At Hillway Residences, we believe your personal information should remain protected and safe from misuse. As a part of the function of our business, we will be required to collect and share some data with relevant parties. For example, we may share your business contact information with a prospective client that we have referred to your business. In this event, we would not share any information about your business or contact information that we would deem to be sensitive information or private. Common sense is our core watchword and we pride ourselves on understanding you and your business and your demand for privacy.
Hillway Residences (“we“, “us” or “our“) is committed to protecting and respecting your privacy.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting hillway.com.au (our “website“) you are accepting and consenting to the practices described in this policy.
If you are a resident of the European Union, the European Union General Data Protection Regulation (GDPR) will apply to your personal data (see clause 12).
If you are a resident of Australia, the Australian Privacy Act 1988 (“The Act”) will apply to your personal data.
The Act defines “personal data” as ‘information or an opinion about an identified individual, or an individual who is reasonably identifiable’ This is true whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
Information We May Collect From You
We may collect and process the following data about you:
1.1 Information you may provide to us. The types of information you may provide to us depends on the nature of your dealings with us as follows:
- (a) If you contact us for the purposes of recruitment or engaging our services and provide us with your personal information, this includes information you provide when you take out a trial of the service, accept a licence agreement, make an enquiry with us online, or subsequently in other ways, including if necessary to provide you with ongoing services. The information you give us may include names, position titles, addresses, telephone numbers, email addresses and other contact details.
- (b) If you are one of our ‘business contacts’ (e.g. a contact person in one of our suppliers, or in an agency with which we deal), you may give us basic business contact information about you. This includes your name, title and work contact details.
- (c) If you are providing us with personal data about a third party, you warrant to us that you have that person’s consent to disclose their personal data to us and that your use and disclosure of the information to us is in accordance with the Act. This paragraph is without prejudice to any obligations you may have to us as a Licensee under any licence agreement for use of our software or services.
1.2 Information we collect about you. With regard to each of your visits to our website we may automatically collect the following information:
- (a) Technical information, including the Internet protocol (IP) address used to connect your computer, tablet, mobile or other device (each being a “Device”) to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information you post online either on our website or on a third-party social media site to which we have access.
- (b) Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
1.3 Information we receive from other sources. We may receive information about you if you use any other websites that we operate or may operate from time to time or other services we provide. We may share information amongst members of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries (“Affiliates”). We may also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
Analytic Tools, Cookies And Remarketing
2.1 Our website and platform uses analytic tools (such as Google Analytics) and cookies to distinguish you from other users of our website or platform and monitor website and platform user activities and behaviours. This helps us to provide you with a good experience when you browse our website or platform and allows us to improve them. By continuing to browse the website or platform, you are agreeing to our use of analytic tools cookies.
2.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your Device. Cookies contain information that is transferred to your device’s hard drive or device.
2.3 We use the following cookies:
- (a) Strictly necessary cookies. These are cookies that are required for the operation of our website/platform. They include, for example, cookies that enable you to log into secure areas of our website/platform, use a shopping cart or make use of e-billing services.
- (b) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website/platform when they are using it. This helps us to improve the way our website/platform works, for example, by ensuring that users are finding what they are looking for easily.
- (c) Functionality cookies. These are used to recognise you when you return to our website/platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- (d) Targeting cookies. These cookies record your visit to our website/platform, the pages you have visited and the links you have followed. We will use this information to make our website/platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
2.4 If you do not wish cookies to be stored on your device, you can block them by activating the relevant setting on your browser which can usually be found in the “help” section. More information on how to do this is available here: www.allaboutcookies.org or www.youronlinechoices.eu.
2.5 We may remarket our services to you in a targeted way, by using third party remarketing services (such as Google Ads, social media or similar providers). Our third-party remarketing vendors may advertise our services to you at multiple online locations. You agree to our use of these third-party vendor remarketing services for the purpose of advertising to you in this way. You can withdraw your consent to this advertising at any time by contacting us directly.
Uses Made Of Your Information
We use information held about you in the following ways:
3.1 Information you give to us. We will use this information:
- (a) to carry out our obligations arising from any contracts entered into between you and us including the provision to you with information, products and services that you request from us, online content and dealing with your requests and enquiries;
- (b) to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about;
- (c) to send newsletters or other communications on topics which may be of interest to our customers and to people who have requested information from us via our website (e.g. to provide a trial of our products or services, provide you with information on our products and services or other information requested);
- (d) where you have expressly consented to us contacting you for marketing purposes, by ticking the relevant box on our website during the sign-up process, to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. We will only provide your data to selected third parties for marketing purposes if you have expressly consented to this. If you do not want us to use your data in this way, please ensure that the relevant box is ticked or unticked as appropriate on the webpage where we collect your data, or click on the unsubscribe button on any email communication from us;
- (e) to notify you about changes to our service or products;
- (f) to contact you in relation to service updates that affect you, regulatory updates that affect our services and any additional information in relation to our service that we think you may find interesting;
- (g) to analyse and improve the services offered on our website/platform; and
- (h) to ensure that content from our website/platform is presented in the most effective manner for you and on your device.
3.2 Information we collect about you. We will use this information:
- (a) to administer our website/platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- (b) to improve our website/platform to ensure that content is presented in the most effective manner for you and for your device;
- (c) to allow you to participate in interactive features of our service, when you choose to do so;
- (d) as part of our efforts to keep our website/platform safe and secure;
- (e) to personalise the way the website/platform content is presented to you and provide you with the most user-friendly navigation experience. We may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes;
- (f) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- (g) to use IP addresses to identify the location of users, to block disruptive use, to establish the number of visits from different countries and to determine whether you are accessing the services from a particular country; and
- (h) to make suggestions and recommendations to you and other users of our website/platform about goods or services that may interest you or them.
3.3 Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
Disclosure Of Your Information
4.1 We may share your personal data with our Affiliates in accordance with this policy.
4.2 We will not rent or sell your information to third parties without your consent. We will not be responsible or held liable for the actions of third party sites from which you may have linked or been directed to our website/platform.
4.3 We or the relevant Licensee may share your information with selected third parties including:
- (a) relevant Licensees appropriate to the services being provided to or by you;
- (b) third parties to whom you expressly consent to your personal data being provided such as prospective employers;
- (c) business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
- (d) analytics and search engine providers that assist us in the improvement and optimisation of our website/platform; and
- (e) external service providers who help us operate our business (e.g. our external internet hosting company). Generally, this would not involve a “disclosure” of the information to the service provider as the provider is generally only holding the information on our behalf, however we reserve the right to disclose personal data to service providers if required in accordance with this policy.
4.4 If we or any Licensee engage external service providers, we will take steps to ensure that those external service providers:
- (a) comply with Australian Privacy Laws or the Act (whichever applies) when they receive, hold or handle personal data; and
- (b) are authorised only to use personal data for the limited purposes specified in our agreement with them
- (c) Comply with relevant international or national legislation where appropriate (e.g. GDPR, see clause 11)
4.5 If we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets; and personal data held about our customers may be one of the transferred assets in the event of sale of the assets of our business to a third party.
Security Of Information We Store And Transfer
5.1 All information you provide to us is stored on secured servers. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website/platform and any transmission is at your own risk. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, platform or our service, you are responsible for keeping this password confidential.
How Long Do We Keep Your Personal Data
How We Manage Sensitive Personal Data
The Act defines certain information as ‘sensitive’ (racial or ethnical origin, political opinions, religious believes, trade union membership, physical or mental health, sexual life, criminal proceedings and offences). If we ever deal with sensitive personal data we will only use this information to provide the service you require and we will ask for your explicit consent.
8.1 You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking/unchecking certain boxes on the pages we use to collect your data. You can also exercise the right at any time by contacting us at [email protected]
8.2 You can always choose not to provide information, however in that event we may not be able to provide you certain services, or fully provide you certain services.
8.3 The Act gives you the right to access information held about you and to request that it is corrected if any of your details held are incorrect. Your right of access can be exercised in accordance with the Act. If you wish to verify the details that we hold, you may do so by contacting us via e-mail to [email protected] Our security procedures mean that we may request proof of identity before we reveal information.
Third Party Websites
9.1 Our website/platform may contain links to and from the websites of our partner networks, advertisers and other third parties. If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
We may from time to time provide you with an “opt in” or “opt-out” mechanism, subject to the requirements of The Act. In each instance, opting-in or opting-out will be up to you and, in addition, if you do not want us to use your personal data for a particular purpose or disclose it to a third party, you may “opt out” at any time by contacting us as provided below. Please note though, by opting-out, you may not be able to participate in certain activities on our website/platform.
Hillway Residences will never send you unsolicited mail asking for a site password.
Hillway Residences will not submit your contact information to a spam list, and we will not forward your contact information to anybody we have good reason to believe, intends to submit or use your contact information in a spam list.
Any complaints regarding users or service providers who misuse your personal information on this site or any child site will be dealt with accordingly. Anybody we deal with who is found using your personal information for spam or other inappropriate purpose will be both:
- (a) Suspended from all trade with our business, and use of our website
- (b) Information may be reported to appropriate authorities (ie. Police, Commerce Chambers etc)
European Union General Data Protection Regulation (GDPR) Compliance
If you are located in the EU, the European Union General Data Protection Regulation (“GDPR”) provides you with enhanced protection for your personal data.
The GDPR affects all businesses that acquire, store or process the personal data of individuals in the EU — including businesses that are based outside the EU.
12.2 In accordance with the GDPR, to cover EU citizens only, we have made the below amendments to our policy:
- (b) We’ve undertaken an audit of our systems
- (c) We have encrypted data where necessary
- (d) Employed internal data security measures, including data encryption where necessary
- (e) Adjusted third party tools for marketing and analytics purposes to ensure compliance
- (g) Implemented cookie consent features
- (h) Implemented new opt-in and opt-out features for data collection and storage.
12.3 For any queries or issues with GDPR compliance, you can contact our company at [email protected]