Privacy Policy





  1. In the course of our business, there may be circumstances where we collect personal information. Our privacy policy has been developed to ensure that the collection, use, disclosure and storage of such information is handled appropriately.


  1. We are committed to complying with the Privacy Act 1988 (Cth) (Privacy Act) in relation to all personal information we collect. This commitment is demonstrated in this policy. The Privacy Act incorporates the Australian Privacy Principles (APPs). The APPs set out the way in which personal information must be treated.


  1. This policy applies to any person for whom we currently hold, or may in the future collect, personal information.


  1. This policy does not apply to acts and practices which relate directly to the employee records of our current and former employees.


  1. In broad terms, ‘personal information’ is information or opinions relating to a particular identifiable individual.


  1. Information or opinions are not personal information where they cannot be linked to a particular individual.



The kinds of personal information that we collect and hold:

  1. Generally, the types of information that we may collect and hold include:
    • contact information;
    • employment history;
    • tax file numbers;
    • date of birth;
    • financial information;
    • business circumstances;
    • information about assets and investments;
    • Any other personal information as required by law or otherwise



How we collect and hold personal information

  1. Where reasonable and practicable, we will collect personal information directly from the person to whom the personal information relates.


  1. We hold personal information:
    • physically, on our premises;
    • electronically;
    • through internal servers;
    • on electronic storage devices, including USB drives
    • Other electronic archive and data storage systems


  1. We will take all reasonable steps to ensure that all personal information we hold is secure from any unauthorised access, misuse or disclosure. However, we do not guarantee that personal information cannot be accessed by an unauthorised person (e.g. a hacker) or that unauthorised disclosures will not occur.


  1. Some of the methods we use to store and secure information include:
    • using unique usernames, passwords and other protections on systems that can access personal information; and
    • restricting access to information on a “needs to know basis”.


  1. In the case of potential employees, the primary purpose the information is collected is to assess the individual’s suitability for a position with us.


  1. Otherwise, we will only disclose personal information to third parties with the relevant individual’s consent or if the disclosure is permitted by the Privacy Act.


  1. We manage the personal information we collect by:
    • providing team members training on privacy issues;
    • regularly reviewing our privacy compliance, including privacy audits;
    • implementing security measures to keep the personal information we collect safe, including using unique usernames and passwords on systems that can access personal information; and
    • appointing a designated privacy officer to monitor privacy compliance and be a contact for any privacy complaints and access or correction requests.


  1. In limited circumstances, it may be possible for a person to use a pseudonym or remain anonymous when dealing with us. If a person wishes to use a pseudonym or remain anonymous they should notify us when making first enquiries or providing initial instructions. We will use our best endeavours to deal with the person as requested, subject to our professional obligations and ability to perform our services of undertaking property development and sales/purchases of land without using the person’s name. In most cases, our professional obligations will require the person to deal with us using their real name.


The purposes for which we collect, hold, use and disclose personal information

  1. We take reasonable steps to use and disclose personal information for the primary purpose for which it is collected. The primary purpose for which information is collected is to provide the services of undertaking property development and sales/purchases of land.


  1. In the case of potential employees, the primary purpose the information is collected is to assess the person’s suitability for a position with us.


  1. Personal information may also be used or disclosed by us for secondary purposes which are within the person’s reasonable expectations and related to the primary purpose of collection.


  1. For example, we may use personal information for the following secondary purposes:
    • For direct marketing purposes including mail outs, newsletter and emails (which can be unsubscribed from at any time); or
    • to provide a referral.


  1. We may disclose personal information:
    • with the consent of the person to whom the information relates; or
    • to third party contractors where it contracts out any financial, administrative, information technology or other services.


  1. We do not disclose personal information to overseas recipients.


How to access personal information and seek correction of any personal information

  1. It is  important  the  information  we  hold  about  persons  is  up-to-date. Persons should contact us if their personal information changes.


  1. Persons may request access to the personal information we hold or ask for their personal information to be corrected.


  1. A request by an person to access or correct personal information about the person must be made to the following contact officer:


Contact person:                       Peter Macdougall

Telephone number:                07 4051 1299

Email address:                

Postal address:                        PO Box 6320, Cairns QLD 4870


  1. We will grant a person access to their personal information as soon as possible, subject to the request circumstances.


  1. In keeping with our commitment to protect the privacy of personal information, we will not disclose personal information to a person without proof of identity.


  1. We may deny access to personal information if:
    • the request is impractical or unreasonable;
    • providing access would have an unreasonable impact on the privacy of another person;
    • providing access would pose a serious and imminent threat to the life or health of any person;
    • providing access would compromise our professional obligations; or
    • there are other legal grounds to deny the request.


  1. We may charge a fee for reasonable costs incurred in responding to an access request. The fee (if any) will be disclosed prior to it being levied.


  1. If a person is able to establish that personal information we hold is not accurate, complete and up-to-date, we will take reasonable steps to correct it so that it is accurate, complete and up-to-date, where it is appropriate to do so.


How to complain about an alleged privacy breach

  1. If a person wishes to complain about an alleged privacy breach, they must follow the following process:
    • The complaint must be firstly made to us in writing. We will have a reasonable time to respond to the complaint.
    • In the unlikely event the privacy issue cannot be resolved between us and the person, the person may take their complaint to the Office of the Australian Information Commissioner.


  1. A person can complain about a breach of privacy by contacting our contact officer specified above.



  1. We may  update,  modify  or  remove  this  policy  at  any  time  without prior  Any changes to the privacy policy will be published on our website.



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