We may collect personal information that is reasonably necessary for one or more of our functions or activities. Depending on the nature of your interaction with River Place, this may include your name, residential or postal address, email address, telephone number and other contact details; enquiry and correspondence details; resident, applicant, occupier, owner, emergency contact or visitor-related information; identification or verification information; payment, billing and account information; resident portal account details; device, browser and IP address information; and records relating to requests, complaints, maintenance, services, access, facilities, safety, building operations or community matters. We may also collect limited sensitive information where it is reasonably necessary and permitted by law, such as information relevant to accessibility, health or emergency contact needs, but where consent is required we will seek it, and we will not collect personal information that is not reasonably necessary for our legitimate business functions and activities.

We generally collect personal information directly from you when you complete online forms, submit an application, use the resident portal, contact reception or management, send us an email, call us, make a payment, request assistance, subscribe to updates, respond to surveys, or otherwise provide information to us. We may also collect information automatically through our website, resident portal and related systems by using cookies, server logs, analytics technologies, authentication records, access logs, tracking pixels and similar tools. In some circumstances, we may collect personal information from third parties where lawful and fair to do so, including from real estate agencies, referees, owners, tenants, residents, contractors, payment providers, IT and portal vendors, service providers, regulators, government bodies, or other persons connected with the services we provide. If practicable, we will collect personal information directly from you, but there are circumstances in which collection from third parties is permitted.

Where we collect personal information, River Place will take reasonable steps at or before the time of collection, or as soon as practicable afterwards, to notify you or ensure you are aware of matters required by law, including our identity and contact details, the fact and circumstances of collection, the purposes of collection, the consequences if the information is not collected, usual disclosures of the information, likely overseas disclosures where relevant, and the availability of this Privacy Policy. For that reason, this Privacy Policy should be read together with any privacy notice, collection statement or explanatory wording provided on our website, resident portal, forms, applications, email sign-up pages or other collection points. This policy is not intended to replace those point-of-collection notices.
 

Where lawful and practicable, River Place may allow you to deal with us anonymously or by pseudonym, for example when making a general enquiry that does not require us to verify your identity. However, this will not be possible in many situations relevant to our operations, including applications, resident portal registration, identity verification, account administration, payments, access control, safety matters, complaints investigation, legal compliance, or where it is otherwise impracticable for us to deal with an unidentified person.
 

River Place collects, holds, uses and discloses personal information for purposes connected with our business functions and activities. These purposes may include responding to enquiries; assessing and processing applications; setting up and administering resident portal access; verifying identity; providing resident, building, property management, operational, community and administrative services; managing access, security, maintenance, accounts, payments, requests, complaints and communications; facilitating amenities or service features; improving our website, portal and systems; maintaining records and audit trails; detecting and preventing fraud, misuse and security incidents; protecting our legal rights and legitimate interests; resolving disputes; and complying with legal, regulatory and contractual obligations. We will not use or disclose personal information for purposes that are unrelated to the purpose of collection unless you consent, the use or disclosure is reasonably expected and permitted by law, or another lawful basis applies.
 

River Place may use personal information to communicate with you about operational matters and, where permitted, about services, amenities, offers, events, promotions, building updates, newsletters or other communications that may be of interest to you. Under Australian privacy law, organisations must not use or disclose personal information for direct marketing unless an exception applies, and electronic marketing messages are also regulated by the Spam Act. Where we send commercial electronic messages, we will do so only in accordance with applicable law, including by identifying River Place as the sender, providing contact details, and including a functional unsubscribe facility. We will not rely on operational or service labels to disguise marketing messages. If you opt out of marketing, we may still send non-marketing communications that are necessary for portal access, payments, building operations, safety, legal compliance, service delivery or account administration.
 

Our website, portal and electronic communications may use cookies, analytics tools, tracking pixels and similar technologies to operate the site, maintain security, remember preferences, authenticate users, analyse traffic and usage, improve services, measure the performance of communications and campaigns, and tailor content or communications. Depending on how those technologies are configured, they may involve the collection, use or disclosure of personal information to third-party technology or marketing providers. The OAIC has issued specific guidance that third-party tracking pixels can raise privacy obligations, and organisations should assess their use carefully. River Place may therefore provide additional notice, obtain consent where required or appropriate, and offer cookie, browser or unsubscribe choices where available. You can usually manage cookies through your browser settings, but disabling certain technologies may affect the functionality of some features of the website or resident portal.

We may disclose personal information to third parties who assist us to carry out our business functions and activities. Depending on the circumstances, this may include our website and cloud hosting providers, resident portal providers, IT support providers, payment processors, communications providers, marketing platforms, analytics providers, contractors, insurers, auditors, advisers, maintenance or service providers, property or facilities management providers, and other third parties reasonably necessary for us to deliver services or operate River Place. We may also disclose personal information where required or authorised by law, to government agencies, regulators, courts, tribunals, law enforcement bodies, or in connection with an actual or proposed corporate transaction such as a restructure, sale, merger or acquisition. River Place does not sell personal information to third parties.
 

Some of our service providers may store or process personal information outside Australia. If River Place discloses personal information to an overseas recipient, we will take reasonable steps in the circumstances to ensure that the recipient does not breach the Australian Privacy Principles in relation to that information, unless an exception applies. Under APP 8, an Australian entity that discloses personal information overseas may in some circumstances remain accountable for acts or practices of the overseas recipient. If it is practicable to do so, our Privacy Policy should identify the countries in which likely overseas recipients are located. For that reason, before publishing this policy you should insert the actual countries relevant to your vendors, if known.

River Place takes reasonable steps to ensure that the personal information we collect, use and disclose is accurate, up to date, complete and, where relevant, not misleading. We may ask you to update your details from time to time and we encourage you to contact us if your information changes. We may also verify and update information using internal checks, account records, transaction records, identity processes, and information provided by you or authorised third parties where appropriate. Maintaining information quality is important both when information is collected and when it is later used or disclosed.
 

We hold personal information in a combination of electronic systems, cloud-based services, resident portal systems, building administration tools, email and document management systems, backups, and, in some cases, paper files. River Place takes reasonable steps to protect the personal information it holds from misuse, interference and loss, and from unauthorised access, modification or disclosure. The measures we use may include role-based access controls, password protections, authentication controls, secure hosting arrangements, audit logs, encryption, restricted staff access, vendor due diligence, contractual controls, secure disposal practices, and incident response measures. However, no internet transmission, third-party platform or data storage system is completely secure, and no representation is made that security can be guaranteed in every circumstance.

River Place will retain personal information only for as long as reasonably necessary for the purposes for which it was collected, for related purposes permitted by law, or as required by law, regulation, contractual obligations, dispute resolution needs, security requirements, or legitimate record-keeping purposes. When personal information is no longer needed for a permitted purpose and we are not required to keep it, we will take reasonable steps to destroy it or de-identify it. If River Place receives unsolicited personal information that it did not request, we will assess whether we could lawfully have collected it. If we could not lawfully have collected it and it is lawful and reasonable to do so, we will destroy or de-identify it as soon as practicable.
 

If the Privacy Act applies to River Place, you may request access to the personal information we hold about you, and you may request correction of personal information that is inaccurate, out of date, incomplete, irrelevant or misleading. We will respond to access and correction requests in accordance with applicable law and may need to verify your identity before actioning a request. In some cases, access may be refused on grounds permitted by law, and if correction is made we may, where required and requested, take reasonable steps to notify other APP entities to which the information was previously disclosed. River Place does not promise an absolute standalone right to deletion in all circumstances, but if you ask us to delete or de-identify information we will consider the request and act where lawful and practicable.
 

If River Place experiences a data breach involving personal information, we will assess the incident in accordance with our legal obligations. The Notifiable Data Breaches scheme requires organisations covered by the Privacy Act to notify affected individuals and the OAIC where an eligible data breach is likely to result in serious harm. River Place may therefore use contact information and other relevant records to investigate, manage, mitigate and notify affected persons of privacy or security incidents where required or appropriate.
 

Our website, emails and resident portal may contain links to third-party websites, systems or services. Those third parties operate independently from River Place and may have their own privacy practices, terms and security standards. River Place is not responsible for the privacy or security practices of third-party sites or services that are not under our control, and you should review their privacy policies before providing them with personal information. This is particularly important where a third-party provider handles payments, bookings, messaging, support or portal functionality on our behalf.
 

River Place’s website and resident portal are primarily intended for adults and for persons dealing with residential, administrative or building-related matters. We do not knowingly collect personal information directly from children except where reasonably necessary in connection with residence, occupancy, emergency contact, access, community administration, safety, or related services, and where collection is permitted by law and ordinarily provided by a parent, guardian or authorised adult. If we become aware that information has been collected in a way that is not lawful or appropriate, we will take steps to address that issue, including by deleting or de-identifying the information where required.
 

If you have a complaint about how River Place has handled your personal information, you may contact us using the details below. Please provide enough detail to allow us to investigate your complaint properly. We will review the matter and respond within a reasonable period. Our Privacy Policy must explain how an individual may complain about a breach of the APPs and how the organisation will deal with such a complaint. If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner.
 

River Place may update this Privacy Policy from time to time to reflect changes in law, regulatory guidance, technology, vendors, service delivery, or business operations. The current version will be published on our website and should be read together with any collection notices or privacy statements presented to you when your personal information is collected. Continued use of our website, resident portal or services after an updated policy is published will not, by itself, override any rights you have under applicable privacy law, but it will indicate that the updated policy applies to future handling of personal information to the extent permitted by law.

If you have questions, concerns, or requests relating to this Privacy Policy or your personal information, please contact:

River Place Management
Email: hr@riverplace.com.au
Phone: (07) 3832 0399
Address: 82 Boundary Street, Brisbane City QLD 4000