Privacy Policy

Last updated: 21st May 2018

REQ2 Pty Ltd trading as Reprecinct (ABN: 93 622 046 520) (we, our, us) operates a platform through which it provides a crowd-sourced commercial real estate property information portal and benchmarking service in Australia (Platform).

To register with us and use our Platform a user (you, your) must provide Information to us about the user. We will also collect Information about you when you access and use the features of our Platform.

This Privacy Policy explains how we collect, use and maintain and the circumstances in which we may disclose Information about you that has been collected by us.

For the purposes of this Privacy Policy, a reference to Information means information that comes within the definition of personal information in the Privacy Act 1988 (Cth) (Act) (Information).

In general terms, under the Act, Information is any information that can be used to personally identify you. This may include, but is not limited to, your name and contact details including phone numbers and email addresses. It will also include any records we keep about your interaction with the Platform or that you provide to us to the extent that you can be identified from that interaction or Information.

By registering as a user of the Platform, you consent to the collection and use of Information, we collect from you, as described in this Privacy Policy.

When do we collect Information?

We collect Information when you provide it to us during the registration process and at other times as you use the Platform or contact us.

We also collect Information from other users of the Platform when they interact with you.

We may use cookies and other technologies to provide us with Information on the way in which you navigate and use the Platform.

If you choose not to provide Information at the time you are seeking to register as a user, you will not be able to complete the registration process to access the Platform.

We may connect with social networking services (such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram) to facilitate the provision of the Platform to you and to communicate with you and other users of the platform. If you communicate with us using one or more of these services we may collect your Information in doing so.

We will assume that Information provided to us by social networking services and/or third-party service providers is being provided with your consent and in accordance with the privacy policy of those services or providers.

We will handle Information provided to us by social networking services and/or third-party service providers in accordance with this Privacy Policy. We will not knowingly use Information where we know that it is not being provided to us with your consent.

If you are concerned about the use that is being made of your Information by a social networking service and/or third-party service provider to whom you have provided Information, you should review their Privacy Policy and/or contact them for more information.

How we use your Information

We will use Information you provide to us, to:

provide you the services offered on the Platform;
facilitate, process and collect data regarding your activity on the Platform;
verify your identity and the accuracy of your Information when you register;
respond to support requests;
allow you to contact other users and allow other users to contact you;
facilitate the 'search' function on the Platform;
help facilitate the resolution of any disputes;
inform you about operation of the Platform, including website disruptions or security updates;
provide you with information that you request from us;
provide you with marketing information about products and services (whether provided by us or third parties) which we think may interest you;
carry out technical analysis to determine how to improve the Platform;
monitor activity on the Platform, including to identify potential fraudulent activity and to ensure compliance with the user terms and conditions that apply to the Platform;
manage our legal and operational affairs; and/or
provide general administrative and performance functions and activities.

Information Sharing

When using the Platform, you will have the ability to provide us with Information about another person. When you provide the Information about another person you warrant the accuracy of that Information and that you have the approval of another person to do so.

When we may disclose your Information

We may disclose Information to third parties:

in accordance with this Privacy Policy;
where it is reasonably necessary in order to enable us to make the Platform available to you;
to support your use of the Platform;
when we are required to do so by law; or
when you give us permission to do so.

We may disclose Information to third parties where reasonably necessary to enable them to perform the services they are providing to us.

Third party service providers have their own privacy policies in respect to the Information we are required to provide to them. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your Information will be handled by them. A list of our third party service providers to which we may provide your Information is available on request.

We may aggregate and/or de-identify Information we collect from you. Our use and disclosure of aggregated and/or de-identified Information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

How do we store and process your Information?

By registering as a user of and accessing the Platform, you agree:

to and authorise us giving your Information, in accordance with this Privacy Policy, to a third party who is not in Australia or a third party who may transfer and store outside Australia your Information (Overseas Recipient);
that, while we will take reasonable steps to ensure that an Overseas Recipient does not breach the APPs, Overseas Recipients are not bound by the APPs and subclause 8.1 of the APPs does not apply to the disclosure of your Information to an Overseas Recipient*; and
that, if an Overseas Recipient handles your Information in breach of the APPs, you will not be able to seek redress under the Act.

*Subclause 8.1 of the APPs requires us to ensure that Overseas Recipients comply with the APPs unless, in accordance with subclause 8.2, you agree otherwise. For more information, please check the Office of the Australian Information Commissioner (OAIC) website.

How do we protect your Information?

We will take reasonable steps to protect your Information from loss, misuse, unauthorised disclosure or destruction, including by means of firewalls, password access, and secure servers.

To enable us to meet our obligations under the Act and to ensure the operation of the Platform, we may need to allow our authorised staff and contractors to access your Information. The staff and contractors are required by contract and policies to maintain the confidentiality of your Information.

When you register as a user of the Platform you must create a password. It is your responsibility to maintain the confidentiality of your user name and password. You are responsible for all activities which are carried out on your account.

If you suspect any misuse or loss of, or unauthorised access to, your Information, please notify us immediately.

We do not knowingly collect Information from children.

How can you access your Information?

You can access some of the Information that we collect about you by logging into your account on the Platform. You also have the right to make a request to access other Information we hold about you and to request corrections of any errors in that Information. To make an access or correction request, email us at admin@reprecinct.com.au

What happens if the ownership of our business changes?

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, re-organisation, dissolution or similar event, Information may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of Reccefy (or its assets) will continue to have the right to use your Information and other Information in accordance with the terms of this Privacy Policy.

Will this Privacy Policy be updated?

We may need to change this Privacy Policy from time to time to make sure it stays up to date with the latest legal requirements and any changes to our management of Information. When we do amend the Privacy Policy, the changes will be effective immediately.

We will take reasonable steps to notify you about any changes made to this Privacy Policy. We also suggest that you revisit this Privacy Policy from time to time to see whether changes have been made.

If you continue to use the Platform after the changes are made, then you will be agreeing to the changes.

How can you contact us?

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

We will treat your queries and complaints confidentially.

Our representative will contact you within a reasonable time after receipt of your query or complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your query or complaint is resolved in a timely and appropriate manner.

You may contact us by email at admin@reprecinct.com.au

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 OAIC by visiting their site http://www.oaic.gov.au/

Published: 21st May 2018