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      Jagonal Pty Ltd - Privacy Policy


      1. Who are we?

        Jagonal Pty Limited (Jagonal) is an internet based real estate portal providing search and database functionality for commercial, retail and industrial real estate. While the general public will be able to access some of the information collected by Jagonal, the predominant users of information will be property agents, brokers, tenants, tenant representatives and owners in the commercial, retail and industrial real estate markets.

      2. What privacy laws do we comply with in Australia?

        Jagonal complies with the requirements of the Privacy Act 1988 (Cth).

      3. What kinds of personal information do we collect?

        Personal information’ is information or an opinion, whether true or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information.

        Examples of the types of personal information we may collect includes name and contact details including address and email address, job title and position and in some cases financial information, such as bank and credit card details. We may collect information from you in response to a survey.

        We also collect information about you that is not personal information. For example, we may collect data relating to activity on our website (such as IP addresses) via cookies or other tracking technology. We generally use this information to report statistics, analyse trends, administer our services and diagnose problems.

      4. How do we collect personal information?

        We collect personal information in a number of ways and how we collect personal information from you will depend on how you use our services.

        Sometimes we will collect this information directly from you (for example if you register an account and post a listing on the website), and when you deal with us over the telephone or correspond with us via fax, letter, email or any other mode of communication.

        We may also collect this information from a third party you have authorised to provide the information including, but not limited to, an agent or tenant representative.

        We may also collect personal information from publically available records (such as council records or Land and Property Information).

      5. How do we use or disclose Personal Information?

        We only use and disclose personal information for the purpose for which it was collected (unless the information is used or disclosed for another purpose with your consent), or otherwise permitted by law.

        The primary purpose for which we collect information from you is to provide you with products and services you have requested, and for purposes necessary or incidental to the provision of goods and services to you. We may also use your personal information:

        • to provide you with news and information about our products and services;
        • to conduct marketing and promotional activities;
        • to manage and enhance our products and services;
        • to communicate with you, including by email, mail or telephone;
        • to verify your identity;
        • to investigate any complaints about or made by you in relation to information on our portal, or if we have reason to suspect that you are in breach of any of our terms and conditions; or
        • as permitted by law, such as to report unlawful activity to a law enforcement body.

        We may also transfer or disclose your personal information to third parties who are:

        • prospective tenants, agents, tenant representatives and owners (who in some cases, may be located overseas) as part of a sale (or proposed sale) of all or part of our business;
        • agents, business partners or joint venture entities or partners engaged by us to provide services in connection with our company’s operations (for example management and maintenance of our information systems).

        If we disclose personal information to recipients outside Australia in countries that do not have legislation similar to the Privacy Act, we will take steps to ensure that adequate measures are taken to protect the personal information before it is disclosed.

      6. How we secure personal information

        Your personal information is held on databases and physical files. Jagonal takes appropriate technical, organisational and physical measures to keep your personal information secure.

        If Jagonal outsources services involving the use of personal information, it will take steps to ensure the protection of your personal information.

      7. Direct marketing

        We will not use your personal information for direct marketing purposes unless you have provided express consent or your consent can reasonably be implied from the circumstances in which we collected the information. If we send you marketing material we will ensure that you can ‘opt-out’ of receiving any future marketing material. In relation to direct marketing via electronic means, such as email, we comply with the Spam Act 2003and in relation to telephone marketing we comply with the Do Not Call Register Act 2006.

      8. Accessing and correcting personal information

        We will generally provide you with access to any personal information we hold about you on request. In limited circumstances however, access may be refused if required or permitted by law. If we do not provide you with access, we will explain the reason for our refusal in writing.

        We will correct any personal information that is inaccurate, out of date, incomplete, irrelevant or misleading.

        We will not charge you for making an application to access your personal information but may charge a reasonable fee to cover the cost of giving access, such as photocopying costs. We will advise you if such a charge applies before your request is dealt with.

      9. Complaints

        We will address any complaints you have about our handling of your personal information in accordance with our Privacy Complaints Handling Procedure. Under that procedure, you will receive an acknowledgement that we have received your complaint and the matter will then be referred for investigation by a person not directly involved in the subject matter of the complaint. Unless there are exceptional circumstances, we aim to resolve the investigation and complaint within 30 days.

      10. Contacting us

        If you wish to contact us about the handling of your personal information, accessing or correcting your information or to make a complaint, please contact:

        James Tucker
        The Privacy Officer
        SUITE 1, LEVEL 5, 15 - 17 YOUNG ST
        SYDNEY NSW 2000

        e: info@jagonal.com.au
        t: 61 2 7900 8535

      Privacy Complaint Handling Procedure


      This Privacy Complaint Handling Procedure sets out the process we will undertake to deal with complaints regarding breaches of Australian privacy law including under the Privacy Act and State and Territory legislation relating to health information.

      Any complaints should be made in writing to the Jagonal Privacy Officer at SUITE 1, LEVEL 5, 15 - 17 YOUNG ST SYDNEY NSW 2000, info@jagonal.com.au and +61 2 7900 8535.

      We will resolve all privacy complaints through this procedure:

      Step 1: A privacy complaint is received (Complaint)

      Step 2: Within (5) business days following receipt of the Complaint, Jagonal will send a communication via post, fax or email to the person whom made the complaint (Complainant) acknowledging receipt of the Complaint.

      Step 3: Following the acknowledgment of receipt of the complaint (as outlined in Step 2), a Jagonal investigator will notify the Complainant via post, fax or email, that they have been assigned to investigate the Complaint and commence the investigation.

      Step 4: The investigator will conduct an investigation of the Complaint. During this process, the investigator may request further information from the Complainant.

      Step 5: Within thirty (30) business days from the date all information is received, the Investigator will contact the Complainant, via post, fax or email, notifying the Complainant of proposed avenues of resolution. The Complainant and the investigator may work together to collaboratively resolve the Complaint to the Complainant’s satisfaction. Jagonal will notify the individual if additional time is needed to respond due to the complexity of the inquiry.

      Step 6: If the Complaint cannot be resolved by the Complainant and the Investigator in accordance with Step 5, then the Investigator will notify the Privacy Officer (Notification) who will then take steps to resolve the matter.

      Step 7: Following receipt of all requested information, the Privacy Officer will contact the Complainant via post, fax or email, and propose an avenue(s) of resolution.

      Step 8: If the Complainant agrees to the proposed avenue(s) of resolution, the Complainant and the Privacy Officer will work together to close the matter.

      Step 9: In circumstances where resolution cannot be achieved in accordance with Steps 1 to 8, the Privacy officer will advise the complainant that they may direct their Complaint to the Federal Privacy Commissioner or take independent advice as to their rights.

      The Complainant may contact the Federal Privacy Commissioner as follows:

      By telephone: 1300 363 992

      By writing: Director of Complaints, Office of Federal Privacy Commissioner, GPO Box 5218, Sydney NSW 1042

      By email: enquiries@oaic.gov.au