1. Introduction
1.1. Company’s Commitment to Privacy
Alcatord Rooms is a brand of Alcatord Management (Alcatord). Alcatord is deeply committed to safeguarding your personal information and upholding the highest standards of privacy and data security. Our dedication to preserving the confidentiality and integrity of the data you entrust to us is unwavering. This commitment extends to every individual, whether they are clients or visitors to our website, regardless of their geographical location.
Our privacy practices are firmly grounded in the principles of transparency, accountability, and strict adherence to relevant privacy laws, including the Australian Privacy Act and the European General Data Protection Regulation (GDPR). We diligently work to gain your trust through open disclosure of our data collection and usage practices and by implementing robust security measures to protect your information.
This privacy policy elucidates the specific measures we have in place to ensure your privacy’s sanctity and the choices you possess concerning the data you furnish to us. By availing our services and navigating our website, you explicitly acknowledge that you have comprehended, assented to, and accepted the terms articulated in this privacy policy.
1.2. Scope of the Privacy Policy
This privacy policy is all-encompassing, encompassing all personal information collected, processed, and stored by Alcatord through our website and associated services. It pertains to the data we gather from our clients, potential clients, and visitors to our website. It is important to note that this policy might be supplemented by supplementary terms, privacy notifications, or consent forms that are specific to certain services or interactions.
Our unswerving dedication is to ensure compliance with the privacy laws of both Australia and Europe, thereby guaranteeing the protection of your data and upholding your rights regarding its utilization and disclosure. We are conscientious about complying with these laws, and this policy has been meticulously crafted to elucidate how we meet these obligations.
1.3. Definitions
To promote absolute clarity and transparency, the ensuing terms are employed in this privacy policy:
– Personal Information: Denotes information that either directly identifies an individual or is potentially linkable to an individual, such as names, addresses, email addresses, phone numbers, or any other data with the potential for reasonable identification.
– Non-Personal Information: Encompasses data that is devoid of personal identifiers and is exclusively used for statistical, analytical, and business purposes.
– Cookies and Similar Technologies: These consist of diminutive text files or code elements positioned on your device when you access our website. They serve to elucidate your preferences, enhance your experience, and proffer personalized content and advertisements.
1.4. Australian Privacy Principles (APPs)
Alcatord is committed to adhering to the Australian Privacy Principles (APPs) as outlined in the Australian Privacy Act. These principles govern the collection, use, and disclosure of personal information, ensuring that your privacy is protected. The APPs will be an integral part of our privacy practices, and they complement the principles outlined in this policy.
2. Information We Collect
2.1. Personal Information
Alcatord collects personal information essential for delivering our services and maintaining effective communication with clients and website visitors. The types of personal information we may collect include, but are not limited to:
– Names
– Contact information (e.g., email addresses, phone numbers)
– Residential addresses
– Financial information (e.g., payment details)
– Identifiers (e.g., customer numbers, client IDs)
This data is collected through voluntary submissions, such as when you register for our services, contact us, or complete forms on our website. The lawful bases for processing this personal information under the General Data Protection Regulation (GDPR) may include the necessity of processing for the performance of a contract (Article 6(1)(b) GDPR), compliance with a legal obligation (Article 6(1)(c) GDPR), and, in some cases, consent (Article 6(1)(a) GDPR).
2.2. Non-Personal Information
In addition to personal information, Alcatord may also collect non-personal information for statistical, analytical, and operational purposes. Non-personal information is data that does not directly identify individuals. This can include, but is not limited to:
– Browser and device information
– IP addresses
– Usage data, such as pages visited and interaction with our website
– Aggregated demographic information
Non-personal information is collected automatically through cookies and similar technologies, as described in Section 2.4.
2.3. How We Collect Information
Alcatord collects information through various means, including:
– Direct Interactions: When you provide information by contacting us, registering for our services, or filling out forms on our website.
– Automated Interactions: When you visit our website, we may collect non-personal information automatically through cookies and similar technologies, as detailed in Section 2.4.
– Third Parties: In some cases, we may receive information from third parties, such as business partners or service providers. We handle this information in accordance with this privacy policy and applicable laws. The lawful bases for processing personal information obtained from third parties under the GDPR may include legitimate interests pursued by Alcatord (Article 6(1)(f) GDPR) and compliance with legal obligations (Article 6(1)(c) GDPR).
2.4. Cookies and Similar Technologies
Cookies and similar technologies are used by Alcatord to enhance user experience, personalize content, and improve our website’s functionality. These technologies may collect non-personal information, and their usage is governed by our Cookie Policy.
You have the option to manage your cookie preferences, including opting out of non-essential cookies. For more information on our use of cookies and how to manage your preferences, please refer to our Cookie Policy.
3. Purpose of Data Collection
3.1. Why We Collect Data
Alcatord collects and processes personal information for specific and legitimate purposes, which encompass, but are not restricted to:
– Service Delivery: To provide our clients with the services they have explicitly requested, such as guidance and education on the conversion of investment properties into Homes of Multiple Occupancies (HMOs).
– Communication: To uphold efficient and responsive communication with clients and website visitors, including addressing inquiries and furnishing updates on our services.
– Legal Obligations: To ensure compliance with legal and regulatory requirements, including those stipulated by the Australian Privacy Act and the European General Data Protection Regulation (GDPR).
– Improvement: To advance the quality of our services, website, and user experience through analytics, research, and feedback from our clients.
3.2. Legal Basis for Data Processing
Alcatord diligently ensures that the processing of personal information is executed in strict adherence to applicable laws. The legal bases for processing personal information may encompass:
– Consent: Whenever individuals have explicitly provided consent for data processing, particularly in the context of marketing or non-essential cookies.
– Contractual Necessity: Processing data that is indispensable for fulfilling a contract or delivering services explicitly requested by the individual.
– Legal Obligation: Processing data to meet legal and regulatory obligations.
– Legitimate Interests: Processing data to address legitimate business interests, ensuring that these interests do not take precedence over the rights and interests of the individual.
Individuals have rights under the General Data Protection Regulation (GDPR), including the right to access, rectify, erase, restrict, and object to the processing of their personal data. They also have the right to data portability. Additionally, individuals have the right to lodge a complaint with a supervisory authority if they believe that their data protection rights have been violated.
3.3. How We Use Collected Data
The data collected serves the following purposes, in compliance with APP 3:
– Administering and overseeing our services.
– Maintaining communication with clients and visitors.
– Ensuring compliance with legal obligations.
– Enhancing our services and user experience.
– Conducting research and performing analytics.
3.4. Data Retention Period
Alcatord retains personal information exclusively for the period necessary to fulfill the purposes articulated in this privacy policy or as mandated by relevant laws. Once the data is no longer requisite, it will be securely deleted or anonymized, ensuring the utmost privacy and data protection.
4. Information Sharing
4.1. Sharing with Third Parties in Accordance with APP 6
Alcatord acknowledges the paramount importance of protecting your personal information and categorically commits to never disclose or sell your personal data to third parties for marketing or advertising purposes. Nevertheless, there are specific circumstances in which we may share personal information with trusted third parties, including but not limited to:
– Service Providers: We may enlist the services of reputable providers to assist in delivering our services. These service providers are contractually obligated to maintain data protection and privacy standards at the same level as Alcatord.
– Legal Obligations: We may disclose personal information when compelled to meet legal or regulatory obligations in accordance with APP 6. This may involve sharing data with government authorities, law enforcement agencies, or responding to valid court orders.
– Business Partners: On certain occasions, we may enter into collaborations with business partners to offer joint services or promotions. Whenever personal information is shared with business partners, it will be clearly and explicitly communicated, and consent will be sought whenever necessary.
4.2. International Data Transfers
Alcatord may transfer personal information to countries beyond the borders of the European Economic Area (EEA) or Australia. In such instances, we ensure that robust safeguards are in place to shield the data and to comply with the pertinent data protection laws, including APP 8 where applicable.
These safeguards may encompass the deployment of standard contractual clauses authorized by the pertinent authorities, ascertaining that third-party recipients have embraced satisfactory data protection measures, or securing explicit consent when the need arises.
4.3. Sharing with Government Authorities
Alcatord recognizes its obligation to adhere to legal and regulatory requisites. In scenarios where it is mandated by law to share personal information with government authorities, law enforcement agencies, or other entities, we will do so with unwavering adherence to the legal framework.
Furthermore, we may also share personal information to protect our rights, privacy, safety, or property, as well as those of our clients, website visitors, or the public, in accordance with the allowances provided by the law.
5. Client Rights
5.1. Right to Access
Clients and website visitors hold the unequivocal right, under the General Data Protection Regulation (GDPR), to request access to their personal information held by Alcatord. We shall furnish information about the data we possess, its origins, and the objectives for which it is currently under processing. To exercise this right, kindly contact us through the methods specified in Section 11.1.
5.2. Right to Rectify
Should you have reason to believe that the personal information we have concerning you is erroneous or incomplete, you possess the right, as provided under the GDPR, to request corrections. Alcatord commits to swiftly update and rectify any inaccuracies in your data upon receiving your request.
5.3. Right to Erasure
Clients and website visitors maintain the right, as granted by the GDPR, to request the erasure of their personal information when it is no longer requisite for the purposes for which it was gathered, or when data processing transgresses the bounds of legality. Alcatord shall adhere to these requests unless there exist legitimate legal or business grounds that necessitate the data’s retention.
5.4. Right to Restrict Processing
You reserve the right, in accordance with the GDPR, to request the restriction of personal information processing under particular circumstances, such as when you dispute the accuracy of your data or when the processing is conducted unlawfully. Alcatord will curtail processing while investigating such requests.
5.5. Right to Data Portability
Clients possess the right, as stipulated by the GDPR, to request the transfer of their personal information to another data controller in a structured, commonly used, and machine-readable format. Alcatord will facilitate such transfers when they are feasible.
5.6. Right to Object
You have the prerogative, in accordance with the GDPR, to object to the processing of your personal information for direct marketing purposes, as well as for legitimate interests pursued by Alcatord. We shall terminate processing personal information for such objectives upon receipt of an objection, unless there exist compelling legal grounds for continued processing.
5.7. Automated Decision-Making
Alcatord may engage in automated decision-making processes, encompassing profiling, for specific purposes such as content personalization and marketing. In situations where such decisions have legal or substantial effects on individuals, you maintain the right to request human intervention, articulate your perspective, and challenge the decision.
To exercise any of the rights outlined in this section, please reach out to us as delineated in Section 11.1. We are committed to responding to your requests within the timeframes mandated by the General Data Protection Regulation (GDPR), ensuring the utmost respect for your rights.
5.8. Compliance with APP Rights
Alcatord is dedicated to respecting and fulfilling the rights of individuals as stipulated in the Australian Privacy Principles (APPs). To exercise any of the rights outlined in this section, please reach out to us as delineated in Section 11.1. We are committed to responding to your requests within the timeframes mandated by the APPs, ensuring the utmost respect for your rights.
6. Data Security
6.1. Security Measures in Accordance with APP 11
Alcatord upholds an unwavering dedication to upholding the highest standards of security for the protection of your personal information, in alignment with APP 11 – Security of Personal Information. We have diligently implemented a comprehensive array of technical, administrative, and physical security measures designed to fortify your data against any unauthorized access, disclosure, alteration, or destruction.
Our security measures encompass, but are by no means limited to:
– Access Controls: Stringently limiting access to personal information exclusively to authorized personnel. We employ robust authentication and authorization protocols to ensure that only individuals with a legitimate need-to-know can access personal data.
– Encryption: The implementation of industry-standard encryption protocols, ensuring the safeguarding of data during both transmission and storage. This includes the use of secure and encrypted connections for data transfer.
– Regular Security Assessments: The conduct of periodic security assessments and audits to identify and rectify potential vulnerabilities. These assessments are conducted to stay ahead of emerging threats and vulnerabilities, and to ensure compliance with security best practices.
– Employee Training: Equipping our employees with privacy and security training to ensure that they are well-versed in best practices and their role in preserving data security. This includes training on how to handle personal information securely and how to recognize and report security incidents.
6.2. Data Breach Response
In the unlikely event of a data breach that could potentially jeopardize your rights and freedoms, Alcatord stands resolute in its commitment to full compliance with all applicable legal requirements, including those outlined in APP 11. Should we determine that a breach has transpired, we will undertake the following steps:
– Notify Data Subjects: In the event that the breach holds the potential to compromise your rights and freedoms, we will promptly notify affected individuals in adherence to legal mandates. This notification will provide a clear account of the breach’s nature, the probable consequences, and the measures undertaken or proposed to address it. We recognize the importance of transparent and timely communication with those affected.
– Notify Authorities: If the breach mandates legal reporting to the pertinent data protection authorities, Alcatord will strictly adhere to the notification prerequisites and timelines outlined in relevant privacy laws and APP 11. We will collaborate with authorities to address the breach effectively.
– Investigate and Remediate: We will expeditiously launch an investigation into the breach, take decisive measures to mitigate potential harm, and institute a robust action plan to forestall any future breaches. Our objective is not only to address the immediate impact but also to prevent similar incidents from occurring in the future.
– Maintain Records: Alcatord will diligently uphold records of all data breaches, encompassing their nature, implications, and the steps taken to rectify the situation, all in strict accordance with the dictates of applicable regulations, including those set forth in APP 11. These records are essential for compliance, transparency, and continuous improvement of our security measures.
7. Third-Party Websites and Services
7.1. Links to Other Websites
Our website may include links to third-party websites, services, or content that are neither operated nor controlled by Alcatord. These third-party websites and services maintain their privacy policies and practices, which might vary from ours. Alcatord does not endorse or assume responsibility for the content, privacy practices, or security of these third-party websites.
We strongly encourage you to diligently review the privacy policies and terms of use of any third-party websites you choose to visit. It’s imperative to understand that Alcatord cannot be held liable for how these websites handle your data.
7.2. Third-Party Services
Alcatord may enlist the services of third-party providers to contribute to various aspects of our business operations, encompassing analytics, advertising, and payment processing. These service providers may have access to your personal information but are contractually bound to safeguard the data and utilize it exclusively for the purposes stipulated by Alcatord.
In accordance with the requirements of the European General Data Protection Regulation (GDPR), when personal data is processed by third-party service providers, Alcatord enters into data processing agreements or contracts with these providers. These agreements ensure that your personal information is handled with the same level of care and protection as outlined in this privacy policy.
While we implement measures to ensure that our service providers uphold the highest data protection standards, it’s essential to acknowledge that Alcatord cannot guarantee the actions of these third parties. It is your responsibility to comprehend and accept that Alcatord shall not be held accountable for the data practices of third-party service providers. We encourage you to review the privacy practices of our third-party service providers for a comprehensive understanding of how they process your data.
8. Marketing Communications
8.1. Consent for Marketing in Accordance with APP 7
At Alcatord, we hold your privacy in the highest regard and are committed to sending marketing communications, such as newsletters, promotional offers, and updates, only when you have provided explicit consent to receive them, in accordance with APP 7 – Direct Marketing. We will unfailingly seek your consent before dispatching any marketing materials, and you retain the full authority to withdraw your consent at any time.
To provide or withdraw your consent for marketing communications, you may employ the preferences or unsubscribe links thoughtfully incorporated within the communication. Alternatively, you can reach out to us using the contact methods delineated in Section 11.1.
8.2. Opting Out of Marketing Communications
Should you ever decide that you no longer wish to receive marketing communications from Alcatord, we respect your choice and offer you the unreserved right to opt out at your discretion. You can achieve this by any of the following means:
– Using the unsubscribe link thoughtfully provided within our marketing communications.
– Adjusting your communication preferences within your account settings (if applicable).
– Directly contacting us through the methods outlined in Section 11.1 to request the removal of your information from our marketing lists.
We do wish to bring to your attention that, even if you opt out of marketing communications, there remains a possibility that you may still receive transactional and service-related messages, which are indispensable for the use of our services or mandated by prevailing legal requirements, as outlined in APP 7.
9. Children’s Privacy
9.1. Age Restrictions
Alcatord maintains a steadfast commitment to preserving the privacy of children. Our services and website are expressly designed for individuals who have attained at least 18 years of age or the applicable age of majority stipulated by their jurisdiction. We are unwavering in our policy not to knowingly collect or process personal information from individuals under the age of 18 without the express consent of their parents or legal guardians. Should you become aware of any instance where we may have inadvertently collected personal information from a child without the requisite consent, we earnestly request you to contact us using the methods outlined in Section 11.1. Rest assured, we will take immediate and decisive steps to rectify the situation.
9.2. Parental Consent
If you happen to be a parent or legal guardian and harbor concerns that your child may have provided us with personal information without your explicit consent, we encourage you to reach out to us as per the details specified in Section 11.1. We are fully committed to working with you to verify the information, acquire your explicit consent, and, where deemed necessary, remove the information from our records.
Alcatord is unwavering in its dedication to strict compliance with all applicable laws governing children’s privacy, including the Children’s Online Privacy Protection Act (COPPA) in the United States and similar regulations in other jurisdictions. We remain resolute in taking all requisite measures to protect the privacy and safety of children online, in accordance with COPPA and similar regulations in other jurisdictions.
10. Changes to the Privacy Policy
10.1. Notification of Changes
Alcatord maintains the right to periodically update and modify this privacy policy to align with evolving data practices, legal requirements, and enhancements to our services, in accordance with APP 5 – Notification of the Collection of Personal Information. In the event of amendments to this privacy policy, the “Last Updated” date at the commencement of the document will be duly revised to indicate the date of the latest revision.
In our dedication to transparency and your privacy, we will also make reasonable efforts to apprise you of substantial changes in our privacy practices. This can occur through a conspicuous notice on our website or, if you have provided us with your email address, by sending a direct notification to your inbox.
We emphasize the importance for clients and website visitors to routinely review this privacy policy. This enables you to remain well-informed about how Alcatord manages personal information and to comprehend your rights and responsibilities regarding your data. Staying updated with our privacy policy empowers you to make informed decisions regarding your personal information, as outlined in APP 5. It is essential for us to notify users of substantial changes in this policy to ensure that you are fully aware of how your data is handled.
11. Contact Information
11.1. How to Contact Us
Should you have any questions, concerns, or requests pertaining to this privacy policy, your personal information, or your privacy rights, please do not hesitate to get in touch with Alcatord at privacy@alcatord.au.
We are fully committed to providing you with swift responses and addressing your inquiries or concerns promptly.
11.2. Data Protection Officer
In accordance with applicable privacy laws, including the General Data Protection Regulation (GDPR), Alcatord has designated a Data Protection Officer (DPO) to ensure the protection of your privacy and data security. The DPO serves as the primary point of contact for all matters related to data protection within our organization.
Our DPO is responsible for overseeing data protection concerns, ensuring compliance with data protection regulations, and safeguarding the privacy of your personal information. To contact our DPO and address any data protection-related inquiries or issues, please refer to the dedicated section of our privacy policy, where you will find the contact details for our Data Protection Officer. Your privacy and data security are of the utmost importance to us, and our DPO is here to assist you with any concerns you may have.
12. Complaints and Dispute Resolution
12.1. Lodging Complaints
Alcatord is deeply committed to the fair and transparent resolution of any complaints or disputes concerning the collection and processing of personal information. If you have concerns or complaints related to our data privacy practices, we strongly encourage you to reach out to us using the methods provided in Section 11.1. Rest assured, we will devote every effort to promptly and transparently address your concerns.
12.2. Dispute Resolution Process
In the event that you believe your concerns have not been adequately addressed by Alcatord or if you are dissatisfied with the resolution provided, you retain the option to seek independent dispute resolution mechanisms. Depending on your location, these mechanisms may encompass contacting your local data protection authority, engaging in arbitration, or availing mediation services.
We wish to underline our unwavering commitment to collaborating with the relevant data protection authorities and actively participating in the dispute resolution process as mandated by applicable privacy laws. Your confidence in our dispute resolution procedures is of utmost importance to us, and we are dedicated to ensuring that your concerns are handled effectively and in compliance with all relevant regulations.
13. Applicable Laws and Jurisdiction
13.1. Governing Laws
This privacy policy and the practices outlined herein are governed by the privacy laws and regulations applicable in Australia and the European Union, including the Australian Privacy Act and the European General Data Protection Regulation (GDPR).
13.2. Jurisdiction and Dispute Resolution
Any dispute, claim, or legal matter arising from or related to this privacy policy, your use of our services, or the handling of personal information by Alcatord, will be subject to the exclusive jurisdiction of the competent courts within the jurisdictions where Alcatord operates.
We are fully committed to strict compliance with the requirements of privacy laws in both Australia and the European Union. In the event of disputes or regulatory inquiries, Alcatord also pledges to cooperate with the competent data protection authorities and other relevant regulatory bodies as needed to ensure the fair and transparent resolution of such matters. Your trust and confidence in our commitment to privacy are of paramount importance to us.
14. Effective Date and Version
14.1. Effective Date
This privacy policy is effective as of 4 November 2023. Any updates or modifications to this privacy policy will be reflected with a revised “Last Updated” date at the beginning of this document.
We encourage you to periodically review this privacy policy to stay informed about how Alcatord handles personal information and to understand your rights and responsibilities concerning your data. Your continued use of our services and website following any updates constitutes acceptance of the revised privacy policy.