PRIVACY POLICY

We are committed to protecting your personal information and

confidentiality. This Privacy Policy applies to Royce Property Group Pty Ltd (RPG, we, us).
We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and we manage and protect your privacy in accordance with the Australian Privacy Principles (APPs).

1. Collection of Personal Information

Personal information is defined in the Privacy Act as being information that identifies or could reasonably identify an individual. This may include an individual’s name, address, email address, and telephone numbers. The type of personal information that RPG collects will vary depending
on the reason for engagement.

RPG only collects personal information where we consider it to be reasonably necessary for our business functions or activities. RPG only uses personal information for the purpose specified or which is reasonably apparent at the time the information was collected, or for a related purpose for which the individual would reasonably expect it to be used.

The kinds of personal information that we may collect include:

  • Contact details such as address, email address, phone and mobile number
    and internet protocol (IP) address;

  • Relevant company, business and financial information;

  • Information about individuals who wish to or express an interest to engage our services

2. How we collect your Personal Information

We will obtain your personal information only by lawful and fair means, and where practical,
directly from you. If you provide your personal information to someone we deal with,
we may obtain it from that person.

By using our services or providing personal information to RPG,
you affirm that you consent, and you have the consent of any other individuals whose information you are providing, to RPG dealing with it under this Policy.

The circumstances in which we directly collect personal information will vary depending
on the nature of the interaction. Some common ways we collect personal information directly
from you are:

  • When you register or subscribe for electronic direct mail outs;

  • When you engage or express an interest to engage our services;

  • When you supply goods and services to RPG;

  • Security holders or investors in RPG;

  • Users of website, social media or other online services.

3. Use and Disclosure of Personal Information

RPG will only use personal information for a purpose which is reasonably apparent at the time when the information was collected. RPG may also use or disclose the information collected for any other related purpose for which the individual would reasonably expect it to be used.

We will obtain your consent if we wish to use or disclose the personal information
in other circumstances.

4. Disclosing Personal Information to Other Parties

We engage with a range of third parties in order to operate our business and provide services.
We may disclose personal information to third parties for the same purposes as are set
out in paragraph 3 above.

Organisations to which we may disclose your personal information include:

  • RPG’s contractors, consultants, advisors and service providers who assist us in the operation
    of our business or to provide a customer service;

  • Joint venture partners for the purposes of seeking relevant regulatory approvals;

  • Relevant parties in situations when RPG is required by law to provide information to government bodies such as the ATO, ASIC, and the police or courts, and in each case, their representatives, contractors, agents and distributors.

RPG limits the information disclosed to external parties to what is required for them to perform their services or what is required by law. RPG does not sell personal information.

5. Protecting your personal information

We store information in different ways, including paper and electronic form.
We take reasonable steps to protect it from misuse, interference, loss, unauthorised access,
human error, modification or disclosure including:

  • secure password protected databases for storage;

  • limiting the provision of personal information to third parties on a need to know basis.

Due to the nature of electronic communications and the public internet, we cannot guarantee that personal information will be protected against unauthorised access or misuse. We do not accept any liability for breaches due to human error, malicious or inadvertent disclosure, technology flaws or malfunction, or the improper actions of unauthorized third parties.

6. Marketing

If we hold your personal information, RPG may use or disclose that information
(other than sensitive information) for direct marketing if:

  • we collected the information from you in accordance with this Privacy Policy; and
    you would reasonably expect us to use or disclose the information for that purpose; and
    we provided you with a simple way to opt out of receiving direct marketing from us; and
    you have not made such an opt out request.

7. Collection of Cookies

RPG may also collect cookies from you during a visit to the RPG website. “Cookies” are data files
(of letters and numbers) that we store within the hard drive of your computer when you interact with our website. Cookies are necessary to allow the website to function effectively and enhance security. Cookies can record information about the user’s visit to assist RPG in understanding the needs of the user. When you visit our website, our servers collect routine logging information such as the pages visited, the time of your visit, your web browser and device type and the IP address associated with your request. We also collect referring URLs of website you have visited or will visit, data about the activities you undertake and how you interact with us online, such as what data
is displayed, clicked on or shared, the click stream patterns, and the length of time you spend
on our site or page.

If users of the RPG website do not wish to receive any cookies, they should set their browser to refuse cookies but this means that certain parts of the RPG website my not function properly.

8. Resolving your privacy issues

If you have any issues you wish to discuss with us or if you are concerned about how we have collected or managed your personal information, please contact our office on through the “Contact Us” section of our website. For information about privacy or if your concerns are not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner at www.oaic.gov.au and on 1300 363 992.

RPG reserves the right to change this policy at any time.