1. SERENITAS’ commitment to your privacy
At SERENITAS, we recognise the importance of protecting your personal information and are committed to protecting the privacy of your personal information. This document sets out our policy on how we collect, handle, store and protect personal information across our business.
This policy applies to SERENITAS[I] as well as agents and contractors engaged to provide goods and services on SERENITAS’ behalf.
SERENITAS is a leading owner, operator and developer of land lease communities in Australia. SERENITAS provides lifestyle and affordable living solutions to retirees and Australians aged over 50 years through its operations in Western Australia, Queensland, New South Wales and Victoria and various brands (including, amongst others, The Vantage at Vasse, The Outlook at Albany, Tuart Lakes, National Lifestyle Villages, RV Homebase, The Anchorage, Lucas Lifestyle Estates and Thyme Lifestyle Resorts). We collect personal information when:
- we provide services to our customers;
- people use our websites or otherwise provide information to us; and
- we perform other activities that form part of the operations of our business.
When handling personal information we comply with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (“the Privacy Act”) which impose regulations on the way in which organisations collect, store, use and disclose personal information and other matters including data quality, security, openness, access and correction.
2. Types of personal information we collect and store
What personal information do we collect and why?
The Privacy Act defines “personal information” to mean any information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent or can be reasonably ascertained, from the information or opinion.
The personal information we collect includes names and contact details, date of birth, personal identification, bank account details, pension information, next of kin and emergency contact details, power of attorney, CCTV footage of you if you visit our premises, vehicle registration details, social media details, preferences and interests about our services (likes and dislikes). We also collect personal information in relation to prospective employees and contractors including curriculum vitaes, job applications and reference checks.
We may collect personal information in the following ways:
- directly from our customers to enable us to deliver services to them;
- when performing other activities that form part of the operation of our business, but which do not directly form part of providing services to our customers;
- from individuals who register with us, email us, arrange a viewing or request brochures or information;
- from third parties where necessary to facilitate an employment or contractor relationship with you;
- from referees and third parties in relation to prospective employees and contractors as part of our recruitment process; and
- from suppliers, contractors and third-party service providers that we engage to help us operate our business.
Due to the nature of the goods and services we provide, it is only practicable or reasonable for us to transact and correspond with you on a named basis. Your personal information may be required in order to provide you with our goods and services, or to resolve any issue you may have.
What sensitive information do we collect?
Sensitive information is defined in the Privacy Act to include information or opinion about an individual’s racial or ethnic origin, political opinions or associations, religious or philosophical beliefs, membership of a trade union or other professional association, sexual orientation or practices, criminal record or health.
In general, we attempt to limit the collection of sensitive information we may collect from you, but depending on the uses you make of our services this may not always be possible and we may collect sensitive information from you in order to carry out the services provided to you. However, we do not collect sensitive information from you without your consent.
The type of sensitive information we may collect about you is dependent on the services provided to you by SERENITAS and will be limited to the purpose(s) for which it is collected.
We may collect other types of sensitive information where you have consented and agree to the collection of such information. We typically seek to obtain your consent for this at (or around) the time we collect the information.
To improve your experience on our websites, like most major websites, we may use methods (including cookies and enhanced conversions) as a tool to remember your preferences. and track your interactions with our ads and website. We will share this information with third parties to perform ad measurement services on our behalf.
You may refuse the use of these methods by selecting the appropriate settings on your browser or managing your consent preferences within Google; however, if you do this, you may not be able to use the full functionality of our website.
Our websites may contain links to other websites. We are not responsible for the privacy practices of such other sites. When you go to other websites, you should read their privacy policies.
Our websites use the analytics tool Google Analytics. This service transmits website traffic data to Google servers that may be located outside of Australia. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us to understand website traffic and webpage usage.
Before any email address is collected for use by SERENITAS, permission will be requested from you. After obtaining authorisation from you, we may use email messages to provide you with ongoing marketing communications, requested services or latest news items, unless you opt out. If you wish to opt out, please follow the instructions in the relevant marketing communication.
How we use personal information
- to answer queries you may have about our products and services;
- to provide services to our customers;
- in the management and administration of SERENITAS communities, including investigating and resolving resident complaints, ensuring that residences within SERENITAS communities are secure and advertising a residence for sale;
- in undertaking marketing and research with our customers and other people;
- in understanding website traffic and usage;
- to share information with third parties to perform advertisement measurement services on our behalf;
- to seek feedback on our services;
- to manage, improve and tailor the user experience on our websites and in respect of our products and services;
- to facilitate our internal and external business processes, including financial operations, training and reporting;
- in connection with the sale, and matters in connection with a potential sale, of our business or company to a third party;
- to notify you about important changes or developments to our services;
- to allow us to assess the suitability of prospective candidates for employment at or engagement with SERENITAS;
- as required or authorised by law; and
- for such secondary purposes that are closely related to the purposes above in circumstances where you would reasonably expect such use or disclosure.
When will we disclose your personal information?
We will only disclose your personal information as set out below. Importantly, we will never disclose or sell your personal information to third parties for advertising purposes or for any other purpose without your authorisation.
We may disclose personal information to:
- other entities that we own or control;
- third parties in connection with the sale, and matters in connection with a potential sale, of our business or company to a third party;
- third parties where you consent to the use or disclosure; and
- third parties that we engage to assist us in providing services to our customers or in the operation of our business (for example, our subcontractors, advisors and suppliers).
We may also be required to disclose personal information when required by law.
We may share non-personal, de-identified and aggregated information with third parties for several purposes, including data analytics, research, submissions, marketing and promotional purposes.
Security of personal information
Your personal information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.
We hold personal information in hard copy and electronic formats. We use a range of physical, operational and technological security measures to protect this information including firewalls, password protection and premises access restrictions.
3. Transfer of personal information outside Australia
We may store personal information within services provided by offshore cloud service providers.
Some of the recipients of your personal information referenced above may be based in countries or regions outside of Australia, including Europe, the United States of America, Japan, Canada and China. Accordingly, any personal information that is collected may be transferred to countries or regions with privacy laws that are different from the privacy laws that apply to this Policy. We will ensure that any such transfer of personal information will only be undertaken in compliance with our legal obligations.
4. Access to, or correction of, your personal information
You may access your personal information or seek to have that information corrected if you believe that it is incorrect at any time.
If you wish to make any changes to your personal information, you may contact us by emailing the Privacy Officer at email@example.com.
To protect your personal information, we may require identification from you before releasing the requested information.
How long do we store information?
We will not keep your personal information for longer than is required for the purposes for which the information may lawfully be used.
We will determine this time period at our discretion.
How to lodge a complaint if you think your information has been mishandled
If you have any questions or concerns regarding your privacy, or if you would like to make a complaint, please contact our Privacy Officer at:
Suite 36.03, 60 Margaret Street, Sydney, NSW, 2000
We take all the privacy complaints we receive seriously.
We will acknowledge the receipt of a complaint and will work with you to resolve it. If you would like more information about our process for handling complaints, please contact the Privacy Officer above. If we are ultimately unable to satisfactorily resolve your complaint, you may take your complaint to the Office of the Australian Information Commissioner.
5. Policy Updates
This Policy may change from time to time and is available on our website. Therefore, we encourage you to periodically review this Policy to be informed about how we are protecting your information.
This Policy was last updated in August 2022.
[i] Serenitas Management Pty Ltd, Serenitas Finance Pty Ltd, Serenitas Communities Pty Ltd, Serenitas Communities Holdings Pty Ltd, Serenitas Communities Holdings II Pty Ltd, Serenitas Finance II Pty Ltd, Serenitas Finance III Pty Ltd, Serenitas Communities AB Pty Ltd, Serenitas Communities CD Pty Ltd, Serenitas Development II Pty Ltd, Serenitas Development Pty Ltd and each trust and subsidiary we own or control (collectively “SERENITAS”).