1. About this policy

This Privacy Policy applies to Vital Communities Pty Ltd, our website at vitalcommunities.com.au, our enquiry and appointment forms, and our interactions with prospective purchasers, customers, residents, suppliers, contractors and other people who contact us.

We aim to manage personal information in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and other privacy obligations that apply to us.

In this policy, “personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

2. The personal information we may collect

The kinds of personal information we collect depend on how you interact with us. This may include:

• Contact details, such as your name, email address, phone number, postal address and preferred method of contact.
• Enquiry details, such as the Vital community you are interested in, your home preferences, budget range, preferred timeframe, downsizing interests and any questions or comments you submit.
• Appointment details, such as your selected appointment type, date, time, location and details needed to confirm, reschedule or cancel a meeting.
• Customer and transaction information, if you choose to proceed with us, such as records relating to deposits, contracts, home selections, site selections, settlement, customer service and resident communications.
• Communication records, such as emails, phone notes, form submissions, survey responses, feedback and records of your marketing preferences.
• Website and digital information, such as your IP address, browser type, device information, pages visited, referring website, approximate location, cookie identifiers and interactions with our website, advertising or email communications.
• Supplier and contractor information, such as contact details, business details, payment details and records needed to manage our working relationship.

Sensitive information

We generally do not seek sensitive information unless it is reasonably necessary for our functions or activities and we have your consent, or collection is required or authorised by law. Sensitive information may include health information, accessibility needs or other information you choose to provide so we can respond appropriately to your circumstances.

3. How we collect personal information

We may collect personal information:

• directly from you when you complete an enquiry form, book an appointment, call us, email us, visit a sales office or display home, attend an event, request information or otherwise deal with us;
• through our website, cookies, analytics tools, advertising pixels and similar technologies;
• from third parties where appropriate, such as referral partners, real estate platforms, marketing platforms, service providers, professional advisers, publicly available sources or someone authorised to act on your behalf; and
• from our related entities, contractors, agents or representatives involved in delivering our communities and services.

Where reasonable and practicable, we collect personal information directly from you. If we receive personal information about you from another source, we will take reasonable steps to make sure you know we have collected it where required.

4. Why we collect, use and disclose personal information

We collect, hold, use and disclose personal information for purposes connected with our business and communities, including to:

• respond to enquiries and provide information about Vital Communities, our locations, homes, pricing, amenities and community updates;
• arrange, confirm, manage, reschedule or cancel appointments, sales meetings and site visits;
• help you explore home and site options, including by understanding your preferences and circumstances;
• manage expressions of interest, deposits, contracts, home selections, customer records and resident or customer communications;
• send newsletters, project updates, construction progress updates, community news and other marketing communications where permitted;
• operate, maintain, personalise and improve our website, forms, booking systems, customer service and communications;
• conduct research, analytics, advertising measurement and business planning;
• manage suppliers, contractors, professional advisers and business relationships;
• protect our rights, property, systems, staff, customers and communities, including preventing fraud, misuse or unlawful activity;
• meet legal, regulatory, insurance, accounting, record-keeping and dispute-resolution obligations; and
• carry out any other purpose explained to you at the time of collection or for which you have consented.

5. Marketing communications

If you submit an enquiry, book an appointment or otherwise ask to receive information, we may send you updates about Vital Communities, including project news, construction progress, community updates, home releases, events and related information.

You can unsubscribe at any time by using the unsubscribe link in our emails or by contacting us. We will take reasonable steps to update your marketing preferences within a reasonable time.

6. Cookies, analytics and advertising technologies

Our website may use cookies, pixels, tags, analytics tools and similar technologies to help the website work, understand how visitors use it, improve the user experience, measure marketing performance and show relevant information or advertising.

These technologies may collect or infer information such as:

• your IP address, browser, device type and operating system;
• pages viewed, links clicked, forms started or submitted and time spent on the website;
• the website or advertisement that referred you to us; and
• general location information based on your device or IP address.

You can usually change your browser settings to refuse or delete cookies. Some parts of the website may not work as intended if cookies are disabled. Third-party platforms may also provide their own privacy settings and opt-out tools.

7. Who we may disclose personal information to

We may disclose personal information to:

• our staff, representatives, related entities, contractors and agents;
• sales managers, customer service providers and community management personnel;
• website, hosting, form, booking, customer relationship management, email, SMS, analytics, advertising and IT service providers;
• builders, consultants, designers, engineers, planners, maintenance providers and other parties involved in developing, operating or supporting our communities;
• professional advisers, including lawyers, accountants, auditors, insurers and financial advisers;
• payment processors, banks and other service providers involved in transactions with us;
• government agencies, regulators, courts, tribunals, law enforcement bodies and other parties where required or authorised by law;
• third parties involved in an actual or proposed business sale, restructure, merger, financing or transfer of assets, subject to appropriate confidentiality arrangements where required; and
• other parties where you have consented or where disclosure is reasonably necessary for the purposes described in this policy.

We do not sell personal information in the ordinary course of our business.

8. Overseas disclosure and cloud services

Some of the technology and service providers we use may store, process or access information outside Australia. This may include providers of website hosting, email, customer relationship management, booking, forms, analytics, advertising, cloud storage and support services.

The countries in which overseas recipients are located may change depending on the provider and the services used. These countries may include the United States and other locations where our service providers or their related bodies corporate, infrastructure or support teams operate.

Where we disclose personal information to overseas recipients, we take reasonable steps to protect that information in accordance with applicable privacy requirements.

9. How we protect personal information

We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. The steps we take may include physical, technical and organisational safeguards such as access controls, secure systems, staff awareness, password protections, secure record handling, service-provider due diligence and internal procedures.

No method of transmission or storage is completely secure. If you have concerns about sending information to us electronically, please contact us to discuss another suitable method.

10. How long we keep personal information

We keep personal information for as long as it is needed for the purposes for which it was collected, including to provide our services, manage customer and resident relationships, maintain business records, resolve disputes and comply with legal, accounting, insurance and reporting obligations.

When personal information is no longer required, we will take reasonable steps to destroy it or de-identify it, unless we are required or permitted by law to keep it for longer.

11. Accessing and correcting your personal information

You may request access to the personal information we hold about you. You may also ask us to correct information you believe is inaccurate, out of date, incomplete, irrelevant or misleading.

To protect privacy, we may need to verify your identity before responding to an access or correction request. We will respond within a reasonable time. We may refuse access or correction where permitted by law, in which case we will explain our reasons where it is reasonable to do so.

12. Anonymity and pseudonymity

Where practical, you may choose not to identify yourself or to use a pseudonym when dealing with us. However, we may need certain personal information to respond to enquiries, book appointments, provide tailored information, manage transactions, verify records or comply with legal obligations.

13. Data breaches

If we become aware of a suspected data breach involving personal information, we will take reasonable steps to contain, assess and respond to the incident. Where required under the Notifiable Data Breaches scheme, we will notify affected individuals and the Office of the Australian Information Commissioner.

14. Privacy complaints and enquiries

If you have a question, concern or complaint about how we handle personal information, please contact us using the details below. Please include enough information for us to understand and respond to your enquiry.

We will consider your complaint and respond within a reasonable time. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner at oaic.gov.au.

15. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes to our business, website, technology, legal requirements or privacy practices. The latest version will be available on our website and will show the date it was last updated.