1. COMMITMENT TO PRIVACY
Marston Living Pty Ltd and its related entities (“Marston Living”, “we” or “us”) are committed to protecting the personal information of our residents. We understand that our residents are concerned about their privacy and the confidentiality and security of information. Marston Living collects, holds, uses and discloses personal information in accordance with this Privacy Policy.

2. COLLECTION OF PERSONAL INFORMATION

2.1 What kinds of personal information do we collect and hold?

The types of personal information that we collect and hold may include:

Information identifying you – such as your name, date of birth, driver’s license number (or the number and details of other types of identification, such as a passport or proof of age card).

Contact details – such as your address, telephone number, fax number, email address.

Billing details – such as the billing name and address.

Financial details – such as credit card and bank account details.

Information we are required or authorised by law to collect.

2.2 How do we collect and hold the personal information?

Sources of personal information may include:

• you, when you communicate with us via phone or email, conduct an online transaction or complete an authority to process a debit to your account;
• recipients of your payments;
• your financial institution.
• your social media profiles should you follow our social media accounts or post to one of our social media sites.

Marston Living may also receive personal information from third parties (such as business partners) who have agreed to share their customer or marketing lists with us.

We may monitor and record your telephone calls to us for quality, training, dispute resolution and security purposes.

2.3 Cookies

Cookies are small pieces of information, stored in simple text files, placed on your computer by a website. Some cookies can be read by the website on your subsequent visits. The information stored in a cookie may relate to your browsing habits on the webpage, or a unique identification number so that the website can ‘remember’ you on your return visit. Other cookies are deleted when you close your browser and only relate to the working of the website.

Cookies may be set when you first visit our website.

Most browsers allow you to turn off cookies or to customise your settings for cookies. To find out how to do this, see the ‘Help’ menu on your browser. Please note that if you turn off cookies or change your settings, some features of our website may not work correctly.

In many cases, the tools used on our website record information in a way that does not identify you as an individual. In other cases, information may be personal information in which case this Privacy Policy will apply. Section 2.2 of this Privacy Policy provides examples of when personal information may be collected through our Website.

3. USE AND DISCLOSURE

3.1 What are the main reasons we collect, hold, use and disclose personal information?

We collect personal information in connection with our services when:

• you register or complete an application for village services;
• you enter details through the Marston Living website;
• you communicate with us via phone or email; and
• you make changes on your account with us.

Marston Living collects your personal information to enable us to collect payment for recurring fees, assist in providing community services tailored to your needs, to contact you when a need arises and to establish a contact list in the event we need to contact your next of kin.

Marston Living may also use or disclose any of your personal information for other purposes and/or to other persons as required or permitted by law. We may also disclose your information to third parties to provide services such as operators of emergency medical monitoring devices.

4. INTEGRITY OF PERSONAL INFORMATION

We take reasonable steps to ensure that your personal information collected is accurate, complete, relevant and up to date. If you believe that any of the personal information we hold about you requires correction, please inform us using the contact details set out below.

If you establish that the information we hold about you is inaccurate, incomplete, not up to date, irrelevant or misleading (“Requires Correction”), we will, after considering the purpose for which the information is held, take reasonable steps to correct any errors and if practicable notify any third parties that Marston Living had previously disclosed the information to of the correction. If we are not satisfied that the information Requires Correction we will, at your request, keep with your personal information a statement apparent to users of the information noting your request that the information Requires Correction.

If at any time we refuse or deny you access to your personal information or refuse to correct your personal information we will provide you with reasons for such denial or refusal.

5. SECURITY OF PERSONAL INFORMATION

We take reasonable steps to protect your personal information within our office and computer systems from misuse, interference, loss, unauthorised access, modification or disclosure. Depending on the circumstances, these measures may include staff authentication, access controls, encryption, records management protocols and secure premises. We store personal information in both physical and electronic form, sometimes with the assistance of third parties such as specialist data hosting providers or data centres.

6. ACCESS TO YOUR PERSONAL INFORMATION

6.1 Access to Personal Information

We will provide you with access to the information held by us in relation to you, except in circumstances where refusing you access is permitted or authorised by law.

6.2 Request for Access

To request access to the information held by us about you, please do so in writing using the contact details listed below. We will respond to your request within a reasonable time after the request is made and provide you your personal information in the manner requested by you, provided it is reasonable and practicable to do so. We will advise you if we will not or cannot provide you access, together with the reasons for denying you access.

6.3 Costs

We reserve the right to charge you for providing access to your personal information. We will notify you of those costs prior to providing you access to the information. We may require those costs to be paid prior to providing you with access.

7. RESOLVING YOUR PRIVACY ISSUES

7.1 Complaint

If you have a complaint about how we have used or disclosed your personal information, or if we have not corrected or provided you access to your personal information, then you may contact our support team and we will endeavour to answer your query by telephone. If we are unable to resolve the matter this way, we will provide you with a form to enable you to notify us of the details of your complaint in writing, by email or by post. Our contact details are provided below.

7.2 Our Response

Within 30 days of receipt of your complaint form, we will notify you in writing as to what action we propose to take in relation to your complaint and will provide you with details of what further action you can take if you are not satisfied with our response. If you are not satisfied with the manner in which we have dealt with your complaint, you may contact the Office of the Australian Information Commissioner.

8. CONTACTING US

If you wish to contact us, please contact our Support Team:

Telephone: 0420 522 668 | 0420 306 668

Email: [email protected]

Post: Att: Support Team

Marston Living Pty Ltd

Address: Suite 201A, 24 Thomas St Chatswood NSW 2067

Last Revised 23 May 2018