Privacy Policy

This Privacy Policy applies to:

• Lindsay Bennelong Developments Pty Limited, and
• CFT Holdings Company Pty Limited and its subsidiaries, collectively referred to as “LBD” in this Privacy Policy).

LBD commits to providing open and transparent management of the personal information of the individuals with whom we deal.

This Privacy Policy formalises and strengthens our commitment to privacy and complies with the Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Cth).

This Privacy Policy formalises and strengthens our commitment to privacy and complies with the Australian Privacy Principles (APPs) as set out in the Privacy Act 1988 (Cth).

This Privacy Policy covers the following:

• The kinds of personal information we collect and hold;
• How personal information is collected and held;
• Purposes for which personal information is collected, held, used and disclosed;
• Sending personal information overseas;
• Accessing and updating personal information;
• Use of our websites and electronic media;
• How to make a complaint or provide feedback.

The kinds of personal information we collect and hold:

Personal information is information or an opinion that can identify an individual or from which the identity of the individual can be reasonably ascertained. An individual’s name, address and telephone number are examples of personal information.

Personal information is information or an opinion that can identify an individual or from which the identity of the individual can be reasonably ascertained. An individual’s name, address and telephone number are examples of personal information.

The type of personal information which we collect will depend upon the dealings you may have with LBD. We collect personal information to:

• provide our Services to our clients including but not limited to: high-end apartment projects, project management and marketing services, residential subdivisions, house and land package developments;  (hereinafter referred to as “Services”); and as part of engaging suppliers and subcontractors to assist us with providing Services.

• as part of engaging suppliers and subcontractors to assist us with providing Services.

Sensitive information

We do not generally collect sensitive information as this information is not required for us to provide our Services. If we do collect sensitive information about you, we will only do so with your consent and directly from you, or otherwise in accordance with the law.

Sensitive information (as defined in the Privacy Act) includes information or opinion relating to:

• racial or ethnic origin;
• political opinions;
• membership of a political association;
• religious beliefs or affiliations;
• philosophical beliefs;
• sexual preferences or practices;
• criminal convictions;
• membership of a professional or trade association; or
• health information.

Employee Records

Acts and practices of employers that are directly related to both employee records and an employment relationship are exempted from the Privacy Act and are therefore not covered by this Policy.

How personal information is collected and held

Collection points

We start collecting your personal information from the time you make an enquiry about our Services. This is usually through our website and application(s) or at our sales office locations.

For suppliers and subcontractors, we collect personal information at the time of first engaging you to perform services for us.

Security of personal information

We take all reasonable steps to protect the personal information we hold from misuse, loss, unauthorised access, modification, or disclosure. This protection applies in relation to information stored in both electronic and hard copy form.

LBD will destroy or permanently de-identify any personal information collected when it is no longer required.

External organisations which provide support services to LBD are also required to appropriately safeguard the security of the personal information which we provide to them.

Purpose for which personal information is collected, held, used, and disclosed

Main purpose

We collect personal information from you or your authorised intermediaries which is reasonably necessary for the following purposes:

• to provide you with our Services; and to do all things necessary to administer, manage, develop and protect those Services;
• to inform you of special offers and products that we or our suppliers may be offering;
• to make applications to local authorities for planning, building, or development consents;  
• to do all things necessary to engage you as a supplier or subcontractor, including but not limited to meeting our legal and insurance obligations in relation to occupational health and safety regulations, workplace and taxation laws;
• to consider applications and approaches which you make to us;
• to maintain your contact details; and
• to meet our legal obligations.

Consequences if information not provided

When we ask you to provide us with personal information, if you do not provide us with that information or if that information is incomplete or inaccurate, it may:

• prevent us from being able to provide our Services to you;
• prevent us from engaging you as a supplier or subcontractor;
• limit our ability to provide you with the level of service you would normally expect from us; and
• prevent us from being able to contact you.

Use and disclosure of personal information

Personal information which is collected by LBD is generally only used and disclosed for:

• the main purpose for which the information was collected as set out above; or
• related purposes, which would be within your reasonable expectations.

Your personal information may be disclosed to our contractors and service providers to assist us in the operation of our business and for the provision of our Services (for example, our website chatbot and our construction trades). We take steps to ensure these organisations abide by this Privacy Policy and the APPs (where applicable).

We may share personal information with our related entities and/or subsidiaries. In this case, the information may only be used or disclosed by the related entity for the main purpose for which it was collected, where required or authorised by law, or for other purposes if you have consented.

If we wish to use or disclose your personal information in any other circumstances, we will only do so with your consent (implied or express) and will also take steps to ensure the party to whom we have disclosed your information agrees to protect the privacy of your personal information.

We do not sell personal information to companies outside LBD.

Disclosure required by law

We may otherwise use or disclose your personal information where the use or disclosure is required or authorised by law (for example, disclosure to government regulatory and law enforcement agencies) or in emergency situations.

Sending personal information overseas

We do not send any personal information overseas.

We will never disclose your personal information to recipients outside of Australia without first obtaining your consent or otherwise complying with the APPs.

Accessing and updating personal information

You may request access to your personal information or request us to correct information which we hold about you. To make a request, please put your request in writing using the contact details below. We may require proof of identification before we provide access to your personal information.

In normal circumstances we will give you full access to the personal information which we hold about you. However, in some circumstances, we may not be required by law to provide an individual with access to or to correct their personal information. If this is the case, you will be provided with the reason(s) for our decision.

We normally provide access without charge unless your request relates to a large volume of personal information, or access to our archived records. In these circumstances, we may impose a fee to recover our reasonable costs.

Use of our websites and electronic media

We outsource the development, maintenance and hosting of our websites, applications, and customer databases to third party service providers who are contract bound to protect your privacy (and who are also bound by the Privacy Act). Personal information may be disclosed to our third-party service providers so they can effectively provide these services.

Use of cookies and web tracking

We use cookies and session tools to improve your experience when accessing our websites and application(s). The information collected by these tools does not include personal information as defined by the Privacy Act, but may include the IP address of the device you are using and information about sites that the IP address has come from, the pages accessed on our site and the next site visited. We use this information to maintain, secure and improve our websites and application(s), and to enhance your experience when using them.

Third parties may also use cookies to collect information about the content you view on our website and application(s). They do this to provide advertising on their websites that’s more relevant to you.

If you wish to opt out, most Internet browsers allow you to change your settings to manage or block these cookies.

Links

We may, from time to time, include links to websites or applications of other organisations which may be of interest to you. We are not responsible for the privacy practices of these organisations.

Website and Application(s) security

As with any internet transaction, the transmission of data over the internet is not completely secure. While we take reasonable steps to ensure your personal information is safe and protected against misuse, loss or unauthorised access, modification or disclosure, we cannot guarantee the security of all data submitted to us over the internet.

Commercial Electronic Messages

The Spam Act 2003 (Cth) sets out the circumstances in which we can send you commercial electronic messages (including email and SMS text messages). From time to time, we may send you advertising material related to the purpose for which your personal information was collected.

Commercial electronic messages sent from us will include information about how to contact us and unsubscribe if required. Please note it may take up to 30 days (or such other time as required by the Spam Act) for our records to be updated to reflect your unsubscribe preference.

How to make a complaint or provide feedback

Questions or feedback about this Privacy Policy and how we handle your personal information should be directed to the Privacy Officer:

Phone: 02 8851 5300

Email: privacy@clarendon.com.au

Address: Ground Floor, 21 Solent Circuit, Norwest NSW 2153

By Post: PO Box 7105, Norwest NSW 2153

If you wish to make a privacy complaint, you may contact the Privacy Officer using the contact details above. We will provide a response within 20 working days. In some circumstances we may request further information and/or time to allow us to properly investigate your complaint.

If you feel we have not adequately dealt with your complaint, you may contact the Information Commissioner on 1300 363 992 or in writing, GPO Box 5218, Sydney NSW 2001.

Changes to this Policy

This is our current Privacy Policy outlining our personal information management practices. It replaces any other Policy published by us to date, whether on our website or in hard copy.

LBD reserves the right to amend this Privacy Policy at any time and will notify you of any changes by posting an updated version of the Policy on our websites.

Dated: 19 January 2024