Privacy Policy

1.About This Policy

This Privacy Policy explains how Vital Operations Bendigo Pty Ltd collects, holds, uses, discloses and protects personal information in connection with the operation and management of Vital Bendigo.

Vital Operations Bendigo Pty Ltd operates and manages Vital Bendigo and is the entity that enters into the Part 4A site agreement with residents. It is therefore the principal entity responsible for personal information connected with prospective resident enquiries, purchaser and resident records, disclosure and contracting processes, site rent and resident administration, community management, utilities and operational services, resident communications and maintenance and community matters.

The policy may also apply to personal information handled by Vital Communities Pty Ltd where that entity provides website, marketing, sales, customer relationship management or administrative services for Vital Bendigo.

Vital Communities Bendigo Pty Ltd is the freehold owner of the Vital Bendigo land. It may receive limited personal information where reasonably necessary in connection with its ownership role, legal obligations or dealings involving the land or community.

In this policy, “Vital”, “we”, “us” and “our” refer to Vital Operations Bendigo Pty Ltd and, where relevant to the particular interaction, the other Vital entity that collects, holds, uses or receives the personal information.

It applies to our website at vitalcommunities.com.au, our enquiry and appointment processes and our interactions with prospective purchasers, customers, residents, suppliers, contractors and other people who communicate or do business with us.

We aim to handle 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.Personal Information We May Collect

The information we collect depends on how a person interacts with us. It may include the following categories.

Contact Information

• Name
• Email address
• Telephone number
• Postal address
• Postcode
• Preferred communication method

Enquiry And Preference Information

• Questions submitted through forms or email
• Home or site preferences
• Approximate budget range
• Desired moving timeframe
• Downsizing interests
• Brochure requests
• Display-home interests
• Information volunteered during a sales conversation

Appointment Information

• Appointment type
• Appointment date and time
• Meeting location
• Telephone or video-meeting information
• Details used to confirm, reschedule or cancel an appointment

Customer And Transaction Information

Where a person chooses to proceed with Vital Communities, we may collect records relating to:

• Expressions of interest
• Deposits
• Contracts and disclosure documents
• Home and site selections
• Plans, specifications and inclusions
• Settlement and handover
• Customer service
• Resident communications

Communication And Preference Records

• Emails
• Form submissions
• Telephone notes
• Survey responses
• Feedback
• Complaints
• Newsletter preferences
• Marketing consent and unsubscribe records

Website And Digital Information

• IP address
• Browser and device information
• Operating system
• Pages viewed
• Links selected
• Approximate location derived from a device or IP address
• Referring website or advertising source
• Cookie and advertising identifiers
• Form and website interactions
• Email engagement information

Supplier And Contractor Information

Where we deal with suppliers, consultants or contractors, we may collect:

• Business contact information
• Company details
• Payment or invoicing information
• Insurance or licensing records
• Information necessary to manage the working relationship

Sensitive Information

We generally do not seek sensitive information unless it is reasonably necessary for our activities and:

• The individual has consented;
• The collection is required or authorised by law; or
• Another permitted circumstance applies.

Sensitive information may include health or accessibility information voluntarily supplied so we can respond appropriately to a person’s circumstances. People should avoid providing unnecessary sensitive information through a general website form.

3.How We Collect Personal Information

We may collect personal information directly from a person when they:

• Submit a website form
• Request a brochure
• Book an appointment
• Call or email us
• Visit a sales office or display home
• Attend a meeting or event
• Enter an agreement with us
• Complete a survey
• Communicate with our team
• Otherwise request information or services

We may also collect information:

• Through website cookies, analytics tools, advertising pixels and similar technologies;
• From an authorised representative;
• From referral or marketing partners;
• From real estate or property platforms;
• From professional advisers or service providers;
• From publicly available sources where appropriate; and
• From related entities, contractors, agents or representatives involved in our activities.

Where reasonable and practicable, we collect personal information directly from the individual. If information is received from another source, we will take reasonable steps to provide any notification required by law.

4.Why We Collect, Use And Disclose Personal Information

We may collect, hold, use and disclose personal information to:

• Respond to enquiries;
• Provide information about Vital Bendigo, available homes, pricing, amenities and community updates;
• Arrange, confirm, manage, reschedule or cancel appointments, meetings and site visits;
• Understand a person’s preferences and circumstances;
• Help prospective purchasers explore suitable homes and sites;
• Manage brochure and information requests;
• Manage expressions of interest, deposits, home selections, customer records and contractual processes;
• Communicate with customers and residents;
• Deliver customer service;
• Send newsletters, project updates, home releases, community news and marketing communications where permitted;
• Operate, maintain and improve our website, forms and booking systems;
• Conduct research, analytics, advertising measurement and business planning;
• Manage contractors, suppliers and professional advisers;
• Prevent fraud, misuse and unlawful activity;
• Protect our systems, staff, customers, residents, property and legal rights;
• Meet legal, regulatory, insurance, taxation, accounting, record-keeping and dispute-resolution obligations; and
• Carry out another purpose explained at the time of collection or authorised by consent or law.

We will not use or disclose personal information for an unrelated purpose unless consent or another lawful basis permits it.

5.Marketing Communications

Where permitted, we may send information about:

• Vital Bendigo
• Available or upcoming homes
• Display-home visits
• Project and construction progress
• Community updates
• Events
• Newsletters
• Related services and opportunities

People can unsubscribe from marketing emails by:

• Using the unsubscribe link in an email; or
• Contacting us using the privacy contact details in this policy.

We will take reasonable steps to update marketing preferences within a reasonable time. Unsubscribing from marketing does not prevent us from sending communications that are necessary to:

• Respond to a current enquiry;
• Manage an appointment;
• Administer a transaction or contract;
• Provide important customer or resident information; or
• Meet a legal obligation.

6.Cookies, Analytics And Advertising Technologies

Our website may use cookies, pixels, tags, analytics tools and similar technologies to:

• Enable website functions;
• Remember preferences;
• Understand how visitors use the website;
• Identify technical problems;
• Improve content and usability;
• Measure form and campaign performance;
• Understand advertising referrals; and
• Show or measure relevant advertising where permitted.

These technologies may collect information such as IP address, browser and device type, operating system, pages viewed, links selected, time spent on the website, form starts or submissions, referring website, advertising campaign source, approximate location and cookie or device identifiers.

Visitors can normally adjust their browser settings to refuse or delete cookies. Some website features may not function as intended if cookies are disabled. Third-party analytics, email and advertising providers may also offer their own privacy controls and opt-out tools.

7.Who We May Share Personal Information With

We may disclose personal information where reasonably necessary to:

• Staff and authorised representatives;
• Related entities;
• Sales and customer-service personnel;
• Community management personnel;
• Website and hosting providers;
• Form and booking providers;
• Customer relationship management providers;
• Email and SMS providers;
• Cloud storage and document-management providers;
• Analytics and advertising providers;
• Information technology and security providers;
• Builders and construction consultants;
• Designers, engineers and planners;
• Maintenance and service providers;
• Lawyers, accountants, auditors, insurers and other professional advisers;
• Banks and payment processors;
• Government agencies and regulators;
• Courts, tribunals and law-enforcement bodies;
• Parties involved in an actual or proposed sale, restructure, financing or transfer of business assets; and
• Other people where the individual has consented or disclosure is otherwise authorised by law.

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

We may disclose personal information to another Vital entity where reasonably necessary for the operation of Vital Bendigo, website and sales administration, contractual processes, community management, legal compliance or the freehold owner’s legitimate ownership responsibilities.

8.Overseas Services And Disclosures

Some providers used for website hosting, customer management, bookings, email, analytics, advertising, cloud storage, communications or technical support may store, process or access information outside Australia.

Overseas locations may include the United States and other countries in which our providers, related companies, infrastructure or support teams operate.

Where personal information is disclosed to an overseas recipient, we take reasonable steps to manage the information in accordance with applicable privacy requirements.

9.How We Protect Personal Information

We take reasonable steps to protect personal information from misuse, interference, loss, unauthorised access, unauthorised modification and unauthorised disclosure.

Safeguards may include:

• Access controls
• Password protections
• Secure systems
• Staff awareness and training
• Service-provider reviews
• Secure record-handling processes
• Physical security
• Internal privacy and information-security procedures

No electronic transmission or storage method is completely secure. A person who is concerned about providing information electronically may contact us to discuss another appropriate method.

10.Retention And Disposal

We keep personal information for as long as reasonably necessary to:

• Respond to enquiries;
• Provide services;
• Maintain customer and resident relationships;
• Administer transactions and contracts;
• Resolve complaints or disputes;
• Maintain business records; and
• Meet legal, regulatory, accounting, insurance and reporting obligations.

Retention periods may vary depending on the type of information, the relationship involved, legal requirements, contractual requirements and the reason the information was collected.

When personal information is no longer required, we will take reasonable steps to destroy it securely or permanently de-identify it unless the information must or may be retained by law.

11.Accessing And Correcting Personal Information

A person may request:

• Access to personal information we hold about them; or
• Correction of information that is inaccurate, out of date, incomplete, irrelevant or misleading.

Requests may be made using the contact information at the end of this policy. To protect privacy and security, we may ask the requester to verify their identity. We will respond within a reasonable time.

Access or correction may be refused in circumstances permitted by law. Where appropriate, we will explain the reason for a refusal and available complaint options.

We generally do not charge for making an access request. If a reasonable administrative cost applies to providing access in a particular form, the requester will be informed before the cost is incurred.

12.Anonymity And Pseudonymity

Where practical, a person may choose not to identify themselves or may use a pseudonym when dealing with us. However, we may need identifying information to:

• Respond to a detailed enquiry;
• Book or manage an appointment;
• Send requested material;
• Provide tailored information;
• Verify customer or resident records;
• Manage a transaction or contract; or
• Meet legal obligations.

If the requested information cannot be provided without identification, we will explain why the information is needed where appropriate.

13.Data Breaches

If we become aware of a suspected data breach involving personal information, we will take reasonable steps to:

• Contain the incident;
• Assess what occurred;
• Reduce potential harm;
• Investigate the cause;
• Address security or process issues; and
• Meet applicable notification obligations.

Where required under the Notifiable Data Breaches scheme, we will notify affected individuals and the Office of the Australian Information Commissioner. Notification requirements depend on the circumstances and applicable law.

14.Privacy Complaints And Enquiries

A person who has a question or complaint about how we handle personal information should contact us using the details below. Please provide enough information for us to understand:

• The privacy issue;
• The information or interaction involved;
• The outcome being requested; and
• How we can respond.

We will consider the matter and respond within a reasonable time. We may ask for additional information or identity verification where required.

If the person is not satisfied with our response, they may contact the Office of the Australian Information Commissioner (opens in a new tab), an external government website.

15.Changes To This Policy

We may update this Privacy Policy to reflect changes to our business activities, information-handling practices, technology and service providers, website features, legal obligations or privacy guidance.

The current version will be published on this website and will display the date it was last updated. Where a material change requires additional notice or consent, we will take the steps required by applicable law.