.1 Sensitive information
Sensitive information is a specific category of personal information, and, when used in this policy the term “sensitive information” has meaning given to it in the Privacy Act. Such information includes membership of a profession or trade association or of a trade union, health information, criminal record, racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs and the like. We may need to collect, hold and disclose limited sensitive information about you in relation to the specific requirements in regard to access to our site, or to provide you with services.
We may collect some de-identified information that is not personal information. This may include aggregated information about how users use Assemble’s Online Services, and answers to surveys.
5. Storage of data
Any personal information provided by you to Assemble may be retained by us. Please let us know if there is any personal information you do not want us to retain. Where we no longer have a permitted basis for retaining your personal information (including where we are no longer required by law to keep records relating to you), we are obliged to take reasonable steps to destroy or de-identify it.
6. How Assemble collects personal information:
Assemble will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner. Where possible, Assemble will only collect your personal information directly from you. We may also collect personal information in a variety of ways, including the following:
6.1Registration and other direct submission
Registration for any of Assemble’s services, including but not limited to, registration for the Assemble App, application for housing with Assemble Communities, registering for services with Assemble Connect or signing up to the Assemble mailing list, requires that you supply certain personal information including, in most cases, a unique email address and demographic information.
If you sign up to an Assemble mailing list, you may opt out at any time if you do not wish to, or no longer wish to, receive marketing promotional information. See below for further details. We may also collect other personal information that you provide to us directly.
6.2 Registration for our Online Services via third-party tools
6.3 User generated comments and public activities (including comments and Facebook and Twitter sharing)
We may offer you opportunities to engage in Public Activities on Assemble’s Online Services. “Public Activities” are any actions you engage in on Assemble’s Online Services, Twitter, Facebook and other social media that are designed to be visible to other users on Assemble’s Online Services, including comments and posting to Facebook or Twitter and other social media. Any information you disclose in your Public Activities, including your screen name, any image or photo, becomes public and may be used by Assemble for online and offline promotional or commercial uses in any and all media. If you choose to engage in Public Activities, you should be aware that any personal information you choose to submit there can be read, collected, and used by other readers of these areas (who may be located outside Australia), and could be used to send you unsolicited messages. We are not responsible for the personal information you choose to submit in these forums, or for the actions of other participants in such forums, and Assemble has no responsibility to publish, take down, remove or edit any Public Activities.
If you have signed up for an Assemble account or as a user of the Assemble App, we may track and aggregate your Public Activities on Assemble’s Online Services. If you choose to participate in Public Activities, you are electing to share and display such Public Activities on Assemble’s Online Services. Also, Public Activities may be included in RSS feeds, APIs, and made available to other websites in other formats. As a result, your Public Activities may appear on other websites, blogs, or feeds.
6.4 Contests, sweepstakes, and special offers
Assemble may collect information provided by you voluntarily in connection with contests, sweepstakes, and special offers.
6.5 Surveys, panels, and market research
Assemble may collect personal information from you in connection with voluntary surveys.
6.6 Reports and analysis
6.7 Third parties
We collect some personal information via third parties when you sign up to receive services from Assemble, for example:
When you become a resident at an Assemble property or sign up to use the Assemble App, your personal information may be collected by StarRez Pty Ltd (StarRez)which provides Assemble’s resident and property management platform.
We will take such steps as are reasonable to ensure that any personal information collected and stored by third party service providers on behalf of Assemble is done so in a manner that is inconsistent with the APPs.
6.8 Activity records
We may keep records of your interactions with us and activities relating to our business, operations and Online Services. This information will not always be personal information, as some of it does not allow you to be identified as an individual. Following are some examples of activity records:
6.8.1 Device Information
We may collect information about the computer, mobile telephone, smart phone, or other device you use to access Assemble’s Online Services.
6.8.2 Cookies and web beacons
6.8.3 Analytics Technologies
We have hired third parties to provide us information, reports and analysis about the usage and browsing patterns of the users of Assemble. This information is collected to analyse trends, administer the site, track users’ movements around the site, and gather aggregate information about our user base. We do not generally aim to tie this data to personal information.
6.8.4 Log files and reading history
We automatically log certain information about your use of Assemble’s Online Services. This information includes reading history of the pages you view. We may use this information to provide you with customised recommendations based on your reading history. We also use log files in aggregate usage of Assemble.
6.8.5 CCTV and monitoring records
Assemble Communities may keep records in relation to things like CCTV, site access and voicemail recordings of persons attending Assemble’s properties for the safety of our residents and those accessing our sites.
7. How do we use your personal information?
We collect, use and disclose personal information for in connection with the following:
7.1 Services you request
Assemble uses personal information you supply to provide you with the service you have requested. For example:
if you subscribe to Assemble Papers or a mailing list provided by Assemble, we may use your email address to send you a confirmation notice and your mailing address to send you the publication.
if you apply to become a resident at one of the Assemble properties, including through Assemble Futures, we will require your personal information to manage your tenancy and the path to owning your home.
if you sign up for services from Assemble Connect, we will require your personal information to manage those services and arrange for payment in connection with those services.
We perform statistical, demographic, and marketing analysis of users of Assemble for product development purposes and to generally inform advertisers about the nature of our users. We also use this information to improve customer relationships.
7.3 Account Related Emails
7.4 Promotional Emails and Direct Marketing
Assemble may also periodically email you newsletters and other messages about products and services that we think may be of interest to you. We may also use the information to communicate with you about new features, products, or services and/or to improve the services we offer by tailoring them to your needs. Similarly, if you enter an online contest, sweepstakes, or giveaway, we will use the information you provide to notify you. You may choose not to receive these sorts of messages in the future by following the “unsubscribe” instructions located at the bottom of each email.
This includes updating our records where appropriate.
7.6 Safety and security
We take steps to protect the safety and security of our people, premises and property including monitoring site access at the Assemble properties.
7.7 Identity and background checks
We may conduct identity and background checks where legally required or appropriate for risk management purposes.
7.8 Legal Requirements
We may conduct investigations into suspected unlawful and inappropriate conduct. We also handle personal information in connection with complying with our legal obligations and defending our legal rights and interests. This may involve cooperating with official investigations or legal proceedings, including, for example, in response to subpoenas, search warrants, court orders, or other legal proceedings.
8. Disclosure of personal information
Assemble does not sell, rent or trade personal information to, or with third parties. We may however, in order to provide our products and services to you, disclose your personal information to third parties in limited circumstances, such as:
8.1 Third party service providers
These include providers of IT services providers, credit-card and billing processing, shipping, email distribution, list processing, and analytics or promotions management to provide you with any goods or services requested by you.
We may also disclose your personal information with other third party service providers to maintain our systems required to provide you with services including, without limitation, web hosting providers, IT systems administrators, data entry service providers and electronic network administrators.
8.2 Assemble Connect third party service providers
If you apply to receive services from Assemble Connect your personal information may be disclosed with third party services providers in connection with those services, including StarRez, Gigafy and Voltio.
8.3 Related entities and partners
We may share personal information with our related entities, and with carefully selected partners.
8.4 Professional advisors
Our lawyers, accountants, auditors and other professional consultants and advisors.
8.5 Government authorities, courts and third party lawyers
E.g. in connection with lawful information requests.
8.6 Financial institutions (where applicable)
Assemble Connect may share your personal information with organisations involved in providing, approving or managing credit (including banks or other financial institutions) when you apply for services from Assemble Connect or a financial product in connection with your residency.
8.7 Other disclosures in connection with human resources
These may include academic institutions, professional and trade associations, referees and other persons seeking a reference.
8.8 Disclosures overseas
Assemble may transfer your personal information to an entity which is in a foreign country to assist the Company in providing its products and services. Such foreign countries may include USA, Japan or other countries.
In these circumstances, Assemble will take such steps as are reasonable in the circumstances to ensure that the information that is transferred to third parties located outside of Australia will not be held, used or disclosed by the recipient of the information in a manner that is inconsistent with the APPs.
8.9 User of Online Services
Where you participate in Public Activities, your comments and posts will be publicly available.
Some of the third parties described above may be located in the USA, Japan or other countries. While those parties will be subject to privacy and confidentiality obligations in many cases, they will not always be bound by the specific requirements of Australian privacy laws. We will not be responsible if any third parties that we have not share your personal information with do not meet those requirements.
8.10 Acquisition or Transfer
As our business changes, we may buy or sell various assets. This may involve collection, use and disclosure of personal information in connection with the sale or potential sale.
9. How information is kept secure
Some of the measures we use to protect the security of personal information we hold are set out below. Which measures are used may depend on the circumstances.
9.1 Network Security
We have implemented a variety of commercially standard encryption and security technologies and procedures to protect information that is stored in our computer systems, including personal information, from unauthorised access. Please be aware that no method of transmission over the internet, or method of electronic storage, is 100% secure, thus we strive to use commercially acceptable means to protect your personal information, but we cannot guarantee its absolute security.
9.2 Management Procedures
We also maintain standard physical and electronic procedural safeguards that limit access to your personal information to our employees (or people working on our behalf and under confidentiality agreements) who, through the course of standard business activities, need to access your personal information.
10. Special Note for international visitors
Assemble’s Online Services is intended for and directed to users in Australia. If you are accessing the Assemble Online Services from the European Union, Asia, the US or any other region with laws or regulations governing personal data collection, use and disclosure that differ from Australian laws, please be advised that through your continued use of the Assemble website and other Online Serices, which is governed by Australian law, this Privacy Notice and our Disclaimer, you are transferring your personal information to Australia and you consent to that transfer.
11. Your privacy rights
You may contact Assemble to request access to the personal information it holds about you at any time. You may also ask us to correct information about you that you may believe is inaccurate, incomplete or out of date.
If we are unable to provide access to or correct your personal information, we will provide written notice which includes reasons for refusal and the available complaint mechanisms.
You may also make a complaint about the way that we have handled or used your personal information.
If you would like to access and/or correct your personal information, or make a privacy complaint, please contact us as follows, making your request to the attention of our Privacy Officer: Lucy Goldsmith
We may need to verify your identity and may ask for your request in writing.
We may need to engage or consult with other parties in order to investigate and deal with your issue. We will keep records of your request and any resolution.
We will provide you with an estimated response timeframe in relation to your complaint. In any event, we will endeavour to respond to your complaint within 30 days.
If a complaint remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au to have the complaint heard and determined.