Privacy Policy

VaultRE
Privacy Policy

Effective as of 11 February 2021

Introduction

Welcome to VaultRE, an online sales, marketing and management service designed especially for real estate agencies and agents. These terms of use (“Terms”) are intended to explain our obligations as a service provider and your obligations as a customer in connection with our collection, use, disclosure, retention and protection of your personal information. Please read them carefully. These Terms apply across all websites that we own and operate and all services we provide, including any online and mobile products, and any other applications or services we may offer (for example, our mobile app, events or training). For the purpose of this notice, we’ll just call them our ‘Services’.

These Terms are binding on any use of any of our Services and apply to you from the time that VaultRE provides you with access to any part of the Services. These Terms may be relevant to you even if you are not a customer of ours, and have never used a website, application or a Service of ours. We may have your personal information because we have received it from a user of a website, application or other Service that we provide.

We will update these Terms from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” of these Terms at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes. We encourage you to periodically review these Terms to stay informed about our collection, processing and sharing of your personal data.. It is your obligation to ensure that you have read, understood and agree to the most recent terms available on our website.

By registering to use any of the Services you acknowledge that you have read and understood these Terms and have the authority to act on behalf of any person for whom you are using the relevant Service.

Your use of the Services is conditional upon you accepting these Terms. By using any of the Services you are deemed to have accepted these Terms. If you do not agree with any of these Terms, you should immediately cease using the Services. If these Terms are inconsistent with our legal obligations that cannot otherwise be lawfully excluded, these Terms will apply subject to those overriding obligations.

When we say ‘personal data’ or ‘personal information’ in these Terms we mean identifiable information or an opinion relating to an individual. Examples include your name, email, address, telephone number, bank account details, payment information, support queries, community comments including identifiers, professional or employment-related information, financial account information, commercial information, visual information, and internet activity information. If you can’t be identified (for example, when personal data has been aggregated and anonymised) then this notice doesn’t apply. Check out our terms of use for more information on how we treat your other data.

When we say “you” this includes any person or entity that has registered with us to use any of the Services or a visitor to any of our websites or other Services.

Who are ‘we’?

When we refer to ‘we’ (or ‘our’ or ‘us’), that means Vault Group Pty Limited and all its subsidiaries and related bodies corporate. Our headquarters are in Australia but we also operate in New Zealand and certain other countries. Address details for all VaultRE offices are available on our Contact us page.

We provide an online sales, marketing and management service designed especially for real estate agencies and agents. At the core of our service is a CRM known as VaultRE. If you want to find out more about what we do, see the VaultRE Website

Our principles of data protection

Our approach to data protection is built around four key principles. They’re at the heart of everything we do relating to personal data.

● Transparency: We take a human approach to how we process personal data by being open, honest and transparent.

● Enablement: We enable connections and efficient use of personal data to empower productivity and growth.

● Security: We champion industry leading approaches to securing the personal data entrusted to us.

● Stewardship: We accept the responsibility that comes with processing personal data.

What personal data do we collect?

We may collect the following types of personal data or information: * name; * mailing or street address; * email address; * telephone number and other contact details; * age or date of birth; * credit card information; * your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information; * details of the Services we have provided to you or that you have enquired about, including any additional information necessary to deliver those Services and respond to your enquiries; * any additional information relating to you that you provide to us directly through our website or indirectly through your use of our website or online presence or through other websites or accounts from which you permit us to collect information; * information you provide to us through customer surveys; or * any other personal information that may be required in order to facilitate your dealings with us.

We may collect these types of personal information either directly from you, or from third parties.

How we collect your data

When you visit our websites or use our Services, we collect a range of personal data about our current and prospective customers, end-users, contractors, employees, suppliers, agents, service providers, other business associates and the people who run the businesses we deal with. The ways we collect it can be broadly categorised into the following:

Information you provide to us directly:
When you visit or use some parts of our websites and/or Services we might ask you to provide personal data to us. For example, we ask for your contact information when you sign up for a demo or trial, respond to a job application or an email offer, participate in community forums, join us on social media, take part in training and events, contact us with questions or request support.
If a third party integration with Office365 or Google Suite is in place, this may also extend to calendar and/or email content depending on what level of integrations has been selected by you.
If you purchase Services, you may need to provide us with payment and billing information, such as your credit card details and billing address. In order to use certain parts of the Services, you also provide us with information about individuals, such as their names and email addresses. We use and process this information to provide the Services in accordance with your instructions.
If you don’t want to provide us with personal data, you don’t have to, but it might mean you can’t use some parts of our websites or Services.

Information we collect automatically:
We collect some information about you automatically when you visit our websites or use our Services, like your IP address and device type. We also collect information when you navigate through our websites and Services, including what pages you looked at and what links you clicked on. This information is useful for us as it helps us get a better understanding of how you’re using our websites and Services so that we can continue to provide the best experience possible (e.g., by personalising the content you see).
Some of this information is collected using cookies and similar tracking technologies. This information will be considered personal information where we can link this information to your account or to an identifiable individual. If you want to find out more about the types of cookies we use, why, and how you can control them, take a look at our cookie notice.

Information we get from third parties:
The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials or trusted third parties like our marketing and research partners. We use this information to supplement the personal data we already hold about you, in order to better inform, personalise and improve our Services, and to validate the personal data you provide.

You are not obliged to provide your personal information to us, but if you choose not to do so, then we may not be able to provide some or all our Services to you. You may however use a pseudonym during some interactions and where it is not necessary for us to identify you. For clarification on circumstances where you must identify yourself, please contact our Privacy Officer at privacy@vaultre.com.au. You may use a pseudonym or not identify yourself when making such a request.

Sensitive information (e.g. information about your race, ethnicity, health or criminal record) is subject to additional legal protections. We will only collect your sensitive information with your consent or when permitted under Australian law.

We use a third-party intermediary to manage credit card processing. This intermediary is not permitted to store, retain or use your billing information for any purpose except for processing credit card payments on our behalf.

We will not adopt a government related identifier as your identifier unless we are required or authorised by law or it is reasonably necessary to verify your identity for the purposes of our activities or functions or necessary to fulfil our obligations to an agency or State or Territory authority.

We will take such steps (if any) as are reasonable in the circumstances to ensure that your personal information we collect, use or disclose is accurate, up-to-date, complete and relevant. Providing us with information about others

If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent or otherwise have a legal basis to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read these Terms.

If you’re someone who doesn’t have a relationship with us, and a VaultRE subscriber has entered your personal data into our websites or Services, you’ll need to contact that subscriber for any questions you have about your personal data (including where you want to access, correct, amend, or ask that the Subscriber delete, your personal data).

Why do we collect, use and disclose your personal data ?

We hold, use and disclose your personal data for various purposes relating to our business, which include the following:

To enable you to use our websites and Services. We process your Personal Data to perform our contract with you for the use of our websites and Services and to fulfill our obligations under the applicable terms of use; if we have not entered into a contract with you, we base the processing of your personal data on our legitimate interest to operate and administer our Services and to provide you with content you access and request (e.g., to download content from our websites)

Managing user registrations: If you have registered for an account with us, we process your personal data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;

To communicate with you. This may include:

○ providing you with information you’ve requested from us (like training or education materials) or information we are required

○ To send to you operational communications, like changes to our websites and services, security updates, or assistance with using our websites and services

○ marketing communications (about VaultRE or another product or service we think you might be interested in) in accordance with your marketing preferences

○ asking you for feedback or to take part in any research we are conducting (which we may engage a third party to assist with).

To support you: This may include assisting with the resolution of technical support issues or other issues relating to the websites or Services, whether by email, in-app support or otherwise.

To bill and collect money owed to us by you. This includes sending you emails, invoices, receipts, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and those third parties collect billing information to track your orders and credit card payments.

To enhance our websites and Services and develop new ones: For example, by tracking and monitoring your use of websites and Services and the personal information of Contacts so we can keep improving, or by carrying out technical analysis of our websites and Services so that we can optimise your user experience and provide you with more efficient tools.

To protect: So that we can detect and prevent any fraudulent or malicious activity, and make sure that everyone is using our websites and Services fairly and in accordance with our terms of use.

To market to you: In addition to sending you marketing communications, we may also use your personal data to display targeted advertising to you online – through our own websites and Services or through third party websites and their platforms.

To analyse, aggregate and report: We may use the personal data we collect about you, Contacts and other users of our websites and Services (whether obtained directly or from third parties) to produce aggregated and anonymised analytics and reports, which we may share publicly or with third parties

Complying with legal requirements: We may use personal data for the purpose of complying with legal requirements, and facilitating the safety and security of our Services (including authenticating users, facilitating secure payments, enforcing our terms and policies, responding to a legal request or claim, protecting against fraud and abuse, and conducting audits

To improve our Services: We may use information like your Contacts’ details and your engagement with them, so we can make more informed predictions, decisions, and products for our customers.For example, we may use data from customer accounts to recommend better products or enable prediction tools to identify persons likely to purchase a property. We will act as a data controller to process data for our data analytics projects in reliance on our legitimate business interests of improving and enhancing our products and Services for our customers. We take the privacy of personal data seriously, and will continue to implement appropriate safeguards to protect personal data from misuse.
If you prefer not to share this data, you can contact us at any time by email us at privacy@vaultre.com.au

For our data analytics projects: For our data analytics projects. Our data analytics projects use data from customer accounts, including your personal data, to provide and improve the Services. We use information, like your email engagement history, provided to us by customers, so we can make more informed predictions, decisions, and products for our customers. If you’d rather not to share this data, you can opt out of data analytics projects at any time by emailing us privacy@vaultre.com.au.

How we can share your data

There will be times when we need to share your personal data with third parties. We will only disclose your personal data to:

● other companies in the VaultRE Group and their employees for the purposes set out in these Terms, (e.g. customer relationship management; software and service compatibility and improvements; and to provide you with any information, applications, products or services that you have requested);

● third party service providers and partners who assist and enable us to use the personal data to, for example, support delivery of or provide functionality on the website or services, or to market or promote our Services to you;

● partners, including system implementers, resellers, value-added resellers, independent software vendors and developers that may help us to provide you with the applications, services and information you have requested or which we believe is of interest to you;

● third parties used to facilitate payment transactions, for example clearing houses, clearing systems, financial institutions and transaction beneficiaries;

● third parties where you have a relationship with that third party and you have consented to us sending information (for example social media sites or other third party application providers);

● third parties for marketing purposes (e.g. our partners and other third parties with whom we work and whose products or services we think will interest you in the operation of your business activities. For example, financial services organisations (such as banks, insurers, finance providers), payment solutions providers, software and services providers that provide business solutions);

● credit reference and fraud prevention agencies;

● Government bodies, regulators and any other third party necessary to meet our legal and regulatory obligations;

● law enforcement agencies so that they may detect or prevent crime or prosecute offenders;

● regulators, law enforcement bodies, government agencies, courts or other third parties where we think it’s necessary to comply with applicable laws or regulations, or to exercise, establish or defend our legal rights. Where possible and appropriate, we will notify you of this type of disclosure

● an actual or potential buyer (and its agents and advisers) in connection with an actual or proposed purchase, merger or acquisition of any part of our business; and

● other people where we have your consent.

Where you permit or enable any of our applications or Services to integrate with another application, product or service (or use a feature of our Services that requires such integration), we will disclose your personal and financial information to the provider of the integrated service and collect your personal and financial information from the software provider (where relevant).

Security

The Services rely on cloud-based web servers hosted by our third-party service provider. Our third-party hosts may host your data in servers located in Australia and the USA or elsewhere. Servers on which we store personal information are located in Australia and the USA (and servers on which our Partners or clients store information may be located outside of Australia, including USA and Canada).

We also use other intermediaries, like email notification providers, payment processors and technical support services that may be located in Australia or overseas, and when you or we use their platform in connection with your account on our Services, your payment information may transit to wherever they or their facilities are situated. Please be aware that the information you provide to us may be processed outside of your home jurisdiction, and our third-party service providers, including hosts and payment processors, may as a result be subject to the laws of other countries, which may not be as protective as the Privacy Act and the Privacy Laws in Australia.

We maintain reasonable administrative, technical and physical safeguards to protect the security, confidentiality and integrity of your data. We have multiple security measures in place to protect against the loss, misuse, or alteration of information under our control. These include encryption of data in transit, regular software security updates, periodic risk assessments, and remediation of identified security vulnerabilities in a timely manner.

However, please be aware that no data transmissions over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit or otherwise provide to us and you do so at your own risk.

If you create an account, you will be asked to select passwords for yourself to access the Services, and this password will be used to allow you to use the Services. You are responsible for maintaining the strict confidentiality of your account password, and for any activity that occurs under your account credentials, whether or not authorised by you..

Using our websites and cookies

We may collect personal information about you when you use and access our website.

While we do not use browsing information to identify you personally, we may record certain information about your use of our website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your computer.

We may also use 'cookies' or other similar tracking technologies on our website that help us track your website usage and remember your preferences. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but our websites may not work as intended for you if you do so.

We may also use cookies to enable us to collect data that may include personal information. For example, where a cookie is linked to your account, it will be considered personal information under the Privacy Act.

We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in these Terms.Our website and services may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from these Terms, so we encourage individuals to read them before using those websites.

Retention

How long we keep your personal data depends on what it is and whether we have an ongoing business need to retain it (for example, to provide you with Services or to comply with any laws). Our retention periods will vary depending on the type of data involved, but, generally, we’ll refer to these criteria in order to set the retention period:

● Whether we have a legal or contractual obligation.

● Whether we need the data to provide our Services.

● Whether our customers have the ability to access and delete the data within their accounts.

● Whether our customers would reasonably expect that we would retain the data until they remove it or until their accounts are closed.

When we no longer have an ongoing business need to retain we’ll make sure your data is deleted or anonymised or, if this is not possible (for example, because it’s been stored in backups), then we’ll securely store your data and isolate it from any further access until deletion / anonymisation is possible.

Your rights

It’s your personal data and you have certain rights relating to it. When it comes to marketing communications, you can ask us not to send you these at any time – just follow the unsubscribe instructions contained in the marketing communication, or send your request to privacy@vaultre.com.au. Requests to opt-out of transfers to our third-party vendors may also be submitted but limitations on data sharing may make it difficult or impossible to provide the Services in this manner.

You also have rights to:

● know what personal data we hold about you, and to make sure it’s correct and up to date

● request a copy of your personal data, or ask us to restrict processing your personal data or delete it

● object to our continued processing of your personal data

You can exercise these rights at any time by sending an email to privacy@vaultre.com.au.

We process and store information on your behalf. If you are an individual interacting with one of our customers on the Services and would no longer like to be contacted by that customer, please contact that customer directly. If you are our customer and would like to opt-out of getting marketing communications from us please contact us at ## or follow the unsubscribe instructions included in marketing emails.

If you are concerned about how we collect, hold, store, use or disclose your personal information, please contact us using the contact information below. We will use reasonable endeavours to address your enquiry or complaint and will endeavour to respond to you within 30 days of receipt of your initial enquiry or complaint. To the extent that we feel your complaint is complex or that we require further time to provide a substantive response, we will send you a notice to that effect. You must provide all reasonable assistance to us to allow us to address your enquiry or complaint, including providing us with all appropriate and relevant information and feedback on request.

If you feel your enquiry or complaint has not been adequately addressed by us, you may contact the regulator in your jurisdiction. However, we highly recommend that you notify us beforehand as to why you feel we have not adequately addressed your enquiry or complaint and to give us an opportunity to further assist you in that respect.

If you would like any further information about your rights to privacy, please contact or visit the regulator in your jurisdiction.


The regulator in Australia is the:

Office of the Australian Information Commissioner

GPO Box 5218

Sydney NSW 2001

Tel: 1300 363 992

Web: www.oaic.gov.au


The regulator in New Zealand is:

Office of the New Zealand Privacy Commissioner

PO Box 10 094, The Terrace,

Wellington 6143

Tel: 04 474 7590

Web: www.privacy.org.nz

How to contact us

We’re always keen to hear from you. If you’re curious about what personal data we hold about you or you have a question or feedback for us on this notice, our websites or Services, please get in touch.

As a technology company, we prefer to communicate with you by email – this ensures that you’re put in contact with the right person, in the right location, and in accordance with any regulatory time frames.

Our email is privacy@vaultre.com.au.

While email is best, you can also contact us as follows:

Tel: 1300 788 689

Mail:

ClientVault
P O Box 1015
WEST PERTH WA 6872