Privacy Policy

Purpose of the privacy policy

This policy outlines the obligation to respect and protect the privacy of personal information obtained across the business processes and activities of Millbray Management Platform Pty Ltd (“Millbray“, “us” or “we“) and its subsidiaries and associated entities. Millbray is committed to protecting all personal information that it handles or processes and is bound by the Australian Privacy Principles under the Privacy Act 1988 (Cth) and other privacy laws which govern the way in which organisations hold, collect, use and disclose personal information.

Application of this policy

This policy applies to all personal information provided to Millbray. This includes personal information of existing and prospective customers, existing and prospective suppliers and any other stakeholders for whom Millbray obtains personal information. It also applies to prospective employees who may provide Ingenia with personal information in relation to potential employment.

The personal information that Millbray may collect

Millbray will only collect personal information which is reasonably necessary to provide our services and to operate and manage business activities across Millbray, its subsidiaries and communities it manages.

The personal information that is collected, held and used by Millbray will depend on the nature of your relationship with us and may include (but is not limited to):

• Personal identification and contact details (including name, postal address, email address and telephone number)

• Financial information (including bank account details, pension and payment and credit card details)

• Tax file and Medicare numbers

• Next of kin and power of attorney details (from residents)

• Criminal History (from job applicants)

If you are applying for employment with Millbray, we may also collect your resume, qualifications, skills, education history, residency status, previous employment history and criminal history information.

Failure to supply required personal information or the provision of incorrect or incomplete information may result in a range of consequences including for example being unable to provide you with our services.

How your information is collected

We may collect personal information about you as required during the course of your interactions with us. For example:

• when using our website;

• completing application forms;

• while receiving services from us;

• during interviews and onboarding, if you are applying to work with us or becoming a supplier of goods and services; and

• if you contact us via telephone or email.

Personal information will where possible be collected directly from you however there may be circumstance where information needs to be obtained from another person or entity. If you provide Millbray with personal information about a third party, you represent, and we collect it on the basis that, you have that person’s consent for us to collect and handle their personal information in accordance with this privacy policy.

Additional privacy measures are in place to protect sensitive information (such as health information, racial or ethnic origin, religious beliefs, sexual preferences, and criminal history). Where we do collect sensitive information, we will only do so with your consent.

The way Millbray uses your personal data

Personal information will generally only be used for the purpose for which we collected it, or for related purposes that we consider to be a reasonable use of the information.

Generally, your personal information will be used for purposes that include:

• providing requested information and responding to your enquiries;

• providing products or services, and to manage our relationship with you;

• handling payments for services relating to you;

• verifying your identity;

• managing any complaints;

• administration with our suppliers in relation to products and services;

• marketing research and marketing purposes; and

• if you are a job applicant, to assess your suitability to work with us.

Storing your personal information and keeping it safe and accurate

Millbray has taken steps to help secure and protect your personal information from unauthorised access, use, disclosure, alteration, or destruction. Millbray keeps personal information in physical and electronic records, at our premises or in the cloud. We will take reasonable steps to:

1. make sure that the personal information we collect, use or disclose is accurate, complete and up to date;

2. protect your personal information from misuse, loss, unauthorised access, modification or disclosure both physically and through computer security methods; and

3. destroy or permanently de-identify personal information if it is no longer needed for its purpose of collection.

Access to and correction of your personal information

You are entitled to access any personal information relating to you which is held by Millbray, except in some exceptional circumstances provided by law (including the Privacy Act). You are also entitled to correct such personal information if the information is inaccurate, out of date, incomplete, irrelevant or misleading.

If you would like access to, or correct any records of, personal information we have about you, you are able to access and update that information (subject to the above) by contacting us directly at the email address listed below. We will endeavour to respond to the request within a reasonable period and provide access to your personal information in the manner requested if it is reasonable and practicable to do so.

Links to Other Sites

We may offer links to sites that are not operated by Millbray. If you visit one of these sites which are not operated by Millbray, you should review their privacy and other policies. We are not responsible for the policies and practices of other companies.

Contact us

To contact Millbray in relation to your personal information please contact us at privacy@millbray.com.au.