This Privacy Policy explains how we collect, handle, use, transmit and disclose your Personal Information and applies to you unless you give us explicit consent to act otherwise. This Privacy Policy also details the options available to you regarding our use of your Personal Information as well as how you can access and update this information.

We are committed to responsible privacy practices and compliance with the Privacy Principles contained in the Privacy Act 1988 (Cth). Please visit legislation.gov.au for more information about the Act.

What Is Personal Information?

Under the Act, "Personal Information" means information or an opinion about an identified individual or an individual who is reasonably identifiable (such as a name, address, telephone number, mobile number or e-mail address).

If you provide us with your personal information, you consent to our collection, use and storage of that information in accordance with this policy.

When Do We Collect Information?

We will collect information from you when you voluntarily provide this to us, such as when you create an account and profile, send us an email or post information or other content to our site. You may be doing this as an owner or occupier of a unit in the Building or because you are providing services to the Building or its occupants or because you are managing the Building or you need access to the Site.

We automatically collect certain information when you use our site and our service, or when you log-in to third party sites from the Site. We may also use cookies and similar technologies including mobile application identifiers to help us recognise you across different devices. You can control cookies through your browser settings and other tools.

What Information Do We Collect?

In order for you to use the Site, we will ask you to provide us with information about yourself when you set up an account on the Site. Some of this information will be Personal Information for the purposes of the Act and may include your name, username, password, contact details (phone, mobile, email address, back-up email address).

Except as described in this policy, we do not generally require you to disclose any sensitive information (e.g. medical information, details of race, religious belief, sexual orientation or membership of a trade union) to us. If you do provide us with sensitive information for any reason, you consent to us collecting that information and using and disclosing that information for the purpose for which you disclosed it to us and as permitted by the Act and other relevant laws.

How We Protect Your Information

We will take reasonable steps to protect your personal information from loss, misuse, unauthorised disclosure or destruction.

The hosting of the Site and the information collected through the Site is outsourced to a third party operator of a data centre located in Australia. This operator is bound by the Act and was selected by us on the basis that its security safeguards are in accordance with current generally accepted industry standards with high grade security features, employing full UPS power back-up generator systems. Limited technical and usage information is, however, disclosed to service providers located in the United States, as described in the "Overseas Disclosure" section below.

The use to which we put information provided to us and our record keeping obligations means that the information will be retained by us even after you have closed your account.

In order to enable us to meet our obligations under the Act and to ensure the operation of the Site we may need to allow our authorised staff and contractors access to your personal information. The staff and contractors are required by contract and policies to maintain the confidentiality of your information.

We will retain your personal information for the period necessary to fulfil the purposes outlined in the Privacy Policy unless a longer retention period is required or permitted by law.

How We Use Your Information

We will use the information to enable us to:

Provide information about the Building (and activities and events occurring in and about the Building – including scheduled and emergency maintenance and repairs)
Provide information about your rights and obligations if you are an owner or an occupier of a unit in the Building
Assist the manager of the Building and its Owners Corporation to comply with their obligations under the Strata Schemes Management Act 1996
Make it easier for you to navigate the Site and make your use of the Site more relevant to your circumstances
Send you promotional communications which we believe may be of interest to you (unless you have opted out of receiving such communications)

Among other things, if we have this information, we can:

Make the Site easier for you to use by not having to enter information more than once
Help you quickly find services or information relevant to your needs
Help us offer up to you content that is relevant to you
Alert you to updated information and other new services available on the Site

We will use the information collected from you when you contact us with a question or complaint about the Site to respond to and, if we believe we need to do so, to investigate your question or complaint further. In addition we also use this information to identify and correct potential problems, monitor trends and improve our support services.

When Do We Share Information with Third Parties?

We will make the information collected from you available to third parties:

Where it is necessary for us to carry out your instructions
As reasonably necessary in order to enable us to make the Site available to you
When we reasonably believe it is required by law, subpoena or other legal process
As necessary to assert our rights and to protect the Site and to maintain the safety of others using the Site
As necessary to assist the Building manager and the Owners Corporation to protect the Building and maintain the safety of other users of the Building

Overseas Disclosure

We use a small number of third-party service providers located in the United States to keep the Site working and to understand how it is used. When you use the Site, limited information is transmitted to and stored on those providers' servers in the United States. They are:

Sentry (Functional Software, Inc.) — error monitoring, to help us detect, diagnose and fix faults
Google Analytics (Google LLC) — usage statistics, to understand which pages and features are used
Microsoft Clarity (Microsoft Corporation) — website usage analytics, including recordings of how visitors interact with pages. This is used only on our public marketing website, not in the resident or building-manager application.

Error monitoring (Sentry)

When a technical error occurs while you are using the Site, diagnostic information about that error is transmitted to Sentry. That diagnostic information includes:

Technical details of the error itself (such as the error message and the part of the Site in which it occurred)
A short trail of recent technical events in your browser session leading up to the error, such as the pages of the Site visited, interface elements interacted with, and the addresses of network requests made by the Site
Information about your browser, device and operating system
An opaque account identifier, which does not itself reveal your name or contact details but which we are able to link to your account in order to investigate a fault affecting you

We do not intentionally send Sentry your name, email address, password or the content you post to the Site, and we apply automated redaction to error data before it is transmitted. We have also configured Sentry not to store the IP addresses of visitors to the Site. Despite these measures, fragments of such information may occasionally appear in the technical detail of an error. Diagnostic information is retained by Sentry for up to 30 days and is then deleted.

Analytics (Google Analytics and Microsoft Clarity)

These services tell us how the Site is used — for example which pages are visited, for how long, from which country, and on what kind of device. Microsoft Clarity, which we use only on our public marketing website, also records how visitors move through and interact with pages.

We do not send these providers your name, email address or the content you post to the Site, and we do not use them to identify you personally. They may set cookies or similar identifiers on your device, and they may receive your device's network (IP) address. You can prevent this by blocking cookies and scripts in your browser settings, or by using the Google Analytics opt-out browser add-on.

Our obligations

Before disclosing personal information overseas, we take reasonable steps, as required by Australian Privacy Principle 8.1, to ensure the overseas recipient handles that information in a manner consistent with the Australian Privacy Principles. We remain accountable under the Privacy Act for personal information we disclose to overseas recipients.

Important Notes

Information that you have shared with other users of the Site will remain visible after you have closed your account.

If you visit other sites through links we provide, personal information may be collected by the operators of those sites. Collection of that information is not governed by this policy but will be governed by the privacy policies of those operators and we encourage you to familiarise yourself with their policies.

Changes to This Policy

We reserve the right to make changes to our Privacy Policy from time to time or as required by law.

If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by placing a prominent notice on our Site. The latest version of this Privacy Policy supersedes all other versions.

Contacting Us

You may want to contact us about the personal information we hold about you (including to correct any information) or to ask a question about our Privacy Policy or to make a complaint about a breach by us of the Act.

You may do so by sending us an email at support@comtylink.com

Complaints

If you have a complaint about our compliance with the Act and we have not resolved your complaint within 30 days after you first notified us of your complaint, you can refer your complaint to the Australian Information Commission (OAIC) by visiting oaic.gov.au.

ComtyLink Pty Ltd · ABN 14 634 966 162