1 PRIVACY POLICY 

1.1 4Retirees Pty Ltd (ACN 627 434 682) is a business registered in Australia (the Company) and is committed to keeping your information safe and secure in accordance with the Privacy Act 1988 (Cth) (the Privacy Act) and the Australian Privacy Principles contained therein. By using and accessing the Company’s website (the Platform) or using the Company’s Services (the Services), you are giving consent to the Company for the use of your private information in the manner set out in this Privacy Policy.

2 COLLECTION OF PERSONAL INFORMATION

2.1 The Company may collect and use the following kinds of information:
(a) Information about your use of the Platform or Services, including:
      (i) your location;
      (ii) your IP address;
      (iii) device name, IMEI, and/or MAC ;
      (iv) browser type;
      (v) version and language;
      (vi) operating system; and
      (vii) “cookies”.
(b) Information about your personal details when you create an account, including:
      (i) your name;
      (ii) phone contact details;
      (iii) address information;
      (iv) email;
  (v) information about your employment; and

      (vi) information provided to the Company by a third-party social network site if you create an account using a social networking account, including your username, site ID and email address.
(c) Information about your behaviour and activities when you use the Platform, including:
      (i) the number of times you viewed a video that was uploaded onto the Platform;
     (ii) the profiles you viewed while browsing the Platform;
     (iii) the number of times you accessed a page;
     (iv) your following list; and
     (v) your property searches, including their prices.

2.2 Information about your personal information may be collected from you in a variety of ways, including but not limited to:
     (a) when you register and create an account on the Platform or log in using a third party social networking account;
     (b) when you interact with the Company electronically or in person, including but not limited to, when you report any video or other user of the Platform or generally seeking our assistance;
      (c) when you access the Company’s Platform or Services; and
      (d) when you upload or post a video onto the Platform.

3 USE AND DISCLOSURE OF PERSONAL INFORMATION

3.1 The Company may use your personal information which the Company has collected to:
     (a) enable your access to the Platform;
     (b) verify your identity when you register and create an account on the Platform;
     (c) track usage and measure traffic statistics of the Platform;
     (d) supply to you the videos that you can access and browse on the Platform;
     (e) enhance your experience on the Platform by suppling to you a more intelligent Platform tailored to you;
     (f) supply to you property recommendations based on your recent searches;
     (g) personalise your advertising, videos you view, people you engage with and your overall experience on the Platform;
     (h) contact you regarding your use of the Platform and the Services offered by the Company;
     (i) contact you in relation to comments, complaints, enquiries or dispute resolution;
     (j) notify you over any changes to the Platform and to our related documentation, including our Terms and Conditions and this Privacy Policy;
     (k) collect payments from you; and
     (l) send you marketing communications such as offers, promotions, or advertisements for property listings.

3.2 The Company will not disclose personal information about you, unless it is required, incidental or otherwise related to the primary purpose of providing the Services to you for which you have consented to by accessing the Platform or using the Services. However, the Company may disclose your personal information to its business partners who can assist them to provide Services to you as a customer.

3.3 The Company, in its sole discretion, may disclose your personal information if it is required to do so by law or legal process, including:
     (a) in order to establish, exercise or defend its legal rights;
     (b) as required or authorised by law; or
     (c) to the extent required to permit the Company to investigate suspected fraud, harassment or other violations of any law, rule or regulation, our policies, or the rights of third parties or any other suspected conduct the Company deem improper.

You will be notified by an email to your email address if your personal information is being disclosed due to law or legal process.

4 SECURITY AND ACCURACY

4.1 It is important that you advise the Company of changes to your personal information that you have provided to the Company as it is essential that your personal information is accurate, complete, and up-to-date in order for the Company to provide the Services to you. If you discover that the personal information you have provided to the Company is incorrect or changes, you can contact us at legal@4retirees.com.

4.2 The Company will take commercially reasonable steps to protect your personal information from misuse, loss, unauthorised access, modification and disclosure. However, the Company is not liable for any unauthorised access to this information.

4.3 The Company will take commercially reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for the purposes of providing our Services to you and where the Company is not required to retain that information by law.

5 ACCESS AND CORRECTION

5.1 You are responsible to ensure that the information you provide to the Company is accurate, complete and up-to-date.

5.2 You may contact the Company at legal@4retirees.com to request to know what sort of personal information is held about you, for what purposes, and how it is collected, held, used and disclosed.

5.3 You may request to access your personal information by contacting the Company at legal@4retirees.com. The Company reserves the right to charge a reasonable administration fee for this access.

5.4 The Company in its sole discretion, may consider that there is a sound reason under the Privacy Act, Freedom of Information Act or other relevant law to withhold personal information, or not make the requested changes.

6 IDENTIFIERS AND ANONYMITY

6.1 You acknowledge that the Company retains, collects and maintains your personal information for statistical analysis purposes (whether for commercial or non-commercial purposes). You agree that the Company may share, distribute and/or transfer information which you have provided to the Company to third parties, after that information has been de-identified.

7 TRANS-BORDER DATA FLOWS

7.1 The Company may use cloud services, and as such, its servers may be located in Australia or overseas and you acknowledge, agree and understand that your personal information may be transferred and stored in Australia and other foreign jurisdictions which the cloud services may direct the data to be stored. You agree for us to transfer your information into foreign jurisdictions for the purposes of providing you with the Services.

7.2 In addition to the above, the Company will transfer personal information to someone who is in a foreign country where:
     (a) the Company reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the Australian Privacy Principles;
     (b) the individual consents to the transfer;
     (c) the transfer is necessary for the performance of a contract between you and the Company, or for the implementation of pre-contractual measures taken in response to your request;
     (d) the transfer is necessary for the conclusion or performance of a contract concluded in your interest between the Company and a third party;
     (e) all of the following apply:
         (i) the transfer is for your benefit;
         (ii) it is impracticable to obtain your consent to that transfer; and
         (iii) if it were practicable to obtain such consent, you would be likely to give it; or
     (f) the Company has taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the Australian Privacy Principles.

8 SENSITIVE INFORMATION

8.1 Sensitive information is defined in the Privacy Act to include information or opinion about such things regarding an individual’s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

8.2 Sensitive information will be used by the Company only:
     (a) for the primary purpose for which it was obtained;
     (b) for a secondary purpose that is directly related to the primary purpose;
     (c) with your consent; or
     (d) where required or authorised by law.

9 COMPLAINTS

9.1 As a valuable customer, if you have any complaints in relation to this Privacy Policy or privacy practice, please feel free to contact the Company at legal@4retirees.com.

9.2 A complaint should identify whether it is about:
     (a) the collection of personal information;
     (b) the use of personal information;
     (c) the disclosure of personal  information;
     (d) the security or storage of personal information;
     (e) the accuracy of personal information;
     (f) a refusal to give access to or provide about their personal information; or
     (g) a refusal to change or delete personal information.

9.3 The Company values your opinions and takes complaints very seriously. Upon receiving written notice of your complaint about privacy, the Company will respond in a timely manner to advise you of the outcome following its enquiring into the same. You will also be invited to respond to its outcome. If a response is received, the Company will assess your response and advise if it has changed its view. If you are unsatisfied with the final outcome, the Company will advise further options including, if appropriate, making a complaint with the Office of the Australian Information Commissioner.

10 OPTING-OUT OF DIRECT MARKETING

The Company aims to give you a highly personalised experience when using the Platform and the Services. In order to do so, the Company may use your personal information to send you advertisements to your email address. If you decide you do not want to receive these emails containing advertisements, you can request to unsubscribe from the mailing list by clicking ‘Unsubscribe’ at the bottom of the email.

11 COOKIES

11.1 The Company uses cookies, web beacons and measurement software (the Cookies) on the Platform and the Services to:
     (a) provide you with a personalised experience tailored to you, for example remembering your preferences and greeting you by name;
     (b) improve the Platform and the Services by using the data collected from the Cookies for analysing trends and reporting statistics; and
     (c) provide you with targeted marketing communications.

11.2 You may reject or delete the use of Cookies through the settings on your mobile or tablet device.

12 MISCELLANEOUS

12.1 Waivers
     (a) In limited circumstances, the Company may allow you to waive application of this Privacy Policy. A waiver of this Privacy Policy must be in writing and signed by the Company. The Company anticipates that the waiver of this Privacy Policy would only be in exceptional circumstances, and the Company encourages that you consider the circumstances leading to the waiver request prior to submitting such a request.

12.2 Governing Law & Jurisdiction
     (a) This Privacy Policy is governed by the laws of New South Wales, Australia. In the event of any dispute arising out of or in connection with this Privacy Policy, you agree that the exclusive venue for resolving any dispute shall be Sydney, Australia.

13 VARIATION TO THIS PRIVACY POLICY

13.1 This Privacy Policy is available online via the Platform.

13.2 The Company reserves the right to modify or amend this Privacy Policy at any time, for any reason, and without any notice, by posting a revised version on its Platform. Any changes to this Privacy Policy will become effective when the Company posts the revised Privacy Policy on the website. Your use of the Platform following these changes means that you accept the revised Privacy Policy.

14 USERS BASED IN THE EUROPEAN ECONOMIC AREA

14.1 There are further privacy protections and rights available to you under the General Data Protection Regulation, Regulation 2016/679 (GDPR) if you access the Platform or the Services from the European Economic Area (EEA).

14.2 The Company handles your Personal Data, which is any information relating to an identified or identifiable natural person as defined in Article 4 of the GDPR (Personal Data).

14.3 Collection of Personal Data
     (a) The Company may collect information about your behaviour and activities on the Platform using automated processes, including retaining your search history and the times you visited the Platform.

14.4 Use of your Personal Data
     (a) The Company may use the Personal Data that it has collected about you to:
          (i) provide you with a personalised experience tailored to you; and
          (ii) supply to your property listings based on your recent searches.

14.5 Your Rights
     (a) In certain circumstances, you may contact the Company to request:
            (i) confirmation from the Company as to whether your personal Data is being processed, including where that Personal Data is being processed and who the Personal Data may be disclosed to;
            (ii) access to your Personal Data;
            (iii) a copy of your Personal Data in a commonly used and electronically readable format;
            (iv) the Company to update any Personal Data that you have discovered is not accurate or has changed;
          (v) the Company to delete and stop processing your Personal Data, unless there are certain legal obligations the Company must comply with or the processing of your Personal Data is in the public interest, is crucial to exercise the right to freedom of expression and information, and is conducted for scientific research purposes; and
            (vi) the Company to limit the way or restrict the processing of your Personal Data.
     (b) You may also contact the Company to:
            (i) withdraw your consent to the processing of your Personal Data by the Company; and
            (ii) object to the processing of your Personal Data.
    (c) If your Personal Data is rectified or deleted, the Company will use commercially reasonable endeavours to notify you by sending you an email to your email address confirming the rectification or deletion.
   (d) To exercise any of the rights outlined in this clause 13.5, you may contact the Company by email at legal@4retirees.com.

14.6 Transferring your Personal Data
     (a) The Company may transfer your Personal Data to other countries outside of the EEA. If the Company does so, your Personal Data will only be transferred to countries that have demonstrated that they are compliant with the GDPR and when the Company is satisfied that there are adequate safeguards in place to protect your Personal Data.

15 CONTACT

15.1 Please contact the Company at legal@4retirees.com if you have any questions regarding this Privacy Policy.

15.2 This policy was last modified on 15th June 2020.

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