PRIVACY POLICY

Human Touch Retirement (HT Retirement) recognises the importance of protecting the privacy of our customers and other third parties who provide their personal information to us. This privacy policy details how we generally manage your personal information and safeguard your privacy when you contact HT Retirement or our villages Mount Gilead Estate, Gibraltar Park and Camden Grove. ‘Personal information’ is any information or opinion, in any form, which identifies an individual or from which an individual’s identity is apparent or can be reasonably ascertained. This Privacy Policy was last updated on September 1st, 2019 and includes disclosure of the matters set out in the Australian Privacy Principles.

PERSONAL INFORMATION WE COLLECT
We only collect personal information that is necessary for us to perform our organisation’s functions and activities, or to comply with our legal and regulatory obligations.

The kind of information we collect and hold will depend on the services you request from HT Retirement and our villages – Mount Gilead Estate, Gibraltar Park and Camden Grove, however it may include:

• Information you give us when you request a service from us, which will include your name, address and contact details and other information provided via e-mail (such as your signature) and;

• Communications between you and HT Retirement and our authorised agents
  Communication between you and HT Retirement using the chat feature on our website or Facebook.Communication between you and HT Retirement via calls to our phone numbers 1300 686 111, 1300 686 122, 1300 686 133 and 1300 686 144.

• We also collect some information from you when you use our website. Your use of the website will determine the amount and type of information which we collect about you. Some of this information will not be personal information because it will not reveal your identity. The only personal information which we collect about you when you use our website is what you tell us about yourself, for example, by completing an online form, or information you provide to us when you send us an email. We will record your email address if you send us an email.

COOKIES
We may use temporary (session) cookies or permanent cookies when you access our web site. This allows us to recognise your browser and track the web pages you have visited. We do not link this information back to your identity or other information that you have provided to us. We do not store any information that identifies you inside cookies. You can switch off cookies by adjusting the settings on your web browser.

COLLECTION OF ANONYMOUS INFORMATION

 

HT Retirement tracks usage patterns on our websites (htretirement.com.au, mountgileadestate.com.au, gibraltarpark.com.au and camdengrove.com.au) on an anonymous basis. To achieve this we use analytics services providers including Google Analytics and Fullstory. This information is used to improve the quality of our website experience, including its content, interface, compatibility with your browser and device. Your identity cannot be reasonable ascertained from this information. When you visit our website, a web server will record your visit and specifically certain information including;

• Date and time of your visit

• Pages accessed during your session(s) and any documents you download

• Referring URLs

• The approximate location of your session(s)

• A session capture that includes pages you navigate and interact with while using our website

• Your internet provider

• Information of a technical nature including your Operating System, device type, and screen size

To opt-out of anonymous information collection by our analytics service providers please see the following links :

Google Analytics 
FullStory

UNSOLICITED INFORMATION
If you send us personal information that we have not requested, or we determine that the personal information you have provided to us is not reasonably necessary or directly related to any of our functions or activities, we may de-identify or delete this information without notifying you to protect your privacy.

HOW WE COLLECT YOUR PERSONAL INFORMATION

Normally we collect information from you directly, unless it is unreasonable or impracticable to do so. We may also collect information from you relating to third parties. Accordingly, we may also collect information about you from a third party. When we obtain personal and other information from third parties whom we are referred to by you, we will assume and you will ensure that you have made that third party aware that you have referred us to them and of the purposes involved in the collection, use and disclosure of the relevant personal or other information. If you supply us with information about another person, you should ensure that you are authorised to do so and you must agree to inform that person who we are, that we will use and disclose their personal information as outlined in our Privacy Policy from time to time and that they may gain access to it should we hold that information.

HOW WE HOLD YOUR PERSONAL INFORMATION

We may hold your personal information in either electronic or hard copy form.

If you provide information to us electronically we retain this information in our computer systems and databases. This includes computer software programs, internet servers, and hosted services and other internet solutions provided by third parties.

 

If you provide information to us in hard copy (paper) this information is normally retained in our files and a copy is made to our electronic files.

SECURITY

We use industry standard security measures to safeguard and protect your information. This includes taking reasonable steps to ensure your personal information is protected from misuse, loss, unauthorised access, modification or disclosure.

IF WE ARE UNABLE TO COLLECT YOUR PERSONAL INFORMATION

If you do not provide us with your personal information, or you do not consent to us using your personal information as outlined in the Privacy Policy, it may not be possible for us to provide you with the services you request.

PURPOSE OF COLLECTION OF YOUR PERSONAL INFORMATION

We collect your personal information so we can carry out the services you have requested from us.

We may also use your personal information to comply with laws or regulations or to comply with any directions given by regulators or authorities. We may also use your personal information to provide you with information about other services offered by us. If you would prefer not to receive this information, please let us know and we will respect your request.

DISCLOSURE OF YOUR PERSONAL INFORMATION

We will disclose personal information you have provided to us so that we can provide the services you have requested.

 

We may disclose your personal information to our service entities and contract out some of our functions (such as printing) to external service providers. We may disclose your personal information to these external service providers but only so that they can provide the services that we have contracted out to them.

 

Your personal information will not be shared, sold, rented or disclosed other than as described in this Privacy Policy.

 

ADVERTISING
HT Retirement employs the use of interest-based advertising which is provided by advertising services providers that include Google, Double Click, Facebook, Microsoft and others from time to time. This type of advertising may include search advertising, banner advertising and other internet advertising (i.e Facebook) to show you our ads based on your likely interests as identified by our advertising partners. If you see HT Retirement advertising or advertising for our villages Mount Gilead Estate, Gibraltar Park and Camden Grove on a website, it is displayed by our advertising service providers on behalf of HT Retirement. We do not specify which websites these advertising service providers should display our advertising on.

 

HT Retirement respects your privacy as a user, and you can opt-out from being included in interest-based advertising provided by our advertising service providers on supported devices: Your iOS mobile device may provide a “Limit Ad Tracking” setting. On Android devices, your settings may allow you to “Opt out of Interest-Based Ads.” When you have opted out using this setting on a device, our advertising partners will not use information collected from that device to infer your interests or serve ads to that device that are targeted based on your inferred interests.

 

Your mobile web browser may also provide a “Do Not Track” browser setting. When you have enabled this setting in your browser, our advertising service providers will not use mobile web browsing information from that browser to infer your interests or serve ads to that device that are targeting based on your inferred interests.

 

Our advertising service providers also offer a number of tools in which you can opt out of interest-based advertising. You can find more details about this below. You may also which to use the Private Browsing function of your web browser or employ the use of a privacy tool such as AdBlock.

 

Our advertising service providers also offer a number of tools in which you can opt out of interest-based advertising. You can find more details about this below. You may also which to use the Private Browsing function of your web browser or employ the use of a privacy tool such as AdBlock.

• Google Advertising Settings

• Facebook Advertising Settings

• Your Adchoices Opt-Out

DIRECT MARKETING

We may send you direct marketing communications and information about products and services offered by us via email, or regular mail. If you have indicated a preference for a method of communication, we will endeavour to use that method wherever practical to do so.

 

You may opt out of receiving marketing communications at any time by responding via the channel in which you received the marketing communication, or by contacting us (see contact information below). If you have provided us with your email address, we may send you emails relating to our services, or other industry specific information. You can unsubscribe from emails by clicking the unsubscribe link on the footer of the email communication you have received. We may use an “email management system” to automate the management and dispatch of these emails. The system operates by inserting tracking codes in the emails that we send to you. The tracking code allows us to collect personal information about you, such as whether you received and opened an email, and whether you clicked through to any links to our website. This information that we collect about you will be stored by our email management system.

 

We use the information that the email management system collects to;

 

• ensure that you only receive correspondence that you have informed us that you wish to receive

• ensure that the email address that you have provided us is still operational

• determine whether emails that we send to you are received by you

• update a request that you make to us to unsubscribe from a communication that we send to you

• review the effectiveness and relevance of our emails to you by collecting other statistical information

We do not provide your personal information to any other organisations for the purposes of direct marketing.

 

 

OVERSEAS DISCLOSURE OF PERSONAL INFORMATION

We may disclose your personal information to third parties and service providers located overseas only in order to provide you with services you have requested or consented to or to ensure we can provide an optimal experience to you when using our website. We may disclose your personal information to the following locations: the United States of America – for database management services in connection with our web hosting, email hosting, email marketing, analytics and data management platforms. We take reasonable steps to ensure that the overseas recipients of your personal information do not breach the privacy obligations relating to your personal information.

 

HOW YOU MAY ACCESS OR CORRECT YOUR INFORMATION

You may access your personal information held by HT Retirement by making a request to us. We will handle requests for access to your personal information in accordance with the NPPs. We will deal with all requests for access to personal information as quickly as possible. Requests for a large amount of information, or information which is not currently in use, may require further time before a response can be given. If your request is unlawful or may interfere with the privacy of others we may reasonably refuse to provide access to your personal information. If you would like us to update or amend your personal information, please contact us and we will make the requested amendments. We may ask you to verify your identity to ensure that personal information we hold is not improperly accessed. If you would like more information about the way we manage personal information that we hold about you, or are concerned that we may have breached your privacy and wish to make a complaint, please contact us by either:

 

Email: info@htretirement.com.au

Mail: The Privacy Officer, HT Retirement, 8/1 O’Connell Street, Sydney NSW 2560

Last updated September 1st, 2019