Privacy Policy ...
This document declares the
undertakings by Real Estate Tips in relation to its handling of
Your Data.
- Data
Collection
- Data
Security
- Data
Use
- Data
Disclosure
- Data Retention and
Destruction
- Access by You to Your
Personal Data
- Information about Data
Handling Practices
- Handling of Enquiries,
General Concerns and Complaints
- Enforcement
- Changes to These Privacy
Undertakings
- Definitions
- Data
Collection
Real Estate Tips undertakes to
collect Your Data by means that are: fair; legal; and transparent.
If you visit Real Estate
Tips's web-site, your web-browser automatically discloses, and
Real Estate Tips's web-server automatically logs, the following
information: the date and time, the IP address from which you
issued the request, the type of browser and operating system
you are using, the URL of any page that referred you to the
page, the URL you requested, and whether your request was
successful. This data may or may not be sufficient to identify
you.
Any additional data that you
provide, e.g. in a web-form, may also be logged. This data may
or may not be sufficient to identify you.
Any additional data that your
web-browser automatically provides may also be logged. This
will be the case, for example, if your browser has previously
been requested to store data on your computer in 'cookies' and
submits them each time you request a web-page within a
particular domain (such as Real Estate Tips.com). This data may
or may not be sufficient to identify you.
If you disclose personal data
to Real Estate Tips in conjunction with an identifier such as
your name or your credit-card details, Real Estate Tips will
collect Your Data. Moreover, any data that becomes available to
Real Estate Tips through any of the means described in the
preceding paragraphs may be able to be associated with that
identifier, and hence become Your Data.
Subject to the qualifications
immediately below, Real Estate Tips undertakes to collect Your
Data from you and not from other parties. This undertaking is
qualified as follows:
where E-Business reasonably
considers that the protection of its financial interests
requires that it gather YourData from other sources, or from
additional sources. This applies in particular where Real
Estate Tips has a lending exposure to you, and seeks
information about your creditworthiness;
where Real Estate Tips reasonably
considers that its capability to deliver quality services to
you will be materially enhanced by gathering YourData from
other sources. This applies in particular to consumer profile
data.
Where Real Estate Tips
collects Your Data from sources other than you, it
undertakes:
- to do so only by legal
means;
- to do so only with your
Consent; and
- to declare to you what
sources it uses, and under what
circumstances.
- Real Estate Tips
undertakes to declare the purpose of collection in a manner
which is clear and meaningful, and to avoid vague, highly
inclusive statements such as 'to support our
operations'.
Data Security
Real Estate Tips undertakes to
store Your Data in a manner that ensures security against
unauthorised access, alteration or deletion, at a level
commensurate with its sensitivity.
Real Estate Tips undertakes to
store Your Data only in jurisdictions where data protections
are at least equivalent to those required under the OECD
Guidelines.
Real Estate Tips undertakes to
transmit Your Data in a manner that ensures security against
unauthorised access, alteration or deletion, at a level
commensurate with its sensitivity.
Real Estate Tips undertakes to
implement appropriate measures to ensure security of Your Data
against inappropriate behaviour by Real Estate Tips
staff-members and contractors. These include:
- training for staff in
relation to privacy;
- access control, to limit
access to Your Data to those staff and contractors who have
legitimate reasons to access it;
- particularly in the case
of sensitive data, audit trails of accesses, including the
identities of staff and contractors accessing the
data;
- reminders to staff and
contractors from time to time about the importance of data
privacy, and the consequences of inappropriate
behaviour;
- declaration of
appropriately strong sanctions that are to be applied in
the event of inappropriate
behaviour
- clear communication of
policies and sanctions; and
- processes to audit, to
investigate and to impose
sanctions.
Data Use
Use refers to the application
of Your Data by any part of Real Estate Tips, or any
staff-member or contractor of Real Estate Tips in the course of
their work.
Real Estate Tips undertakes to
use Your Data only for:
the purposes for which it was
collected; such other purposes as are subsequently agreed
between Real Estate Tips and You; such additional purposes as
may be required by law. In these circumstances, Real Estate
Tips will take any reasonable steps available to it to
communicate to You that the use has occurred, unless it is
precluded from doing so by law; and such additional purposes as
are authorised by law (in particular to protect Real Estate
Tips's interests, e.g. if it believes on reasonable grounds
that You have failed to fulfil your undertakings to Real Estate
Tips or have committed a breach of the criminal
law).
Real Estate Tips undertakes to
use YourData only if it has demonstrable relevance to the
particular use to which it is being put.
Real Estate Tips undertakes to
use YourData in such a manner as to take into account the
possibility that it is not of sufficient quality for the
purpose, e.g. because it is inaccurate, out-of-date,
incomplete, or out-of-context.
Data Disclosure
Disclosure refers to making
YourData available to any party other than Real Estate Tips and
You. The term disclosure may include many different conditions
of data transfer, including selling, renting, trading, sharing
and giving.
Real Estate Tips undertakes to
disclose Your Data only under the following
circumstances:
in the course of business
being conducted between You and Real Estate Tips, where
disclosure is necessary to a contractor, such as a transport
company. Where Your Data is disclosed in this way, Real Estate
Tips undertakes to exercise control over Real Estate Tips's
contractors to ensure that their actions are compliant with
these Terms;
in other circumstances that
are directly implied by the purpose agreed between You and Real
Estate Tips at the time of data collection or subsequently.
Where Your Data is disclosed in this way, Real Estate Tips
undertakes to exercise control over Real Estate Tips's
contractors to ensure that their actions are compliant with
these Terms; with your consent, or at your request; where
required by law, such as a provision of a statute, or a court
order such as a search warrant or sub poena. In these
circumstances, Real Estate Tips will take any reasonable steps
available to it to communicate to You that the disclosure has
occurred, unless it is precluded from doing so by law; where
permitted by law (e.g. the reporting of suspected breach of the
criminal law to a law enforcement agency; and in an emergency,
where Real Estate Tips believes on reasonable grounds that the
disclosure of YourData will materially assist in the protection
of the life of health of some person), provided that Real
Estate Tips will apply due diligence to ensure that the
exercise of the permission is justifiable.
In all cases, Real Estate Tips
undertakes to disclose only such of Your Data as is necessary
in the particular circumstances.
Data Retention and
Destruction
Subject to the qualifications
immediately below, Real Estate Tips undertakes: to retain Your
Data only as long as is consistent with its purpose; and to
destroy Your Data when its purpose has expired, and to do so in
such a manner that Your Data is not subsequently capable of
being recovered. This undertaking is qualified as
follows:
Your Data may be retained in
Real Estate Tips's logs, backups and audit trails within
short-term retention cycles that are devised to protect the
company's operations. In such cases, Your Data will be
destroyed in accordance with those cycles;
Your Data may be retained
beyond the expiry of its purpose if that is required by law,
such as a provision of a statute, or a court order such as a
search warrant or sub poena, or a warning by a law enforcement
agency that delivery of a court order is imminent. In these
circumstances, Real Estate Tips: will take any reasonable steps
available to it to communicate to You that Your Data is being
retained, unless it is precluded from doing so by law; and will
only retain Your Data while that provision is current, and will
then destroy Your Data; Your Data may be retained beyond the
expiry of its purpose if it is authorised by law (in particular
to protect Real Estate Tips's interests, e.g. if it believes on
reasonable grounds that You have failed to fulfil your
undertakings to Real Estate Tipsc or have committed a breach of
the criminal law). In these circumstances, Real Estate Tips
will only retain Your Data while that situation is current, and
will then destroy Your Data.
Access by You to Your Personal
Data
Real Estate Tips undertakes to
provide you with access to Your Data, subject to only such
conditions and processes as are reasonable in the
circumstances. In particular, Real Estate Tips undertakes to
enable access: conveniently; without unreasonable delay; and
without cost.
Real Estate Tips undertakes to
establish and operate identity authentication protections for
access to Your Data that are appropriate to its sensitivity,
but practical. This may involve some inconvenience; for
example, relatively straightforward procedures may be involved
in order to provide you with access through a channel that you
have previously registered with Real Estate Tips (such as a
particular email-address), but may impose more onerous
procedures if you wish to use some other channel.
In the event that you dispute
some aspect of Your Data, Real Estate Tips undertakes to take
reasonable steps in relation to the amendment, supplementation
or deletion of Your Data.
You undertake: not to seek
access for frivolous purposes, or unreasonably
frequently;
to accept that deletion of some
data may not be consistent with the provision of particular
services by Real Estate Tips to you.
Information about
Data-Handling Practices
Elmore Music undertakes to
make information available to you about the manner in which
Real Estate Tips handles your data:in general terms, in a
readily accessible manner; and
in more specific terms, on
request. Where Your Data is disclosed to a contractor, Real
Estate Tipsundertakes to make information available to you on
request about the manner in which Real Estate Tips contractors
handle your data. Real Estate Tips undertakes to ensure that
the information provided is meaningful, and addresses your
concerns.
You undertake:
not to seek such information
for frivolous purposes, or unreasonably frequently;
and
to accept that the disclosure of
excessive detail may harm the security of Your Data and Real
Estate Tips's business processes, and may harm Real Estate
Tips's commercial interests.
Handling of Enquiries, General
Concerns and Complaints
If you have enquiries, general
concerns, or complaints about these Terms, or about Real Estate
Tips's behaviour in relation to these Terms, you
undertake: to communicate
them in the first instance: to Real Estate Tips only;
in sufficient
detail; through a
channel made available by Real Estate Tips for that
purpose; Real Estate
Tips undertakes:
to provide one or more
channels for communications to Real Estate Tips, which are
convenient to users; to
promptly provide acknowledgement of the receipt of
communications, including the provision of a copy of the
communication, the date and time it was registered, and Real
Estate Tips's reference-code for the communication;
to promptly provide a response to
the communication, in an appropriate and meaningful
manner. You further
undertake to not pursue Real Estate Tips through any Regulator
or the media: until and
unless Real Estate Tips has had a reasonable opportunity to
respond to the initial communication; and
while Real Estate Tips and
you remain are conducting a meaningful dialogue about the
matter.
Enforcement
Real Estate Tips declares that
its undertakings in these Terms are intended to create legal
obligations, and that those obligations are intended to be
enforceable under appropriate laws in appropriate
jurisdictions. These include laws relating to data protection,
privacy, fair trading, corporations and criminal
laws.
You undertake to seek
enforcement only in a jurisdiction that is relevant to the
transactions that have taken place between You and Real Estate
Tips, in particular the jurisdiction in which you live or in
which you performed the relevant acts, and the jurisdiction in
which Real Estate Tips is domiciled or performed the relevant
acts.
If you wish to discover the
relevant laws in any particular jurisdiction, Real Estate Tips
draws your attention to the following resources:
WorldLII Privacy
Links
Compilation of [U.S.] State and
Federal Privacy Laws, Privacy Journal, Providence RI
Privacy Law Sourcebook 2004,
EPIC, Washington DC
the Australian Privacy
Foundation's pages:
International Instruments
Relating to Privacy Law
Privacy Laws of Countries of the
World
Privacy Laws of the Commonwealth
of Australia
Privacy Laws of the States and
Territories of Australia
Privacy International
Changes to These Privacy
Undertakings
Real Estate Tips
undertakes:
not to materially change these
Terms in a manner that reduces the protections for Your
Data;
to take all possible steps to
prevent any company that acquires this company or any of its
relevant assets from materially changing the Terms applicable
to Your Data in a manner that reduces the protections for Your
Data; where it is
considering making changes to these Terms, or creating more
specific Terms relating to specific services, to consult with
appropriate representative and advocacy
organisations; where
it makes changes to these Terms, to ensure that the differences
between successive versions are readily
accessible; to
maintain all prior versions of these Terms in such a manner
that they are dated, and readily accessible.
Your Data means data that is
capable of being associated with you, whether or not it
includes an explicit identifier such as your name or customer
number. In particular, it encompasses all data that Real Estate
Tips is capable of correlating with you, using such means as
server-logs and cookie-contents.
Your Data does not refer to
data that can no longer be associated with you. This includes
aggregated data that does not and cannot identify the
individuals whose data are included in the
aggregation.
Consent means your concurrence
with an action to be taken by Real Estate Tips. Consent may be
express or implicit, but in either case must be informed and
freely-given.
Definitions
Real Estate Tips means the
company providing marketing material.
Your Data means data that is
capable of being associated with you, whether or not it
includes an explicit identifier such as your name or customer
number. In particular, it encompasses all data that ThisCompany
is capable of correlating with you, using such means as
server-logs and cookie-contents.
Your Data does not refer to
data that can no longer be associated with you. This includes
aggregated data that does not and cannot identify the
individuals whose data are included in the
aggregation.
Consent means your concurrence
with an action to be taken by ThisCompany. Consent may be
express or implicit, but in either case must be informed and
freely-given.
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