AVJennings Privacy Policy 

The AVJennings Limited privacy policy describes how the Company and its related entities (“the Company”) comply with privacy legislation and the Australian Privacy Principles. 

Collection of information 

The Company operates the business of residential land and housing development.. 

The Company collects personal information about individuals in order to carry out its business. Sometimes we may use agents or service providers to do this for us although the information will be provided by you and you will be made aware that the information is for the Company. The primary purpose for the collection of personal information is to enable the Company to provide you with information about our products and services, or to communicate with, its customers, suppliers, subcontractors and investors. 

Guidelines for the collection of personal information 

Personal information collected from customers, suppliers, subcontractors and investors must be relevant and appropriate for the operation of the business. 

Where practical it is the Company’s policy to collect information from the individual concerned. The Company could, in particular situations, collect personal information about individuals’ personal preferences to assist it in its marketing initiatives. 

From time to time the Company may employ third parties to monitor the effectiveness of its advertising or marketing initiatives. Any information so collected will be anonymous and will not identify people. 

Information collected is only used for the purposes of a particular transaction, contract, or for use within the Company for its marketing initiatives or communications with the individual concerned. We do not collect sensitive information. 

How personal information is collected 

Personal information is generally collected through the following means:

• an application form
• the Internet
• a questionnaire or survey
• a contract or order with the Company
• a telephone or personal inquiry

The information collected is used only for the prime purpose underlying its collection and for use within the Company or to communicate with individuals. 

Types of Information collected 

The types of information collected will generally consist of your name, address, contact details and buyer profile (eg first home buyer, investor, your budget, product preferences and timing preferences). 

Additional information about personal information collected over the Internet 

Personal information is collected in the following situations:

• When an individual registers with the Company to receive information
• When an individual requests information using the e-mail links provided on the Company’s website
• As a result of an individual’s use of the website
• In other instances (such as through an inquiry form or user survey)

Personal Information collected over the Internet or via the Company’s website may include an individual’s name, e-mail address, user identification, password and other information collected by our cookies (described below). It may also include information which the individual chooses to provide in the process of submitting questions and answers whilst interacting or corresponding with the Company via the website. 

The Company may also collect personal information at the website through cookies. Cookies are very small text files placed on the individuals hard drive by the Company’s or other computer servers. A cookie serves as an individual’s identification card whilst on the site and is unique to that person. Only the server that gave it to the individual can read the cookie. Cookies tell the Company that an individual has returned to a specific page on the website and helps the Company track transactional habits and preferences. They help the Company personalise a customer’s experience at the website by permitting the computer to remember who the individual is. 

Most web browsers are set by to default to accept cookies. If an individual does not wish to receive cookies he or she may set their browser to prompt them about cookies or to refuse to accept cookies. Rejecting cookies may interfere with their use of the site. 

The Company’s use of your personal information 

• The Company uses personal information to assist in providing our products and services, to respond to existing and potential customer queries and to complete any dealings the Company has with them. Generally the information supplied by us will relate to the Company’s products and services. The Company may also provide information about promotions and other products which it thinks may be of interest.
• The Company uses personal information for operational purposes in relation to transactions with its suppliers and sub contractors and others.
• The Company uses personal information about its shareholders and personal investors for share registry purposes and to track investor interest.

The Company’s disclosure of personal information to third parties 

Parties to whom the Company may disclose personal information include:

• The web or server provider for the Company’s website
• Consultants, including solicitors or real estate agents acting on the Company’s behalf.
• Corporate affiliates
• Valuers
• Related parties or entities for marketing purposes.
• Parties to whom the Company has outsourced various functions e.g. share registry.
• The Company’s email and research providers, which are based in the US.
• Regulatory or other authorities as required by law or when deemed advisable by the Company to conform to legal and regulatory requirements and to protect the safety, rights and property of users of the site and the public.

The information is provided to third parties to enable the Company to provide its products and services or to satisfy legal requirements which apply to us. The third parties are under the same obligations as the obligations set out in this privacy policy. 

Access and Correction 

The Company will take reasonable steps to ensure that all personal information it holds is accurate, complete and up to date. 

Individuals have the right to seek access to the personal information which is held about them and to ask for correction if they consider it to be inaccurate, incomplete or out of date. The Company realises it is important to individuals to be able to control their personal details. Should an individual wish to find out about personal information held they should contact one of the contact points listed at the end of the policy. 

In the first instance the Company will generally provide the individual with a summary of the information held about them. The Company will assume (unless told otherwise) that the request relates to current records. These current records may include personal information on its databases and in paper files, which may be used by the Company on a day to day basis. 

To provide access to personal information the Company would ordinarily provide a printout of the relevant personal information from its database or photocopies of records that are held on paper files. If the personal information e.g. name and address is duplicated across different databases the Company will generally provide one print out of this information rather than multiple printouts. Ordinarily the Company will not charge for the cost of providing access to this type of record. 

For legal and administration purposes the Company may also store records containing personal information in its archives. An individual may seek to access non-current records held by the Company. In that case the Company may charge for the cost of providing access. 

Complaints 

An individual may complain if they believe the Company has breached any of the Australian Privacy Principles. They may do so at first instance by contacting one of the contact points at the bottom of this document. Any complaint will be investigated and the Company will subsequently respond to the individual. 

Security of information 

The Company will take reasonable steps to protect an individual’s personal information whether collected on line or by other means. For on line information, technology such as encryption, access, control procedures, firewalls and physical security will be used. For information held in paper files reasonable steps will be taken to ensure that only authorised personnel have access to the information. Where information is stored on machines, the Company will ensure that the information is removed prior to disposal of the machine. 

Investors /Shareholders in the Group 

The Company has outsourced its Australian Share Registry function to Link Market Services Limited. They have a privacy policy about the type of information they collect on behalf of the Company and to whom they disclose such information. Their policy may be viewed online. Their privacy officer may be contacted as below: 

privacy.officer@linkmarketservices.com.au

Link should be contacted if a shareholder has a complaint about privacy, would like details of the personal information held or would like to correct it. For shareholder protection, Link’s internal procedures must be satisfied before they will disclose personal information. If a shareholder/investor is not satisfied by Link’s response to their concern they should contact the AVJennings Company Secretary. 

The Company has outsourced its Singaporean Share registry function to the Central Depository (Pte) Ltd (CDP) in Singapore. The shareholders on this registry are predominantly Singapore based. The CDP’s policy is to only disclose personal information on individual shareholders to the Company or to the individual shareholder concerned. Apart from the above, the Company would not normally disclose information to an overseas recipient. 

Changes to this Privacy Policy 

The Company may make changes to this privacy policy from time to time. It will post changes to the policy on its website, so be sure to check periodically. 

This policy was issued on 6 May 2014. 

Contacting AVJennings about privacy issues 

Individuals with questions or comments about this policy or about how the Company has handled personal information should contact the Company Secretary on: