Last Updated: 3 May 2018
dwell Student Living or also known as Centurion SA Investments Pty Ltd (ABN 94 939 412 759) and/or its related corporations (each, “dwell”, the “Company”, the “Group”,
“we”, “us” or “our”) collectively or singularly as the context requires, recognises the importance of protecting Personal Information.
dwell adopts a pragmatic approach in our business conduct.
dwell collects Personal Information only for what is required in business or in activities conducted by our organisation and will properly destroy the Personal Information once there is no business or legal purpose for retaining it. We do not collect Personal Information randomly or indiscriminately without purpose.
dwell does not disclose your Personal Information unless prior consent has been obtained and we have administrative, physical and Information Technology (IT) security measures to protect your Personal Information.
This does not affect any rights which dwell may have at law in connection with the collection, use or disclosure of your Personal Information.
1. Your Personal Information
1.1 “Personal Information” as defined in the Privacy Act means any information about an identified individual, or an individual that is reasonably identifiable whether: (a) the information or opinion is true or not; and (b) the information or opinion is recorded in a material form or not. Examples of such Personal Information which you may provide us include, but is not limited to (depending on the nature of your interaction with us):
2. Collection of Personal Information
2.1 Generally, dwell collects your Personal Information in the following ways:
2.2 If you provide Personal Information of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that you have obtained the consent of that third party for the collection, use and disclosure of their Personal Information for the purposes set out above.
3. How do we use Personal Information and to whom we disclose it?
3.1 dwell’s goal is to understand your needs and provide you with products and services that you require. To do this effectively, dwell needs to collect certain Personal Information.
3.2 In general, dwell may collect, use and disclose your Personal Information for the following purposes:
3.3 In addition, dwell may collect, use and disclose your Personal Information for the following purposes, depending on the nature of our relationship with you:
a. If you have a customer account with us, are a prospective customer or a customer:
b. If you use download or use any of our mobile applications (“apps”):
c. If you are a prospective tenant/resident or a tenant/resident:
d. If you are a vendor, a prospective vendor or a contractor:
e. If you submit a job application to us as a candidate for employment:
3.4 When you apply for or hold a co-brand product which is offered jointly by dwell and its co- brand partner, dwell may also collect, use and disclose your Personal Information with the co-brand partners for offering, marketing and promoting any products, services, offers or events which the co-brand partner thinks may be of interest to you.
3.5 In relation to particular products or services or during your interactions with dwell, we may also notify or have specifically notified you of other purposes for which dwell collects, uses or discloses your Personal Information. If so, we will collect, use and disclose your Personal Information for these additional purposes as well, unless we have specifically notified you otherwise.
3.6 Your Personal Information will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Information may, depending on the products or services concerned, be disclosed to the following third parties:
3.7 dwell requires that third party organisations which handle or obtain Personal Information, such as service providers to dwell, acknowledge the confidentiality and sensitivity of this personal information, undertake to respect any individual’s right to privacy and comply with the Privacy Act. dwell also requires that these organisations use this information only for limited purposes which have been agreed upon and follow dwell’s reasonable directions with respect to this information.
3.8 By submitting your Personal Information, you consent to the disclosure of your Personal Information in the manner and method listed above as applicable.
4. Direct Marketing
4.1 We may send you marketing material. You may choose to “opt-out” of receiving this material by emailing email@example.com. We will not charge you any additional cost or in any way disadvantage you for choosing to “opt-out” of receiving marketing material.
Keeping Your Personal Information Accurate and Up-To-Date
5.1 dwell endeavours to ensure that Personal Information stored by us is accurate and up-to-date. dwell also understands that Personal Information may change frequently, such as changes of address and other personal circumstances. As such, dwell encourages you to contact the DPO at firstname.lastname@example.org to update your Personal Information. Incomplete or outdated Personal Information may result in our inability to provide you with products and services you have requested.
Storing of Personal Information
8.1 We will safeguard the confidentiality of your Personal Information, whether you interact with us personally, by telephone or mail, over the Internet or through forms of other electronic media. We hold Personal Information in a combination of secure computer storage facilities and paper based files and other records and take steps to protect the Personal Information we hold from misuse, loss, unauthorised access, modification or disclosure. Where we no longer require any Personal Information that we hold, that Personal Information would be destroyed or have particulars or information which may identify individuals removed.
Your Personal Information will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.
All electronic storage and transmission of personal information is secured and encrypted with appropriate security technologies.
Although every reasonable effort has been made to ensure that all personal information will be so protected, dwell cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications. In the event that there is a data breach, dwell will act in accordance with the requirements under the Notifiable Data Breaches scheme in the Privacy Act.
Transfer of your Personal Information overseas
9.1 We will not transfer your information overseas without your consent. We may disclose your Personal Information to other related entities of the dwell group which are located outside of Australia in locations that include United Kingdom, United States of America and Singapore.
Access Requests and Withdrawal of Consent
10.1 Please contact us via email@example.com should you wish to have access to or withdraw the consent to collect and use your Personal Information.
Your email should identify yourself and state which Personal Information and information about its use and / or disclosure is requested. If you withdraw your consent to any or all purposes and depending on the nature of your request, dwell may not be in a position to continue to provide our products or services to you.
Management and Security
How to contact us
12.1 If you have any questions about this Policy or any complaints relating to your Personal Information, or you would like to obtain access and make corrections to your Personal Information, please contact the designated Data Protection Officers for the respective business units as follows:
Business Entity: dwell Student Living
Name of Data Protection Officer (DPO): Data Protection Officer
Contact Number: +65 6740 5825
Email Address: firstname.lastname@example.org
Review of the Policy
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What are cookies?
Cookies are small files containing a string of characters that is sent to your computer when you visit our Websites.
Depending on the type of cookies, they may store user preferences and other information.
When you interact with us on our Websites, we may collect for the purposes of analysis statistical information from which individuals cannot be identified (“Aggregate Information”), such as number of users, their frequency of use, the number of page views (or page impressions) that occur on the Websites and common entry and exit points into and out of the Websites.
We use such statistical information to understand how people use our Websites and to help us improve their structure and contents. We cannot identify you personally from this information.