Privacy Policy

You have come through to this page from a website or app which is published by Real Pass Pty Ltd (ABN 36644777855) of 4/1 Locke St, New Farm, QLD 4005.
In this Privacy Policy, Real Pass , us , we or our means Real Pass and its related bodies corporate, partnerships and joint venture entities. Real Pass is the operator of the network (which includes our websites and apps) and the data controller for the personal information collected and processed via the network.
This Privacy Policy sets out:

• what is considered personal information;
• what personal information we collect and hold;
• how we collect, hold, use or disclose personal information;
• the purposes for which we collect personal information;
• what happens if we are not able to collect personal information;
• how to seek access to and correct your personal information;
• whether we disclose personal information outside Australia; and
• how to contact us.

We are bound by the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (Privacy Act) (subject to exemptions that apply to us under that Act) and any other applicable data or information protection laws, including the EU General Data Protection Regulation (GDPR) and New Zealand's Privacy Act (the Privacy Act, GDPR, New Zealand's Privacy Act and any other applicable data or information protection laws are together the Privacy Laws). However, due to the nature of some of our business activities, from time to time, we will handle personal information relying on the media exemption in the Privacy Act where appropriate. Where we do so, we will ensure that we comply with the Australian Press Council Privacy Standards. We may also rely on related bodies corporate, employee records and other exemptions in the Privacy Act. If you require more information on the collection and use of personal information in the course of journalism, please visit the Australian Press Council Privacy Standards at www.presscouncil.org.au/privacy-principles.
Your privacy matters to us, so whether you are new to Real Pass or are a long time user, please take the time to get to know our practices.

What is personal information

When used in this Privacy Policy, the term "personal information" has the meaning given to it in the Privacy Act or any other Privacy Law. In general terms, it is any information that can be used to personally identify you. This may include (but is not limited to) your name, age, gender, postcode and contact details (including phone numbers and email addresses) and possibly financial information, including your credit card, direct debit or PayPal account information. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What personal information do we collect and hold

We may collect the following types of personal information;

• name;
• business or residential address;
• email address;
• telephone number;
• age or birth date;
• profession, occupation or job title;
• gender;
• financial and transaction information (including information about your assets, financial situation and claims history);
• information about your interactions with us;
• information about the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services or to respond to your enquiries;
• information relating to you that you provide to us directly through our network or indirectly through use of our network or online presence through our representatives or otherwise;
• information you provide to us through our service centre, customer surveys or visits by our representatives from time to time; and/or
• other personal information we may require from time to time to manage your business relationship with us.

Cookies

When you visit our websites or use our mobile apps, we or our business partners may also collect information about your use of those websites or apps (usage data) through the use of cookies and other tracking software. This usage data enables us to provide you with an improved and more effective and personalised service, keep track of the products and services you use, analyse trends, measure transaction and search patterns, administer our website, diagnose problems, test and improve the quality of our products and services, gather broad demographic information and enable us to conduct targeted online advertising.
You can manage the use of cookies on your computer or mobile device. If you do not wish to receive cookies you can set your browser so that your computer or device does not accept them. You can also clear stored cookies from that browser or device at any time. Please note however that blocking cookies may affect your browsing experience and result in our services not operating as efficiently or effectively as they could.
The usage data we collect and use in cookies is not of itself personally identifiable information but if it is linked to personal information about an individual, it may become personally identifiable usage data. In those circumstances we will treat that usage data as personal information and only use it in accordance with our Privacy Policy, the Privacy Act and any other applicable data protection legislation.

How we collect personal information

We collect your personal information directly from you unless it is unreasonable or impractical to do so. We do this in ways including:

• when you engage with us to use or acquire our products and services;
• when you contact or request information from us including via our websites, apps, online forms and surveys and emails;
• through your conversations with our staff and our representatives;
• when you complete an application or make a listing enquiry; and/or
• when you write to us including via hard copy forms.

We may also collect personal information from third parties including:

• our service providers;
• third party companies such as credit reporting agencies, law enforcement agencies and other government entities;
• advertisers;
• recruitment agencies;
• contractors and business partners; and/or
• through someone else who has provided us with your information (e.g. a real estate agent).

Why do we collect, hold, use and disclose personal information

We collect, hold, use and disclose your personal information for the following purposes:

• to provide products and services to you and deliver the best possible quality of customer experience;
• to provide you with news, information or advice about our existing and new products and services;
• to communicate with you, including but not limited to, by email, mail, SMS or telephone;
• to manage and enhance our products and services;
• to personalise and customise your experience;
• to provide you with access to protected areas of our websites;
• to verify your identity;
• to provide as part of statistics, insights or business data to third parties or to use internally in our business;
• to conduct business processing functions for operation of our websites or our business;
• to manage our sales or other business relationships with you;
• for our administrative, promotional, planning, product/service development, quality control and research purposes, or those of our contractors, external service providers or business partners;
• to provide your updated personal information to us, our contractors, external service providers or business partners;
• to recover any amounts you may owe to us;
• to investigate any complaints about or made by you, or if we have reason to suspect that you are in breach of any of our terms and conditions or that you are or have been otherwise engaged in any unlawful activity; and/or
• as otherwise required or permitted by any Privacy Law (including the Privacy Act).

Marketing

We may also use your personal information to send you marketing communications about our product and services and the products and services of our business partners that you may be interested in. We may do this through mail, phone, SMS, social media, email, app notifications and advertising through our apps, websites or third-party websites.
You can contact us at any time to opt-out from receiving direct marketing communications from us by contacting us directly, by following the unsubscribe instructions in the relevant communication or by updating your personal details on your account profile. We do not provide your personal information to other organisations for the purpose of direct marketing unless expressly authorised by you.
If you receive communications from us that you believe have been sent to you other than in accordance with this Privacy Policy, or in breach of any law, please contact us using the details provided below.
Your personal information will not be shared or disclosed other than as described in this Privacy Policy.

What happens if we can't collect your personal information

The provision of your personal information is voluntary and is neither required by a statutory nor a contractual obligation. The provision of your personal information may, however, be necessary to receive our services/products as requested by you. If you do not provide us with the personal information described in this Privacy Policy, some or all of the following may happen:

• we may not be able to provide you with the products or services you requested, either to the same standard, or at all (for example, if you do not register as a member of a website, you will not be able to access features or services that are reserved for members only);
• we may not be able to continue our sales or other business relationship with you;
• we may not be able to provide you with information about products and services that you may want, including information about discounts, sales or special promotions; or
• we may be unable to tailor the content of our network to your preferences and your experience of our network may not be as enjoyable or useful.

How we disclose your personal information

We may disclose your personal information to a number of third parties in the course of operating our business and for one or more of the above purposes or related purposes. These parties include:

• our employees, related bodies corporate, business partnerships and joint venture entities;
• our external service providers including without limitation web hosting providers, advertisers, IT systems administrators, mailing houses, newsagents, couriers, payment processors, photographic analysers, data entry service providers, electronic network administrators, debt collectors, and professional advisers such as accountants, solicitors, business advisors and consultants;
• our existing or potential agents and/or business partners;
• insurers, reinsurers, intermediaries and claims assessors;
• our sponsors, or promoters of any competition that we conduct or promote via our services;
• specific third parties authorised by you to receive information held by us;
• the police, any relevant government authority or enforcement body, or your Internet Service Provider or network administrator, for example, if we have reason to suspect that you have committed a breach of any of our terms and conditions, or have otherwise been engaged in any unlawful activity, and we reasonably believe that disclosure is necessary;
• as otherwise required or permitted by law (including the Privacy Act or other Privacy Laws).

Accessing and correcting your personal information

You may request access to any personal information we hold about you by contacting us using the contact information provided below. We will not charge for simply making a request and will not charge for making any corrections to your personal information. However, depending on the nature and scope of the personal information you have requested, we may charge you a reasonable fee to provide access to this information.
If you make an access request, we will ask you to verify your identity. There may be instances where, for legal reasons, we cannot grant you access to the personal information we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others, or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
If you believe that personal information we hold about you is incorrect, incomplete or inaccurate, then you may request us to amend it. We will consider if the information requires amendment. If we do not agree that there are grounds for amendment, then we will add a note to the personal information stating that you disagree with it.
Members of our websites will generally be able to access and update their membership details online. We request that you keep your information as current as possible so that we may continue to improve our service to you.

How you can complain about a breach of privacy

If you believe your privacy has been breached by us or have any questions or concerns about our Privacy Policy or privacy practices, please contact us using the contact information below and provide details of the incident so that we can investigate it.
We have a process for investigating and dealing with privacy breaches. Once the Privacy Officer receives a complaint, the Privacy Officer will commence an investigation with the relevant business unit from which the alleged breach stemmed. The investigator will endeavour to determine the nature of the breach and how it occurred. We may contact you during the process to seek further clarification if necessary. If a breach is found, the Privacy Officer will work with senior management so that the process can be rectified to prevent any further breaches from taking place. We will also contact you to inform you of the outcome of the investigation. We will endeavour to resolve all investigations within a reasonable time.
We will treat your requests or complaints confidentially. Our representatives may contact you after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your complaint is resolved in a timely and appropriate manner.
Please contact our Director at:
Real Pass Pty Ltd, 4/1 Locke St New Farm, QLD, 4005.
Email: sam@real-pass.com

Disclosure of personal information outside Australia

We may disclose your personal information to entities located overseas for some or all of the purposes listed above. This may include disclosure to the following entities:

• our related bodies corporate, partnerships and joint venture entities;
• our data hosting and Cloud-based IT service providers; and
• other external service providers including those located in the U.K, U.S, Philippines and India.

Retention

Your personal information will only be retained for as long as it is reasonably necessary to fulfil the purposes for which it was collected or as required for a legal, accounting or reporting purpose.

Security

We will take all reasonable steps to protect the personal information that we hold from misuse, loss or unauthorised access, including by means of firewalls, password access, secure servers and encryption of credit card transactions. If you suspect any misuse or loss of, or unauthorised access to, your personal information, please let us know immediately.
If we become aware of a notifiable privacy breach, we will notify you if and to the extent required by the applicable Privacy Law.

Links

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy practices of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

Changes to our Privacy Policy

We may, from time to time, review and update this Privacy Policy, including taking account of new or amended laws, new technology and/or changes to our operations. All personal information held by us will be governed by the most recent updated Privacy Policy. Any updated versions of this Privacy Policy will be posted on our website. This Privacy Policy was last updated in February 2023